1

UNITED STATES OF AMERICA

DEPARTMENT OF ENERGY

PUBLIC MEETING

ENERGY CONSERVATION STANDARD

PRELIMINARY ANALYSIS AND ACTIVE MODE TEST PROCEDURE

NOPR FOR FLUORESCENT LAMP BALLASTS

U.S. Department of Energy 1000 Independence Avenue, SW Washington, DC 20585 Room 8E-089

Monday April 26, 2010

Chair:

Linda Graves Department of Energy

Facilitator

Jim RabaExecutive Court Reporters (301) 565-0064 2

Participants Identified: Tim Ballo Earth Justice

Ed Thomas GE Lighting

John Green Cooper Lighting

Joe Parisella Osram Sylvania

Justin Newmann

NEMA

Mike McGaraghan Energy Solutions

Joanna Mauer Appliance Standards Awareness Project

Charlie Stephens Northwest Energy Efficiency Alliance

Evan Haynes ICF International

John Cymbalsky Department of Energy, Appliance Standards

Linda Graves Department of Energy, Appliance Standards

Graham Parker Pacific Northwest National Laboratory

Natasha Collins Pacific Northwest National Laboratory

Amanda Lowenberger American Council for an Energy-Efficient Economy

Eric Anderson Pacific Northwest National Laboratory

Ian SwinkExecutive Court Reporters (301) 565-0064 3

U.S. Department of Justice, Antitrust Division

Mark Duffy GE Lighting

Keith Cook Philips Lighting

Susan Anderson Osram Sylvania

Jeff Plaskon GE Lighting

Tom Eckman Northwest Power and Conservation Council

Kyle Pitsor

NEMA

Bob Lingard Pacific Northwest National Laboratory

Gavin McCormick Pacific Northwest National Laboratory

Mimi Gupta Navigant Consulting

Ali Lehr Navigant Consulting

Matthew Walker Navigant Consulting

Pekka Hakkarainen Lutron Electronics

Bob Erhardt Philips Lighting Electronics

Betsy Kohl Department of Energy, General Counsel ‟ s Office

Andrew deLaski Appliance Standards Awareness Project

Alvin RazonExecutive Court Reporters (301) 565-0064 4

National Rural Electric Cooperative Association

I N D E X

AGENDA ITEMS PAGE Welcome, Ms. Graves 5

Introductions 7

Agenda Review, Mr. Raba 10

Opening statements 12

Test procedures: Overview and Existing Method 26 Mr. Walker

Test procedures: Alternative Methods 54 Mr. Walker

Test procedures: Proposed Method 76 Mr. Walker

Energy Conservation Standard Introduction, 110 Statute, and Context Ms. Lehr

Market and Technology Assessment; Screening 128 Analysis Ms. Lehr

Engineering Analysis 145 Ms. Lehr

Energy Use and Markup Analysis 193 Mr. Lingard

Life-Cycle Cost and Payback Period Analysis 208 Mr. McCormick

National Impact Analysis 235 Mr. McCormick

Preliminary Manufacturer Impact Analysis 270 Mr. Carmichael

NOPR Analyses 275 Mr. Lingard

Final Questions/Discussions and closing 278Executive Court Reporters (301) 565-0064 5

Ms. GravesExecutive Court Reporters (301) 565-0064 6

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

9:00 a.m. 2

MR. RABA: Introducing Linda Graves, Project 3

Manager. 4

MS. GRAVES: Good morning and welcome to the 5

U.S. Department of Energy. I ‟ m Linda Graves. I ‟ m the 6

project leader for lighting standards, and we are 7

doing something that we ‟ ve done only a couple times in 8

the past, we are presenting two rule makings in a 9

single day. And the purpose of today ‟ s meeting is to 10

discuss the energy conservation standard preliminary 11

analysis for fluorescent lamp ballasts, as well the 12

draft proposed test procedures. 13

We are particularly interested in your 14

reaction to this format, because it ‟ s our intention to 15

follow this approach from now on, of compressing what 16

used to be maybe a full day public meeting per rule 17

making into half days, so we really would appreciate 18

your response on the surveys at the end of the 19

meeting. If this worked for you, we are still very 20

intent upon getting your full participation and 21

contribution. We ‟ ve learned a lot from the back and 22

forth with you, both at public meetings and through 23

your written comments. So we certainly want to 24

preserve that. 25Executive Court Reporters (301) 565-0064 7

I ‟ m here with my new boss, John Cymbalsky, 1

but he ‟ s not new to the U.S. Department of Energy. He 2

was formerly with the Energy Information 3

Administration for 20 years, and he is an expert on 4

forecasting, and you can certainly see how that 5

applies to our rulemaking. 6

I ‟ m also here with my, frankly, brilliant 7

lighting teams from Pacific Northwest National 8

Laboratory, and Navigant Consulting. They will be 9

presenting the basic information to you. 10

And I ‟ m also here with Jim Raba, who is also 11

from the Appliance Standards Group, but he has 12

graciously agreed to facilitate for us. He has 13

facilitated many times in the past, and I can always 14

count on Jim ‟ s calm demeanor to keep things friendly 15

and civil and so everyone hears everyone. 16

So with that, I ‟ m turning the meeting over 17

to Jim. 18

MR. RABA: Linda, you ‟ re too nice. Yes, we 19

know that. Well, good morning. I ‟ m Jim Raba, I ‟ ll be 20

facilitating your public meeting today. And as a 21

facilitator, I try to keep you on track and focused. 22

You ‟ ve come a long way to accomplish a lot, so to make 23

the best use of your time and your comments back to 24

the Department of Energy ‟ s rule making and preliminary 25Executive Court Reporters (301) 565-0064 8

analyses. So everybody will have an opportunity to 1

speak, so when you, be concise. 2

Some things to go around the room first, 3

like to have everybody introduce themselves, and when 4

you do, notice the green lights on the microphones at 5

the table. The green light should be on. If you want 6

to push the mute, just push the button and it ‟ ll be a 7

mute as well. Let ‟ s go around the room and introduce 8

ourselves, starting with this side, please. Your 9

name, the organization affiliation. 10

INTRODUCTIONS 11

MR. THOMAS: Hello, I ‟ m Ed Thomas. I ‟ m with 12

GE Lighting. 13

MR. RABA: You hear okay, court reporter? 14

Okay. Just speak closer. Thank you very much. 15

Proceed. 16

MR. GREEN: John Green, with Cooper 17

Lighting. 18

MR. PARISELLA: Joe Parisella with Osram 19

Sylvania. 20

MR. NEUMANN: Justin Neumann with NEMA. 21

MR. MCGARAGHAN: Mike McGaraghan with Energy 22

Solutions, here on behalf of Pacific Gas and Electric 23

Company, and Southern California Edison Company, and 24

San Diego Gas and Electric. Three large investor-run 25Executive Court Reporters (301) 565-0064 9

utilities in California. 1

MS. MAUER: Joanna Mauer, Appliance 2

Standards Awareness Project. 3

MR. STEPHENS: Charlie Stephens. I 4

represent the Northwest Energy Efficiency Alliance. 5

MR. HAYNES: Evan Haynes, ICF International. 6

MR. CYMBALSKY: John Cymbalsky, Department 7

of Energy, Appliance Standards. 8

MS. GRAVES: Linda Graves, Appliance 9

Standards. 10

MR. RABA: In the back, the microphones that 11

are standing are live. You can use them to introduce, 12

please. 13

MR. PARKER: Graham Parker, Pacific 14

Northwest National Laboratory. 15

MS. COLLINS: Natasha Collins. I ‟ m from 16

Pacific Northwest National Labs. 17

MS. LOWENBERGER: Amanda Lowenberger, 18

American Council for an Energy-Efficient Economy. 19

MR. ANDERSON: Eric Anderson, Pacific 20

Northwest National Laboratory. 21

MR. SWINK: Ian Swink, U.S. Department of 22

Justice, Antitrust Division. 23

MR. DUFFY: Mark Duffy, GE Lighting. 24

MR. COOK: Keith Cook, Philips Lighting. 25Executive Court Reporters (301) 565-0064 10

MS. ANDERSON: Susan Anderson, Osram 1

Sylvania. 2

MR. PLASKON: Jeff Plaskon, GE Lighting. 3

MR. ECKMAN: Tom Eckman, Northwest Power and 4

Conservation Council. 5

MR. PITSOR: Kyle Pitsor, NEMA. 6

MR. RABA: Over here, please. 7

MR. LINGARD: Bob Lingard, Pacific Northwest 8

National Laboratory. 9

MR. McCORMICK: Gavin McCormick, also 10

Pacific Northwest National Lab. 11

MS. GUPTA: Mimi Gupta, Navigant Consulting. 12

MS. LEHR: Ali Lehr, Navigant Consulting. 13

MR. RABA: Now we had a few come in -- and 14

one more -- I ‟ m sorry, I didn ‟ t see you over there. 15

MR. WALKER: My name ‟ s Matthew Walker, also 16

from Navigant Consulting. Thanks. 17

MR. RABA: Go ahead, please. 18

MR. HAKKAHANEN: Pekka Hakahanen, Lutron 19

Electronics. 20

MR. ERHARDT: I ‟ m Bob Erhardt, Philips 21

Lighting Electronics and chairman of the NEMA ballast 22

section. 23

MS. KOHL: Betsy Kohl, Department of Energy, 24

General Counsel ‟ s Office. 25Executive Court Reporters (301) 565-0064 11

MR. RABA: Thank you very much. 1

2

3

OPENING REMARKS, AGENDA ITEMS 4

MR. RABA: Some things we ‟ ve come to think 5

of as norms at our public meetings to help get through 6

and have everybody speak and be heard are some things 7

we have established over many years and we ‟ re 8

comfortable with. Ask everybody to listen as an ally, 9

we ‟ re here to accomplish a purpose for your benefit. 10

Be concise when you speak please. Speak one at a 11

time. Raise your hand, I ‟ ll recognize you and queue 12

you one at a time for both introductory comments, 13

statements, and final on discussions as well. 14

Please put your cell phones on silent or 15

vibrate or stun. No sidebar conversations -- take 16

them out in the back or the hallway, perhaps, too. 17

And keep the focus up here on the 18

presentations, on the topics as well, so keep moving 19

along. We have a lot to cover today, want to make the 20

best use of your time. 21

Some housekeeping items. Let ‟ s see, very 22

quickly, restrooms are at the far end of the hallway, 23

either one. Coffee shop downstairs on the ground 24

floor, about this position on the ground floor. We ‟ ll 25Executive Court Reporters (301) 565-0064 12

take breaks later on in the morning, and throughout 1

the day. Yes, please. 2

Has everybody signed in at the reception 3

desk and checked in with a packet of information? All 4

set there? Okay. Good. 5

Agenda, I ‟ ll deal with very quickly. You 6

can see that the morning will be focused on the test 7

procedures, an overview of them. We ‟ ll look for a 8

time to take a break. We have a schedule here, but we 9

can see how the meeting flows through the day. Breaks 10

are scheduled, we ‟ ll take a look at that as they come 11

along. Take a break for lunch when ‟ s appropriate. We 12

may get ahead of schedule, which is good, may not. 13

We ‟ ll take a look and see at that, and then later on 14

this afternoon test procedures. 15

Any question on today ‟ s agenda? 16

So as we say, the Department of Energy wants 17

to hear from you. It ‟ s a good time to speak. Make 18

oral and written statements, which will be very 19

helpful in lighting, when the comment period 20

continues. And again, when you speak, please be 21

recognized, state your name for the record, and your 22

organization, affiliation. We have a court reporter 23

here who will be transcribing today ‟ s proceedings. 24

There ‟ ll be a copy of the transcript available after 25Executive Court Reporters (301) 565-0064 13

the public meeting, and there ‟ ll also be an attendance 1

sheet, a list of attendees provided to you as the 2

meeting ‟ s over. So you ‟ ll have that for your records 3

as well. 4

I understand the PowerPoint slides we ‟ ll be 5

using today, there ‟ s a lot of content in them. 6

They ‟ re using comment boxes focus for the key point 7

and issues, so we ‟ ll look at them also, and each of 8

the presenters will give their introductions and 9

proceed with that and key you up on those comments and 10

questions too. 11

I think we ‟ ve covered that so far. So 12

essentially right here, right now, we ‟ re inviting 13

anyone to make opening statements or remarks for the 14

records, and if you ‟ d like to do that, you ‟ re welcome 15

to. Keep them short, concise, limit your time, 16

please. About three minutes, the most, if you would. 17

OPENING STATEMENTS 18

MR. RABA: Are there any persons who would 19

like to speak at this time? Opening statements, 20

perhaps? State your name for the record. 21

MS. GUPTA: I was just saying, this is Mimi 22

Gupta, Navigant Consulting. I think we have a couple 23

of presentations some stakeholders submitted, so this 24

is probably the best time for it. 25Executive Court Reporters (301) 565-0064 14

MR. RABA: It ‟ s a good time. All right. 1

MR. ERHARDT: They ‟ re more than three 2

minutes long, probably, but we an leave it to three 3

minutes. 4

MR. RABA: Okay, go ahead, but start -- 5

would you like to start? Who would like to start? 6

MR. WALKER: Yeah, we ‟ ve got a PowerPoint 7

presentation we submitted, I think. 8

MR. RABA: Okay, cuing it up now? 9

MR. WALKER: He ‟ s cuing it up. 10

MR. RABA: That ‟ s fine. Okay, the 11

highlights, mostly. Thank you. And state your name 12

please, for the record. 13

MR. ERHARDT: Bob Erhardt, Philips Lighting 14

and Electronics. Chairman of the NEMA ballast 15

section. 16

(Discussion regarding use of computer.) 17

Hello. Bob Erhardt, Philips Lighting and 18

Electronics. Chairman of the NEMA ballast section. 19

NEMA would like to thank the Department of Energy for 20

allowing us to participate again. We participated two 21

years ago, and again at the HID meeting, and we feel 22

it ‟ s been very fruitful. We also would like to 23

congratulate Navigant. We feel they ‟ ve done a good 24

job on their report of investigation, was quite a bit 25Executive Court Reporters (301) 565-0064 15

to go through. We ‟ ve been very active the last 1

several weeks. We have a few areas we ‟ d like to 2

comment on, but we were very impressed with how in 3

depth they were able to go, and we appreciate how 4

diligent they were in accepting our input. We feel 5

they represented our input quite well. 6

Some further areas of discussion. We have a 7

few areas of discussion. We ‟ ve been in parallel, 8

working on method of measurement, trying to improve 9

accuracy and Ed Thomas will give a more detailed 10

presentation on that, and we ‟ ll have detailed comments 11

during the morning ‟ s activities. 12

We have a couple comments on using common BF 13

filaments for different lamp types, a little bit on 14

sales projections, cost analysis, scaling technique 15

and considerations for emerging technologies. Again, 16

as I said, Ed Thomas will be giving a more detailed 17

presentation on method of measurement. 18

We feel that we appreciate that DOE and 19

Navigant, with Navigant ‟ s recommendation, is looking 20

at ballast efficiency. We have some further comments 21

on that. We ‟ ve been doing some further work. We ‟ d 22

like to talk about our work with you, seeing lamp 23

loads with ballast efficiency measurements. 24

We ‟ d also like to remind you that even 25Executive Court Reporters (301) 565-0064 16

though ballast efficiency measurements are more 1

precise and more reproducible than lighting -- than 2

light output measurements, please take into 3

consideration there will still be some tolerances to 4

be taken into account. I think we ‟ ve been talking 5

about two and a half percent one should assume per 6

measurement BY accuracy in ballast efficiency and five 7

percent for BEF measurements. 8

Short comment on BEF limits for different 9

lamp types. By definition, BEF refers to a light 10

output from a given lamp. We feel that when you ‟ ve 11

used the same BEF measurement for you medium bi-pin, 12

we feel that since the lamps were of the same light 13

output that we agree with using one common set of BEF 14

standards for T12 and T8. The medium bi-pin, we ‟ d 15

like you to take into consideration when you go to the 16

T8 HO, the T12 HO, there is a 13 percent light output 17

difference when you ‟ re looking at the rated lumens and 18

then so therefore the T12s would have a 12 percent -- 19

a 13 percent disadvantage when you use a common BEF. 20

Sales projections, we have a couple comments 21

from NEMA biz on sales projections. There were some 22

hills and valleys in the sales projections that we 23

just historically haven ‟ t seen, and we question that 24

and we ‟ ll have some comment on that. 25Executive Court Reporters (301) 565-0064 17

Cost analysis. Very difficult to do, we 1

recognize. We ‟ re still trying to see if we can do it. 2

We ‟ re trying to pull together some cost numbers. I ‟ ll 3

make one comment here. There was an assumption that 4

the most efficient ballast was cheaper than the lesser 5

efficient ballast. We wish that were true, but we 6

haven ‟ t been able to find that fountain of youth or 7

oxymoron, if you will. 8

Scaling techniques. I think the scaling 9

techniques are valid -- well, scaling techniques are 10

valid. We have a couple comments on maybe where we 11

could give some tweaks to them. I went to the 12

California Energy Commission has a data base of over 13

400 ballast models, and they are submittals that 14

manufacturers must make to sell to California. They 15

must come from a certified laboratory. So as far as I 16

know, that ‟ s the best data base I ‟ ve found for public 17

domain information on certified ballast parameters. 18

And I used that, and I found your scaling techniques 19

were pretty good. There might be some area with the 20

one lamp, we had a lot of fall-out on the one lamp 21

side. The data from the California Energy Commission 22

website, when I did some averaging, it appears that 23

maybe we would like some allowance on the one lamp. 24

Some small differences in the -- going from 25Executive Court Reporters (301) 565-0064 18

lamp power -- I ‟ m sorry -- on the low, medium, and 1

high output. In general, the LWs have lower 2

efficiency. The high outputs actually have a little 3

higher efficiency, you gave them lower. We ‟ re not 4

going to complain. But we may talk about that a 5

little bit. 6

We ‟ ve going to have some comments on T5. If 7

you look at the CSL-3 limits, a lot of us, even our 8

premium products, our high-line products are on the 9

edge or a half a point below what you propose. We ‟ d 10

like to talk about that a little bit. T5s, there ‟ s 11

some considerations -- first of all, because it ‟ s a 12

smaller lamp, it has the opportunity for more 13

efficacious luminaires -- because you get better 14

optical control out of them, and we ‟ d like you to take 15

that into consideration. 16

And T5 lamps, at their operating 17

temperature, they ‟ re lumen output goes up slightly, 18

and the T8s go down slightly, so that ‟ s another area 19

we ‟ d like you to take into account when considering 20

the BEF requirements for T5. 21

And then, we ‟ d like you to consider, when 22

you ‟ re looking at both the -- when you ‟ re looking at 23

future sales of fluorescent ballast, consider the 24

emergence of solid state lighting. It is -- two years 25Executive Court Reporters (301) 565-0064 19

ago, nobody knew exactly how it was taking off. Well, 1

then I think the indication now is maybe it ‟ s coming 2

to be time, and you might want to consider if ten and 3

15 years from now, what exactly the fluorescent market 4

will be because there are some projections that solid 5

state could be taking over as much as 50 percent of 6

the lighting market in the ten year time frame. 7

General comments. I mentioned we looked at 8

the California Energy Commission. We ‟ re going to 9

comment on the CSL 2 and 3 data. 10

The other thing we ‟ d like you to consider is 11

manufacturers are, you know, I think all of us here 12

were very involved in improving energy efficiency. 13

We ‟ re doing it -- the newest areas of energy 14

efficiency -- lighter controls and working with new 15

light sources have the potential to generate 16

significantly more energy savings than picking up one 17

or two percent on an efficiency standard for a 18

fluorescent ballast. So we hope that you ‟ ll 19

appreciate that when you ‟ re talking about what it 20

would take to dedicate engineering resources to 21

redesigning fixed output ballast, please realize 22

that ‟ s probably energy resources you could be talking 23

away from a much more beneficial technology, and 24

please take that into consideration. 25Executive Court Reporters (301) 565-0064 20

And those are my beginning comments. I hope 1

I didn ‟ t go over three minutes. 2

MR. RABA: You did fine. That is very 3

helpful. Very helpful indeed. 4

MR. WALKER: We also have a second 5

presentation? 6

MR. THOMAS: Yes. 7

MR. WALKER: All set. 8

MR. THOMAS: Good morning you all. I ‟ m Ed 9

Thomas. I ‟ m with GE Lighting. I ‟ m also the chair of 10

the ballast technical committee within the NEMA group. 11

And I ‟ d like to talk to you a little bit about test 12

methodology. 13

Of course, as Bob mentioned, we certainly 14

want to thank the department for allowing us this 15

opportunity. We also want to thank Navigant and the 16

team of Navigant that we worked with very closely 17

during a lot of testing and qualification that we were 18

doing. And we ‟ d like to continue to work with both 19

the department and Navigant to finish off this work 20

and move toward a ballast efficiency measurement. 21

The advantages of ballast efficiency are 22

many, more repeatable, less chance of errors, removes 23

inaccuracies associated with lamp to lamp variation, 24

manufacturer ‟ s variation, and photometric variation. 25Executive Court Reporters (301) 565-0064 21

It allows the accurate evaluation of a high 1

performance product, but still there ‟ s some issues. 2

The proposed rule involves utilization of a 3

standard fixed resistance load where it is designed 4

for a normal light level ballast. As you know, the 5

industry has several different light levels of 6

ballasts, and if you were to try to engage a normal 7

load on a low light level ballast, and impedance 8

mismatch occurs, and therefore drives the ballast from 9

its proper operating, high performance, efficiency 10

point. And the same is true with the high ballast 11

factor to normal ballast factor as well. 12

And there was some discussion about scaling, 13

saying that a certain percentage shift would be 14

expected. That may be true on one particular type or 15

a narrow range of types of ballast, but across the 16

industry, that is not necessarily a true statement. 17

To operate properly, the ballast would 18

require a specific load for the specific light level. 19

These loads, I think the people at Navigant are 20

familiar with these loads, they ‟ re very costly, 21

precision-resistive networks, and you would require 22

one per lamp channel and so a four lamp ballast would 23

require four sets of these precise resistors, and then 24

you would require a different bank for each particular 25Executive Court Reporters (301) 565-0064 22

light level, and the necessity of arriving at these 1

values come standardization of lamp types. As lamp 2

types become available, they need to be standardized 3

and the resistance value derived from them. 4

So what our recommendation would be would be 5

to utilize lamps as the load for testing the ballast. 6

Ballasts are inherently designed to operate lamps. 7

The lamp has a dynamic load. It adjusts to the light 8

level provided by the ballast. Lamps are readily 9

available. Lamps can be obtained from any 10

manufacturer at low cost and provide a proper 11

operating point for the ballast. 12

We, as NEMA, have been working for a couple 13

of years now on developing a ballast efficiency test 14

procedure. It has recently circulated throughout our 15

NEMA committees. It ‟ s been balloted and approved, and 16

I believe it is a handout here at this meeting today. 17

So if you would refer to that, that would be helpful. 18

Again, just to highlight a few 19

characteristics. Electrical efficiency brings you 20

independent of lamp load characteristics. As you 21

know, fluorescent lamps are manufactured in high 22

volume. There ‟ s variation from manufacturer to 23

manufacturer and lot to lot, and unfortunately, these 24

variations affect the input wattage to the ballast, 25Executive Court Reporters (301) 565-0064 23

over which the ballast has no control. And you 1

combine that with some errors in the photometric 2

system, then that leads to the inaccuracies of the 3

present BEF photometric base system. However, even 4

with a pure electrical measurement, some issues still 5

exist with accuracy. 6

When you ‟ re looking at modern, high7

performance ballasts, they operate roughly in the 20 8

through, basically 100 kilohertz region, and when 9

you ‟ re accurately measuring frequencies of that 10

extent, you need a fairly sophisticated instrument. 11

Just doing a quick back of the envelope calculation on 12

the instrument, gives me a basic 1.5 percent accuracy 13

for the instrument itself at that type of frequency, 14

and this is not an inexpensive instrument. 15

When you couple the current transducers and 16

the wiring capacitances, that error increases a little 17

bit more to the range that Mr. Erhardt had mentioned 18

earlier. And even with these errors, you still get a 19

more accurate, more repeatable measurement than if you 20

use the existing photometric system. 21

MR. ERHARDT: Could I make one comment, Ed? 22

MR. THOMAS: Yes, sir. 23

MR. ERHARDT: Each piece of equipment has 24

about a one and a half percent. 25Executive Court Reporters (301) 565-0064 24

MR. THOMAS: Yes. 1

MR. ERHARDT: And when you ‟ re doing ballast 2

efficiency, you ‟ re using two pieces of equipment, 3

you ‟ re taking the ratio, so it ‟ s the addition of the 4

two accuracies that you ‟ re talking about. So if you 5

have plus or minus a half, and plus or minus a half, 6

one and a half, that ‟ s where we ‟ re getting our two and 7

a half percent from. 8

MR. RABA: Thank you, and your name and 9

organization for the record? 10

MR. ERHARDT: I ‟ m sorry, Bob Erhardt, 11

Philips Electric. 12

MR. RABA: Thank you. 13

MR. THOMAS: Just briefly here, measurement 14

errors will affect the readings, and as we mentioned, 15

the instrument alone is typically a couple percent. 16

The photometric measurements are typically five 17

percent or greater variability, and when you consider 18

the fact that you have a light measuring system, you 19

have a lamp that may vary in parameters, you have a 20

ballast with electrical measurement in front of it -- 21

all these errors cumulate through the existing 22

photometric base system. And just to give an 23

understanding, a typical ballast efficacy factor would 24

be 1.58. Many people recognize CEE standards as a 25Executive Court Reporters (301) 565-0064 25

more or less industry standard. If you start to apply 1

the errors that cumulate through the system, you can 2

see where the BEF numbers will vary greatly and 3

there ‟ s been talk of putting a third digit on the end 4

of a BEF number, and based upon the accuracies that we 5

see, that third digit doesn ‟ t mean anything from a 6

statistical viewpoint. 7

Again, this is just a table for the CEE, 8

showing where my 1.58 came from before. Just in 9

tabular form, just showing a range of the numbers with 10

a three percent error, the range of numbers with a 11

five percent error. And just a -- roughly, this is a 12

plot that I generated some time ago, and it appears my 13

bar has shifted -- the black bar here is supposed to 14

be at the point of 1.58. I don ‟ t know how that 15

happened. But anyways, the part I wanted to call your 16

attention to is the error bars that are on the plot, 17

that ‟ s going to cover quite a range of BEFs versus 18

efficiency. 19

And again, this is just the table that the 20

raw data come from, and the one point I ‟ d call here is 21

the relationship for a conversion factor. You look at 22

this set of numbers for the Instant Start system, 23

you ‟ re seeing an average of about 1.7. Average of the 24

numbers here, you ‟ re seeing for Program Start systems, 25Executive Court Reporters (301) 565-0064 26

a little bit less efficient. There ‟ s about a 1.68, 1

and we did notice somewhere through the documents that 2

some of the performance ratings for Program Start 3

systems seem to be a little bit higher than that for 4

Instant Start systems, which is not really consistent 5

with what we find in the industry. 6

And again, this is a plot that was generated 7

by our friends at the Lighting Research Center while 8

working with Navigant, and we see distribution of 9

ballasts that we tested during the work, and a 10

clustering right around 89-90 percent efficiency, 11

which is the mark that we were looking for. 12

And that ‟ s it. Any questions? Yes, ma ‟ am. 13

MS. GRAVES: Yeah, Ed. 14

MR. RABA: Name please? 15

MS. GRAVES: Linda Graves, Department of 16

Energy. Your presentation will be part of the docket, 17

part of the record of this meeting, so if you would 18

like to submit a correction to that one slide, that 19

would be fine. 20

MR. THOMAS: I can do that, thank you. 21

MR. RABA: Yes. Charlie Stephens. 22

MR. STEPHENS: Charlie Stephens, Northwest 23

Energy Efficiency Alliance. I just wanted to -- when 24

you were using the term light level, that ‟ s ballast 25Executive Court Reporters (301) 565-0064 27

factor. As you using that for a synonym for ballast 1

factor as you ‟ re talking about the different -- in 2

general when you use that term? 3

MR. THOMAS: Right. That ‟ s right. 4

MR. STEPHENS: Okay. Thank you. 5

MR. RABA: Other questions? Comments. Very 6

good. Thank you. Very thorough. Very thorough. 7

Thank you. Anyone else wish to make an opening 8

statement? We did see a couple new arrivals. For the 9

record, will you please, if you came in late, please 10

state your name for the records and your organization 11

affiliation. There ‟ s a hot mike standing up behind 12

you, and there ‟ s a mike at the table. The green light 13

should be on. You, sir. 14

MR. deLASKI: Andrew deLaski, Appliance 15

Standards Awareness Project. 16

MR. RABA: And the back, please? 17

MR. RAZON: Alvin Razon, National Rural 18

Electric Cooperative Association. 19

MR. RABA: Thank you, welcome. Proceed. 20

TEST PROCEDURE: OVERVIEW AND EXISTING METHOD 21

MR. WALKER: Thank you for those 22

presentations. Let ‟ s pick back up where Jim left off, 23

throughout his presentation he presents particular 24

issues on which it seeks comments in these blue boxes 25Executive Court Reporters (301) 565-0064 28

you can see on this slide. These issues correspond to 1

those 11 issues particularly identified in the Notice 2

of Proposed Rulemaking, the one that was published a 3

few weeks ago. 4

These issues won ‟ t necessarily be presented 5

in this order in this presentation, and we just remind 6

everyone that comments are welcome on any aspect of 7

the analysis, not just these 11 issues. 8

So the test procedure portion of the 9

presentation will have four main parts. First, a 10

discussion of the regulatory history and rulemaking 11

process. Then a few slides on the existing test 12

procedure, and a discussion of some of the 13

alternatives that DOE considered, and then finally, 14

some summary of the proposal in the Notice of Proposed 15

Rulemaking. 16

So a little history. In 1975 the Energy 17

Policy and Conservation Act initially established the 18

energy standards conservation program. Then in 1988, 19

the National Appliance Energy Conservation Amendments 20

amended EPCA to add fluorescent lamp ballasts to the 21

program. This Congressional Act also required DOE to 22

initially establish test procedure to set minimum 23

efficiency standards for ballasts, and then it also 24

required DOE to amend these standards two times. Also 25Executive Court Reporters (301) 565-0064 29

within these -- this energy bill it was indicated that 1

DOE could consider additional ballasts in its 2

revisions of standards. 3

Then in 1989 initially established the test 4

procedure for fluorescent lamp ballast. In 2000, DOE 5

published an energy conservation standard as the first 6

amendment in accordance with the statute. And in 7

2005, the Energy Policy Act of 2005 added new energy 8

conservation standards for ballasts that operate 9

energy saver lamps. In 2008, DOE published a 10

framework document for the energy conservation 11

standard that ‟ s currently under development, and that 12

is the standard that we ‟ ll be discussing in the 13

afternoon. It was at this meeting that DOE first 14

received comment that it should review the active mode 15

test procedure. 16

Then in 2009, DOE published a final rule 17

addressing standby and off-mode test procedures for 18

ballasts. This was in response to a provision in the 19

Energy Independence and Security Act of 2007, EISA 20

2007. And finally, just a few weeks ago, on March 21

24th, DOE published both the NOPR for the active mode 22

test procedure, and Notice of Public Meeting, 23

announcing the availability of the preliminary 24

analysis for the standards rulemaking. 25Executive Court Reporters (301) 565-0064 30

So from this point on, the presentation will 1

focus on the test procedure. The test procedure in 2

general consists of two parts. First, a NOPR, and 3

then a final rule. DOE has published this NOPR on 4

March 24th and it seeks comment both through oral 5

comments at today ‟ s meeting, and through written 6

comments which are due by June 7, 2010, just about a 7

month and a half from now. DOE will then review and 8

consider all of these comments before publishing a 9

final rule, which will be published on or before the 10

same day as the final rule for the energy conservation 11

standard rulemaking, which is about June 2011. 12

The test procedure is very much 13

interconnected with decisions that are made in the 14

standards rulemaking, in particular the scope of 15

coverage under consideration, so in order to 16

synchronize the two rulemakings, DOE will publish both 17

of them around the same time. 18

The test procedure NOPR accomplishes several 19

items. First it serves as the seven-year review of 20

the active mode test procedure. One of the provisions 21

of EISA 2007, one of the recent energy bills, requires 22

DOE to review its test procedures every seven years. 23

Next, the test procedure NOPR proposes to 24

update ANSI references in the existing test procedure. 25Executive Court Reporters (301) 565-0064 31

It then proposes a new test procedure based on ballast 1

efficiency correlated to BEF for use with amended 2

standards, and these amended standards are those that 3

are currently under development and will be discussed 4

in the afternoon. Finally, it proposes to set up 5

certification requirements for use with both the 6

existing standards and the amended standards. 7

while there are currently energy 8

conservation standards for ballast, manufacturers 9

aren ‟ t required to submit written documentation 10

indicating compliance, so DOE is proposing to make a 11

change. 12

So at the bottom of this slide you can see a 13

diagram that describes the timing of these provisions. 14

First. on June 2011, the test procedure final rule and 15

standards final rule will be published. Thirty days 16

after that, the updates to the existing test procedure 17

will be come effective, and that ‟ s the updated ANSI 18

references and the existing light output base method. 19

Then in June 2012, DOE is proposing that manufacturers 20

use the updated existing test procedure to indicate 21

compliance with existing standards. 22

Then in June 2014, the energy conservation 23

standard will become effective, and on that same date, 24

the new test procedure which uses ballast efficiency 25Executive Court Reporters (301) 565-0064 32

correlated to BEF will also become effective. This 1

test procedure will be located at Appendix Q-1 of the 2

Code of Federal Regulations, whereas the existing test 3

procedures, in Appendix Q. 4

Then finally, in June 2015, one year after 5

this new test procedure becomes effective, 6

manufacturers will again be required to submit written 7

documentation that indicates compliance with the 8

amended standards using the new test procedure. 9

So at this time we have our first issue for 10

comment. This actually comes from the energy 11

conservation standard preliminary analysis. Some 12

manufacturers observed that there are non-compliant 13

ballasts available in the marketplace, and DOE ‟ s 14

requesting comment on reasonable ways to enhance the 15

certification and enforcement procedures for these 16

ballasts. 17

Floor ‟ s open. 18

MR. ERHARDT: Bob Erhardt, Philips Lighting 19

Electronics, NEMA ballast section chair. I think 20

we ‟ ve commented before, and in California, the 21

California Energy Commission requires that all test 22

data be done by a certified laboratory, that there ‟ s a 23

certified copy of data available for inspection. 24

We ‟ ve already -- we are already submitting data in 25Executive Court Reporters (301) 565-0064 33

this format. Laboratories that are certified by UL, 1

CSA, or other recognized laboratories that -- if your 2

lab is certified for doing UL work, meaning that you 3

have an audit program and that you ‟ re showing that you 4

meet your ISO criteria, et cetera, that ‟ s what 5

California ‟ s been using for their submission of data. 6

We propose something common so we may use 7

the same set of data, preferably. 8

MR. RABA: Understandable. Thank you. Any 9

other comments, please, at this time? 10

MR. deLASKI: Andrew deLaski, Appliance 11

Standards Awareness Project. Bob, this is a question 12

for you. The slide there says manufacturers have 13

observed non-compliant ballasts, and I ‟ m wondering if 14

you -- if the NEMA ballast section has a sense of 15

where are those problems, you know, is it certain 16

types of ballast? I mean, can you characterize the 17

nature of the problems that the ballast section has 18

observed? 19

MR. ERHARDT: I don ‟ t know, maybe I ‟ ll let - 20

- actually Justin ‟ s rather new with NEMA. I don ‟ t 21

know that our company has been the one bringing this 22

to attention, but some of the NEMA companies have been 23

bringing this up, that they ‟ ve observed some offshore 24

suppliers that are doing private labeling, don ‟ t 25Executive Court Reporters (301) 565-0064 34

necessarily meet the requirements that they ‟ re 1

claiming. But I can ‟ t speak for my own company. I 2

can open it up to the other NEMA company 3

representatives. 4

MR. RABA: And that was Bob Erhardt? 5

MR. ERHARDT: And that was Bob Erhardt. 6

MR. RABA: Thank you. Anybody else. Okay. 7

MR. WALKER: All right. Great. So we ‟ ll 8

move on to the second section where we ‟ ll discuss the 9

existing test procedure, some of the comments we 10

received on potential drawbacks. 11

Existing procedures based heavily on 12

ANSI82.2, the 1984 version which calculates ballast 13

efficacy factor by first measuring ballast factor, a 14

measure of relative light output, and dividing by the 15

ballast input power, and multiplying by 100. In the 16

NOPR, DOE is proposing to amend the existing test 17

procedure by updating the ANSI reference from the 1984 18

version of C82.2 to the 2002 version. In addition, 19

it ‟ s proposing to indicate particular ANSI standards 20

for use with ballasts that operate at low or high 21

frequency. 22

At this time, we seek comments on the 23

updates to the existing test procedure -- the updates 24

-- the test procedure by updating the ANSI standards 25Executive Court Reporters (301) 565-0064 35

and the appropriate use of the three standards 1

mentioned on this slide. 2

MR. RABA: Comments? Sir. You have 3

comments on this? 4

MR. THOMAS: Yes. Busy taking notes here, 5

excuse me. Ed Thomas, GE Lighting. Yeah, we found 6

issues with this system because it ‟ s based upon input 7

power for one. Lamps have variation and that 8

variation relates to the wattage of the lamp that it ‟ s 9

actually going to operate at. With the efficient 10

ballast, typically -- let ‟ s just pick a number -- 90 11

percent efficiency -- 90 percent of the input wattage 12

that ‟ s represented by the input power comes from the 13

lamps. The ballast manufacturer has no control over 14

that level of wattage. And so that number will vary 15

around at the pleasure of the lamps being used in the 16

test. And when you add to that, the errors associated 17

with the photometric measurement, this is where we 18

find large variations in ballast efficacy factor that 19

can make a high performance ballast look not so good. 20

And if one were to -- how shall I use the 21

term -- shop for laboratories, you could find an 22

improvement in your ratings, should you desire to do 23

that. Not a recommended practice, but it has been 24

heard of in the industry. So between the variations 25Executive Court Reporters (301) 565-0064 36

between laboratories, variations in the lamp types, 1

and even the skill between the different laboratories, 2

even though the test method is defined, if you were to 3

read through the test method, it ‟ s not accurately 4

defined, and there ‟ s a lot of latitude that ‟ s involved 5

in the measurement. 6

MR. RABA: Further comments? 7

MR. ERHARDT: Yeah, Bob Erhardt, Philips 8

Lighting and Electronics. We ‟ d also like to comment, 9

and when we ‟ re talking about using ballast efficiency 10

measurements, we currently have only developed 11

correlations for instant start ballasts and ballasts 12

that do filament cutout when operating at full output. 13

ANSI test procedures for BEF will be required for 14

rapid start and other lamp types that -- other ballast 15

types that leave filament heating in place. 16

There is a new version of ANSI 82.2 coming 17

out. It is -- Ed maybe you can keep me corrected here 18

-- but I believe it ‟ s being voted on currently, is 19

that right? 20

MR. THOMAS: 82.2? 21

MR. ERHARDT: Yes. 22

MR. THOMAS: I believe it ‟ s certainly in the 23

works. I don ‟ t know quite where it is now. 24

MR. ERHARDT: Anyhow, we believe it ‟ s out 25Executive Court Reporters (301) 565-0064 37

for vote currently, and it ‟ s publication will be 1

imminent. So you may wish to consider using the 82.2, 2

2010 I believe it would be. 3

MR. RABA: Thank you. Anyone else please? 4

Go ahead. 5

MR. MCGARAGHAN: This is Mike McGaraghan on 6

behalf of California investor-run utilities. We would 7

generally support this shift to ballast efficiency, 8

provided that DOE agrees with NEMA ‟ s finding that it 9

does decrease variation in lamp testing. But I do 10

have a handful of questions, some of them may be best 11

for DOE, some perhaps for NEMA. 12

The first is if someone could provide a 13

little more detail on the resistor bank method one 14

used for program start ballasts. Does it capture 15

cathode heating? The second question, does using a 16

number of different resistors for different ballast 17

factors accurately capture impedance in lamps? The 18

variation of impedance? And the third question -- why 19

don ‟ t we start with those two? And if anyone has 20

responses, that ‟ d be great. And then I ‟ ll get to the 21

third question. 22

MR. RABA: Restate the first question, 23

please? 24

MR. ERHARDT: I think I understood the 25Executive Court Reporters (301) 565-0064 38

questions. First of all, I think -- 1

MR. RABA: Bob Erhardt? 2

MR. ERHARDT: Bob Erhardt, Philips Lighting 3

and Electronics. I think we ‟ ve already stated that 4

for now we are only proposing ballast efficiency 5

measurements for instant start ballasts and for 6

program start ballasts that have full filament cutout 7

at full operation, so when the filaments are not being 8

heated. And getting back to what Ed was talking 9

about, we are now proposing -- we have a preferred 10

method of actually using reference lamps for doing the 11

ballast efficiency measurement. The reason being that 12

while, for a given ballast operating at a different 13

power point, at a given ballast factor, a set of 14

substitution resistors can be reasonably accurately 15

developed, and resistors can offer some opportunity 16

for ease of measurement. You can do just an RMS 17

voltage across them if you know it ‟ s a non-shifting 18

precision resistor, for instance. 19

However, the -- even small variations in 20

ballast factor move the ballast away from its normal 21

operating point when you ‟ re using a common set of 22

resistors for all ballasts, and it would -- we would 23

propose that if you were to use resistors that you 24

would at least have one for each class, which would 25Executive Court Reporters (301) 565-0064 39

mean you would have to have separate resistors defined 1

for low, medium, and high output, and maybe even 2

further delineated because a high output ballast could 3

be a one ballast factor, or it could be a 1.2 ballast 4

factor, and you do start to see significant deviations 5

from the proper operating point of the electronic 6

ballast when you ‟ re moving it away from its design 7

operating point. 8

We have found -- I ‟ ve been in the industry 9

28 years, we been using substitution resistors without 10

any difficulty all along. Occasionally, you will find 11

a ballast that operates differently on resistors than 12

it does on lamps, and that is another factor to take 13

into consideration. And one of the reasons why we 14

would again propose that you look at using reference 15

lamps to do ballast efficiency measurements, the lamp 16

automatically compensates for the power level, and the 17

ballast should be able to operate the lamps. There 18

have been times when a ballast may not start properly 19

if they ‟ re connected with resistors, or there may 20

other difficulties. 21

MR. RABA: Is there any follow-on to the 22

comments? Response. Next question? 23

MR. MCGARAGHAN: So I just want to clarify. 24

MR. RABA: Sure. 25Executive Court Reporters (301) 565-0064 40

MR. MCGARAGHAN: NEMA ‟ s proposing to use 1

reference lamps. DOE has proposed to use resistors. 2

In the DOE proposal using resistors, how do you intend 3

to measure program start lamps without cathode cutout? 4

MR. WALKER: I think I can answer your 5

question. In the proposed method, a program start 6

ballast that uses cathode cutout would have maybe just 7

a residual amount of electroheating left. That would 8

still be captured in an output power measurement, but 9

it would be very similar to an instant start system. 10

However, for a rapid start system that does 11

include cathode heating, the heating power would be 12

included in the output power measurement as the 13

proposal stands at this point. 14

MR. RABA: That was Matt Walker. Does that 15

help your concerns? 16

MR. MCGARAGHAN: Yes, thank you. And the 17

last question I had was DOE indicated in the TSD, not 18

in the test procedure NOPR, that it cannot -- it 19

interprets -- I ‟ m not sure if it ‟ s referencing a 20

statute, but it says that it cannot move away from the 21

BEF metric, and that ‟ s why it ‟ s proposing BE into BEF. 22

Can DOE provide more background on why it believe it 23

cannot move away from BEF? 24

MS. KOHL: I ‟ m not sure -- this is Betsy 25Executive Court Reporters (301) 565-0064 41

Kohl from DOE -- I ‟ m not quite sure that we ‟ re there 1

yet, whether that was an error in the document or not. 2

Do you have a citation you can give me and we can make 3

sure -- 4

MS. GRAVES: Could you speak into the 5

microphone, please. 6

MS. KOHL: Sorry. This is Betsy Kohl, DOE 7

GC. And I was asking for a reference to the document 8

where he ‟ s looking. 9

MR. MCGARAGHAN: On Page 221. 10

MS. KOHL: Okay. 11

MR. MCGARAGHAN: "Doe preliminarily 12

determined that it cannot change their recorded metric 13

from BEF." 14

MS. KOHL: We will take a look at that. 15

MR. MCGARAGHAN: The follow-on comment to 16

that is that the California Investor-run utilities 17

would support the transition to relative system 18

efficiency, and believe that that could be done as a 19

conversion from ballast efficiency to ballast efficacy 20

factor, and then on to relative system efficiency. 21

MR. RABA: Other comments. 22

MR. THOMAS: Thank you. Ed Thomas, GE 23

Lighting. I ‟ d like to go back to the point that 24

Matthew mentioned just a minute ago, when you 25Executive Court Reporters (301) 565-0064 42

mentioned the testing of rapid start -- 1

MS. GRAVES: Ed, we need you to speak into 2

the microphone, please. 3

MR. THOMAS: I ‟ m sorry, yes. Going back to 4

the point that Matthew mentioned about testing the 5

rapid start systems and having the heating energy 6

taken as part of the output. Therefore, there would 7

be no difference in the performance level between a 8

rapid start system that heats the lamps continuously 9

and an instant start system that does not and 10

transfers all of its energy to light. I can ‟ t 11

understand how those two would be equated. 12

MS. GUPTA: Matthew, this is Mimi Gupta, 13

Navigant. I think you misspoke, right. 14

MR. MCGARAGHAN: I think I did mispeak. 15

Thank you. 16

MS. GUPTA: I think the cathode heating is 17

not included in the outcome power to the lamp so a 18

rapid start ballast would be less efficient than an 19

instant start according to the test procedure. 20

MR. THOMAS: Yeah, I guess the reason I 21

raised that is I noticed how the groupings of systems 22

were put together with rapid start grouped in the same 23

categories as instant start. And with the power that 24

is lost in the cathode heating, I ‟ m just wondering how 25Executive Court Reporters (301) 565-0064 43

that ‟ s going to be rationed out, and where is that 1

loss going to be assigned to, I guess would be the 2

question that I actually have. 3

MS. GUPTA: I get -- this is Mimi Gupta from 4

Navigant Consulting. What do you mean, where would it 5

be assigned to? You mean would the standard account 6

for it? 7

MR. THOMAS: More or less, yes. You have a 8

certain amount of energy that ‟ s in a rapid start 9

system that would be transferred to the making of 10

light, if you will, and there ‟ s a certain amount of 11

energy that ‟ s transferred simply to heat the cathodes. 12

Okay. That ‟ s in a rapid start system. In an instant 13

start system, all the energy is transferred into 14

making light. Therefore it ‟ s going to be more 15

efficient system. 16

What the present rule seems to have is a 17

rapid start grouped in the same exact category as 18

instant start, and I just need to understand how that 19

can be. 20

MS. GUPTA: Right. I think this gets to 21

product classes, which is what we ‟ ll discuss later 22

this afternoon, but I think the idea is, does DOE -- 23

DOE tries to determine whether there ‟ s a unique 24

utility between a T12 rap, four foot medium bi-pin rap 25Executive Court Reporters (301) 565-0064 44

start system, and a T8 instant start system. And in 1

the preliminary analysis, DOE determined there wasn ‟ t 2

a unique utility, so even though a rapid start system 3

would have to expend some energy to keep those 4

cathodes, there ‟ s no additional utility between the 5

two systems so that ‟ s why they set the same standard 6

for both and put them in the same product class. 7

MR. ERHARDT: May I respond? 8

MR. RABA: Yes. 9

MR. ERHARDT: Bob Erhardt. Just a couple 10

quick comments. One, at the risk of getting ahead 11

into the product categories, rapid start systems fall 12

somewhere more between instant start and program start 13

as far as how well they treat the lamps. Before there 14

was program start, rapid start was the preferred 15

configuration for longer lamp life and frequent 16

switching. 17

I believe that Navigant answered the 18

questions by saying that filament heating would be 19

considered as losses in doing a ballast efficiency 20

measurement, and I think that ‟ s a clarification for 21

Mr. Thomas. 22

One small comment is that I don ‟ t know 23

exactly how significant it is, but filament heating 24

will reduce cathode fall which could affect column 25Executive Court Reporters (301) 565-0064 45

efficacy. It may only be on the order of one or two 1

percent, but it ‟ s not exactly pure losses because your 2

cathode fall may go down a couple volts, and that 3

could increase your column efficacy. 4

MR. RABA: In the back, please? 5

MR. STEPHENS: Charlie Stephens. So would 6

that effect on the lamp cathode show up in a 7

photometric measurement from the output from the lamp, 8

as it ‟ s currently -- as the test currently is done? 9

MR. ERHARDT: Bob Erhardt. As the test is 10

currently done, light output ‟ s light output. So it 11

take into account all effects and you ‟ re looking at -- 12

actually you ‟ re looking at the column efficacy, and so 13

in the current BEF, no, I guess the current BEF where 14

you ‟ re looking at just one portion of the two, would 15

be very close to what Navigant has proposed. 16

MR. STEPHENS: Okay, the reason I asked 17

that, I think I recall something in the Federal 18

Register Notice where there was some descriptions of 19

this issue where it was reference to cathode heating, 20

having an impact on the lamp efficacy and the light 21

output of the lamp. And so the current test, if 22

you ‟ re measuring with a photocell, the output of the 23

lamp, if there is an improvement in other words, of 24

the light output of the lamp as a result of that, it 25Executive Court Reporters (301) 565-0064 46

wouldn ‟ t, as you suggested, be entirely losses. 1

MR. RABA: Yes, Charlie Stephens. 2

MR. STEPHENS: Charlie Stephens. 3

MR. ERHARDT: Let me clarify. I may be 4

back-tracking a little bit here. The column efficacy 5

is -- there ‟ s a -- the column discharge which is 6

giving you light, and then there ‟ s the cathode fall. 7

And so the total lamp voltage, if you have a 130 volt 8

lamp, for instance, 10-15 volts of that might be 9

cathode fall that produces no light. It ‟ s a power 10

dissipation. That ‟ s one of the -- and that is what 11

filament heating can affect. So yes, heating the 12

filaments can improve the efficacy -- well, can 13

improve the efficacy of the column, but not enough to 14

cover the losses you ‟ re putting into the filaments by 15

heating the filaments. 16

I ‟ m just saying that -- I ‟ m getting into 17

minutiae and perhaps we ‟ re getting a little too 18

detailed because I don ‟ t think NEMA has any objection 19

to putting rapid start with instant start for the 20

purpose of classification. 21

MR. RABA: I see a nodding of the head. 22

Thank you Bob. Further comments? 23

MS. GUPTA: Jim, can I -- 24

MR. RABA: Mimi Gupta. 25Executive Court Reporters (301) 565-0064 47

MS. GUPTA: I just wanted to ask a follow-on 1

question, Bob. So you mentioned how there ‟ s no 2

ballast efficiency measurement method for rapid start 3

that NEMA has come to a consensus on, is that correct? 4

MR. ERHARDT: Well, we have not come to 5

agreement on -- and I guess I read quite a bit of this 6

document, I don ‟ t claim to have read all of the 7

document, and we have not come to consensus on how to 8

treat the filament losses if we wanted to use a 9

ballast efficiency. There have been proposals, but we 10

haven ‟ t done any testing to back it up, and we do have 11

quite a bit of round robin testing and testing at 12

certified labs, with the instant start configuration. 13

We just have not done the diligence on the program 14

start and the rapid start with filament heating in 15

place. 16

We think the Navigant proposal of including 17

the filament heating with the losses is a good first 18

pass approximation. We just have not done the due 19

diligence to convince ourselves that we want to 20

support that. 21

MR. RABA: Thank you, Bob, very thorough. 22

Questions to follow on? Comments? Matt? 23

24

MR. WALKER: All right. This slide ‟ s going 25Executive Court Reporters (301) 565-0064 48

to hit on two of the things we just talked about, but 1

I ‟ ll go ahead and go through it again for 2

completeness. At the framework document meeting, many 3

-- DOE received many comments on potential sources of 4

variation in the existing test procedure, both through 5

lamp manufacturing, and differences in the measurement 6

technique itself. As well, many commentors pointed 7

out that the metric of BEF might have some 8

limitations. 9

First, for lamp manufacturing variation, 10

some commentors indicated that ballasts tested with 11

the reference lamp, the measured power of this 12

reference lamp can deviate up to 2.5 percent of the 13

rated lamp power, which then impacts the ballast input 14

power and ultimately, BEF. 15

Then in terms of differences in the 16

measurement technique itself. DOE received comment 17

that the same ballast tested at different facilities 18

may exhibit different values of BEF. One possible 19

source of this difference could be differences in 20

ambient temperature from one facility to the next. A 21

lamp is known to change its operating characteristics 22

in response to temperature, and this can affect 23

ballast input power, and again, ultimately BEF. 24

Commentors also noted that to measure 25Executive Court Reporters (301) 565-0064 49

ballast factor in electronic ballasts is often 1

compared to reference circuit that operates at low 2

frequency. DOE also received comment that lamps from 3

different manufacturers may respond differently to 4

this change between low and high frequency operation, 5

which affects the consistency of the ballast factor 6

measurement, and again, ultimately, the efficiency 7

metric of BEF. 8

And the finally, DOE received many comments 9

on the fact that BEF cannot be used to directly 10

compare ballasts that operate different total wattage 11

loads, different wattage lamps, and different numbers 12

of lamps. 13

Along this same lines, several commentors 14

suggested that the metric could be changed from BEF to 15

an alternative, such as ballast efficiency or relative 16

system efficacy. As we ‟ ve described before, DOE has 17

preliminarily setting standards in terms of BEF, but 18

may consider alternatives. And in this proposal, DOE 19

is proposing to measure ballast efficiency using a 20

ballast resistor system, and then correlate this 21

measured ballast efficiency to BEF. 22

On this slide, DOE is just seeking comments 23

on all aspects of the existing test procedure. I 24

think we ‟ ve already received a lot of comment to the 25Executive Court Reporters (301) 565-0064 50

effect of this issue, but if there is any lingering 1

thoughts? 2

MR. ERHARDT: Bob Erhardt, Philips Lighting 3

and Electronics. One small comment. I saw in the 4

document, and you just said it again, BEF is related 5

to the light output, not the power of the lamp. And 6

so for that reason, you can conceivably use the same - 7

- you can compare BEFs for lamps with like light 8

output, reference light output. But again, it ‟ s -- 9

one reason that you ‟ re using BEF is that there is some 10

variation in the light output of the lamp and since it 11

is a photometric measurement, you want to be measuring 12

the ballast, then, so you use a reference lamp and you 13

do a comparison. 14

But as I said in my opening comments, we 15

agree you can use the same BEF limits for the two 16

lamps you specified for your medium by-pin. You had a 17

34 watt T12, and you had a 32 watt T8, but they had 18

within a percent or so, the same lumen output. And in 19

that case, when you ‟ re assuming the same lamp, the 20

same reference lamp, rating on the reference lamp, 21

then I think it is fair to use the same metric, the 22

same limits of BEF, when you have the same light 23

output. It ‟ s not power, it ‟ s the light output. 24

MR. RABA: Okay. 25Executive Court Reporters (301) 565-0064 51

MR. HAKKAHANEN: Pekka Hakahanen, Lutron 1

Electronics. One small comment is that while ballast 2

efficacy factor is a photometric measurement, so is 3

the relative system efficiency, or relative system 4

efficacy metric, and suffers from these same problems 5

that -- of inaccuracy that the BEF does. 6

MR. RABA: Thanks. 7

MR. deLASKI: Could you bring up the 8

previous slide, please? 9

MR. WALKER: Sure. 10

MR. deLASKI: Andrew deLaski, Appliance 11

Standards Awareness Project. In your last step, 12

there, your last bullet here, to ... BE to BEF, so 13

what ‟ s the purpose of that step? 14

MR. WALKER: I guess the purpose is to -- I 15

feel like I ‟ m saying the same thing -- the goal is to 16

set standards in terms of BEF, so in order to reach 17

that BEF value that we can set standards on, the 18

measured efficiency metric needs to be correlated to a 19

different number. Is that answering your question? 20

MR. deLASKIV: Let ‟ s hear what Bob has to 21

say. 22

MR. ERHARDT: This was NEMA ‟ s proposal and 23

in principle, the light output is proportional, at 24

least to a first order approximation, to the output 25Executive Court Reporters (301) 565-0064 52

power for an instant start system, and that ‟ s why we 1

have some -- we haven ‟ t come to agreement yet on what 2

to do when you ‟ re still heating the filaments. But 3

for an instant start system, the column power is 4

almost directly proportional to the output power. So 5

if you ‟ re measuring ballast efficiency for an instant 6

start system, and you ‟ re measuring the output power 7

over the input power, you ‟ re measuring a parameter 8

that has, we feel, a direct correlation to light 9

output. Output power has a direct correlation to 10

light output. 11

And so that ‟ s why we feel you can develop a 12

correlation between BEF, which is a relative light 13

output, and it ‟ s the BF is the light output of the 14

ballast over the reference light output. It ‟ s a 15

number. But again, it ‟ s light output that you ‟ re 16

talking about. And output power has a correlation to 17

light output, so you can develop a correlation -- if 18

you agree that output power is proportional to light 19

output, and that ‟ s what our testing -- you know, we ‟ ve 20

done testing to show this -- then you can use a 21

mathematical formula for a given lamp type, after 22

you ‟ ve developed -- after you ‟ ve developed a lumens 23

per watt, if you will, for a lamp, then you can just 24

take that -- you can take that number and put it into 25Executive Court Reporters (301) 565-0064 53

your output watts over input watts formula, and get 1

light output over input watts, which is BEF. 2

MR. deLASKI: Okay. 3

MR. RABA: You look puzzled. 4

MR. deLASKI: It ‟ s okay. 5

MR. ERHARDT: I have been accused of being 6

over-detailed. 7

MR. RABA: Thank you, Bob. We ‟ ll study it 8

later. The record. Thank you very much. Comment 9

there, please? 10

MR. MCGARAGHAN: Mike McGaraghan, California 11

utilities. I just wanted to respond to the gentleman 12

from Lutron, I ‟ m sorry I missed his name. 13

MR. RABA: Pekka. 14

MR. MCGARAGHAN: Pekka. Mentioned a minute 15

ago that RSE, relative system efficiency, would have 16

the same negative aspects as ballast efficacy factor 17

because it ‟ s based on lumen output. But I just want 18

to make sure -- my understanding is if you can 19

correlate ballast efficiency to ballast efficacy 20

factor with this set of mathematical equations, that 21

you could do the same thing from ballast efficiency to 22

relative system efficiency. And the benefit of 23

relative system efficiency is that you can -- or one 24

benefit -- is that you can compare ballasts operating 25Executive Court Reporters (301) 565-0064 54

different numbers of lamps. So instead of 70 product 1

classes, by my count, we ‟ d be down to 18 or 20, I 2

forget which. 3

MR. RABA: Thank you. Yes, please. 4

MR. HAKKAHANEN: Pekka Hakahanen, Lutron. 5

Agree with your last comment. I just wanted to point 6

out that the -- if it ‟ s used in the form of 7

photometric measurements, then it has the same 8

problems. If we start with ballast efficiency, and 9

then move to whichever metric, we avoid the problems. 10

MR. RABA: Bob? 11

MR. ERHARDT: This is Bob Erhardt. Just a 12

couple of comments. One, yes, RSE does make -- give a 13

set of numbers that are easier to understand. When 14

you ‟ re comparing for the same lamp, an RSE gives -- 15

and you have different numbers of lamps, agreed, it 16

gives you an indication of the efficiency of the 17

ballast. 18

Whether you can take the 40-odd number of 19

medium by-pin categories and put them into -- cut them 20

by a factor of 12 or more, you have to recognize that 21

they have -- we have recognized that there are -- that 22

high power ballasts are more efficient than low power 23

ballasts, and Navigant has made a recommendation, and 24

DOE has it in the preliminary analysis that the -- you 25Executive Court Reporters (301) 565-0064 55

would effectively have a higher RSE - a lower RSE 1

allowance for a one-lamp low power ballast, than you 2

would a four-lamp high power ballast, because there 3

are formulas for taking into account the relative 4

efficiencies of different categories of ballasts. 5

And the other issue with RSE. I think if it 6

wasn ‟ t for the T8 lamp being a 60 hertz referenced 7

lamp, and that at high frequency it doesn ‟ t run at 32 8

watts, I think NEMA would be more open to RSE. But 9

RSE gets a little confusing because it takes the rated 10

lamp power and puts it into the equation. And for a 11

T5 lamp, for instance, where the rated lamp power is 12

at a ballast factor of one; for a T8 lamp, the rated 13

light output with a ballast factor of one does not 14

occur at 32 watts. So it still is not -- for 15

differing lamp types, it ‟ s still not -- it ‟ s still not 16

a direct reference. 17

MR. RABA: Are you okay? 18

MR. ERHARDT: Am I saying too much again? 19

MR. RABA: No, you ‟ re fine. Fine. Just 20

want to make sure that we cover it so if there ‟ s any 21

more to draw out we can do that. Further comments, 22

questions? Follow-on? Matt. 23

TEST PROCEDURE: ALTERNATIVE METHODS 24

MR. WALKER: Right. Matthew Walker. As a 25Executive Court Reporters (301) 565-0064 56

follow-on to this discussion, DOE did then begin to 1

consider some alternative methods after receiving 2

comments that the existing test procedure may have 3

some deficiencies. Before looking at alternative 4

metrics, DOE looked at improving the variation and the 5

existing lineup of base method by looking at the 6

particular specifications within this method. 7

DOE believes that some of the variation in 8

the ANSI-based light output base test procedure can be 9

reduced by further specifying some key factors. The 10

first would be to reduce the tolerance on lamp 11

measured power for a reference lamp, from plus or 12

minus 2.5 percent of rated wattage, to plus or minus 13

one percent. 14

Next, the tolerance on testing facility 15

ambient temperature can be reduced from plus or minus 16

one degree Celsius to plus or minus half a degree 17

Celsius, from 25. 18

The next three bullets provide some 19

additional clarification on the ballast factor 20

measurement. DOE could specify that a reference lamp 21

be operated at constant voltage, that electric heating 22

be used in the reference circuit for the purpose of 23

ballast factor measurement, for ballasts of all 24

starting methods that operate medium bi-pin, miniature 25Executive Court Reporters (301) 565-0064 57

bi-pin, or recessed double-contact lamps. And finally 1

for ballast factor measurement, DOE could specify that 2

light output measurements be used for ballasts of all 3

starting methods. 4

And finally, in a improved light output5

based method, DOE would specify the type of lamp to be 6

the most common wattage lamp and that the ballast 7

operate the maximum it ‟ s capable of operating for 8

testing. 9

So like any method, it has potential 10

advantages and disadvantages. The procedure would be 11

familiar to industry. The ballast does operate its 12

natural load, such that measurements of its 13

performance do reflect how it ‟ s actually used in 14

practice. And DOE does expect that measurement 15

variation would be reduced by tightening these 16

tolerances. 17

However, the tighter tolerances will come 18

with additional burden to those who are required to 19

perform the testing, and the effects of lamp 20

manufacturing variation are not eliminated through 21

these improvements. 22

So at this time we could maybe have a few 23

comments on this improved light output-based test 24

procedure as an alternative to the existing method? 25Executive Court Reporters (301) 565-0064 58

MR. STEPHENS: Charlie Stephens. Could you 1

go back to a previous slide. I ‟ m getting lost in the 2

terminology here a little bit. The second to last 3

bullet down there, ballast factor. Do you literally 4

mean "ballast factor" there? 5

MR. WALKER: I do. 6

MR. STEPHENS: Okay. 7

MR. WALKER: Maybe I can just provide a 8

little more context? 9

MR. STEPHENS: Yeah, a little more 10

explanation of that. 11

MR. WALKER: You ‟ re talking of this one 12

here? 13

MR. STEPHENS: Yes, what are you speaking to 14

there? 15

MR. WALKER: Right. In the 2002 version of 16

ANSI C82.2, it specifies that light output 17

measurements can be used for measuring the reference 18

system and your ballast of interest for rapid start 19

and program start ballast, whereas a power measurement 20

can be used for instant start systems. And I guess 21

earlier in this rulemaking process, DOE came under the 22

understanding that it was industry practice to use 23

light output measurements for ballasts of all starting 24

methods. So this is an attempt to synchronize with 25Executive Court Reporters (301) 565-0064 59

industry practice and to make sure things are 1

consistent across all test facilities. Does that 2

help? 3

MR. STEPHENS: Yes. When people use the 4

term "ballast factor" I ‟ m -- I ‟ m used to thinking of 5

.88 and 1.0 and 1.2 as those numbers. So is that what 6

you ‟ re speaking about in that -- 7

MR. WALKER: That is what we ‟ re speaking 8

about. 9

MR. STEPHENS: So you ‟ re using the light 10

output essentially to determine that number? 11

MR. WALKER: Right. 12

MR. STEPHENS: Okay. Thank you. 13

MR. THOMAS: Ed Thomas, GE Lighting. Just 14

wanted to make a quick comment about the temperature 15

control characteristics that you mentioned. 16

Controlling a large photometric laboratory to within 17

one half of a degree C is a pretty daunting task, with 18

people and activities going on in a laboratory and 19

trying to maintain that type of temperature would be 20

somewhat of a burden, not only on my lab, but I guess 21

on everybody else ‟ s lab too. Would be resulting in 22

upgrades of air conditioning, air handling controls, 23

so there would be some cost associated with that, 24

certainly. 25Executive Court Reporters (301) 565-0064 60

MR. PARISELLA: This is Joe Parisella from 1

Osram Sylvania. I would also say from a practical 2

standpoint, normally the test laboratories, as opposed 3

to the design laboratories, normally efficiency 4

measurements are taken very frequently in the design 5

laboratories, whereas there would have to be some 6

correlation factor that the designers would have to 7

use, or the manufacturing facilities would have to 8

use, because using photometric measurements would be 9

very time consuming and have to be some correlation 10

there anyway. So I just wanted to point that out that 11

traditionally in design laboratories efficiency 12

measurements are very commonly taken. 13

MR. ERHARDT: Just a short answer -- Bob 14

Erhardt, Philips Lighting and Electronics. I think we 15

would agree that tightening the tolerances on the 16

reference lamp and the temperature would improve the 17

accuracy of BEF. Holding temperature to within plus 18

or minus half a degree would likely require some 19

specialized equipment. You might have to have some 20

type of test box or something. 21

Also, I don ‟ t know what the impact would be 22

of requiring that plus/minus one percent tolerance on 23

the lamp power. As it is, we don ‟ t just pick up the 24

phone and order a box of reference lamps. We order 25Executive Court Reporters (301) 565-0064 61

boxes of lamps and test and test and test until we get 1

a collection of reference lamps. Those reference 2

lamps also only tend to remain reference lamps for a 3

while, and then you test and test and test multiple 4

boxes of lamps until you have reference lamps again. 5

So that would of course increase the difficulty of 6

keeping a cache of reference lamps. I think we can 7

take it under consideration, but it ‟ s practical to try 8

to take that to one percent. 9

MR. RABA: Good comments. Any further? 10

MR. WALKER: All right. Matthew Walker 11

again. So after looking at improving the light 12

output-based method, DOE then began to consider 13

alternative metrics that it could correlate back to 14

BEF. As we ‟ ve talked about already today and Ed 15

presented on earlier, a NEMA ballast technical 16

committee has drafted a test procedure that measures 17

ballast efficiency with a lamp and ballast system. In 18

general, the lamp and ballast system is energized, 19

output power and input power are measured while the 20

system is at steady state. Ballast efficiency would 21

then be calculated as output power divided by input 22

power. And then DOE currently would plan to convert 23

this ballast efficiency to BEF using a transfer 24

equation. 25Executive Court Reporters (301) 565-0064 62

So again, we ‟ ve already kind of heard this 1

directly, but some advantages to the method are that 2

it does accurately characterize the real life 3

operating conditions of the system, particularly in 4

comparison to a ballast and resistor system. The lamp 5

is a dynamic load and is able to respond accurately to 6

a different ballast factor, again in contrast to a 7

resistor, which is specifically matched to one lamp 8

impedance. 9

And the calculation of ballast efficiency 10

makes the method less sensitive to lamp power and 11

environmental conditions because these variations 12

impact both the input power and the output power, and 13

the calculation of ballast efficiency tends to 14

minimize these effects. A lamp is still involved in 15

the system, so there may be some variation from lamp 16

to lamp, so it may still be an issue. 17

We ‟ ve already talked about this method quite 18

a bit, but if there are any additional comments on the 19

lamp-based ballast efficiency method correlated to 20

BEF, this is a good time to air some of those. 21

MR. THOMAS: Ed Thomas, GE Lighting. I ‟ d 22

just like to point out that where you listed as 23

potential disadvantages, lamp to lamp variation is not 24

so much of an issue because any changes in the lamp 25Executive Court Reporters (301) 565-0064 63

operating conditions aren ‟ t going to be a ratiometric 1

change that would be in the ratio for ballast output 2

power divided by ballast input power. So if the lamp 3

should run slightly higher in energy or slightly lower 4

in energy due to design variation, manufacturing 5

variation, it will still come out in the ratio as not 6

really having a very large effect on the measured 7

electrical efficiency of the system. 8

MR. WALKER: Okay. Thanks. 9

MR. RABA: Charlie? 10

MR. STEPHENS: Charlie Stephens. As a 11

follow-up to that, and I assume then that the 12

reference lamp becomes not dependent at all on light 13

output. It ‟ s essentially taken into account. Would 14

you still need a reference lamp? 15

MR. THOMAS: Ed Thomas, GE. You would need 16

a reference lamp only in terms of electrical 17

characteristics. Reference lamps right now are 18

defined primarily as electrical operating point under 19

a given set of conditions on the lamp. There ‟ s no 20

representation of what the particular luminous output 21

must be, at least in terms of an absolute scale. So, 22

in this case, if you ‟ re using the lamps strictly as 23

electrical load, you ‟ d just be using it as such, as an 24

electrical load. 25Executive Court Reporters (301) 565-0064 64

MR. RABA: Additional? 1

MR. ERHARDT: Yeah, this is Bob Erhardt. 2

Again, the use of the reference lamp is to keep it -- 3

to keep the ballast at or near its design operating 4

point. It ‟ s, you know, the differences are minimized, 5

but if you had a lamp that was running -- if they were 6

five percent higher power, then your ballast would be 7

at a different operating point than it was designed 8

for. Now, the -- by taking an efficiency measurement, 9

you are minimizing that effect, but by keeping -- the 10

point of the reference lamp is to keep the ballast 11

operating as close as possible, as practicable, to its 12

design operating point. 13

MR. RABA: I see heads nodding. Any others 14

please? 15

MR. WALKER: I ‟ d like to ask a follow-on. 16

This is Matthew Walker from Navigant. Does anyone, 17

particularly NEMA, have suggestions or ideas on a 18

correlation method between the lamp-based BE and BEF? 19

In the proposed method, we measure both metrics, and 20

find a correlation between the two using a line of 21

best fit. Does that seem like a reasonable approach? 22

MR. ERHARDT: NEMA -- the NEMA ballast 23

companies -- sorry, Bob Erhardt, Philips Lighting and 24

Electronics. The NEMA ballast sections approach had 25Executive Court Reporters (301) 565-0064 65

been -- we had intended to bring in the lamp section 1

and try to get an industry consensus, however, we do 2

agree that if you have a set of certified data points, 3

and we have done some round robin testing of -- at 4

different certified labs, for the purpose of DOE 5

rulemaking, we think the DOE could adopt something if 6

we cannot get agreement with the lamp section in time. 7

We think that ‟ s quite reasonable. 8

I ‟ ll also comment that, similarly, while 9

NEMA from an academic and standards point of view 10

hasn ‟ t agreed on the efficiency method for program 11

start and rapid start, for the purpose of DOE 12

rulemaking, I think you could make an assumption that 13

filament heating is part of losses and we would take 14

that into account when we discuss what the BEF levels 15

should be. 16

MR. THOMAS: Ed Thomas, GE Lighting. 17

Earlier, in my presentation, there was a plot that 18

showed a relationship between ballast efficiency and 19

ballast efficacy factor. Again, based upon the data 20

that Bob had mentioned. We had done some work like 21

that and responding is a line of a best fit is 22

probably an acceptable method at this time. As Bob 23

mentioned as well, we ‟ d like to get cooperation of the 24

lamp companies to look at the transfer function that 25Executive Court Reporters (301) 565-0064 66

we ‟ re thinking about, and certainly we think that 1

there would be one transfer function that would relate 2

to instant start and full cathode cut systems, and 3

other transfer functions would relate to systems that 4

utilize some level of continuous cathode heating. So 5

I don ‟ t think it ‟ s one transfer function. It could be 6

a couple. In my presentation, I alluded to roughly 7

two different transfer functions, just based on 8

preliminary data that I had. 9

MR. RABA: Thank you. Matt. 10

MR. WALKER: All right. The final 11

alternative that DOE considered was relative system 12

efficacy, which has already come up today. Just to 13

summarize again, RSE does use the same test method or 14

could use the same test method as the existing test 15

procedure. They also discussed that it could be an 16

output of a transfer equation, if you measure 17

something else, not just ballast efficiency. RSE then 18

normalizes the BEF for ballast of different total 19

rated lamp power or ballast loads of different total 20

rated lamp power. 21

You can see on the slide, RSE is then equal 22

to BEF divided by 100 times total rated lamp power. 23

Some advantages, as we ‟ ve discussed, is that 24

RSE could be potentially more comparable across 25Executive Court Reporters (301) 565-0064 67

different ballast types in comparison to a BEF metric. 1

It does use a familiar test procedure. I guess in 2

this NOPR, DOE found that because RSE is, if you 3

measure it directly using the BEF measurement 4

technique, it ‟ s based on the same varied inputs and 5

doesn ‟ t provide improvement in measurement variation, 6

which was one of the main goals of this revision. 7

So at this time we have a moment for 8

additional comments on relative system efficacy. 9

MR. RABA: State your name, please? 10

MR. deLASKI: Andy deLaski, Appliance 11

Awareness Project. Is this what you -- the 12

methodology that you propose to use for RSE or a 13

different methodology? 14

15

MR. MCGARAGHAN: Mike McGaraghan, California 16

utilities. I think Matt just addressed my concern 17

that I raised earlier, or my suggestion was using RSE 18

based on a set of transfer values from ballast 19

efficiency, rather than using it based purely on BEF 20

or photometric measurements. So the disadvantages 21

shown there on the slide would not apply to the RSE 22

proposal I made, and I think Matt acknowledges that. 23

MR. deLASKI: Thanks. 24

MR. RABA: Further? 25Executive Court Reporters (301) 565-0064 68

MS. GUPTA: I ‟ d like to ask a question. 1

Mimi Gupta, Navigant. So is there an advantage to 2

using RSE -- like if DOE were to use RSE as the 3

metric, it would be changing the metric. Is there an 4

advantage to using RSE over ballast efficiency? 5

MR. MCGARAGHAN: This is Mike on behalf of 6

the California utilities. The main problem that we 7

see with either BEF or BE that has -- without some 8

sort of normalization based on total rated lamp power, 9

is it ‟ s hard to compare, and in the marketplace, I 10

think you ‟ ll see an increased -- people will be able 11

to take advantage of more efficient ballasts in their 12

system designs. If you ‟ re comparing a two lamp system 13

to a three lamp system, you don ‟ t know which ballast 14

is more efficient, and in many circumstances, you 15

could specify either that two lamp system or that 16

three lamp system. So it would just be an extra tool 17

for specifiers of lighting projects to take advantage 18

of all the savings potential on the table. 19

MR. RABA: Thank you. Mike, does that help? 20

Head nod. Others? 21

MR. ERHARDT: Yeah, I ‟ ll just reiterate my 22

comment and -- Bob Erhardt, Philips Electronics. I 23

agree, RSE for a lamp type does make the numbers much 24

easier to understand. The area where you need to be 25Executive Court Reporters (301) 565-0064 69

careful is that if you ‟ re going to -- if consumers are 1

going to be comparing a T8 system with a T5 system, 2

for instance, then they ‟ re going to be misled by an 3

RSE number, unless you have a good, high frequency 4

power number for the T8. Because the T8 is -- T8 5

lamps have high frequency, don ‟ t have a ballast factor 6

of one at 32 watts. They have a ballast factor of one 7

at, I don ‟ t know what the number is, 28 or something 8

like that. 9

And so if you ‟ re comparing -- this is a 10

legacy we have of the switch from 60 hertz systems to 11

high frequency systems. All the new systems, T5, 12

CFOs, et cetera, are referenced on a high frequency 13

reference ballast. They already take into account the 14

efficacy gains in the lamp at high frequency. The T8 15

lamp is a old legacy, 60 hertz system, that -- it ‟ s 32 16

watt power rating is at 60 hertz, and it does not show 17

the benefit of operating at the high frequency. So if 18

you start dividing everything by 32 watts for a T8, 19

and everything by 28 for T5, the T8s are going to look 20

pretty bad. Much worse than they are. 21

MR. deLASKI: Follow up for Bob. This is 22

Andrew from Appliance Standards Awareness Project. So 23

in your example here, comparing a T5 system to a T8 24

system, does BEF or BE give you comparable metrics? 25Executive Court Reporters (301) 565-0064 70

Metrics that enable a consumer to compare one with the 1

other? 2

MR. ERHARDT: Only when the lamp lumen 3

outputs are the same. 4

MR. deLASKI: Right. Okay. 5

MR. ERHARDT: Now, I don ‟ t have the 28 watt 6

T5 memorized right now. I think they ‟ re pretty close, 7

so that might actually be closer. And actually, Mark 8

Duffy, do you know off hand the lumen output rating of 9

a T8 versus a T5? 10

MR. DUFFY: Yeah, a 28 watt -- 11

MR. RABA: Speak up please -- use the 12

microphone up there if you would so we can all hear. 13

State your name, please? 14

MR. DUFFY: Yeah, Mark Duffy with GE 15

Lighting. I ‟ ve been asked to comment on the lumen 16

output of a 28 watt T5 lamp that ‟ s rated at 2800 17

lumens, and for an F32 T8, depending on the type, you 18

can have something on the order of 2950 lumens for the 19

highest output types. 20

MR. RABA: Okay. Thank you. Does that 21

help, Andrew? 22

MR. deLASKI: Sure. Thank you. 23

MR. ERHARDT: Bob Erhardt. I think a 24

summary of that would be that BEF might be closer in 25Executive Court Reporters (301) 565-0064 71

that case, but still wouldn ‟ t be accurate, because of 1

the 2800 to 2900 lumen difference. So the -- you 2

would expect the BEFs to vary by the ratio of those 3

light output ratings. For similar systems, for 4

similar efficaciousness. 5

MR. deLASKI: Right. But if I could 6

summarize, it seems to me that the disadvantages -- I 7

mean there ‟ s no approach that solves that particular 8

problem of being able to compare your T5s to your T8 9

system. There ‟ s no metric that ‟ s going to solve that 10

particular problem, other than having -- the higher 11

level of capacity --- 12

MR. ERHARDT: Well ballast efficiency is a 13

metric of the efficiency of the ballast, so we feel 14

ballast efficiency is a better metric of comparing all 15

systems, because that ‟ s what we do. We can only work 16

on the efficiency of the ballast. We ‟ re not really 17

affecting the -- well, filament heating, of course, is 18

going to be affecting the efficiency -- efficacy of 19

the lamp, if you will. But that ‟ s one reason we ‟ re 20

proposing ballast efficiency, because ballast 21

efficiency is the metric that rates the -- how energy 22

frugal your ballast is, if you will. I mean it ‟ s the 23

energy efficiency of the ballast. Ballast efficiency. 24

The second effect is of course the filament 25Executive Court Reporters (301) 565-0064 72

heat. Filament heat on a -- if you ‟ re providing 1

filament heat, you ‟ re providing extra losses. 2

Navigant has proposed that you include those in the 3

overall losses when you specify an efficiency. That 4

is an approach to consider, as long as you recognize 5

that systems that do program start are generally 6

specified for lighting systems where you ‟ ll have 7

occupancy sensing with frequent switchings, which will 8

save significant energy. So as long as you take these 9

factors into account when you ‟ re setting your 10

requirements, it can be a good indication of the 11

overall efficiency of the system, if you just put the 12

filament losses in with the overall losses, and use 13

efficiency as a metric. 14

MR. RABA: I saw three hands go up. First, 15

Charlie, then the back, young lady, and the gentleman 16

up there too. Charlie. 17

MR. STEPHENS: Charlie Stephens, Northwest 18

Energy Efficiency Alliance. I just wanted to throw in 19

too here, that the utility of RSE can kind of lose 20

itself if you ‟ re actually doing lighting design 21

anyway. I mean you start getting into room cavity 22

ratio, the fixture efficiency, fixture spacing, the 23

requirements on the desk, you know, 55 lumens on the 24

desk -- I mean you have to -- once you get into that, 25Executive Court Reporters (301) 565-0064 73

you need so many lumens and you need it this many feet 1

off the desk, and you start taking those into account. 2

You ‟ re not picking the fixture and the ballast and the 3

lamp combination for its most efficient combination. 4

You ‟ re picking it, potentially, because you need that 5

many lumens spaced at that many feet apart, this many 6

feet above the desk. And you need this many of them 7

in this room to provide the illumination after X 8

number of hours of lamp degradation and everything. I 9

mean there ‟ s all these factors that go into this 10

stuff. And in the end, you ‟ re not really picking 11

these things on just a one or two percent difference 12

in a ballast efficiency. You ‟ re picking a system, 13

quite frankly, and so I ‟ m not sure the RSE is going to 14

be of that much utility to a lighting designer, in the 15

end, compared to these other methods. 16

MR. ERHARDT: Yeah, I guess -- commenting on 17

that, for a lighting designer, you may very well be 18

right, the BEF is maybe the better utility because he 19

is picking a lamp for its lumens and BEF takes the 20

ballast factor, which again, tells him his lumens, and 21

then BEF tells him how much power he ‟ s going to have 22

based on the lumens he ‟ s chosen. And if he had RSE, 23

he ‟ d have to do an extra conversion. 24

MR. RABA: Saw a head nod there. In the 25Executive Court Reporters (301) 565-0064 74

back, please. Comments, questions? Covered? 1

PARTICIPANT: Yes, basically. 2

MS. GUPTA: I have one follow-up. Mimi 3

Gupta from Navigant. Just a quick follow-up question. 4

So, in talking about metrics and comparability across 5

different ballast types, is -- using ballast 6

efficiency, could you compare a two-lamp ballast to a 7

four-lamp ballast? 8

MR. THOMAS: Ed Thomas, GE. Yes, you can 9

because the ballast efficiency is going to give you a 10

number, like say, 90 percent or 92 percent, and that 11

will enable you to understand which ballast is a 12

higher performance ballast. Now, to this gentleman ‟ s 13

-- to Charlie ‟ s point -- yeah, when you couple this 14

with a fixture and with a certain set of lamps, then 15

the system becomes more complicated, but we ‟ re -- 16

we ‟ re a couple steps back from that approach. We ‟ re 17

at the approach where the OEM manufacturer is deciding 18

what product to put within the fixture or the ability 19

for people to say, I want a more energy efficient 20

product. I want to reduce the loads on my HVAC, and I 21

want to make sure that I ‟ m getting -- and energy cost 22

is going to be the greatest percentage of the cost of 23

ownership. So a ballast that will run cooler is more 24

efficient, has less losses, can be expressed by 92 25Executive Court Reporters (301) 565-0064 75

percent or some number that expresses the performance 1

of that ballast, notwithstanding other circumstances 2

in the system. 3

All the measurements that we ‟ ve talked about 4

beforehand are all system-based measurements and 5

interdependencies with ballast efficiency, you have 6

the measurement of the ballast itself, then you 7

combine your system from that point. 8

MR. ERHARDT: Just a small comment -- Bob 9

Erhardt, Philips Lighting and Electronics. Just a 10

small comment and that is, from what I read of the 11

intent of the DOE to go to the max tech approach in 12

setting its guidelines, then you ‟ re not going to have 13

much difference in efficiency -- ballast efficiencies 14

to be comparing for a given category. If you choose 15

your, even your CSL2 levels, that ‟ s pretty much going 16

to correlate to our NEMA premium products and there ‟ s 17

not a lot of ballast efficiency left. 18

If you consider a full range of possible 19

ballast efficiencies, might be 85 to 91, 92 or so, but 20

that ‟ s really pushing it, you know, our NEMA premium 21

comes in around 90, and there ‟ s not a lot of variation 22

once you start specifying a ballast efficiency of 89 23

or 90. There ‟ s just not that much there any more. 24

MR. RABA: Okay. 25Executive Court Reporters (301) 565-0064 76

MR. MCGARAGHAN: Mike McGaraghan, California 1

utilities. I just wanted to respond to Charlie and 2

others. I agree that a lighting designer with some 3

degree of expertise is not picking ballasts based on 4

RSE or the efficiency value of the ballast. They ‟ re 5

going to design a system, but I think there is a wide 6

range of expertise in practice, and I think that ‟ s 7

actually something that will come up later when we 8

discuss standards. I know in the lamp rule, DOE 9

assumed different scenarios for level of expertise. 10

High level of expertise and none, no expertise in 11

lighting designer and retrofit situations. So that ‟ s 12

a question that I ‟ ll bring up later for DOE to see 13

kind of how they ‟ re interpreting that for this rule. 14

But certainly some retrofit situations and some design 15

situations happen with less than optimal expertise., 16

and that would be an advantage for RSE to help 17

simplify it. 18

MR. RABA: Matt? 19

MR. WALKER: All right. This actually wraps 20

up the discussion of alternative methods, and it might 21

be a good time for a break. 22

MR. RABA: Sounds good to me. Ready for a 23

break? I think it ‟ s a good time. You ‟ ve done very 24

well so far. We ‟ ll take a 15-minute break right now. 25Executive Court Reporters (301) 565-0064 77

Come back at, I don ‟ t know, let ‟ s make it on the hour. 1

(Whereupon, a 19-minute recess off the 2

record was taken.) 3

MR. RABA: Welcome back. Okay, Matt, you 4

want to start on the proposed procedures, that right? 5

MR. WALKER: Sure thing. 6

MR. RABA: Okay. 7

TEST PROCEDURE: PROPOSED METHOD 8

MR. WALKER: All right, the remainder of the 9

morning we ‟ ll discuss the proposal in the NOPR for the 10

test procedure. 11

So in 2008, DOE did have a chance to 12

participate in the NEMA ballast committee ‟ s round 13

robin and its investigation of the resistor-based 14

ballast efficiency method. In the proposal, DOE does 15

proposed this ballast efficiency measurement, using a 16

ballast and resistor system. 17

The next few slides describe some of the 18

measurements and techniques in more detail, but in 19

general ballast input power and output power are 20

measured, using a ballast and resistor system. 21

Ballast factor is then measured using a lamp and 22

ballast system so that the appropriate transfer 23

equation can be selected. And then BEF is calculated 24

from BE, using this transfer equation. 25Executive Court Reporters (301) 565-0064 78

At the bottom of this slide, there ‟ s a 1

diagram that shows just what a resistor load bank 2

might look like, or does look like. In the middle, 3

you see a single resistor to the lamp arc. Then the 4

remaining four resistors are for the electrodes. Each 5

of these electrode resistors are assigned an 6

equivalent resistance equal to half that one of lamp 7

electrode. By assigning equivalent resistance to each 8

of these electrode resistors, DOE is modeling the lamp 9

arc traveling from the center of one lamp electrode to 10

the center of the other. 11

But to determine the actual resistance for 12

each of these physical resistors, DOE used a 13

combination of ANSI standard C78.81, 2005, as well as 14

some empirical methods. C78.81 provides electrode 15

resistance for all lamps while operating at any 16

frequency, and then it provides select lamp arc 17

resistances for certain operating frequencies. 18

And this is sort of the legacy thing that 19

Bob was alluding to earlier. So in the case that a 20

lamp arc resistance was unavailable, for example, high 21

frequency operation of a four-foot medium bi-pin T8 22

lamp, DOE then needed to measure this lamp arc 23

resistance empirically. 24

So we mentioned before that a resistor can 25Executive Court Reporters (301) 565-0064 79

only simulate a lamp while being operated at a 1

particular ballast factor, however, a lamp can be 2

driven at many different ballast factors, and can 3

change impedance in response to this. The lamp 4

impedance tends to decrease as ballast factor gets 5

higher and higher. 6

So rather than specify multiple ballast 7

factors, specific resistors, in the NOPR DOE proposes 8

to use a single resistor for testing a ballast of all 9

ballast factor. During testing DOE found that when a 10

ballast is tested with a resistor that does not 11

exactly match its ballast factor, the measured ballast 12

efficiency is different than if it ‟ s tested with the 13

appropriate resistor, or with a resistor that does 14

exactly match the ballast factor. 15

So to account for this change or this 16

effect, DOE specifies multiple transfer equations, 17

each one specific to a particular ballast factor bin. 18

And DOE took this approach with the effort of reducing 19

the testing burden by only requiring one resistor load 20

bank per lamp. 21

This time we have a moment for comments on 22

the use of a ballast factor measurement for 23

determining the appropriate transfer equation, as well 24

as the effect of using a single resistor value for 25Executive Court Reporters (301) 565-0064 80

measuring ballast efficiency of multiple ballast 1

factor ballasts. 2

MR. PARISELLA: This is Joe Parisella from 3

Osram Sylvania. I think we ‟ ve touched on this 4

already, but one of the biggest issues is using that 5

single resistor is that you are talking about having a 6

scaling factor, but different ballasts will react 7

differently. So if you have a single resistor, 8

certain ballasts, the scaling factors are going to 9

have to be different for different types of ballasts, 10

and I think different ballasts will react differently 11

to that same resistor value. Do depending on the 12

circuitry and the way it ‟ s tuned and things like that, 13

so I think that could be an issue with that. 14

MR. RABA: Thank you. 15

MR. THOMAS: Ed Thomas, GE. I would just 16

like to point out that ballasts are primarily designed 17

to operate lamps, and it may not -- may not provide 18

the same level of performance on a resistor as they 19

would on a lamp. 20

MR. RABA: Okay. Thoughts? Comments? All 21

right. 22

MR. WALKER: All right. We ‟ ll move on. 23

This slide provides a little more detail on the 24

measurements included in the proposed method. First 25Executive Court Reporters (301) 565-0064 81

for ballast efficiency, the electrical measurements 1

are taken within one minute of energizing the ballast. 2

These measurements include input voltage, current, 3

power, as well as output power. In the proposal DOE 4

specifies that ballast capable of operating at 5

multiple input voltages should be tested at 277 volts 6

for a commercial ballast, and then 120 volts for a 7

residential and cold temperature sign ballast. 8

Then for ballast factor, in the proposal DOE 9

indicates ballast factors should be measured according 10

to ANSI82.2, the 2002 version. And that includes some 11

of the amendments discussed in the improved light 12

output base method, those being the additional 13

specifications, and just sort of clarifications on how 14

ballast factor can be measured to make things 15

consistent from one facility to the next, as well as 16

to specify that a ballast be operated -- operate lamps 17

of a particular wattage, this being the most common 18

wattage lamp and the maximum number of lamps the 19

ballast was designed to operate. Nd the test 20

procedure. 21

DOE does specify what this most common 22

wattage is, so that there is clarity on that issue. 23

So you have any comments on the test 24

measurements? 25Executive Court Reporters (301) 565-0064 82

MR. THOMAS: Yes, Ed Thomas, GE. I ‟ d like 1

to point out that when you ‟ re taking electrical 2

measurements within one minute, the ballast has not 3

reached an optimal operating temperature. When 4

ballasts are designed for an application, the 5

application is typically a steady state application 6

where certain electronic components achieve a rate of 7

electrical efficiency that would be more 8

representative of how they will operated during the 9

long duration of operation. Certain diodes and 10

certain magnetic materials actually become more 11

efficient actually after they ‟ ve had a time to reach 12

the operating temperature that the ballast will be 13

designed for. 14

Taking the measurement within one minute may 15

not present the ballast in its true level of 16

performance, compared to a measurement taken after 17

some period of time, after these components have 18

reached some thermal operating point or thermal 19

equilibrium, as they would see in your normal 20

application. 21

MR. RABA: Thank you, good information. 22

MS. GUPTA: Mimi Gupta, Navigant Consulting. 23

So, Ed, would you suggest that DOE amend this to say 24

the measurement should be taken after some minimum 25Executive Court Reporters (301) 565-0064 83

period of time? and what would that minimum be? 1

MR. THOMAS: Ed Thomas. In the NEMA 2

discussion that were presented, we talk about the 3

stability of measurement anywhere between a time 4

period of 15 minutes to within an hour, but it was 5

talking about an overall system stability, which is 6

the ideal characteristic. If I use this room as an 7

example, the lights went on here probably six o ‟ clock 8

in the morning. By 11:30 now, they ‟ ve reached, 9

certainly reached a steady state equilibrium, and 10

they ‟ re operating in the condition that they ‟ re going 11

to operate in for the next eight or nine hours, 12

whatever the case may be. 13

Certainly if you immediately come into a 14

room, turn them on and in one minute take a snapshot, 15

you ‟ re operating characteristics are going to be far 16

different than if you allow them to operate and come 17

up to proper operating temperature. I think that if 18

you allow them to reach the point of designed 19

efficiency, and with modern day electronics, we do 20

understand that components operate differently at 21

different temperatures. And that ‟ s all taken in 22

during the design consideration. 23

Again, we design a ballast to operate over a 24

long term, not for I guess momentary applications. 25Executive Court Reporters (301) 565-0064 84

MR. RABA: Answer your question? 1

MS. GUPTA: Uh-huh (yes). 2

MR. RABA: Okay. Others? Back to you, 3

Matt. 4

MR. WALKER: Okay. Let ‟ s now move on to a 5

couple slides describing the process DOE used to 6

develop transfer equations for converting the measured 7

value of BE to BEF. 8

DOE tested both of these metrics for 9

multiple ballasts and key product classes. It used 10

the proposed resistor-based method for the measurement 11

of ballast efficiency. It then used the existing test 12

procedure, based on light output measurements for the 13

determination of ballast efficacy factor. 14

Then using this test data, DOE found a 15

linear relationship between BE and BEF. In assigning 16

this line of best fit, DOE chose to anchor the line to 17

the origin, such that when ballast efficacy equalled 18

zero, BEF would also equal zero. And in doing this, 19

the equation -- the transfer equation took the form 20

BEF equals slope of the line times ballast efficiency. 21

So DOE did have test extensive data in many 22

product classes, but for those that did not have 23

extensive data, DOE began to develop scaling 24

relationships. I should also mention that the test 25Executive Court Reporters (301) 565-0064 85

data that DOE collected during the process is 1

available in Appendix 5-C of the energy conservation 2

standard. 3

So for those product classes that did not 4

have extensive testing, DOE used extensive data from 5

the four-foot medium bi-pin and eight-foot slim line 6

ballast classes to calculate relationships between 7

slopes for changes in starting method, number of 8

lamps, ballast factor, and total rated lamp power. 9

And just as an example, if you look along 10

the horizontal line on this table, you can see the 11

axis on which DOE would use a relationship for number 12

of lamps. The vertical line would indicate the 13

relationship based on ballast factor, et cetera. 14

So at this time, we ‟ d like to seek comments 15

on the transfer equations, the actual equations used 16

to convert BE to BEF, as well as the techniques used 17

for scaling these equations. 18

MR. STEPHENS: Charlie Stephens. Could you 19

go back two slides please? On your graph there, I 20

take it each little green dot is an individual ballast 21

that was tested? 22

MR. WALKER: Correct. 23

MR. STEPHENS: Can you give me a sense of 24

the order of magnitude of the variation from your nice 25Executive Court Reporters (301) 565-0064 86

straight slope, to the individual green dots as far as 1

how that compares to the discussion we had earlier 2

about one and a half percent or two and a half percent 3

measurement error? 4

MR. WALKER: I don ‟ t know if I can speak 5

specifically to that variation. We did notice, just 6

relatively speaking, at this point all I can say is 7

that BEF did have maybe more spread in the data 8

compared to BE for a particular ballast. I don ‟ t 9

really have my hands on the particular numbers. 10

MR. STEPHENS: Yeah, I ‟ m trying to get a 11

sense of, you know, are we worried about two and a 12

half percent in our measurements only to wash all that 13

out in a slope that really doesn ‟ t come all that close 14

to the actual performance of individual ballasts by 15

the time you ‟ re done. 16

MS. GUPTA: Yes, this is Mimi Gupta, from 17

Navigant Consulting. I think you bring up a good 18

point, that one aspect of this methodology is the 19

correlation, and, you know, using the test data from 20

four foot medium bi-pins, you see a fairly good 21

relationship, but definitely for some ballast 22

categories, that relationship was not so great. So 23

it ‟ s one drawback to this proposal and DOE seeks 24

comment on whether doing this correlation is bringing 25Executive Court Reporters (301) 565-0064 87

us backward. 1

I think that though the resulting BEF may 2

have some -- some error associated with it, I think 3

using the ballast efficiency and correlating to BEF 4

insures that manufacturer to manufacturer, test to 5

test facility, you ‟ re going to get a consistent 6

measurement. MR. STEPHENS: This is Charlie 7

Stephens. True, but you -- I think we were talking 8

about an accurate representation about the efficiency 9

of individual ballasts being selected by designers or 10

whoever, manufacturers of fixtures in the marketplace. 11

And I ‟ m not sure that the accuracy or the consistency 12

of those measurements is important if you ‟ re going to 13

wash it out by twice as much when they use the factor, 14

whatever factor you use in the scaling here. 15

MR. RABA: Response over here? 16

MR. ERHARDT: Yeah, Bob Erhardt, Philips 17

Lighting and Electronics. I guess I ‟ m not sure I 18

understand what your two-to-one concern is. I mean, 19

this is a little bit of a confusing way to look at it 20

because, I have to sit here and think about what we ‟ re 21

going through with it. What you ‟ re really comparing 22

is -- this slope, if I ‟ m interpreting it correctly, 23

and I had to think about it for about five minutes to 24

convince myself, is that you ‟ re getting kind of an 25Executive Court Reporters (301) 565-0064 88

average BE over an average BEF by putting that slope 1

through there, to get a conversion factor. 2

And because what you really need to know is 3

when you ‟ re -- what we would have compared would have 4

been, instead of putting all these plots on the same, 5

do an individual by individual and then take an 6

average, but that ‟ s in effect what they ‟ ve done by 7

doing the fit. Because it ‟ s going to be -- the BEF is 8

light output over ballast efficiency -- I ‟ m sorry, 9

light output over watts, watts in, and BE is watts out 10

over watts in. So when you take the ratio of them, 11

you ‟ re -- should be canceling out the watts out, and 12

getting light -- I ‟ m sorry, you should be canceling 13

the watts in, and so your slope should then be light 14

per ballast factor over watts out, is what this slope 15

should be representing. Trying to do this in my head, 16

I think that ‟ s what you ‟ ve got there. 17

MR. STEPHENS: Yeah, this is Charlie 18

Stephens. Let me just make it a little more clear. 19

Look at the furthest right there at a BE of .92, plus 20

or minus, it says its ballast efficiency or ballast 21

efficacy factor is 1.55. It will, according to that 22

slope, it would receive a rating of about 1.57, not 23

1.55. My question is, if you -- if the accuracy of 24

your measurement delivered a BE of .92, if the actual 25Executive Court Reporters (301) 565-0064 89

BE was, you know, .907 or .909 or whatever, how much 1

worse is that than the .02 going from 1.55 to 1.57 in 2

its delivered rating via this equation? 3

MR. RABA: I think a response in the back. 4

MR. ERHARDT: It would be 1.5 -- 5

MR. RABA: Sorry, go ahead Bob, sorry. 6

MR. ERHARDT: It would -- okay, so you ‟ re 7

looking at one point and you ‟ re saying what would be 8

the error on that one point, and you ‟ re saying it 9

would be -- and I guess you ‟ ve done the calculation, 10

it would be 1.57 -- 11

MR. STEPHENS: No, I ‟ m just looking at the 12

graph, it ‟ s rating, based on that nice average line 13

would be 1.57. Direct graphically, I ‟ m seeing a BEF 14

of 1.57 -- 1.566 and -- the fact is, I ‟ m trying to 15

interpolate between the lines there. But what I ‟ m 16

saying is there ‟ s an error in the reported BEF at any 17

given BE -- and I ‟ m trying to compare the magnitude of 18

that error on this, using these transfer equations. 19

MR. ERHARDT: Okay. And I guess I -- again, 20

Bob Erhardt. I guess our response to that is two 21

points on 1.55 is one and a half percent. Okay. The 22

BEF measurement itself has a five percent error. So 23

the one and a half percent is kind of a wash when you 24

-- and the idea is we ‟ re trying to cancel the five 25Executive Court Reporters (301) 565-0064 90

percent by taking an overall average of all these BF 1

measurements using light, okay. 2

We ‟ re going to try to come up with a 3

correlation factor. We ‟ ve done round robin testing of 4

at least three labs, maybe it was four or five, I 5

don ‟ t remember actual certified testing organizations, 6

CSA, TL, UL, et cetera. I think LRC. And we ‟ re going 7

to compare their measurements, their BEF measurements 8

for the same sets of lamps and try to get a 9

correlation based on the average of all these, so to 10

get a wash out of this plus/minus five percent. And 11

then we ‟ re going to put that in -- and so then we ‟ re 12

going to take that correlation factor. 13

Now, using that correlation, which in effect 14

may be -- they ‟ ve done here, some of these were high, 15

some of them are low. Although they might have done 16

this on one testing lab. Was this all done all on 17

LRC? 18

MR. WALKER: It was all in one testing lab, 19

and actually each of these points represents an 20

average of three samples of a particular ballast. 21

MR. ERHARDT: In any case, the idea is we ‟ ve 22

tried to wash out the five percent tolerance by taking 23

averages of many BEF measurements, many light output 24

measurements, we ‟ re trying to wash out that error by 25Executive Court Reporters (301) 565-0064 91

taking an average that we can agree to, and then 1

coming up with a correlation factor that then is 2

applied to a metric that has a two and a half percent 3

error, instead of one that -- and use it instead of 4

taking the five percent error. 5

MR. RABA: The gentleman in the back has 6

been very patient. Go ahead, sir. 7

MR. COOK: Keith Cook from Philips Lighting. 8

I guess maybe expanding upon this a little bit. Matt 9

touched upon it. Is, what is the repeatability of 10

this test setup? I mean if you have a particular 11

ballast and a particular lamp, and you put it all 12

together and you run a test, then you tear it all 13

down, and you have a different operator come in and he 14

puts it all together, did you run any testing to see 15

how consistent this approach is using even the same 16

ballast and lamp? 17

MS. GUPTA: So -- this is Mimi Gupta from 18

Navigant Consulting. We had the Lighting Research 19

Center do all these tests for us, and unfortunately we 20

don ‟ t have a representative of them here. But as I 21

understand it, and I think manufacturers, you probably 22

know this better, the Lighting Research Center is a 23

certified lab, so I think they do continuous tests 24

like on the calibration -- 25Executive Court Reporters (301) 565-0064 92

MR. COOK: That has nothing to do with my 1

question. My question -- I agree that their test 2

results may be very accurate, but there ‟ s still the 3

way you set it up and the way you take the readings is 4

inducing another amount of error. And that can have 5

an effect upon, you know, the test results. And 6

that ‟ s what I ‟ m trying to understand, is how 7

repeatable is the test setup. 8

MR. RABA: Bob? 9

MR. ERHARDT: Yeah, this is Bob Erhardt, and 10

we ‟ ll be given a more detailed response in our written 11

response, but we have done -- we have tried exactly -- 12

to deal exactly that effect, Keith, by doing round 13

robin testing of multiple test labs, with the same 14

lamps and the same ballasts. So we are actually 15

looking at the repeatability of the test, and the 16

average of the test, and that ‟ s how we come up with 17

our five percent number for this BEF accuracy. And we 18

want to use the average correlations from these 19

multiple test labs, multiple certified test labs, on 20

the same ballast and the same lamps, to come back with 21

a formal response to your question on a correlation 22

factor. 23

MR. RABA: Was that helpful? 24

MR. COOK: Yes. 25Executive Court Reporters (301) 565-0064 93

MR. RABA: Thank you. And you can always 1

submit your questions or comments later on in written 2

statements and all too. Thank you, and likewise to 3

you, Bob. Further? Yes, sir. 4

MR. PARISELLA: Joe Parisella, Osram 5

Sylvania. I ‟ d just like to get some further 6

clarification on the graph here. Is this -- this was 7

done with a normal ballast factor ballast. Did you do 8

the same test with a low ballast factor and a high 9

ballast factor, ballast with the same resistor, and 10

did you get the same slope, or not? 11

MR. WALKER: Right, so we -- we would do the 12

same test using the same resistor and ballast with 13

different ballast factors, and you would actually get 14

a different slope. And that sort of comes -- due to 15

the fact that the resistor is not the exact match for 16

the ballast factor of the ballast. So the different 17

slope attempts to account for that effect. 18

MR. PARISELLA: And that ‟ s where the scaling 19

factor comes in? 20

MR. WALKER: Well, so we actually -- we 21

would have -- let ‟ s see. 22

PARTICIPANT: Go to the next slide. 23

MR. WALKER: Yeah, I ‟ ll just point to this 24

table here. For example, this slope and this one were 25Executive Court Reporters (301) 565-0064 94

all based directly on test data. And then we would 1

establish a ratio between the high and normal to 2

establish a ballast factor scaling ratio. 3

MR. PARISELLA: Okay. 4

MR. WALKER: So there was an initial test 5

based on test data directly used to develop the 6

scaling ratio. Does that help? 7

MR. PARISELLA: Yep. Thank you. 8

MR. WALKER: Okay. 9

MR. THOMAS: Ed Thomas, GE. Matt, I ‟ m just 10

curious if any effect of the lamps under -- when doing 11

the BEF measurements, if you looked at efficacy of the 12

lamps under full power loads versus low light level 13

loads, did you find that the efficacy of the lamp 14

varied between a normal light level and a low light 15

level ballast, or a normal light level and a high 16

light level ballast, given the watts loading in the 17

tube? 18

MR. WALKER: I don ‟ t think we -- I don ‟ t 19

think we have data that answers that. 20

MR. ERHARDT: Yeah, just one comment. I ‟ m 21

sorry, Bob Erhardt, Philips Lighting and Electronics. 22

And one comment concerning scaling factors. We agree 23

that scaling factors can be valid. We will be 24

supplying in our written report, in our written 25Executive Court Reporters (301) 565-0064 95

comments, again I said -- and I have in front of me, 1

but it ‟ s much too much to put on the screen. I ‟ ve got 2

-- I took 400 medium -- I took from the California 3

Energy Commission, 400 medium bi-pin test data. I 4

looked at the, from the four major manufacturers, I 5

took the highest BEFs for each category in your 6

matrix, and I did averages of those, and I developed 7

some correlation factors that are pretty close to what 8

you came out with, but you may wish to analyze the 9

further data if you haven ‟ t done so, and I will be 10

supplying it to you. 11

MR. RABA: Thank you. Matt? 12

MR. WALKER: All right. We ‟ ve move on to 13

the transfer equations. So this is the final content 14

side for the ballast test procedure. And I think it ‟ s 15

come up earlier today, it is the case that during 16

testing we did find that some ballasts did not operate 17

resistors. We then confirmed that the ballast did 18

properly operate lamps, and while this wasn ‟ t a 19

widespread problem, ballasts that operate different 20

types of lamps -- well, what am I trying to say? This 21

phenomenon was observed for different ballast types. 22

It was only a few, it wasn ‟ t a widespread problem. 23

But in the case that a ballast is unable to 24

operate a resistor, DOE is proposing that the light 25Executive Court Reporters (301) 565-0064 96

output base test procedure described in Appendix Q of 1

the CFR be used for these ballasts. 2

In the issue box, you can see number six, 3

DOE is seeking comment on why some ballasts may not 4

operate a resistor load bank while they are able to 5

properly operate a lamp. We also invite comments on 6

other approaches for testing these ballasts. 7

DOE is also seeking comment on the 8

effectiveness of the proposed resistor-based method, 9

as well as comment on its assessment of anticipated 10

test burden. Bob. 11

MR. ERHARDT: Yeah, we ‟ ve already made some 12

comment on the resistor requirements and having to 13

have one for each category. Concerning your issue 14

six, it ‟ s not uncommon for some self-oscillating 15

ballast to not have enough drive if you load them at 16

start up, and so would not be uncommon for a ballast 17

that had a self-oscillating output stage to not start 18

if you had it resistively loaded. We accommodate this 19

in production because we do resistive loads to test 20

our ballasts in production -- my company does anyway - 21

- by starting the ballast without the resistive load, 22

and then introducing the resistive load. 23

But again, NEMA does propose that -- and you 24

would not have this issue with lamp loads either, so 25Executive Court Reporters (301) 565-0064 97

again, NEMA prefers a lamp load efficiency 1

measurement. 2

MR. RABA: Comment, Ed? 3

MR. THOMAS: Ed Thomas, GE. If we ‟ re going 4

to use a system where some equivalent ballasts are 5

tested on the BEF method, and some are going to be 6

tested on the resistive method, is there going to be 7

some means of denoting which methodology is used? 8

Because, as we saw a couple slides earlier, there is 9

some variation between what the outcome will be. This 10

may be favorable or unfavorable to certain 11

manufacturers. So how does the department intend to 12

address that particular issue? 13

MS. GUPTA: Mimi Gupta, Navigant Consulting. 14

I think the current proposal is not to denote whether 15

the ballast has been tested with one procedure or the 16

other, and both would be subject to the same standard. 17

So if stakeholders have comment on this issue of 18

whether it should be denoted and any modifications 19

that need to be made, DOE would definitely be 20

receptive to that. 21

MR. THOMAS: Well, I think there needs to be 22

some sort of indication, because we ‟ ve seen that test 23

methodologies that utilize the photometrics tend to 24

have a larger percentage of error than test 25Executive Court Reporters (301) 565-0064 98

methodologies that utilize either a resistive load or 1

a lamp load relating to ballast efficiency. So I 2

think there is going to need to be some delineation of 3

the test method used for a particular ballast if 4

alternate methods like this can be used. 5

The suggestion would be to utilize lamp 6

loads and thereby eliminating this problem entirely. 7

MR. deLASKI: This is our last round on this 8

method? 9

MR. WALKER: This is the last slide. 10

MR. deLASKI: Okay. I just want to come 11

back to -- 12

MR. RABA: Andrew deLaski. 13

MR. deLASKI: -- the issue that was raised 14

earlier on about DOE choice of metrics. Mike raised 15

this earlier in his remarks about the authority to go 16

to an RSE metric, and Betsy, I appreciate that you 17

look into this further. But I think Matt, in this 18

docket, we ‟ re working under the assumption that we 19

were stuck with the BEF. So if the department now 20

thinks we are not stuck with the BEF, it would really 21

help in preparing our comments to know that. And I 22

think a lot of what you just saw in the previous slide 23

is some -- a lot of work going on, Bob, what NEMA ‟ s 24

been doing and what the department ‟ s been doing to try 25Executive Court Reporters (301) 565-0064 99

to work within this BEF construct. But yet it seems 1

that quite possibly the department ‟ s not stuck in that 2

construct, of that particular metric. So I don ‟ t know 3

if there ‟ s a method for that. 4

But I guess I ‟ ll just make a couple more 5

comments is that it strikes me that ... some other 6

dockets that the department, for example, with clothes 7

washers, the initial statutory requirement was energy 8

factor, and it was changed to modified energy factor. 9

So the department has changed requirements for the 10

metric by which things are measured in other dockets, 11

and we ‟ re having a conversation in another docket, 12

which Betsy, you know very well, about the air 13

conditioner test method. And we think the department 14

has wide discretion in that docket as well to use 15

other than those that are named in the statute. 16

But in this case, the particular barrier 17

that the department has identified as being a 18

potential concern in that docket isn ‟ t one in this 19

docket. So it strikes me that it would really help 20

the commentors to know, you know, does the department 21

think you ‟ re stuck with BEF or do you think that there 22

may be more discussion. 23

MR. RABA: Follow comment? Tim Ballo with 24

EarthJustice. 25Executive Court Reporters (301) 565-0064 100

MR. BALLO: Tim Ballo from EarthJustice. 1

Second a lot of what Andrew said, and from reading the 2

TSD it ‟ s not clear, at least in the language I ‟ m 3

looking at in 2.4.1.2, that the department has 4

expressed that it is compelled to stick with BEF, that 5

seems to be one reading that one could take of the 6

language that you ‟ re using for consistency with ... 7

statute, DOE preliminarily determined that it cannot 8

change their point of metric. That seems to be a 9

legal conclusion, but there ‟ s no rationale, there ‟ s no 10

explanation of how the department arrived at that 11

conclusion and why the department feels -- believes 12

that the statute compels them to stick with BEF. 13

I ‟ m not saying that should be the 14

department ‟ s conclusion. I would argue just the 15

opposite. But there has to be some rationale for 16

commentors to comment on, and here all we have is just 17

a facial conclusion of the statute -- it seems to be 18

saying that the statute compels this, but we don ‟ t 19

know why. 20

MS. KOHL: This is Betsy Kohl from DOE. I 21

think the proposal was written the way it was for 22

consistency with the Congressionally laid out 23

standards for these lamps in 6295. 24

MR. RABA: Speak up, Betsy. 25Executive Court Reporters (301) 565-0064 101

1

MS. KOHL: And seven -- it ‟ s in the 2

document that you were reading from, but I don ‟ t think 3

that necessarily means that we have concluded that we 4

therefore have to use BEF forever. So send us comment 5

on that issue, and then you can also send us comments 6

on what it should be if it were not. 7

MR. deLASKI: This is a follow up -- Andrew 8

deLaskiv. Betsy, is there any mechanism for the 9

department to give a view prior -- we have comments to 10

the end of June, I think. Is there a mechanism for 11

the department to express a view on this during -- 12

MS. KOHL: It would probably be another 13

Federal Register notice, to let the world know. But I 14

don ‟ t know whether we have plans to do that. It 15

certainly is something we can think about though. 16

That would help commentors. 17

MR. ERHARDT: Bob Erhardt, Philips Lighting 18

and Electronics. Just a small clarification -- a 19

small correction to one of my earlier statements, now 20

that I ‟ ve had my coffee and my esteemed colleague here 21

has brought it to my attention. 22

I had the RSE BEF relationship for T5 And T8 23

inverted. It is the T5 that comes up looking of poor 24

quality when compared with an RSE compared to a T8. 25Executive Court Reporters (301) 565-0064 102

MR. RABA: Good catch. Yes, Mike. 1

MR. MCGARAGHAN: Mike McGaraghan. I just 2

wanted to point out that the comment deadline is June 3

7th, as far as I can see from the NOPR on the test 4

procedure. 5

MR. RABA: Further comments on this? Yes, 6

sir. 7

MR. DUFFY: This is Mark Duffy from GE 8

Lighting. If you could back up a couple slides to the 9

scaling transfer equations -- right there. If you 10

take a careful look at this, and you realize that 11

ballast efficiency is output watts divided by input 12

watts, the fact that the scaling factors are different 13

for high, normal and low ballast factor is going to 14

create a bias that ‟ s going to force high ballast 15

factor or low ballast factor ballast to have more 16

efficient operation, if you lay a line on ballast 17

efficiency factor. So I thin you should be careful to 18

realize that while you get a lot of variation when 19

you ‟ re measuring with ballast efficiency factor, and 20

so those scaling factors could have a lot of variation 21

to them. The reality is, if you ‟ re going for watts 22

out divided by watts in as a figure of merit for 23

ballasts, then those number should be uniform across 24

the vertical direction. Thank you. 25Executive Court Reporters (301) 565-0064 103

MR. RABA: Mike. 1

MR. WALKER: I think your comment makes 2

sense. I just wanted to point out one thing about -- 3

maybe one reason for why the scaling relationships are 4

different between ballast factor. Because a ballast - 5

- any ballast factor is tested with the same resistor, 6

a low ballast factor ballast, or a high ballast factor 7

ballast measured ballast efficiency is not the same as 8

if it was measured with the appropriate resistor. 9

So for that reason, we try to scale -- we 10

try to bring the ballast efficiency to the correct BEF 11

using a different number, does that help? 12

MR. DUFFY: Yeah, that helps clarify, 13

Matthew, I appreciate that. And I guess it makes one 14

more statement that the use of lamps as a load is -- 15

would take that factor out of the picture. 16

MR. RABA: Yes. 17

MR. ERHARDT: Bob Erhardt, Philips Lighting 18

and Electronics. If you like I can give you a couple 19

of quick indications of what I found when I looked at 20

larger populations of lamps. I found that the -- 21

going from a one lamp to a two lamp is about a two 22

percent -- I ‟ m sorry here. Can be as high as a three 23

percent BEF with the two lamp being three percent 24

higher efficiency than the one lamp. And going up to 25Executive Court Reporters (301) 565-0064 104

a four lamp, the four lamp can actually be more 1

efficient than the two lamp by about two percent. 2

So actually here, I have a lot of data here. 3

I have program start, instant start, two lamp to four 4

lamp, low wattage to high wattage. These are based on 5

average BEFs of the four highest BEF models from the 6

four major manufacturers of each category. And the 7

average overall is three and a half percent lower BEF 8

for a one lamp compared to a two lamp, and about two 9

percent higher for a four lamp compared with a two 10

lamp. 11

Going from low to high, the overall average, 12

it ‟ s about plus or minus -- about plus or minus one 13

percent, relative to a two lamp. A low wattage is 14

about one percent less efficient, and a high wattage 15

is about one percent higher efficiency. 16

MR. RABA: Thank you. Yes, sir, in the 17

back? 18

MR. ANDERSON: Eric Anderson, Pacific 19

Northwest National Laboratory. Matt, if you ‟ d go back 20

to issue 11, I just want to make sure we don ‟ t skip 21

over that. I heard it mentioned a little bit earlier 22

that there were some concerns about perhaps having to 23

do some facility modifications in order to conduct 24

some of this testing, and I ‟ m wondering if there are 25Executive Court Reporters (301) 565-0064 105

other things that are of concern with regard to 1

implementing this test procedure and the burden 2

imposed by that? 3

MR. THOMAS: Ed Thomas, GE Lighting. 4

Certainly the need to acquire multiple banks of 5

precision resistors would be a concern. The resistors 6

utilized in the NEMA testing were between one and 7

$2000 a set. And that was for one specific load bank. 8

We may need multiples of that, depending upon what the 9

final outcome of the rule is, and these resistors will 10

be basically in a closet until they ‟ re needed for 11

testing, and then with different ballast types and 12

different lamp times still in development. Additional 13

resistors will need to be purchased as different types 14

of systems come on to the market. Again, it ‟ s a case 15

for lamp utilization. 16

And I think also, a little bit on issue 12, 17

if existing BEF measurements are still required, the 18

ability to control the temperature is going to be a 19

costly proposal. 20

MR. RABA: Okay. More on burden? Anything 21

else. Matt? 22

MR. WALKER: I think we ‟ re all set. Thank 23

you for your attention. Thank you. 24

MR. RABA: So, as you note, the comment 25Executive Court Reporters (301) 565-0064 106

period test procedures closes June 7th. We ‟ ve got a 1

lot of good information here to think about. Go back 2

and formulate and submit to the department your 3

comments, anything else, you can contact the project 4

manager as well, Linda Graves, for any questions you 5

might have along the way. 6

We ‟ re pretty much right on schedule here. 7

Well, actually a little ahead. So let ‟ s do this. 8

Take a lunch break right now. There are two places 9

you might go for lunch, again, down below, the ground 10

floor, there ‟ s a Dunkin Donuts and a Subway. Or to 11

the West Building, on the ground floor and just follow 12

the crowd, I would say, to the far end, past the 13

auditorium, up the escalator, the second level and 14

there ‟ s a cafeteria there. You have to go out of the 15

building, so to speak, check in with the card, check 16

in again. So take your visitors passes with you. 17

And we ‟ ll return -- start -- we ‟ ll say we ‟ ll 18

give you one hour. Promptly at 12:45, so keep on 19

schedule. We ‟ ve a lot more to cover on standards. 20

Any questions so far? Yes, sir. 21

MR. HAKKAHANEN: May we leave our -- this 22

will be locked? 23

MR. RABA: Yes, we ‟ ll keep this room secure 24

for you. I would say if you leave the building, the 25Executive Court Reporters (301) 565-0064 107

campus, it ‟ s kind of hard to get back in, you ‟ d have 1

to have someone like us to bring you back in, so stay 2

in the building somewhere, if you would, just for your 3

own convenience ‟ s sake 4

Again, thank you very much, good round of 5

comments, and discussion. See you back in an our. 6

(Whereupon, at 11:45 p.m., the meeting was 7

recessed, to reconvene at 12:45 p.m., this same day, 8

Monday, April 26, 2010.) 9

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26Executive Court Reporters (301) 565-0064 108

A F T E R N O O N S E S S I O N 1

12:48 p.m. 2

MR. RABA: Welcome back. I ‟ ve been asked to 3

start again. People who are missing will probably get 4

back shortly. 5

Is there anyone here who is new in this half 6

of the public meeting, this part being Standards, or 7

who hasn ‟ t introduced him or herself earlier in the 8

day. 9

Yes, sir. Say your name, please, for the 10

record, and your organization and affiliation. 11

MR. CARPENTER: Yes, Fred Carpenter with the 12

Acuity Brands Lighting. 13

MR. RABA: Thank you very much. Thank you. 14

Anybody else? 15

MR. GALLANT: Pierre Gallant, Natural 16

Resources Canada. 17

MR. RABA: Say again, please? 18

MR. GALLANT: Pierre Gallant, Natural 19

Resources Canada. 20

MR. RABA: Thank you. And you gave -- 21

Brenda ‟ s got your information? 22

MR. GALLANT: Oh, yeah, I was here from the 23

beginning. Maybe just a couple minutes after everyone 24

presented themselves. 25Executive Court Reporters (301) 565-0064 109

MR. RABA: Okay. And thanks for catching up 1

with us. Or are we catching up with you. 2

To start this out is Energy Efficiency 3

Standards and preliminary analysis view point. And to 4

lead off is Ali Lehr. Ali. 5

MS. KOHL: Okay. Thank you. I ‟ m sorry. 6

This is Betsy Kohl from DOE. Just to clarify on an 7

issue that we were talking about. 8

MR. RABA: Betsy Kohl. 9

MS. KOHL: The metric issue that we were 10

talking about before we broke for lunch. I just kind 11

of wanted to reiterate again that we ‟ re still 12

reconsidering what the appropriate metric would be. 13

So I don ‟ t know that another Federal Register notice 14

on that issue would be of any use. So I just wanted 15

to let you guys know that that issue is still under 16

consideration so if you can let him know it would be 17

great. 18

Thank you. 19

MR. RABA: Thanks for filing us in. 20

Yes, please. 21

MR. HAKKARAINEN: Pekka Hakkarainen from 22

Lutron. Betsy, when would we expect a decision on 23

that issue? 24

MS. KOHL: Well, I mean, that ‟ s part of this 25Executive Court Reporters (301) 565-0064 110

rulemaking. I mean, you can supplement if you want. 1

But in the Notice of Proposed Rulemaking for the test 2

procedure we laid out the BEF, but then we laid out 3

the BE, we laid out the RSE, so, I mean, that ‟ s why 4

you guys submit comments and we consider them and then 5

for the final test procedure, which is the next step, 6

that ‟ s when it would come out. Okay? 7

MR. HAKKARAINEN: It might be June of next 8

year then? 9

MS. KOHL: Yes. 10

MR. RABA: Yes, please. 11

MS. MAUER: Just a clarification. 12

MR. RABA: Your name, please? 13

MS. MAUER: Joanna Mauer. I think part of 14

the question was just whether DOE thinks it can 15

establish a metric that ‟ s different from BEF even 16

though there are several different options for what 17

that alternative metric could be. 18

MS. KOHL: Yeah, and I think those 19

statements from the TSD we need to clean those up, but 20

we are still considering what the appropriate metric 21

would be. We proposed them as BEF for consistency 22

with the standards that Congress had set. But we are 23

still looking at what the best metric would be. 24

MR. RABA: And Joanna, with the Appliance 25Executive Court Reporters (301) 565-0064 111

standards project? 1

MS. MAUER: Yes. 2

MR. RABA: Okay. Thank you. 3

Anyone else? Good follow on, Betsy. Thank 4

you. 5

Anything else? 6

Okay. Now, Allison, if you would please. 7

MS. LEHR: Thanks. 8

ENERGY CONSERVATION STANDARD INTRODUCTION, 9

STATUTE, AND CONTEXT 10

MS. LEHR: All right. This afternoon we are 11

going to be talking about the preliminary analysis 12

stage for the fluorescent lamp ballasts standards 13

rulemaking. 14

Okay. So I ‟ m going to start by giving an 15

overview of the standards rulemaking to date and then 16

we ‟ ll talk about each analysis in more detail. And 17

finally we ‟ ll end by talking about the analysis for 18

the NOPR and the next steps in the rulemaking process. 19

There are typically four major stages in a 20

DOE standards rulemaking. The framework document, 21

preliminary analysis, notice of proposed rulemaking 22

and final rule. 23

Each stage includes a Federal Register 24

notice to place information in public view. At 25Executive Court Reporters (301) 565-0064 112

multiple points in the process DOE invites both oral 1

and written comments on its analysis. These comments 2

can be in response to not just the Federal Register 3

notice, but also any technical support document and 4

analytical spreadsheets that may be posted on line. 5

Stakeholders are invited and even encouraged 6

to participate during each of the public meetings and 7

comment periods. 8

This rulemaking started I early 2008 with 9

the publication of a framework document. Just last 10

month DOE published a notice in the Federal Register 11

announcing the availability of the preliminary 12

analysis and the date of this meeting. 13

Later this year DOE plans to publish a NOPR 14

and hold another public meeting to receive comments on 15

that proposal. 16

Six months after that DOE plans to publish a 17

final rule. Any amended standards would take effect 18

three years after the final rule is published which 19

DOE estimates to be June 2014. 20

So now we ‟ ll start to talk in more detail 21

about the analyses. As I mentioned, we are currently 22

in the preliminary analysis phase. This slide 23

summarizes all the analyses conducted during this 24

stage. 25Executive Court Reporters (301) 565-0064 113

I ‟ m going to start by talking about the 1

market and tech assessment, screening analysis and 2

engineering analysis. These analyses serve as the 3

foundation for the life cycle cost analysis and 4

national impact analysis which we ‟ ll be discussing 5

later on today. 6

In the market and technology assessment DOE 7

determines the scope of coverage for this rulemaking. 8

DOE also characterizes the fluorescent lamp ballast 9

market, identifies several measures to improve the BEF 10

of a ballast, known as technology options, and 11

establishes product classes for all covered products. 12

The screening analysis considers the technology 13

options and determines whether they meet the four 14

screening criteria described by EPCA. 15

Technology options that meet the screening 16

criteria are called “design options” which are input 17

for the engineering analysis. 18

EPCA defines a fluorescent lamp ballast as a 19

device which is used to start and operate fluorescent 20

lamps by providing a starting voltage and current and 21

limiting the current during normal operation. 22

Several fluorescent lamp ballasts are 23

already subject to energy conservation standards and 24

they are summarized in the table on this slide. In 25Executive Court Reporters (301) 565-0064 114

general, only T12 ballasts that operate four-foot 1

medium bi-pin, eight-foot single pin slimline and 2

eight-foot high-output lamps are included in coverage. 3

There are currently three types of ballasts 4

exempt from standards. And these exemptions include 5

dimming ballasts, residential ballasts, and ballasts 6

designed for use in cold-temperature outdoor signs. 7

As part of this rulemaking DOE considered 8

expanding the scope of coverage to include addition 9

fluorescent lamp ballasts. When expanding the scope 10

DOE considered three main criteria. The first was the 11

potential for a ballast type to demonstrate 12

significant energy savings. As part of this criteria, 13

DOE also considered ballast types whose shipments may 14

not currently be high volume but have the potential to 15

grow such as in the case that they become a substitute 16

for a regulated ballast. 17

And, finally, DOE considered improving the 18

BEF of a certain ballast type was both technologically 19

feasible and economically justified. 20

DOE concluded that several additional 21

ballast types met the criteria to be included in the 22

scope of coverage. 23

This slide summarizes all the ballasts in 24

the preliminary determination of scope. 25Executive Court Reporters (301) 565-0064 1 15

In general DOE is extending coverage to 1

ballasts that operate additional lamp types such as 2

four-foot T5 lamps, ballasts that operate additional 3

lamp diameters such as T8, four-foot medium bi-pin 4

lamps in addition to T12 and ballasts that operate 5

additional numbers of lamps. 6

Please note that DOE did not include dimming 7

ballasts in this preliminary determination of scope. 8

However, DOE invites comment on all aspects of the 9

expanded scope of coverage including those ballasts 10

that DOE chose not to include. And DOE also reminds 11

stakeholders that any expansion of scope from that 12

presented in this preliminary analysis would require a 13

modification to the test procedure presented earlier 14

today. 15

A test procedure must exist for any covered 16

product and therefore DOE asked stakeholders to 17

comment on appropriate test procedures for any ballast 18

that they wish to include in an expanded scope. 19

MR. RABA: Thoughts on the scope that ‟ s been 20

presented? Charlie. 21

MR. STEPHENS: I ‟ m Charlie Stephens. Could 22

you tell me how one knows an outdoor -- well, lamps 23

that are designed to operate in cold temperature for 24

outdoor signs? 25Executive Court Reporters (301) 565-0064 116

MS. LEHR: Sure. They in general have a 1

designation that they ‟ re able to operate and they ‟ re 2

usually referred to as “sign ballasts” and the y would 3

say that they ‟ re able to operate down to negative 20 4

degrees Fahrenheit. 5

MR. STEPHENS: What about a ballast that ‟ s 6

just labeled “outdoor”? I mean, I have -- 7

MS. LEHR: All right. Someone behind you 8

can answer the question. 9

MR. RABA: Yes, please? 10

MS. ANDERSON: Susan Anderson, Osram 11

Sylvania. If it ‟s just labeled “outdoor” it‟ s 12

probably that the case is moisture resistant. 13

MS. LEHR: Okay. 14

MS. ANDERSON: As opposed to the cold 15

temperature which means that it can start at a lower - 16

- 17

MR. RABA: Wait, wait, stop. Forgive me. 18

My bad. Would you please use the stand up microphone 19

so we can all hear you. Thank you very much. 20

MS. ANDERSON: Certainly. If a ballast is 21

labeled “outdoor” it means it can be exposed to 22

moisture or is moisture resistant. As opposed to cold 23

temperature starting might still need to be enclosed - 24

- suitably enclosed, but it can start the ballast at 25Executive Court Reporters (301) 565-0064 117

colder starting -- start the lamps at colder starting 1

temperatures. Typically minus 20 degrees Fahrenheit. 2

MR. RABA: Thank you. 3

MR. STEPHENS: Okay. Charlie Stephens back 4

again. So that would mean that if it was simply 5

labeled “outdoor” but not labeled to start at minus 20 6

Fahrenheit, then it would be covered? 7

MS. LEHR: Right. 8

MR. STEPHENS: And if it ‟ s labeled to start 9

at minus 20 then it ‟ s not covered? 10

MS. LEHR: No, well -- 11

MR. STEPHENS: It ‟ s not supposed to be 12

covered, but is not covered now? 13

MS. LEHR: Right. I guess what we ‟ re 14

looking for is any suggestions you would have. These 15

ballasts are currently exempted from the scope of 16

coverage. And so there ‟ s language in the Code of 17

Federal Regulations for which type of ballasts are 18

exempted. And so for including them the scope of 19

coverage for any future phase we would need to have 20

suggested regulatory language for how to define what ‟ s 21

covered and what ‟ s not. If you had recommendations 22

for how we should define this -- I guess this part, 23

this ballast type, we would be willing to take any 24

suggestions. 25Executive Court Reporters (301) 565-0064 118

MR. RABA: Suggestion here? 1

MR. ERHARDT: I ‟ m just commenting that 2

Navigant has proposed that they do include outdoor 3

ballasts. They ‟ re only giving them a different level 4

to meet. And they are specifying the cold temperature 5

rating with that. All they ‟ re proposing is that they 6

make some allowance for cold temperatures starting in 7

the BEF requirement. 8

MR. STEPHENS: Okay. Charlie Stephens 9

again. I ‟ m just having trouble with language as I try 10

to translate this and then I don ‟ t know how many 11

people here in the room have bought a ballast in the 12

last six weeks or so, or six months through the 13

system. I do. I buy them fairly regularly. I 14

haven ‟ t succeeded recently in buying one that isn ‟ t 15

labeled “outdoors”. But I don‟ t know what that means. 16

And I don ‟ t know what electronic means anymore either. 17

So I ‟ m trying to get straight on what is and isn ‟ t 18

covered. It ‟ s hard to make recommendations on what to 19

cover if I ‟ m not straight on what is covered. So -- 20

MR. RABA: Can you help us? 21

MR. ERHARDT: Yeah. There are UL safety 22

ratings for outdoor and there ‟ s Type 1 outdoor, Type 2 23

outdoor and they are based on moisture resistance 24

whether you need just a basic enclosure around them or 25Executive Court Reporters (301) 565-0064 119

if you need some kind of hermetic enclosure that will 1

keep all moisture away from them, et cetera, whether 2

they ‟ re fully encapsulated or not. 3

That, as I understand, is not the 4

eliminating factor in these proceedings. When they 5

talk about outdoor, they are giving an allowance for 6

cold temperature starting for sign ballasts and that 7

when you do have cold temperature starting you have 8

higher VAs in your product and you -- you know, it ‟ s 9

harder to meet the BEFs. So, as I understand the 10

general Type 1 or Type 2 outdoor rating as applied to 11

all products is not an eliminating factor only on the 12

sign ballasts. 13

MR. RABA: Okay. That last comment was from 14

Bob Erhardt. 15

MR. ERHARDT: Bob Erhardt, Philips 16

Electronics. 17

MR. RABA: Philips. And Charlie I see you 18

nodding? 19

MR. STEPHENS: Yeah. The second one is that 20

in the Federal Register notice DOE used the term 21

“electronic” in a lot of cases. And I can ‟ t tell if 22

you are using that to refer to a high frequency 23

ballast or just a ballast that has electronic 24

components. Because I ‟ ve bought -- when I ‟ ve gone in 25Executive Court Reporters (301) 565-0064 120

and asked for an electronic ballast I ‟ ve been handed a 1

60 Hertz ballast and I ‟ ve been handed a high frequency 2

ballast and it ‟ s not always the same thing. Though 3

you can tell if it ‟ s a program start ballast it ‟ s got 4

some electronics to it. So I ‟ m not sure when DOE uses 5

that term what they ‟ re referring to, but I wish it 6

were consistent and that I understood what it was. 7

MR. ERHARDT: My only comment is that that 8

hasn ‟ t been a factor in setting the requirements, the 9

electromagnetic or cathode cutout semi-electronic, if 10

you like, or the full electronic all have to meet the 11

same BEFs. So in the end I don ‟ t think it ‟ s 12

important. I think they use those terms to describe 13

ballast types. And as I read the report, it would 14

appear that they are talking about high frequency 15

versus low frequency given that high frequencies pick 16

up efficacy in the lamp and therefore when they ‟ re 17

talking about a given regulation only being able to be 18

met by an electronic they ‟ re talking about a BEF that 19

is high enough that if they don ‟ t have the extra 10 20

percent efficacy pick up from the lamp you ‟ re not 21

going to be meeting it. That was my interpretation 22

from reading the report. 23

Again, Bob Erhardt, Philips Lighting 24

Electronics. 25Executive Court Reporters (301) 565-0064 121

MR. RABA: Mimi, are you turned on? 1

Microphone turned on. 2

MS. GUPTA: Oh, it ‟ s out of batteries. 3

MR. RABA: Give it a moment to warm up, 4

please. 5

MS. GUPTA: Mimi Gupta, Navigant Consulting. 6

Bob is correct. When we say “electronic” we do mean 7

high frequency in the literature. But your comment is 8

well taken about the terminology and we will 9

definitely try to be clearer moving forward. So, 10

thank you. 11

MR. STEPHENS: And I would just suggest that 12

if you mean high frequency that you say high 13

frequency. Because when you look at the ballasts that 14

are out there, it ‟ s not consistent. 15

MR. RABA: Thank you. 16

MR. deLASKI: Andrew deLaski Appliance 17

Standards Awareness Project. We had commented at the 18

framework stage in favor of expanding the scope of 19

coverage. And I think the Department has, by and 20

large, gone in the direction in which we recommended 21

at that time in covering both residential ballasts and 22

low temperature ballasts. So we certainly applaud 23

that correction and support it very strongly. 24

I think as I read through the analysis here 25Executive Court Reporters (301) 565-0064 122

it strikes me -- I ‟ m really struck that the energy 1

savings in this docket is in the newly covered 2

products. And the analysis shows that even though the 3

sales were relatively small, the savings are in these 4

things that are newly covered. So it is in this area 5

in coverage at the very beginning of this presentation 6

today that we ‟ re seeing the decisions that actually 7

drive the savings in this docket so. We can make 8

decisions here. 9

I do have a question which is your rationale 10

for not covering the dimming? So what ‟ s driving that 11

particular -- because we had recommended the framework 12

stage covered dimming as well. So I ‟ m curious as to 13

why you came to a different conclusion on that one 14

relative to say the outdoor or the residential? 15

MS. LEHR: It was predominantly the low 16

market share that we were able to detect for dimming 17

ballasts. It was less than 1 percent. The market we 18

were looking at was the primary driver. 19

MR. ERHARDT: This is Bob Erhardt, Philips 20

Lighting Electronics. I ‟ ll also point out in the 21

report they were commenting that, you know, dimming 22

ballasts because of their expense are not going to 23

represent a loophole that people aren ‟ t going to be 24

buying them as a way to not have to meet efficiency 25Executive Court Reporters (301) 565-0064 123

levels because a dimming ballast is significantly more 1

expensive. 2

I will also comment that NEMA has commented 3

asking that dimming ballasts not be covered in the 4

rulemaking given that when a dimming ballast by its 5

specification is there to be part of a high-efficiency 6

system that can realize much higher energy savings 7

than a fixed output ballast on its own. 8

The other issue that NEMA wishes to bring up 9

concerning dimming ballasts are that rating a dimming 10

ballast at its full output can be misleading because 11

dimming ballasts, if they are specified, are generally 12

not operated at their full output and a means of 13

determining the overall energy efficiency of a dimming 14

ballast has not been well defined in our opinion and 15

will be quite cumbersome. You ‟ ll find dimming 16

ballasts, especially if they ‟ re used with -- 17

especially if they ‟ re used with daylight harvesting 18

and can realize savings of 30, 40, even 50 percent on 19

energy if you have significant daylight available. 20

And it ‟ s when you ‟ re operating in these dim modes that 21

we ‟ re not covering their efficiency. And there are 22

significant differences in the efficiency of dimming 23

ballasts in these dim modes. And we haven ‟ t come up 24

with a practicable, if you will, method of looking at 25Executive Court Reporters (301) 565-0064 124

the overall efficiency of a dimming system. 1

MR. RABA: That covers a lot. Good 2

question, Charlie. Go ahead. Thanks bob. 3

MR. deLASKI: So just a follow-on. You 4

know, I think we ‟ re -- 5

MR. RABA: deLaski. 6

MR. deLASKI: -- going to address the new 7

ballast in our written comments. But I hear both the 8

arguments, both in terms of the sales volumes and in 9

terms of the measurement issues. 10

MR. RABA: Yes, in back please. 11

MS. ANDERSON: (Off mike.) 12

MR. RABA: Can you speak up. 13

MS. ANDERSON: (Off mike) might want to talk 14

about the New York Times Building and the actual 15

energy use there as opposed to the design -- 16

MR. RABA: We can ‟ t hear you up front, 17

please. 18

MS. GUPTA: Susan, do you want to come up to 19

the table? 20

MR. RABA: Yeah, come on up. Yeah, please. 21

Thank you. Good call. Welcome. 22

MS. ANDERSON: Susan Anderson, Osram 23

Sylvania. I speak a lot for NEMA. And one of the 24

examples that we give people in proposing that they 25Executive Court Reporters (301) 565-0064 125

consider the idea of dimming ballasts is one of the 1

Lutron success stories which is the New York Times 2

Building which is actually operating at less than 40 3

percent of its designed watts per square foot because 4

of the fact that they are using dimming ballasts 5

incorporated as part of a daylight -- day lighting 6

system. 7

So I think they ‟ re at something like .38 8

watts per square foot. And it was supposed to have 9

been around 1.2, 1.29. They ‟ re operating at about 70 10

percent less than what they had anticipated in the 11

designed watts per square foot. 12

MR. RABA: Very interesting. Thank you. 13

Further? 14

MR. ERHARDT: Yeah, Bob Erhardt, Philips 15

Lighting Electronics. One comment on exemptions that 16

we just actually talked about last night at dinner. 17

And we haven ‟ t had a full vetting of the discussion, 18

but we ‟ re not -- we don ‟ t even have necessarily a 19

proposal that maybe hopefully we will for our written 20

comments. 21

Currently for EMI sensitive environments 22

electromagnetic ballasts are used. And the proposals 23

for efficiency levels that are being made here will 24

not allow electromagnetic ballasts. And we would like 25Executive Court Reporters (301) 565-0064 126

to propose some type of consideration and I would know 1

how it would be worded, but somehow can we come up 2

with some kind of a rating for EMI sensitive -- I 3

understand the difficulty of enforcement and, you 4

know, you don ‟ t want people filling their whole 5

building with electromagnetic, but from what we know 6

there is still common practice -- the normal practice 7

for hospital environments to be using electromagnetic 8

product. 9

MR. RABA: Good point. Go ahead, sorry. 10

MR. THOMAS: Ed Thomas, GE Lighting. I 11

would just like to further the point that Bob just 12

made. Occasionally there are situations in critical 13

care suites, surgery suites of hospitals, also areas 14

that will be critical in the life support function, 15

let ‟ s say a control tower of an aircraft landing or an 16

airport rather. We certainly have situations where 17

ballasts that generate no or low EMI are needed. 18

I got an inquiry from one of the research 19

labs at Princeton about ballasts for their nuclear 20

medicine laboratories. They wanted to see if they 21

could still maintain with magnetic systems for 22

specialized applications. Certainly not for general 23

lighting, but, again, for specialized applications 24

there should be some exemptions involved. 25Executive Court Reporters (301) 565-0064 127

MR. deLASKI: Andrew DeLaski, Appliance 1

Standards Awareness Project. I think Bob put his 2

finger on, you know, the challenge here which is how 3

do you define the exemption in a way that it prevents 4

a loophole. And this has been a problem with lighting 5

standards in particular. You know, because the market 6

buys what you offer, or has the opportunity to buy 7

whatever you offer, and you don ‟ t necessarily control 8

who buys which products as manufacturers. So I think 9

the challenge is in finding that. So I would really 10

put it back to you guys to think about how are you 11

going to define -- how can we define the exemption -- 12

an exemption in a way that prevents it from becoming, 13

you know, the new energy saver. You know, we had -- 14

we thought we had to revise the law in 2005 to deal 15

with the energy saver ballasts. And you know, we have 16

to -- we are still wrestling with the BR lamp 17

exemption and condenser reflector lamp docket. So, 18

you know, one docket after the other with lighting 19

products we find the market kind of -- you squeeze it 20

in one way and it comes out somewhere else. So we 21

have to define these in ways that are really bullet 22

proof. 23

MS. GUPTA: Mimi Gupta, Navigant Consulting. 24

So I have a question. It was my understanding that 25Executive Court Reporters (301) 565-0064 128

coming standards for fluorescent ballasts were going 1

to eliminate -- no these ones that we ‟ re talking 2

about, but the ones that are coming effective I think 3

in 2010 or something like that. 4

MS. LEHR: Like July 2010? 5

MS. GUPTA: Yeah. They were going to 6

eliminate most electromagnetic ballasts except for 7

maybe the high output variety; is that not your 8

understanding? 9

MR. ERHARDT: Bob Erhardt, Philips Lighting 10

Electronics. We ‟ re going to have to look at this 11

because this came up over dinner last night and this 12

is the first time we ‟ re, as NEMA companies, addressing 13

it. We are going to have to take a look at this 14

situation. We don ‟ t know, maybe this is something we 15

missed. And we my have to try to correct it. But 16

this is something that, you know, we ‟ ve been very 17

wrapped up in the shift to electronic product and 18

focused on it and then the shift to control systems 19

and this is something we may have overlooked. We ‟ ll 20

try to address it in our written comments. 21

MR. RABA: Written comments, remember that. 22

Thank you. 23

Anybody else, please? 24

Ali? 25Executive Court Reporters (301) 565-0064 129

MARKET AND TECHNOLOGY ASSESSMENT; SCREENING 1

ANALYSIS 2

MS. LEHR: So DOE establishes separate 3

standards for different groups of products called 4

“product classes”. To do this DOE considered the type 5

of energy used, the capacity, and any performance6

related feature that would require a different 7

standard level. Of these criteria DOE focused on the 8

last one where a difference in the BEF of a ballast 9

was accompanied by a difference in consumer utility. 10

Using this methodology DOE established 11

product classes based on these six factors: Lamp 12

length, number of lamps, lumen package, lamp diameter 13

for T5 lamps, starting method and market sector. 14

DOE found that features that affected the 15

input power of a ballast also affected its BF. In 16

general longer lamps tended to have higher wattages 17

than shorter lamps. And therefore a ballast that 18

operated in longer lamps had lower BEFs. Similarly 19

the more lamps a ballast operated, the larger the 20

ballast input power and the lower the BEF. 21

DOE believes that both lamp length and 22

number affect the ability of a lamp and ballast system 23

to be used in a particular fixture. For example, 24

ballasts operating eight-foot lamps would require 25Executive Court Reporters (301) 565-0064 130

physically larger fixtures than ballasts operating 1

four-foot lamps. Additionally ballasts operating six 2

lamps would require more physical space than ballasts 3

operating two lamps. 4

Because of this impact on both BEF and 5

consumer utility DOE established separate product 6

classes for ballasts that operate different maximum 7

numbers of lamps and ballasts that operate four8

versus eight-foot lamps. 9

DOE also considered features that affected 10

the lumen output of a lamp and ballast system. DOE 11

found that high output systems tended to have higher 12

input powers and therefore lower BEF ‟ s compared to 13

standard output systems. Similarly DOE found that 14

ballasts with high or low ballast factor had lower 15

BEFs than normal ballast factor ballasts. 16

DOE believes that consumers use systems with 17

different lumen packages for different applications. 18

For example, high lumen output systems may be 19

installed in a high ceiling or outdoor applications 20

where large quantities of light are needed. 21

Alternatively, low-lumen package systems might be 22

installed in lower ceiling applications such as 23

offices or hospitals where the distance between the 24

light source and the illuminated surface is not as 25Executive Court Reporters (301) 565-0064 131

large. 1

Given the impact on both BEF and consumer 2

utility DOE established separate product classes for 3

standard versus high output systems and ballasts that 4

operate low, normal, and high ballast factor. Similar 5

to the test procedure DOE created three bins to 6

delineate ballast factor with divisions at .78 and 7

1.1. 8

DOE also considered lamp diameter as a 9

potential class setting factor. Because the most 10

common wattage lamp associated with each lamp 11

diameter, T12 ballasts typically have lower BEFs than 12

T8 ballasts which in turn have lower BEFs than T5 13

ballasts. However, DOE did not establish product 14

classes based on lamp diameter alone because not all 15

lamp diameters provide a unique consumer utility. 16

For example, DOE kept both T8 and T12 17

systems in the same product class because they are 18

direct replacements for each other. However, because 19

T5 systems offer a similar total lumen package as T8 20

or T12 systems, but over a much smaller surface area, 21

DOE believes these lamps are not suitable for direct 22

lighting applications. 23

For this reason DOE established a separate 24

product class for ballasts that operate T5 lamps. 25Executive Court Reporters (301) 565-0064 132

This approach is consistent with the July 2009 final 1

Rule that amended energy conservation standards for 2

general service fluorescent lamps. 3

DOE also considered starting method as a 4

potential class setting factor. DOE found that both 5

program start and rapid start ballasts have lower BEFs 6

than instant start ballasts due to electo heating. 7

Even though there is a difference in BEF, DOE did not 8

establish a separate product class for rapid start 9

ballasts because rapid start and instant start 10

ballasts are commonly used as substitutes for each 11

other. 12

However, occupancy sensors are almost 13

exclusively used in combination with program start 14

ballasts. For this reason DOE feels there ‟ s unique 15

utility associated with program start ballasts. 16

Because of this utility and the associated decrease in 17

BEF DOE established a separate product class for 18

program start ballasts. 19

Last, DOE considered features related to the 20

market sector or application in which the ballast was 21

used. DOE noticed that residential ballasts had more 22

stringent EMI requirements and less stringent power 23

factor requirements than ballasts that operate in the 24

commercial sector. Due to the EMI requirements, a 25Executive Court Reporters (301) 565-0064 133

commercial ballast cannot be used as a substitute in 1

the residential market. 2

According to test data the more stringent 3

EMI requirements seem to result in lower BEFs than 4

commercial ballasts. For these reasons DOE 5

established a separate product class for ballasts that 6

are designed for use in the residential sector. 7

Last, DOE noticed that ballasts designed for 8

use in cold temperature outdoor signs have lower BEFs 9

than ballasts that are not designed for cold 10

temperature environments. Because regular ballasts 11

cannot be used as substitutes DOE established a 12

separate product class for ballasts that are used in 13

cold temperature outdoor signs. 14

So, in total, for the entire scope of 15

coverage DOE established 70 product classes. This 16

slide just shows an example of the product class 17

structure for ballasts that operate four-foot medium 18

bi-pin lamps in the commercial sector. You can see 19

that after accounting for divisions in starting 20

method, ballast factor and number of lamps there were 21

36 product classes for ballasts that operate this lamp 22

type. 23

DOE requests comment on the factors it used 24

to establish product classes especially the ranges 25Executive Court Reporters (301) 565-0064 134

identified for high, low and normal ballast factor. 1

MR. RABA: Charlie? 2

MR. STEPHENS: Charlie Stephens. Could you 3

go back over the residential list there? I mean, I ‟ m 4

somebody whose house is full of high frequency 5

ballasts for four-foot and three-foot T8. So I ‟ m kind 6

of trying to figure out what the problem is here. 7

MS. LEHR: I guess I ‟ m not sure what you 8

mean by what the problem is. 9

MR. STEPHENS: You have more stringent EMI 10

requirements in the residential sector? 11

MS. LEHR: That ‟ s correct. It ‟ s an FCC 12

requirement. 13

MR. STEPHENS: Okay. But I ‟ m not sure I 14

understand those. I mean, do they just -- what ‟ s the 15

purpose of those? 16

MR. RABA: I think we have a comment over 17

here from -- 18

MR. ERHARDT: I ‟ ll respond. 19

MR. RABA: Bob Erhardt. 20

MR. ERHARDT: Bob Erhardt, Philips Lighting 21

Electronics. FCC has differing requirements for 22

residential and for commercial. As my shorthand 23

description which might not be entirely accurate, but 24

in residential -- in commercial it ‟ s assumed if you ‟ re 25Executive Court Reporters (301) 565-0064 135

disturbing yourself, that ‟ s fine. But in residential, 1

if you ‟ re in an apartment and you don ‟ t want to 2

disturb your neighbor. In any case, there are more 3

stringent requirements for residential EMI than there 4

are for commercial as an FCC regulation. 5

So, yes, you should find that class B FCC 6

rating for your residential ballasts that are in your 7

home. 8

MR. RABA: Charlie, you look puzzled. 9

MR. STEPHENS: Well, only because I don ‟ t 10

understand the FCC requirement. But, you know, if 11

it ‟ s an FCC requirement that ‟ s fine. You know, like I 12

said, I don ‟ t -- I don ‟ t know when that was set, but 13

there ‟ s no evident impact that I can detect. 14

MR. ERHARDT: The more stringent FCC class B 15

requirement does require a more sophisticated EMI 16

filter which will result in slightly higher losses. 17

Although the lower power factor requirement more than 18

offsets it. So you ‟ re probably not noticing much of 19

an impact on your residential efficiencies, if you 20

will, because the -- when you can allow a .6 power 21

factor and 200 percent THD, you can eliminate a whole 22

stage of your ballast which has a much bigger impact 23

than the addition of one more EMI component. 24

MR. RABA: Mimi. 25Executive Court Reporters (301) 565-0064 136

MS. GUPTA: Yes, Mimi Gupta. 1

MR. RABA: Turn on. 2

MS. GUPTA: Mimi Gupta, Navigant Consulting. 3

So, Bob, are you saying that residential ballasts can 4

actually achieve a higher efficiency than commercial 5

ballasts due to the power factor requirement? 6

MR. ERHARDT: I ‟ ll be supplying my -- you 7

know, you can go to the California Energy website -- 8

California Energy Commission website as well and a 9

dedicated residential ballast that has a low power 10

factor can have higher efficiency than a full 11

communication ballast. 12

MR. RABA: Charlie, is that helpful? 13

You could always send a written comment or 14

concern about that too later on. 15

MR. STEPHENS: Yeah, I ‟ ll have to do a 16

little digging. 17

MR. RABA: Thank you. Bob? 18

MR. ERHARDT: I ‟ ll make some other comments 19

in the request for comments. 20

On your subdividing of product classes for 21

low, normal, and high ballast factor, I would say the 22

industry for T8 will typically talk about a normal 23

ballast factor is about a .85 to generally .995. For 24

a T5 a normal ballast factor would be a ballast factor 25Executive Court Reporters (301) 565-0064 137

of one. We ‟ ll supply written comments. But I think 1

that having the normal range extend all the way down 2

to .78 is on the low side and having it go all the way 3

to 110 by -- for T8, certainly, that ‟ s pretty high. 4

If you have a 1 or a 105, you may wish to consider if 5

that ‟ s going to be -- well, you may wish to see how 6

products break out in your analysis. 7

Also, on low and high ballast factor 8

ballasts both having lower BEFs than normal ballast 9

factor, as we commented earlier during the measurement 10

phase, I think some of this is based on your 11

measurement procedures where you ‟ re using the same -- 12

as I understand you ‟ re using the same resistors for 13

low, normal and high. And that likely might -- will 14

have affected the results. We have some comments that 15

we ‟ ll be giving that, again, I have -- we ‟ ll be 16

supplying my analysis of the California Energy 17

Commission database and not that we don ‟ t appreciate 18

it, but high ballast factor ballasts don ‟ t necessarily 19

have lower efficiency. They tend to have higher 20

efficiency. 21

But the low ballast factor may have -- we 22

may look for some additional relief on that side. The 23

same thing with one versus four ballasts -- four lamps 24

on a ballast. The one lamp ballasts tend to be 25Executive Court Reporters (301) 565-0064 138

trended towards low efficiency. And that ‟ s just an 1

empirical observation. But they do. And the higher - 2

- the four lamps have slightly higher efficiency than 3

the two lamps. 4

MR. RABA: Thank you. Thank you. 5

MS. GUPTA: Can I just ask one follow on. 6

Mimi Gupta, Navigant. So, Bob, when you say 7

“efficiency” just for clarity, do you actually mean 8

ballast efficacy factor? 9

MR. ERHARDT: I ‟ m talking about ballast 10

efficiency. 11

MS. GUPTA: You ‟ re talking about ballast 12

efficiency? 13

MR. ERHARDT: Ballast efficiency. Which 14

will translate to BEF. 15

MS. GUPTA: Okay. 16

MR. ERHARDT: Because, you know, if the 17

ballasts are operating the same lamps then ballast 18

efficiency will, you know, translates to BEF. 19

MS. GUPTA: Okay. 20

MR. ERHARDT: Well, actually, okay, let me 21

back off. The data I analyzed was BEF though 22

actually. So I should -- I ‟ ll leave it at -- I will 23

withdraw my statement. I ‟ ll say this data was based 24

on BEF. I don ‟ t know if the lamps are going to move 25Executive Court Reporters (301) 565-0064 139

in one way or another based on a .88 versus 1.1 1

ballast factor. There may be some contribution there. 2

But the analysis -- the California Energy Commission 3

numbers are BEF numbers, actual light output BEF 4

numbers that I analyzed. 5

MR. RABA: A lot to think about. Good 6

comments. Thank you. 7

Anything else, please? 8

MR. deLASKI: Andrew deLaski, Appliance 9

Standards Awareness Project. And this is a question 10

for the industry or for Navigant. For a non-technical 11

person can you just give me a brief description of 12

what is it about a cold temperature ballast that makes 13

it more difficult for it to reach a given efficiency 14

level? 15

MR. ERHARDT: This is Bob Erhardt, Philips 16

Lighting Electronic. Higher ignition voltages. So 17

you ‟ re going to need more VAs in the -- you know, more 18

turns on the secondary transformer, more I squared R 19

losses. VAs volt amps, it ‟ s the throughput of the 20

product. VAs affect efficiency. If you have -- for 21

the same power, if you have more VAs you have lower 22

efficiency. So if you have two HO ballasts and one 23

has a higher open circuit voltage than the other, the 24

one with the higher open circuit voltage will like -- 25Executive Court Reporters (301) 565-0064 140

can be expected to have lower efficiency. 1

MR. deLASKI: Thanks. 2

MR. RABA: Further on the scope? 3

(No response.) 4

MR. RABA: Back to you, Ali. 5

MS. LEHR: So in the technology assessment 6

DOE identifies all possible technology options that 7

can improve the BEF of a ballast. To do this DOE 8

looked at commercially available ballasts, 9

manufacturer literature, patents research papers, and 10

considered input from both stakeholders and technical 11

experts. As a result DOE identified several 12

technology options to improve the BEF of covered 13

ballasts. Some of these options included using an 14

electronic ballast instead of a magnetic one. Within 15

the same product class using a T8 instead of T12 16

system. Improving the efficiency of internal 17

components such as transformers, diodes, capacitors 18

and transistors. And finally improving the circuit 19

design such as incorporating cathode cutout technology 20

or using an instant start instead of a rapid start 21

ballast. 22

DOE invites comment on all of the technology 23

options identified to improve the BEF of the ballasts. 24

MR. RABA: So comments on these options, any 25Executive Court Reporters (301) 565-0064 141

additional ones? Anybody? Please. 1

MR. PARISELLA: This is Joe Parisella from 2

Osram Sylvania. Some of the comments made regarding 3

the components as in -- there seemed to be a tradeoff 4

between efficiency and cost. With the active 5

rectification you would have a higher cost to get 6

about a 1 percent savings in efficiency that would 7

probably be prohibitive in why the industry isn ‟ t 8

doing that right now. And especially at higher 9

voltages that will be measured at 277 the impact of 10

efficiency would be much less. They mentioned using 11

silicon carbide Schottky diodes. 12

Typically in the input section it would be 13

cost prohibitive. In other parts of the circuit like 14

the PFC, the power factor correction circuit, 15

typically ballasts that we ‟ re talking about are in the 16

range of about 100, 120 watts or so. And these would 17

be much more effective at higher power levels using 18

different types of power factor correction circuits. 19

Transformers, what I saw there, they were 20

mentioning -- it looked like they were talking about 21

laminations used in older style ballasts. And if they 22

were mentioning ferrites or something, then I think 23

that in the higher frequency, different material would 24

be more effective, but the frequency range to be using 25Executive Court Reporters (301) 565-0064 142

right now seem like materials appropriate. 1

So I think my main point is that I think the 2

suggestions were really good, but I think it ‟ s a 3

tradeoff between costs and efficiency and it seems 4

like some of these suggestions might be cost 5

prohibitive. 6

MR. RABA: Yes. 7

MR. ERHARDT: This is Bob Erhardt again. I 8

also have a comment. There was a discussion to use 9

some Schottky diodes on the input. Unless there ‟ s 10

been some development I ‟ m not aware of, I don ‟ t think 11

you have shock key diodes in the voltage ranges that 12

are used on the input. Shock key diodes tend to be 13

low voltage devices and input voltage diodes you ‟ re 14

going to want something on the order of 600 to 1,000 15

volts for input rectifiers. 16

Integrated circuits, I agreed with the 17

Navigant observations that topologies that use 18

integrated circuits can have higher efficiencies. 19

It ‟ s not the integrated circuit itself that is 20

providing the efficiency, but it ‟ s the topology that 21

uses an integrated circuit. 22

There are some issues with that though in 23

that generally the integrated circuits are used with 24

series lamp topologies and when you go to a parallel 25Executive Court Reporters (301) 565-0064 143

lamp operation and you want to use a resonant topology 1

the control becomes much more complicated and it ‟ s not 2

clear that -- well, it ‟ s not -- again, as Joe says, 3

there ‟ s going to be some significant cost 4

considerations when you want to go from a self5

oscillating to a resonant type design and keep the 6

same functionality. The market has a strong 7

preference for independent lamp operation. We ‟ re 8

finding that out with dimming products where the 9

market is pushing us towards independent lamp 10

operation when it becomes quite complicated to do so 11

in a dimming application. So it ‟ s not -- it ‟ s not an 12

easy analysis to look at the effectiveness of -- cost 13

effectiveness. 14

MR. RABA: Thank you. 15

Comment? 16

MR. McGARAGHAN: Mike McGaraghan, California 17

Utilities. I just wanted to dig a little bit deeper 18

on some of the technologies that Navigant identified 19

that may be currently in use in power supplies. I 20

know active rectification was one of them. It sounds 21

like that should be cost prohibitive in ballasts, but 22

has there been any analysis into sign or power supply 23

technology and the differences that might exist there 24

that has allowed it to make its way into that 25Executive Court Reporters (301) 565-0064 144

technology? Or do you intend to look into that at 1

all? 2

MR. RABA: Takes a moment to warm up. 3

MS. GUPTA: Mimi Gupta, Navigant. So let me 4

just be clear, your question is, have we looked into 5

other types of like power supplies and the 6

technologies used in those not ballasts that can be 7

utilized potentially in ballasts; that ‟ s correct? 8

MR. McGARAGHAN: Yeah. And if they can be 9

cost effective. 10

MS. GUPTA: Right. I think that ‟ s a great 11

question. Well be asking for a comment on this issue 12

later today. I think we tried to put together a 13

technology option list that was comprehensive. Later 14

when we get into the engineering analysis with regards 15

to MaxTech, I think we have a comment to ask for a 16

comment from stakeholders on what is the maximum 17

technologically feasible level for this technology 18

because our engineering analysis right now caps out at 19

commercially available. So, that ‟ s what we want to 20

know from industry and from you folks. 21

MR. ERHARDT: This is Bob Erhardt again. I 22

can make a general comment. I think there ‟ s more 23

specific questions coming up later, but when you look 24

at the -- what we ‟ ve delineated as our NEMA premium 25Executive Court Reporters (301) 565-0064 145

type products, you ‟ re getting to the point of 1

diminishing returns if you ‟ re going to try to go much 2

beyond that when you ‟ re talking about efficiency. 3

Active rectification on the front end to pick up an 4

extra 1 percent on ballast efficiency we feel it does 5

not justify the engineering resources. 6

And as I stated in my opening comments, we 7

feel that the fixed output ballast is a mature 8

technology. We agree with Navigant ‟ s conclusion that 9

the state-of-the-art product on the market today does 10

represent a high performance product that is cost 11

effective. 12

Going beyond that, I would say considering 13

the engineering resources that would be pulled from 14

things like control systems and solid-state lighting 15

and new light sources would not justify the return and 16

we request -- we agree with Navigant ‟ s conclusions and 17

we would like the DOE to look very strongly at writing 18

regulations that the existing high performance 19

products can meet. 20

MR. RABA: Okay. Anybody else to hear? 21

(No response.) 22

MR. RABA: That cover that. Ali. 23

24

25Executive Court Reporters (301) 565-0064 146

ENGINEERING ANALYSIS 1

MS. LEHR: In the screening analysis DOE 2

considers whether technology options meet the four 3

screening criteria outlined on this slide. 4

The screening criteria include technological 5

feasibility, practicability to manufacturer install 6

and service, adverse impacts on product utility or 7

availability to customers and adverse impacts on 8

health or safety. As a result of this analysis DOE 9

screened out one option using laminated sheets of 10

amorphous steel to improve transformer efficiency. 11

DOE found that this option would increase the size and 12

weight of the ballast which would affect its ability 13

to be installed. DOE also believes that increasing 14

the size and weight would affect consumer utility 15

because it may limit the places a consumer could use 16

the ballasts in a building. 17

DOE invites comment on this technology 18

option that was screened out. 19

MR. RABA: Or was screened out -- was 20

screened in. Thoughts and comments perhaps. 21

MR. ERHARDT: Bob Erhardt, Philips Lighting 22

Electronics. I think Joe said it quite succinctly. 23

This would be an option for an electromagnetic 24

product, electronic product going through an amorphous 25Executive Court Reporters (301) 565-0064 147

steel is a step down in efficiency compared with 1

ferrite. And if I ‟ m clear that amorphous steel would 2

even bring electromagnetic up into the range that 3

you ‟ re looking for given that you ‟ re limited to the 60 4

hertz and you ‟ re starting it at 10 percent efficacy 5

handicap already due to the low frequency. 6

MR. RABA: Okay. That was good. Comment, 7

Earthjustice? 8

MR. BALLO: Tim BALLO with Earthjustice. 9

I ‟ m sorry if this displays my ignorance of the 10

product, but when talking about the amorphous steel 11

and how it would affect size and weight, did you look 12

into what are the sort of size and weight constraints 13

within which you operate when you ‟ re putting lights in 14

a building? It seems like there would probably be a 15

substantial amount of space, you know, surrounding the 16

fixture. How much of an increase are you talking 17

about in size and weight? 18

MS. LEHR: I guess all increase is relative. 19

We looked at -- we considered whether or not it would 20

require essentially the ballast to step outside of its 21

existing footprint. That in general the trend in 22

industry is to get smaller and smaller and to have 23

smaller ballasts instead of larger. And so we were 24

just looking at things that would require enlarging of 25Executive Court Reporters (301) 565-0064 148

the existing ballast footprint. 1

MR. BALLO: Are you saying that the 2

footprint would affect the fixture it goes into? The 3

screw holes would match up, for example? 4

MS. LEHR: Right. I mean, there could be 5

additional changes that go along. I guess if you had 6

any comments on what you felt was appropriate to look 7

at for changes in size we would welcome those. 8

MR. BALLO: I was just getting at it seems 9

odd to talk about size and weight constraints unless 10

you define, you know, the constraints that you are 11

actually operating in. I understand you may affect 12

the size or the weight -- 13

MS. LEHR: Right. 14

MR. BALLO: -- but at what point does it 15

become a problem? 16

MR. RABA: Charlie, follow-up? 17

MR. STEPHENS: I ‟ m Charlie Stephens. I ‟ ve 18

been doing, like I said, a lot of ballast work lately. 19

And all of the ballasts that I ‟ ve been installing are 20

all quite a bit smaller as a package than what they -- 21

than the one I removed. They still fit in the same 22

slot, they ‟ re designed to fit in the same space, but 23

the newest ones are quite a bit smaller and lighter 24

than the old ones. It ‟ s not to say that you couldn ‟ t 25Executive Court Reporters (301) 565-0064 149

put them back toward the size of the one I replaced 1

was. And I ‟ m only talking about four-foot, you know, 2

and eight-foot fixtures here, for the most part. It ‟ s 3

different in the small compact fluorescent type 4

fixtures, of course. But I don ‟ t know that you 5

couldn ‟ t expand the size of the package at least 6

somewhat and still have it be smaller than what I ‟ m 7

taking out of the fixture now. 8

MS. LEHR: Okay. 9

MR. ERHARDT: Yeah, I have -- Bob Erhardt, 10

Philips Lighting Electronics. I have a response for 11

that, yes. On retrofits, if you ‟ re talking about 12

luminaires from 10, 15 years ago, they were designed 13

around the -- what ‟s called the “old style” ba llasts. 14

The newer ballasts have a cross-section that have 15

allowed luminaire manufacturers to reduce the size of 16

their luminaires and use less material and in some 17

cases have better optics. And, no, you may not 18

increase the cross-section. Length luminaire 19

manufacturers tend to be able to accommodate, but the 20

cross-section is what generally determines, you know, 21

it ‟ s the width and the height. And I know we had a 22

big industry discussion on whether or not the new 23

standard should be 1.1 inch or 1.18 inches or one inch 24

because this affects the ballast cover design in the 25Executive Court Reporters (301) 565-0064 150

luminaire. Maybe Fred Carpenter can comment. 1

MR. CARPENTER: Fred Carpenter, Acuity 2

Brands Lighting. Everything that Bob said is 3

completely accurate. If you ‟ re talking about, you 4

know, retrofitting a product that was made five, ten, 5

15 years ago, then there was plenty of room. As the 6

ballasts have gotten smaller, the luminaires have 7

gotten smaller, there have been optical efficiency 8

gains in doing that. And, you know, as Bob pointed 9

out, there are a number of luminaire designs that can 10

accommodate, can increase in length of the ballast, 11

but many of the luminaire designs out there now are 12

designed around the current smaller size of the 13

ballasts. 14

MR. RABA: Yes, comment in the back? 15

MR. COOK: Keith Cook from Philips Lighting. 16

Even on the length you have to be careful because we 17

have run into considerations for luminaires that have 18

emergency ballasts also in there. And so you do end 19

up with a constraint sometimes for that accommodation 20

also. 21

MR. RABA: Interesting point. Thank you. 22

Ali. 23

MS. LEHR: Okay. So now we ‟ re going to move 24

on to the engineering analysis. 25Executive Court Reporters (301) 565-0064 151

The purpose of the engineering analysis is 1

to develop a relationship that identifies the 2

manufacturers ‟ selling price necessary for achieving 3

increased BEF. The results of this analysis are then 4

used downstream for the lifecycle costs and payback 5

period analysis and the national impact analysis. 6

This slide shows step-by-step the general 7

methodology DOE used for the engineering analysis. 8

DOE began by looking at all 70 product classes and 9

choosing a few representative product classes to 10

analyze in more detail. Within those representative 11

product classes DOE identified baseline models which 12

generally represented the lowest BEF, most common 13

ballast in that product class. DOE then selected 14

higher BEF substitutes for the baseline models while 15

trying to maintain similar light output. 16

For both the baseline and higher BEF 17

substitutes, DOE calculated manufacturer production 18

costs using teardown information when possible. After 19

developing candidate standard levels for 20

representative product classes, DOE then scaled those 21

levels to product classes that were not directly 22

analyzed. 23

Of the 70 total product classes DOE selected 24

ten to be representative. DOE bases its selection on 25Executive Court Reporters (301) 565-0064 152

those product classes with the highest volume 1

shipments. DOE selected a representative product 2

class for ballasts that operate each lamp type and 3

within the most popular category which were ballasts 4

that operate four-foot medium bi-pin lamps in the 5

commercial sector. Doe selected four representative 6

product classes. 7

After selecting these representative product 8

classes DOE then selected a baseline ballast. 9

Typically the baseline ballast either just met the 10

existing energy conservation standard or represented 11

the most common lowest BEF ballast available in that 12

class. In some cases DOE selected multiple baseline 13

ballasts to ensure consideration of different ballasts 14

and their associated consumer economics. 15

For example, for ballasts that operate two, 16

four-foot, medium bi-pin lamps in the commercial 17

sector DOE selected both a T12 rapid start and T8 18

instant start ballast as baselines. 19

After identifying baseline ballasts DOE then 20

selected higher BEF substitutes. This slide shows an 21

example of the baseline and higher BEF units for the 22

ballasts that operate two, four-foot, medium, bi-pin 23

lamps in the commercial sector. As you can see, 24

there ‟ s both the T8 and T12 baseline and both BEF and 25Executive Court Reporters (301) 565-0064 153

ballast deficiency increase with increasing CSLs. 1

For ballasts for which DOE did not have test 2

data for the measured BEE or BEF, DOE intends to 3

conduct additional testing for the NOPR. 4

DOE invites comments on its selection of 5

representative product classes baseline ballasts and 6

higher BEF substitutes. By statute DOE is required to 7

evaluate the maximum technologically feasible level in 8

each product class. DOE recognizes that commercially 9

available ballasts may not include the max tech level. 10

DOE conducted manufacturer interviews to see if any 11

working prototypes existed that had higher BEF ‟ s than 12

commercially available ballasts. Although there were 13

no prototypes there was some indication that the BEF 14

could be improved by using improved components. 15

DOE invites comments on the max tech level 16

which represents the highest CSL identified for each 17

product class. 18

MR. RABA: Comments on product classes, 19

representative product classes, baseline ballasts and 20

the systems chosen? 21

MR. ERHARDT: Bob Erhardt, Philips Lighting 22

Electronics, Chairman of the NEMA Ballast Section. 23

Actually in our discussions in the NEMA Ballast 24

Section, we felt Navigant did a pretty good job with - 25Executive Court Reporters (301) 565-0064 154

- a very thorough job with defining product classes 1

and we think they did a good overall analysis of the 2

industry. 3

We have some comments, again, as we said, 4

about scaling factors. And now that I understand that 5

your scaling factors and some of your levels came from 6

using the same resistor for BEE measurement thing 7

become a little clearer and we ‟ ve already commented on 8

using lamps for differing resistors. But overall we 9

thought that the overview of the industry was quite 10

thorough and balanced. Our only question, and we ‟ ll 11

get into that in the next sections are, you know, do 12

some of the volumes of some of the areas justify 13

having 72 classes? 14

We do understand though that reducing them - 15

- the number of classes will be difficult. We may 16

actually be asking you to increase the number of 17

classes when you get to HO and say, you ‟ ve lumped T8s 18

and T12s into the same category on the HO level, 19

although we don ‟ t object to having T8s and T12s in the 20

same category on medium bi-pin. 21

But, overall, we feel that Navigant did a 22

good job. 23

MS. GUPTA: Mimi Gupta, Navigant Consulting. 24

I just wanted to make a clarification when it comes to 25Executive Court Reporters (301) 565-0064 155

the use of the same resistor over multiple valve 1

factor ins. There ‟ s two scalings that we ‟ re dealing 2

with here. For the test procedure one resistor was 3

used for all three ballast factor bins. But then in 4

the correlation from BEE to BEF, that we tried to 5

account for that fact so that we ended up with a BEF 6

that was representative of a low and high ballast 7

factor. So, if the scaling that you see and we ‟ ll 8

talk about later in the preliminary analysis energy 9

conservation standard doesn ‟ t look representative of 10

low, medium -- or low, normal, and high ballast factor 11

ballasts then that should be -- because of the -- 12

MR. ERHARDT: All right. Bob Erhardt again. 13

I think your scaling factors are pretty close. I 14

didn ‟ t find big differences. Like I said, I think you 15

had plus/minus 2 percent on one of them and when I did 16

an analysis of actual product I had minus 3.5 and plus 17

1. That ‟ s pretty close considering there were two 18

different approaches taken to the analysis. So 19

overall we think that the analysis was pretty close 20

and we ‟ re just going to have some comments on some 21

small areas where we would like to tweak things a 22

little bit. 23

Oh, and I ‟ ll make this comment again. I 24

don ‟ t think I can make it enough. To redesign a 25Executive Court Reporters (301) 565-0064 156

product line is a significant undertaking. And we 1

strongly recommend that you try to accommodate. We do 2

have lines -- all of the major manufacturers have 3

lines of premium products that are pretty close, I 4

guess we would call them your max-tech. We can argue 5

with they can be increased another percent or so in 6

efficiency, but we really question the return on 7

investment there. Because of the -- you know, it 8

could cost a million dollars to redesign a whole 9

product line by the time that you put the engineering 10

resources into it, and you put your -- the disruption 11

to your factor when you do engineering builds and your 12

testing. And, as I say, we ‟ re -- we consider this a 13

mature technology. We don ‟ t think there are big gains 14

to be made beyond our quote/unquote “max

- tech”. And 15

we hope you will take a good look at our existing 16

premium products and try to accommodate existing 17

products on the market with the regulations. 18

Again, I think all of us are looking at 19

controls. You ‟ ve just heard how a building is saved 20

60 percent energy savings by using building -- by 21

using dimming controls. You know, don ‟ t make us go 22

after another 1 or 2 percent when 30 to 50 percent and 23

even 60 percent energy savings are out there for us to 24

go after. 25Executive Court Reporters (301) 565-0064 157

MR. RABA: Go ahead. 1

MR. McGARAGHAN: Mike McGaraghan, California 2

Utilities. I wanted to find out a little bit more 3

about testing that DOE did of these products that 4

resulted in the various CSLs proposed. My 5

understanding is that DOE conducted its own testing 6

because values from catalogues or CEC database or CEC 7

database are often not accurate enough for your 8

purposes. But we aren ‟ t able to translate. We don ‟ t 9

know which ballasts you tested. So it ‟ s hard for us 10

to comment on whether you ‟ ve captured the most 11

efficient products. 12

The tables that you provide in the Appendix, 13

I think it ‟ s 5C, there ‟ s actually some formatting 14

issues in them. And in one of the columns it ‟ s 15

supposed to show the number of lamps. It doesn ‟ t. 16

And the numbers have gotten mixed up in a different 17

column, I think. So that would be one thing that 18

would be really helpful is just to see that 19

reformatted. 20

Another thing that would be very helpful is 21

to see that table with the catalogue BEF values. 22

The best we can do is take a look at the 23

existing product lists and catalogues and databases 24

out there. And from everything that we ‟ ve seen, the 25Executive Court Reporters (301) 565-0064 158

values are much higher than the CSLs proposed here. 1

For example, for the main product class, two-lamp 2

normal ballast factor instant start, the CEC database 3

has several models there that are up at 1.64, 1.65 and 4

even one at 2.0. And that may be an outlier, but your 5

max-tech is, I think, 1.55. So that would be one 6

thing that we would appreciate. 7

In addition, I think what we found is a 8

bigger range of efficiencies in the existing product 9

databases. So even if the numbers are just shifted 10

down a little bit, it still seems like maybe you 11

haven ‟ t captured as much of the market as you could 12

have potentially. I think in some of the product 13

classes the range of even the CEC list which is 14

supposed to be just efficiency products, the range 15

inefficiency in that product class is often bigger 16

than the range that DOE has provided from their 17

baseline to their one CSL. So maybe various people 18

have comments on why that ‟ s happened or the background 19

behind that. 20

MR. RABA: Bob. Thank you. Thank you, 21

Mike. 22

MR. ERHARDT: There are -- you have a 23

reference to a 1.64 -- there ‟ s a 1.64 BEF on a two 24

lamp normal on the CEC database. And it ‟ s shown four 25Executive Court Reporters (301) 565-0064 159

times by the same manufacturer under four different 1

names. It ‟ s one ballast. And we can question other 2

than that it drops down to then if you go after the 3

next product you ‟ re dropping down to 1.6 and the CSL 3 4

number that DOE has talked about is 1.56. Well, the 5

difference -- it ‟ s only a 2.5 percent difference 6

between the 1.56 and the 1.6. It ‟ s not a dramatic 7

difference. We do think that Navigant did a pretty 8

good job. 9

When you look at the -- when you look at 10

what the top four manufacturers can supply in a two11

lamp normal output, the range is from -- these are the 12

highest efficiency ballasts offered on the California 13

Energy Commission website from the four major 14

manufacturers that ranges from 1.525 to 1.64. Those, 15

again, that ‟ s the highest from the four major 16

manufacturers. So if you ‟ re going to try to set 17

something -- and one of those numbers doesn ‟ t even 18

meet, and it ‟ s from a high-efficiency series from that 19

manufacturer, that doesn ‟ t even meet the 1.56 that DOE 20

is requiring. So I think if you look at -- in general 21

-- the numbers proposed by Navigant, they do represent 22

the state-of-the-art of what ‟ s on the market today. 23

MR. RABA: I think it would be most helpful 24

-- I know you ‟ re both are familiar with visual things 25Executive Court Reporters (301) 565-0064 160

that we can ‟ t see here in the room. 1

Any other thoughts or comments? And perhaps 2

in your written comments you might want to illustrate, 3

with your comments, your concerns, your questions, and 4

likewise, Bob, what you found too, and in your finding 5

as well. Some visual presentation because we can ‟ t 6

imaging this in our heads what you ‟ re looking at 7

there. I think it would be good content both, but I 8

just can ‟ t visualize it. 9

MR. deLASKI: I think the question is really 10

one for Navigant or for the Department which is that 11

we observe, looking at published data, BEFs higher 12

than what you have shown to be the highest possible. 13

I ‟ m asking the Department how did you screen out or 14

how did you eliminate? Bob is giving one hypothesis 15

but I ‟ m interested in the Department ‟ s view on how you 16

got rid of those values that are higher than what are 17

in the document. 18

MR. RABA: I ‟ ve got four hands here coming 19

up right away. Let ‟ s go around. 20

MS. LEHR: If I can just make an initial 21

comment, I guess. 22

MR. RABA: Fine. 23

MS. LEHR: We didn ‟ t take any steps to 24

eliminate values that we thought might be too high. 25Executive Court Reporters (301) 565-0064 161

All the data that we obtained for this analysis is 1

provided in that TSD chapter and if the formatting is 2

incorrect, then we ‟ ll correct it. 3

We, in general, found from our testing that 4

the tested values were lower than the catalogue 5

values. And we also found that the range of values 6

was much smaller than what the catalogue value showed 7

there was. So I guess your observations are similar 8

to ours and we tried to provide the test data so that 9

everyone would have access to what we had access to. 10

MR. deLASKI: So, as a follow-up, could you 11

check on that table and find out if it is formatted 12

improperly so we just find that out today? That would 13

help us to be able to evaluate the data. 14

MS. LEHR: Sure. 15

MR. McGARAGHAN: Can I add just real quick 16

that there ‟ s two sides to that question. One is the 17

formatting of the table. The other is providing the 18

BEFs, the catalogue BEFs of those products so that we 19

could see. Otherwise we have no frame of reference so 20

we don ‟ t know which products were tested and we don ‟ t 21

know whether to recommend or how to comment on whether 22

you ‟ ve captured the whole market or not. 23

And this is just for setting up a max-tech 24

level. Not even talking about standards yet, just 25Executive Court Reporters (301) 565-0064 162

establishing max-tech. 1

MR. RABA: Follow-up, Bob? 2

MR. ERHARDT: Yeah. I am puzzled. I have 3

another important comment I wanted to make. The 4

California Energy Commission website and the CEC 5

websites should, by definition, be test data from 6

certified laboratories, catalogues are not. You know, 7

we have a long history of we talk about commercial 8

data and we talk about certified data. 9

And I can comment a little it about what I 10

think was going on with Navigant because when I see 11

their max-tech, what do they have, a 1.56. Well, I 12

see a product on the CEC website from actually the 13

largest ballast manufacturer that is coming in at 14

1.58. Well, that ‟ s pretty darn close and I think what 15

they did was try to take products from their 16

representative categories of max-tech products and 17

different manufacturers on their max-tech lines, one 18

will be higher than the other in this model and one 19

will be higher than that model in the other model. 20

There are also some differences even on the certified 21

measurement with the -- between labs. And remember, 22

we are still saying you ‟ re going to have a 3 percent 23

difference. You have a plus/minus 3 percent 24

difference even using the ballast deficiency test 25Executive Court Reporters (301) 565-0064 163

method. 1

Our experience is that our testing is, we 2

think, conservative. We compare our test data. We 3

benchmark against other manufacturers. And, for 4

instance, we talked earlier about whether you allow a 5

one-minute warm-up or whether you allow 15 minute to a 6

half hour warm-up. When we do our measurements, we do 7

them one-minute warm up which, actually, to our 8

surprise was making us very conservative because the 9

ballasts do pick up another percent or two when you 10

run them for 15 minutes or a half hour or an hour. 11

So there are still some differences on the 12

test data, but if you ‟ re going to be looking at the 13

data, again my approach was to look at the highest 14

technology products form the four major ballast 15

manufacturers and draw some conclusions from that 16

because that is the maximum technology. I mean, it is 17

the filament cut out, it is the -- you know, when 18

you ‟ re talking about these program starts and it is 19

the -- this is the NEMA premium stuff. And so this is 20

what the four major manufacturers have for their high21

end product. 22

There ‟ s going to be -- you know, yes, there 23

are a couple percent, three -- you know, 3 percent 24

difference between manufacturers in measurement method 25Executive Court Reporters (301) 565-0064 164

and maybe in their technology. But, again, is that 1

worth redesigning product lines for, I guess, is our 2

question? Or, you know, is it going to -- is the 3

market better served by getting rid of the other 80 4

percent of the product that don ‟ t meet the high tech 5

level of the major manufacturers premium product 6

lines. 7

MR. RABA: Mimi? 8

MS. GUPTA: Mimi Gupta, Navigant Consulting. 9

So, just to respond to your questions. The way the 10

analysis was conducted is that we did purchase the 11

highest efficiency products from the major 12

manufacturers and tested them. And of those that we 13

tested, we chose the highest efficiency one as our 14

highest standard level. 15

I mean, another -- we ‟ ve discussed a couple 16

of possible sources of why the data is different than 17

CEC than catalogue. Another one is that we 18

implemented a different test procedure. We used the 19

ballast efficiency test procedure and correlated it to 20

ballast efficacy factor which might account for some 21

of that change depending on how good the correlation 22

is. 23

In terms of the appendix, unfortunately, my 24

version of the TSD is before it was PDFed. So the 25Executive Court Reporters (301) 565-0064 165

appendix looks fine in my version. You ‟ re welcome to 1

come and take a look at it. But if it looks 2

incorrect, the web will definitely fix that. I see no 3

problem with including the catalogue BEFs as the 4

source of reference is that would be helpful. 5

MR. McGARAGHAN: What about, as Bob 6

mentioned, the catalogue BEFs are provided by the 7

manufacturers, the CEC lists have to go through a 8

certified lab, could you provide those CEC values 9

instead, or does that create more -- 10

MS. GUPTA: So you mean do a cross-reference 11

to the CED database? We ‟ ll have to look into that. I 12

can ‟ t answer that right now. 13

MR. McGARAGHAN: I guess just as long as 14

whatever you provide is labeled if it ‟ s from catalogue 15

or if it ‟ s from CEC -- 16

MS. GUPTA: Sure. 17

MR. McGARAGHAN: -- that would be helpful. 18

Thank you. 19

MR. RABA: I ‟ m sorry. Heading on back there 20

to you, sir. Comment? 21

MR. PLASKON: Jeff Plaskon, GE Lighting. 22

MR. RABA: Use the microphone, please? 23

MR. PLASKON: I think I can talk loud 24

enough. Jeff Plaskon, GE Lighting. Just as a 25Executive Court Reporters (301) 565-0064 166

benchmark from our round robin testing that we did 1

validating the BEE metric, five major manufacturers 2

were tested and the test results were anywhere between 3

89.8, I believe, up to 92 percent for that two-lamp 4

normal. So the highest being the 92 percent listed 5

for max-tech. So I think what ‟ s important is to look 6

at ballast efficiency as a good benchmark of where 7

that BEF should be as opposed to our catalogue ratings 8

of backing into a ballast deficiency. 9

I think that ‟ s one of the reasons why we ‟ re 10

trying to lead to a more accurate measurement with 11

ballast efficiency to get moved back up the ladder to 12

BEF. Because we ‟ re avoiding that error measurement 13

with the lamp. 14

MR. RABA: Did you get that? Most of it. 15

Okay. 16

MR. PARISELLA: Joe Parisella, Sylvania. 17

Yeah, I want to elaborate on what Jeff said. 18

Basically I think the problem lies here with a 19

correlation between the ballast efficiency and BEF. 20

And there ‟ s some distribution that goes around that. 21

So if, let ‟ s say the nominal value at 90 percent was 22

1.58 as we might expect from CEE, but if you have a 23

distribution on one side of the BEF and then in the 24

efficiency measure was on the other side, you could 25Executive Court Reporters (301) 565-0064 167

see some type of variation here. You might even see a 1

variation in the other direction. 2

So, I don ‟ t know if we have a good 3

correlation right now of BEF versus ballast efficiency 4

but, you know, I think that ‟ s something that we have 5

to take into consideration. 6

MR. RABA: Charlie. 7

MR. STEPHENS: Charlie Stephens. Yeah, I 8

think this is a real important set of issues to get 9

around. I can understand why the catalogue values 10

might be different. But just speaking about CEC 11

numbers and CEE numbers, and correlations, I mean, if 12

you get a .05 difference in BEF that is kind of what 13

we ‟ re talking about here, you know, the difference 14

between 1.58 and 1.53, say, something like that, 15

you ‟ re kind of implying that several 2.5 percent, 2 16

percent difference in ballast deficiency here, we ‟ re 17

arguing over whether we should talk about 1 percent 18

increase in the ballast efficiency. So there ‟ s -- we 19

really need to get this straightened out and find out 20

whether the correlation is a problem or what the 21

problem is. Because I hate to be arguing over 1 22

percent ballast efficiency improvements when we can ‟ t 23

even get the correlation straight within 3 percent or 24

4 percent. So, somewhere along here I would like to 25Executive Court Reporters (301) 565-0064 168

know what numbers we ‟ re working with for regulatory 1

purposes. 2

MR. RABA: Can you respond? 3

MR. ERHARDT: Yeah, I don ‟ t think it was -- 4

this is Bop Erhardt again. I don ‟ t think it was a 5

correlation that gave -- well, maybe we can have an 6

off-line discussion. But, again, Navigant found a 7

1.56. I see a product that is listed in the CEC site 8

at 1.58 that from our testing has the highest BEF, 9

higher than the one that is on the CEC website at 1.64 10

from our testing. Again, we benchmark -- the 1.58 is 11

our product. We benchmark it against our competitors 12

and when we test one against the other in the lab our 13

1.58 was higher than the 1.64. And Navigant says the 14

highest one they found, if it was us, they came up 15

with 1.56. Well, 1.56 to 1.58 is pretty darn good 16

correlation, if you ask me. If that ‟ s indeed what 17

happened. 18

MR. STEPHENS: Charlie Stephens. 19

MR. RABA: Wait. 20

MR. STEPHENS: Yeah, I want to follow-up on 21

that. 22

MR. RABA: Okay. Follow-up on that Charlie. 23

MR. STEPHENS: Yeah, but again we ‟ re getting 24

it down to where we ‟ re talking about a percent or two 25Executive Court Reporters (301) 565-0064 169

on the ballast deficiency side within those two or two 1

and a half points. 2

MR. ERHARDT: The BEF measurements. 3

MR. STEPHENS: Right. And if I take a 2.5 4

point what you were talking about, I mean, it equates 5

over to a 1 percent or so -- 6

MR. ERHARDT: 1 percent. 7

MR. STEPHENS: BE difference which is what 8

we ‟ re arguing potentially about. So I don ‟ t want to 9

just understand where it comes from and I ‟ m thinking 10

it might come from the way -- you aren ‟ t using diodes; 11

right? 12

(Simultaneous conversation.) 13

MR. STEPHENS: -- using resistors to do your 14

testing? 15

MR. ERHARDT: No, this was a real ANSI BEF 16

measurement. 17

MR. STEPHENS: And were you using resistors 18

to do your testing or the proposed method or -- 19

MS. LEHR: Right. The BEF numbers that are 20

reflected in these tables are based on the test 21

procedure being discussed this morning. 22

MR. STEPHENS: Being proposed. 23

MS. LEHR: So they would be a ballast 24

efficiency measured with a resistor and then using the 25Executive Court Reporters (301) 565-0064 170

correct slope to translate that to BEF. 1

MR. STEPHENS: Okay. So maybe that ‟ s 2

something of what we ‟ re seeing here. But whatever it 3

is, I would love to see it get resolved. Thank you. 4

MR. RABA: In the back first, please? 5

MS. GUPTA: Can I just make one comment 6

related to this, Jim? Sorry. 7

MR. RABA: There you are. 8

MS. GUPTA: Mimi Gupta. In the appendix 9

when you guys can actually read it properly, there ‟ s 10

also the measured BEF for the ballasts for which that 11

was tested based on the light output measurements. So 12

-- 13

MS. LEHR: Right. So the appendix -- 14

(Simultaneous conversation.) 15

MS. LEHR: The appendix would have ballast 16

efficiency according to the resistor based test method 17

and BEF according to the current test procedure which 18

is the using the lamp to measure BEF. 19

MR. RABA: I saw a big not and a thumbs up 20

from Charlie Stephens. You can ‟ t see that in the 21

record, you know. 22

MR. STEPHENS: Now you can. 23

MR. RABA: Yeah, sure. 24

In the back, sir, you had a comment? 25Executive Court Reporters (301) 565-0064 171

MR. PLASKON: Jeff Plaskon. I was just 1

going to make -- 2

MR. RABA: We can hear you here, but the 3

court reporter is kind of hiding back here and having 4

difficulty. 5

MR. PLASKON: Thank you. Jeff Plaskon, GE 6

Lighting. I was just going to use as an example the 7

normal ballast factor with the CEE ratings of 1.58 for 8

the ballast efficacy factor. Using the slope that 9

would equate to 93.1 percent efficiency. And in our 10

round robin testing that we ‟ ve done, we didn ‟ t find 11

any valves that operated at 93 percent efficiency. So 12

there ‟ s obviously an error or a measurement error 13

associated with the lamp aspect of it. So, again, 14

important to reference back to ballasts electrical 15

efficiency as a practical measurement that we should 16

focus on. 17

MR. RABA: Okay. Good. Thank you. 18

Some more comments over here, follow-on? 19

MR. McGARAGHAN: Just one more that I just 20

have 21

MR. RABA: And you are, sir? Mike? 22

MR. McGARAGHAN: Sorry. Mike McGaraghan. 23

MR. RABA: Thank you. 24

MR. McGARAGHAN: I want to make sure the 25Executive Court Reporters (301) 565-0064 172

discussion stays on max-tech. I understand that we 1

would likely not land at a standard level that 2

couldn ‟ t be met by the major four manufacturers. But 3

if DOE is attempting to identify that max-tech 4

commercially available, there would be no reason to 5

limit yourselves to just the major four. So that may 6

explain why there are certain values that were above 7

the round robin -- values that came out of that. 8

MR. RABA: Follow-on? Thank you. Follow9

on? 10

MR. PLASKON: Follow-on. 11

MR. RABA: Jeff Plaskon 12

MR. PLASKON: The alternative to -- 13

alternatively there ‟ s a compliance problem, you know. 14

And that came up the first thing this morning, but, 15

you know, that ‟ s something else that, you know, I 16

think folks in this room should have an interest in 17

bringing to the Department ‟ s attention. If there ‟ s a 18

compliance problem people out there claiming 19

efficiencies that aren ‟ t being achieved in the 20

marketplace, let ‟ s know about it. I mean, you ‟ ve seen 21

that the Department has been much more enthusiastic 22

over the past several months and worrying about 23

compliance problems, so, please, you know, let ‟ s get 24

it out in the open so that these folks who aren ‟ t 25Executive Court Reporters (301) 565-0064 173

complying can be identified and brought into 1

compliance. 2

I have a follow-on, but on a different 3

topic. So -- 4

MR. RABA: Okay. 5

MR. PLASKON: -- I ‟ ve got some arms up. 6

MR. ERHARDT: This is Bob Erhardt. This is 7

exactly the point that we are bringing up. Why we 8

bring up measurement accuracy, the CEC website data 9

has a plus/minus 5 percent accuracy. So it ‟ s not to 10

say that -- and we want to bring up this point because 11

we feel it ‟ s important that the Department of Energy, 12

when they set these limits, don ‟ t take the highest 13

claimed measurement that you ‟ ve seen and say that 14

everyone has to meet that. Because you have this 15

measurement accuracy you have to deal with. When I 16

say that this 1.64 that we saw that ‟ s compared with 17

1.58, that ‟ s -- okay, that ‟ s 4 percent difference. If 18

you are looking at a plus/minus and you ‟ re looking at 19

a life output, it ‟ s within the measurement error. 20

It ‟ s not that they ‟ re out of compliance. And we want 21

the DOE to consider this that when you ‟ re either in 22

setting the limits or in determining compliance, you 23

know, that if you ‟ re going to use the published data 24

and we would recommend you then take some averages or 25Executive Court Reporters (301) 565-0064 174

something, you know, worst case of -- I ‟ ll call it 1

“worst case max

- tech” is what I would like to 2

encourage, but consider either in writing the 3

regulation either then if it ‟ s a 5 percent measurement 4

write in an extra 5 percent. Well, maybe you don ‟ t 5

want to do that, but at least put it into the 6

compliance that you ‟ re only going to say they ‟ re 7

noncompliant if they ‟ re up more than 5 percent. 8

Because there is this -- this is real variation in 9

measurement. This is lab to lab people -- diligent 10

people trying to do the right job. This was in our 11

round robin too, we found these differences. And it ‟ s 12

real. It ‟ s just, you know, how long -- in this case 13

it was -- like I said, we turn ours on and measure it 14

one minute and low and behold we find, oh, yeah, you 15

leave it on for 15 minutes or an hour and you pick up 16

an extra couple percent. Then that gap closes quite a 17

bit. And it ‟ s one person ‟ s equipment versus another. 18

And there ‟ s -- we ‟ re trying to bring up how difficulty 19

it is to do these measurements and to take this into 20

consideration when you ‟ re looking at compliance and/or 21

setting a limit. 22

MR. RABA: Reemphasize this morning ‟ s test 23

procedure discussion with accuracy. 24

Yes, sir. 25Executive Court Reporters (301) 565-0064 175

MR. COOK: Keith Cook from Philips Lighting. 1

I guess I need a little clarification. I ‟ m a little 2

confused. For your CSLs that you ‟ ve got here, are you 3

proposing these as being minimum values or average 4

values? 5

MS. GUPTA: Well, we need to hear from 6

Navigant. They would be minimum values that you would 7

have to comply with. So whatever average -- yeah, you 8

have to test four ballasts and then you report 9

something like that, is it the 95th percent confidence 10

interval? Yeah, you use some equation with those four 11

tests of the ballasts to determine the reported 12

ballasts efficacy factor. Currently that ‟ s the way it 13

is. And then this would be the minimum standard you 14

need to meet with that. 15

MR. RABA: Thank you. Charlie. 16

MR. STEPHENS: Charlie Stephens. Half of my 17

working life is centered on statistical analysis these 18

days. And I ‟ ve got to say, I mean, there ‟ s got to be 19

some sort of statistically valid method for how you 20

report these things. Because if what we are seeing 21

out there is not plus or minus 5 percent, but minus 22

zero plus 10, then we ‟ ve got a problem. And I don ‟ t 23

know if that ‟ s what we ‟ re seeing. But if there is 24

any statistical validity to what ‟ s being reported, and 25Executive Court Reporters (301) 565-0064 176

that ‟ s what I look for in my business, then it should 1

bill plus of minus 5 or plus or minus 2.5. It 2

shouldn ‟ t be minus zero plus 10 consistently. So, I ‟ m 3

hoping that we ‟ ll come out with some sort of what was 4

referred to earlier as an average value statistically 5

valid also. 6

MR. RABA: Over here first and then in the 7

back second. 8

MR. ERHARDT: Yeah, what I just heard from 9

Navigant actually has me concerned if we ‟ re supposed 10

to have a 95 percent -- this Bob Erhardt -- if we ‟ re 11

supposed to have a 95 percent confidence level that 12

all our products meet this. Because these numbers 13

that you ‟ re working from are, we consider, nominal 14

representative numbers. And when you look at the 15

California Energy Commission compliance, somebody help 16

me here, I think I recall that you test five ballasts 17

and three have to comply. So it is a nominal that 18

you ‟ re nominal product has to meet this minimum 19

requirement. And it ‟ s not a 95 percent confidence 20

level that all of your product is going to meet this 21

requirement. If that ‟ s the case, then we really have 22

strong objections to the levels that you ‟ ve come up 23

with. 24

MR. RABA: Interesting. 25Executive Court Reporters (301) 565-0064 177

More on that is subject and topic? 1

MR. PARISELLA: Joe Parisella, Osram 2

Sylvania. 3

(Simultaneous conversation.) 4

MR. RABA: Yes, Earthjustice? Forgive me. 5

Sorry, Joe. 6

MR. BALLO: This is Tim Ballo, Earthjustice. 7

I think I ‟ m asking the same question maybe. But I 8

take it the Department didn ‟ t actually follow the 9

compliance testing parameters when it tested ballasts 10

to come up with the numbers that it used in the 11

preliminary TSD for CSLs or for the baseline rather? 12

MS. GUPTA: Mimi Gupta, Navigant Consulting. 13

These do represent average numbers. That ‟ s correct. 14

So, I mean, if stakeholders feel that DOE should use 15

that same equation in developing the standard levels, 16

then we welcome that comment and we ‟ ll consider it and 17

revise if necessary. 18

MR. RABA: Go ahead, Bob. 19

MR. ERHARDT: Yeah, you can ‟ t use average 20

values I setting a limit and then say 95 percent of 21

the product has to meet it. There needs to be some 22

consistency. And to develop a 95 percent confidence 23

level you need a significant sample size to get the 24

statistics from it and recognize that this is a test 25Executive Court Reporters (301) 565-0064 178

that each time you test one ballast it might take you 1

two hours to test one ballast. So if you ‟ re going to 2

have to do 10 or 20 ballasts to get some statistically 3

significant data out of it -- out of multiple 4

production lots out of -- et cetera, this is a highly 5

burdensome requirement. I mean, you ‟ re going to have 6

70 categories and you ‟ re going to require us to do 10 7

or 20 three-hour tests for each category. This is 8

highly burdensome. 9

MR. RABA: Follow-on, please? 10

MR. PARISELLA: Yeah, Joe Parisella, Osram 11

Sylvania. What Bob just said is really what I was -- 12

something very similar to what I was going to say. 13

Thank you. 14

MR. RABA: Yes, thank you. 15

Yes, sir. 16

MR. THOMAS: I would just like to go on 17

record -- Ed Thomas of GE -- as agreeing with both Bob 18

and Joe in the matter that this would be extremely 19

burdensome to require this statistical significance 20

like this. 21

MR. RABA: Good to know that. Thank you. 22

Both sides. 23

MS. MAUER: Joanna Mauer. I just had a 24

specific question on the previous slide, the table. 25Executive Court Reporters (301) 565-0064 1 79

Is there a reason on the CSL3 level why the input 1

power and therefore the annual energy consumption is 2

actually higher for CSL3 than CSL2? 3

MS. LEHR: Sure. There ‟ s a small difference 4

in ballast factor. And so if you normalized the input 5

power based on ballast factor the CSL3 would be less 6

than the other levels. This is an abbreviated version 7

of a table to fit on the slide. 8

MR. RABA: And there ‟ s more detail in the 9

TSD, you ‟ re saying? 10

MS. LEHR: Yeah, there ‟ s more detail in 11

Chapter 5 of the TSD. 12

MR. RABA: Mike? 13

MR. McGARAGHAN: Mike McGaraghan. Is there 14

also going to be more discussion on this later in the 15

presentation? 16

MS. LEHR: On normalized input power? 17

MR. McGARAGHAN: Yeah, on normalized input 18

power. 19

MS. LEHR: I believe that later slides cover 20

that, yes. 21

MR. McGARAGHAN: Thanks. 22

MS. GUPTA: Mimi Gupta, Navigant. John 23

actually just mentioned something to me that is 24

important to mention. So it does use -- the current 25Executive Court Reporters (301) 565-0064 180

reported value calculation does use some sort of 1

confidence interval. I don ‟ t have it by memory. But 2

then it also divides it by a number which bumps that 3

number up a little bit. So I would encourage you all 4

to look at that equation in the regulations. And make 5

comment on whether you feel like the standards 6

represented represent what those ballasts comply and 7

if not how they should be shifted. 8

MR. ERHARDT: I guess I ‟ ll -- this is Bob 9

Erhardt. I guess I ‟ ll turn that back and say how does 10

Navigant see their proposals when they ‟ re testing. In 11

the case of T5 your report said you tested one 12

ballast. And you generated eight categories out of 13

it. Is that what the report said? 14

MS. LEHR: I don ‟ t think so. 15

MR. ERHARDT: Okay. I ‟ ll look for it. But 16

the sample size that Navigant used is not 17

statistically significant. It ‟ s just a -- you know, I 18

think I heard a sample size of three. That ‟ s not 19

going to -- that ‟ s not a statistically significant 20

sample size, especially when you bought it from one 21

location with one date code. And so if you ‟ re going 22

to require compliance with a statistical confidence 23

level, then, yes, we would like to know how you ‟ ve 24

come up with requirements that show what products can 25Executive Court Reporters (301) 565-0064 181

meet with that confidence level, how you ‟ re basing 1

your requirements and saying that they can be met with 2

that confidence level. 3

MS. GUPTA: Mimi Gupta. For the preliminary 4

analysis I believe we tested three ballasts of each 5

model that we tested. And then these numbers 6

represent an average of those. If stakeholders 7

believe that that number should be increased, the 8

number of ballasts tested per model should be 9

increased in order to set a minimum efficiency 10

standard, then I would encourage you to submit 11

comments saying that and how many it should be. 12

MR. RABA: Much to think about; written 13

comments, please, we welcome those. Most helpful. 14

We ‟ ve captured what we ‟ ve spoken about today so far. 15

And additional thoughts as you think about it when you 16

go home. 17

But is there more on this discussion for 18

this particular topic? 19

(No response.) 20

MR. RABA: Should we move on? Let ‟ s do 21

that. 22

Ali. 23

MS. LEHR: After CSLs were developed DOE 24

calculated manufacturer production costs. These costs 25Executive Court Reporters (301) 565-0064 182

were calculated from a tear-down analysis. In a tear1

down a ballast is taken apart so that all the 2

components can be identified. With this information 3

DOE then estimates the material and labor costs 4

required to assemble the ballasts. However, DOE is 5

not able to tear down all ballasts due to potting. 6

For those ballasts that were not able to be torn down, 7

DOE developed manufacturer production costs by 8

comparing retail prices to tear down results. 9

After determining manufacturer production 10

costs DOE then used publicly-available information to 11

determine manufacture mark-ups. DOE found the average 12

manufacturer mark-up to be 1.5 and therefore applied 13

this mark-up to calculate manufacturer selling price. 14

Calculations were verified with confidential prices 15

provided by manufacturers. 16

The following table shows the manufacturer ‟ s 17

selling price associated with each CSL for ballasts 18

that operate two, four-foot, medium, bi-pin lamps in 19

the commercial sector. As you can see, the MSP for T8 20

ballasts was determined using tear down information. 21

However, the MSP of the T12 baseline ballast was 22

determined using the retail price scaling method 23

because this ballast was potted. 24

As you can see, the prices of the two 25Executive Court Reporters (301) 565-0064 183

baseline ballasts are significantly different 1

indicating different economics for these two 2

consumers. This difference is consistent with 3

information from manufacturers and trends observed in 4

retail prices. 5

Similar to the fact that DOE could not tear 6

down the T12 baseline ballasts there were five 7

representative product classes for which all ballasts 8

were potted. For these classes DOE used the retail 9

price scaling method to determine manufacturer 10

production costs. DOE requests comment on the scaling 11

method and also it requests comments on its estimates 12

for overhead and manufacturing markup. 13

MR. RABA: Scaling techniques, markup? 14

Comments? Questions? 15

(No response.) 16

MR. RABA: Wow. Last call. Quickly. 17

MR. ERHARDT: Yeah, we commented -- this is 18

Bob Erhardt, Philips Lighting Electronics, NEMA 19

section chair. 20

We find that using teardown analysis to 21

develop end product costing to be very difficult even 22

when we ‟ re doing competitor analysis and we know what 23

our production costs are and we know what we pay for 24

components. And we feel that Navigant has taken on a 25Executive Court Reporters (301) 565-0064 184

very ambitious undertaking by trying to come up with 1

accurate cost analysis using teardown analysis. 2

NEMA -- we appreciate the difficulty and the 3

reason we haven ‟ t been able to give you data before 4

and we know the reason you had to do this was because 5

we didn ‟ t give you the data. We are attempting to 6

come up with some confidential sanitized 7

differentiation numbers for our written comments. 8

It ‟ s not clear we ‟ re going to be able to accomplish 9

this but through our confidential NEMA business unit 10

we ‟ re going to try to supply from each company, at 11

least on the -- you know, at least where we see some 12

issues such as more efficient ballasts are cheaper to 13

build than less efficient ballasts. We ‟ re going to 14

try to come up with some better representation of 15

those numbers for you. 16

MR. RABA: Thank you. Let ‟ s keep moving. 17

Quickly, Andrew. 18

MR. deLASKI: I think that ‟ s great. I think 19

it ‟ s really valuable to have the industry provide that 20

kind of data and we see it in other dockets both with 21

NEMA and with other trade associations have been very 22

helpful in providing that kind of data. 23

I also think it ‟ s critical that the 24

Department continue with the teardown approach as 25Executive Court Reporters (301) 565-0064 185

well. Because having both I think is a robust way to 1

approach the docket. Especially given that you ‟ re not 2

sure you ‟ re going to be able to get the data. 3

MR. RABA: That was Andrew deLaski. 4

Okay. Let ‟ s just move on now. 5

MS. LEHR: No more request for comment. 6

In response to framework document, DOE 7

received comments that upcoming safety and hazardous 8

material regulation could affect the price and 9

efficiency of commercially available ballasts. So DOE 10

requests more information on the specific impact these 11

regulations might have so that DOE can assess how the 12

requirements may affect payback calculations? 13

MR. RABA: Safety requirements, system 14

requirements? 15

MR. ERHARDT: Bob Erhardt, Philips Lighting 16

Electronics. Yeah, I think this comes from our 17

comments from two years ago. There has been some 18

progression and it ‟ s still not clear to us if there ‟ s 19

going to be impact from some of this safety 20

regulation. The IEC which is the international 21

standards body for -- and it has a lighting section, 22

has just adopted requirements for end-of-life 23

circuitry on T8 lamps. Previously it had only been on 24

T5 and narrower diameter lamps. At this time we don ‟ t 25Executive Court Reporters (301) 565-0064 186

know if it ‟ s going to be a U.S. requirement. 1

Now, ANSI has not -- American National 2

Standards Institute -- the T8 lamp in this country is 3

not an IEC lamp. So by one interpretation we would 4

not have to add end-of-life circuitry to the T8 5

ballasts. End-of-life circuitry especially for a 6

parallel lamp product is costly and will affect 7

efficiency. The reason it has not been a requirement 8

in the United States is our lamps run at half the lamp 9

current, our T8 lamps and the European lamps. And so 10

there is a lower risk of overheating at end-of-life. 11

But we don ‟ t have the formal statements and 12

regulations in place where we know that we won ‟ t be 13

needing that meet lists. We do know that both CSA and 14

UL have adopted the IEC requirements for the narrower15

diameter lamps for end-of-life. If they were to adopt 16

the IEC requirements for T8 lamps, then it would 17

become a U.S. requirement and we would have to start 18

redesigning our products to accommodate it. 19

MR. RABA: Thank you. Yes, sir. 20

MR. COOK: Keith Cook from Philips Lighting. 21

Under the hazardous materials portion another thing 22

that may be coming about is Rohaus compliance. And 23

that does drive up capital costs, and it also drives 24

up some component costs. And right now that ‟ s being 25Executive Court Reporters (301) 565-0064 187

considered as part of a NEMA call to action initiative 1

which may be included in the Tosca Bill this year. 2

MR. RABA: I missed some of that only 3

because I don ‟ t know the subject. But you can make 4

written comments, if you wish, the bill and all. 5

Thank you. 6

Yes. 7

MR. ERHARDT: Bob Erhardt. I don ‟ t know if 8

it ‟ s in this question or if it ‟ s in another. We ‟ ve 9

also had discussions that some of the RoHS 10

requirements, lead-free solder, for example, will have 11

an impact -- well, can have an impact on product 12

reliability and we just don ‟ t have enough experience 13

to know how significant that impact is and how it 14

would affect the payback analysis. 15

We do know that, you know, we ‟ re in a 16

learning curve for lead-free solder. We do know that 17

lead- free solder has this effect called “dendrite 18

formation” which can cause shorts between different 19

parts of ballast circuitry. So there is a potential 20

for lead-free solder to have an adverse effect on 21

ballast reliability and life time. 22

Manufacturers are in a learning curve. Our 23

European sister companies are on the leading edge, 24

shall we say, and we ‟ re learning about this. But it ‟ s 25Executive Court Reporters (301) 565-0064 188

still not known if there will be an impact on lifetime 1

significant enough to affect the payback analysis. 2

MR. RABA: That was a RoHS amendment to a 3

bill, did you say? 4

MR. ERHARDT: Well, the world is moving to 5

elimination of hazardous materials. 6

MR. RABA: Right. And -- 7

MR. ERHARDT: Lead-free solder is probably 8

the most significant impact to ballasts. And lead9

free solder can have an effect on ballast lifetime. 10

MR. RABA: Okay. Thank you. And the bill ‟ s 11

name is? 12

MR. COOK: It ‟ s called TSCA. It ‟ s Toxic 13

Substances Control Act. 14

MR. RABA: Ah, thank you. 15

MR. PARISELLA: Joe Parisella, Osram 16

Sylvania. Yeah, stricter EMI requirements will also 17

affect efficiency as well. 18

MR. RABA: Electromagnetic interference? 19

MR. PARISELLA: Yes. 20

MR. RABA: Thank you. 21

More? 22

(No response.) 23

MR. RABA: Okay. Move on, please? All 24

done? 25Executive Court Reporters (301) 565-0064 189

MS. LEHR: Almost. 1

MR. RABA: Okay. Keep going. 2

MS. LEHR: So after developing CSLs for 3

representative product classes DOE then had to scale 4

these levels to product classes not directly analyzed. 5

To do that DOE needed to develop a relationship 6

between ballasts that operate different numbers of 7

lamps, have different starting methods and have 8

different ballast factors. To develop these scaling 9

factors DOE focused its effort on the large amount of 10

test data obtained for ballasts that operate four-foot 11

medium bi-pin lamps in the commercial sector. 12

Using this data DOE found a strong 13

correlation between BEF and total rated lamp power. 14

DOE used the equation outlined on this slide to scale 15

from ballasts that operate two or four lamps to 16

ballasts that operate one, three, five, or six lamps. 17

DOE also found an average increase in BEF associated 18

with program start ballasts and DOE therefore uses 2.2 19

percent reduction to scale the program start ballasts 20

when necessary. 21

And last, DOE found an average decrease in 22

BEF associated with high or low ballast factor 23

ballasts and therefore DOE use a 3.4 or 1 percent 24

reduction when scaling to high or low ballast factor 25Executive Court Reporters (301) 565-0064 190

product classes. 1

So DOE requests comment on the methodology 2

used to scale the nonrepresentative product classes. 3

MR. RABA: Yes, sir. 4

MR. ERHARDT: Bob Erhardt, Philips Lighting 5

Electronic. We ‟ ve commented a couple times already. 6

We will be supplying data. I have done some analysis 7

and will be providing it in our written response from 8

California Energy Commission data. I do find some 9

minor differences. The averages that I used showed a 10

3 percent difference between instant start and program 11

start rather than the two. The low ballast factor and 12

high ballast or one lamp and the four lamp we found 13

3.5 and 1 instead of 2.2 and 2.2. And we ‟ ll be 14

reporting on this. 15

On this comment again, and maybe I ‟ m 16

misinterpreting it and maybe you can clarify for me 17

because I just asked a question about sample size for 18

T5 HO. I ‟ m reading now from page 5-49, 5.10.1. It 19

says, “For the two lamp, four -foot, mini bi-pin and 20

T5HO normal BF product class designated by product 21

class 44 in Table 5.10.1 hereafter referred to as the 22

four-foot T5 mini bi-pin HO representative product 23

class, DOE chose to analyze one baseline ballast.” 24

What does that mean? 25Executive Court Reporters (301) 565-0064 191

MS. LEHR: That means it selected one 1

baseline for that product class instead of two. So, 2

for example, for the four-foot medium bi-pin product 3

class we chose both a T12 and T8 baseline. And so 4

what that is saying is that there ‟ s just one baseline 5

from which to measure improvements and energy 6

efficiency. 7

MR. ERHARDT: And then what was that three 8

samples of that one model? 9

MS. LEHR: Well, there was additional 10

testing done, but we have one representative unit we 11

are showing for the baseline. 12

MS. GUPTA: Right. Mimi Gupta, Navigant. 13

The baseline -- the purpose of the baseline is to feed 14

that into analyses like the life-cycle cost in NIA 15

where you ‟ re saying, well, what ‟ s the energy 16

consumption of my baseline? What ‟ s the cost of my 17

baseline? And let me compare it to a higher 18

efficiency unit. So in terms of that T5, we took the 19

lowest efficiency T5 we saw during tests and said, 20

that ‟ s our baseline. And then we took the higher 21

efficiency ones to compare against that baseline. 22

MS. LEHR: And in the T5 specifically the 23

baseline is actually magnetic. So that wasn ‟ t a 24

ballast we tested. That was a ballast that we 25Executive Court Reporters (301) 565-0064 192

essentially created to show what could enter the 1

market if standards didn ‟ t exist. 2

MR. RABA: Was that helpful? 3

MR. ERHARDT: Well, I still don ‟ t see 4

anywhere in the report what -- how you developed your 5

CSL numbers. You ‟ ve given some verbal comment, but -- 6

MS. LEHR: I would say in general for the 7

report product classes we had a large number of 8

ballasts that we tested within that product class. 9

And in general the CSLs reflects natural divisions in 10

the test data. So, you know, the three CSLs were 11

four-foot mini bi-pins would reflect three natural 12

divisions in what we observed in the test data. 13

MR. ERHARDT: Okay. All right. I ‟ ll have 14

to look in more detail at the report, I guess. 15

MR. RABA: Okay. Last, go ahead. 16

MR. McGARAGHAN: Mike McGaraghan. I just 17

wanted to ask, and I apologize if this was covered 18

earlier, but did the product classes that you chose as 19

the representative product classes, were those based 20

on market share? 21

MS. LEHR: Right. Shipments. 22

MR. McGARAGHAN: And so all two-lamp and 23

four-lamp fixtures basically the ten product classes 24

that you analyzed were the ten highest shipment 25Executive Court Reporters (301) 565-0064 193

products? 1

MS. LEHR: Correct. 2

MR. McGARAGHAN: Okay. 3

MR. STEPHENS: Charlie Stephens. Was there 4

anything -- did you focus any testing on -- based on 5

where the savings from the standards are? Like the 6

products that will deliver the most savings so that 7

they ‟ re well defined and well tested and well -- and 8

somewhat rigorously analyzed? 9

MS. LEHR: I guess I believe those would be 10

included in the ballasts that we chose to test. We 11

chose ballasts from a range of efficiencies, not just 12

the low end of the market, but also the very high end 13

of the market. 14

MR. STEPHENS: I was just thinking about, 15

more, you know, focused on the stuff that ‟ s not 16

covered right now and that, you know, is -- you 17

focused on -- I know you focused on this heavy 18

shipment stuff which if you set a significant increase 19

in the standard would deliver significant savings, but 20

my concern is that you ‟ ve focused a lot of analysis on 21

something that will maybe increment a standard a tiny 22

bit and deliver a few savings and you may not have 23

rigorously analyzed some of the other product that has 24

much lower shipments but where significant savings are 25Executive Court Reporters (301) 565-0064 194

because -- 1

MS. LEHR: I guess we have testing for, for 2

example, sign ballasts as well, which shipments wise 3

might not have huge shipments, but have some of the 4

largest energy savings of what we ‟ re looking at. So 5

we have testing done for them as well. 6

MR. STEPHENS: Okay. Thank you. 7

MR. RABA: All good. All good. Let ‟ s move 8

on now to the next -- thank you very much Ali. 9

I don ‟ t want to fall too far behind because 10

it ‟ s all good discussion. Good things are bringing 11

out. 12

I think the next thing now is Energy Use and 13

Markup Analysis. And we have Bob Lingard, PNNL, 14

Pacific Northwest National Laboratory. Bob. 15

ENERGY USE AND MARKUP ANALYSIS 16

MR. LINGARD: Thanks, everybody. I ‟ m Bob 17

Lingard with PNNL. 18

I ‟ m going to talk about the energy use 19

characterization and the markup analysis. These form 20

sort of a bridge between the engineering analysis and 21

the economic analyses. The LCC and the NIA analyses 22

that my colleague Gavin McCormick will discuss 23

shortly. 24

So specifically the markup -- the markups 25Executive Court Reporters (301) 565-0064 195

analysis and the energy use examining two basic 1

questions. One, what is the annual energy consumption 2

of our representative systems that we ‟ ve evaluated in 3

the engineering analysis? And, two, what are the 4

typical markups that are applied to the manufacturer 5

selling prices that were also developed in the 6

engineering analysis? 7

Let ‟ s take a look at energy use first. It ‟ s 8

a rather simple equation to get to annual energy 9

consumption. It ‟ s the system input power times the 10

annual operating hours. And we take a look at two 11

different system power ratings in our analyses. I 12

think this will get to an earlier question. One of 13

them is the rated -- the rated system input power. 14

The other one would be the normalized system input 15

power. We ‟ ll take a look at each of these. 16

We have an example table here on this slide. 17

In the fourth column of this table you ‟ ll see what 18

we ‟ re calling the system input power. This would 19

correspond with the measured input power for 20

representative lamp and ballast systems developed in 21

the engineering analysis. 22

Here we have a baseline system and we have 23

an energy efficient substitute. You can see we have 24

different system input powers. The CSL1 uses less 25Executive Court Reporters (301) 565-0064 196

input power than the baseline. And they have 1

different light outputs. 2

The next column over, the system mean lumen 3

or mean light output. Basic criterion that applied to 4

most of the representative lamp and ballast systems 5

evaluated in the engineering analysis was that they 6

had similar light output, generally within about 10 7

percent. Now, there were some exceptions to that, but 8

that was the general rule. 9

So we have two scenarios that we would apply 10

this measured system input power and normalize system 11

input power to. The first would be a replacement 12

scenario. And this is where much like this conference 13

room you have a fixed layout of fixtures in the 14

ceiling. And you don ‟ t have the option of moving 15

fixtures around, so it would be important to you that 16

you have similar light output between a baseline and a 17

substitute system. So therefore again we chose 18

representative systems that generally had light output 19

within 10 percent. In this case we would use the 20

measured system input power. 21

The other scenario we examined in the 22

economic analysis was a new construction renovation 23

type scenario where you ‟ re not married to a fixed 24

lighting layout in the system and you can actually 25Executive Court Reporters (301) 565-0064 197

look at things on an equal lumens basis. So if you 1

look over to the right-hand side of this table you ‟ ll 2

see where we ‟ ve normalized the light output for the 3

baseline system and the substitute system based on the 4

baseline system ‟ s light output and have normalized the 5

system input power. So obviously the story here is 6

for equal lumens the standards system is consuming 7

less or it has a lower input power rating. 8

So those are the two input powers we used 9

for that first part of our annual energy consumption, 10

the system input power. 11

Now, looking to annual operating hours. DOE 12

developed annual operating hours data from a number of 13

DOE surveys, some of which I ‟ m sure you ‟ ll recognize 14

as the lighting market characterization study, the 15

commercial buildings energy consumption, the 16

manufacturer energy consumption and residential energy 17

consumption surveys. The LMC gave us annual operating 18

hours by building type, lamp type, and different 19

applications within these building types. We would 20

marry that with data from the energy consumption 21

surveys, the CBECS, the other energy consumption 22

surveys which basically provide a distribution of U.S. 23

buildings across census divisions in large states. We 24

merged these data types, the operating hours by 25Executive Court Reporters (301) 565-0064 198

building type, lamp type application along with the 1

distribution of building types and this allows us to 2

develop an operating hours distribution by census 3

division and by large states. 4

Now, presented on this slide you see 5

weighted average values and these are what we used in 6

our preliminary analyses. However, as we ‟ ll discuss 7

with the LCC and the NIA, we also have the capability 8

of doing a variability or a Monte Carlo analysis which 9

would allow you to tunnel into the different building 10

types, lamp types, applications represented in this 11

source data. So based on DOE ‟ s analysis of this data, 12

we came up with the following weighted average annual 13

operating hours for different sectors of use, 14

commercial, industrial, and residential. 15

What I would like to bring your attention to 16

on this slide is a subset of the commercial operating 17

hours where for our preliminary analyses we took a 18

look at the impact of lighting controls on operating 19

hours in the commercial sector. Based on our 20

preliminary literature review, we arrived at a value 21

of approximately 30 percent energy savings based on 22

lighting controls. Now, we ‟ ve already heard some 23

examples here today that Susan brought up and Bob 24

echoed as well with the New York Times Building. So 25Executive Court Reporters (301) 565-0064 199

there ‟ s obviously a range of possible energy savings, 1

there ‟ s some exceptional cases such as the New York 2

Times Building with 60 percent-plus energy savings. 3

Based on our literature review we developed 4

a 30 percent energy savings or assumed 30 percent 5

energy savings. And we basically translated this into 6

a 30 percent reduction in operating hours. So that 7

would explain the difference you see in the 3400 hours 8

and the approximately 2400 hours you see for program 9

start ballasts on occupancy sensors. And that leaves 10

the remaining operating hours for industrial and 11

residential. 12

This leads us to a couple of requests for 13

comments. For issue number 11, we would seek your 14

comments, no only the basis and the assignment of 15

these end-user profiles which are detailed in 16

considerable detail in the TSD. And in a related 17

issue we also invite comments on the use of lighting 18

controls. And that has been a conversation topic 19

today and would certainly welcome your input on the 20

scale and the timing of penetration of lighting 21

controls and their effects on annual operating hours. 22

MR. ERHARDT: Bob Erhardt, Philips Lighting 23

Electronics. The NEMA discussion on this, our 24

consensus was we have no objection. We have no better 25Executive Court Reporters (301) 565-0064 200

analysis than what you ‟ ve proposed. We think it ‟ s 1

reasonable. 2

MR. deLASKI: Andrew deLaski. The biggest 3

savings when you get to the NIA are in the sign 4

ballasts. What did you use for hours -- operating 5

hours on the sign ballasts? 6

MR. LINGARD: We ran both the commercial and 7

the industrial scenarios and my colleague Gavin will 8

detail that in the discussion of the NIA, recognizing 9

that they would occur in -- that they could possibly 10

occur in those two sectors. 11

MR. deLASKI: So you did some weighted 12

average, we ‟ ll get to that, I guess, but you did some 13

weighted average. 14

MR. RABA: And NIA is National Impact 15

Analysis? 16

MR. LINGARD: You ‟ re correct, sir. 17

MR. RABA: Okay. Thank you. Further? 18

(No response.) 19

MR. RABA: Wow, that was good. Keep going. 20

MR. LINGARD: Next, to speak about our 21

markups analysis. This is where we bridge the 22

manufacturers ‟ selling price with an assumed or an 23

estimated end-user ballast prices. And there has been 24

some discussion of the manufacturer markups. We ‟ re 25Executive Court Reporters (301) 565-0064 201

going to focus here on the distribution chain. This 1

happens after the manufacturer lets the ballast go. 2

You ‟ ll see a diagram on the left representing two 3

potential distribution chains for fluorescent lamp 4

ballasts. One being for fixture ballasts, the other 5

being for replacement ballasts. The main distinction 6

being that the fixture ballast distribution chain will 7

involve an OEM fixture manufacturer. So basically add 8

another step and another markup. 9

We looked at distribution channel 10

percentages for our preliminary analyses we based on a 11

breakdown used also in the 2000 ballast rule. As 12

you ‟ ll see, we ‟ re assuming approximately 63 percent 13

through the OEM distribution chain and 37 percent 14

through the wholesaler chain. The actual markups were 15

based upon an evaluation of publicly available SEC 16

Form 10K data. This is a pretty standard method for 17

evaluating financial data for publicly traded 18

companies. Such variables as net sales, cost of 19

sales, gross profit. 20

A small version of this analysis was done to 21

develop the manufacturer markup for the manufacturer 22

selling price. Based on that analysis, what you might 23

find of interest is the markups for the OEM 24

manufacturer are 1.51. I believe that ‟ s pretty 25Executive Court Reporters (301) 565-0064 202

similar to what was found for the ballast 1

manufacturers, somewhere around 1.5 and then as you go 2

down the distribution chain through electrical 3

wholesalers lower values approximately 1.4 for the 4

electrical wholesalers and a standard assumed value of 5

1.13 for electrical contractors. And you ‟ ll see 6

baseline and incremental markups. The baseline, being 7

basically a manufacturer -- a multiplier to take you 8

from the manufacturers ‟ selling price to the end user 9

selling price for a baseline product. The incremental 10

as it relates to higher efficiency products is 11

generally lower because it ‟ s assumed certainly within 12

the distribution chain that fixed costs such as labor 13

and occupancy would not change significantly between 14

efficiency levels that the labor required to 15

distribute an energy-efficient ballast would be 16

similar to that for a baseline ballast. So as you 17

would expect, these incremental markups are slightly 18

lower. 19

And the sales tax was based on a survey of 20

national and local and state sales taxes weighted by 21

census data. So this is basically a weighted national 22

average. But we also have this data on a state-by23

state and a census division level for use in more 24

detailed variability analyses. 25Executive Court Reporters (301) 565-0064 203

And that finally resulted in the weighted 1

overall baselines markup and the weighted incremental 2

markup that you see at the bottom of that table. And, 3

again this flows into our LCC and our NIA analyses. 4

And as we kind of previewed, as Bob Erhardt 5

indicated earlier, NEMA is going to try to provide 6

more detailed sanitized manufacturer price data. We 7

would also seek input on typical distribution chain 8

markups as well as detailed pricing data. You ‟ re 9

going to hear this echoed in our economic analyses 10

discussion particularly with shipments any detailed 11

data that you can supply will help us further refine 12

our preliminary analyses as we head into the NOPR 13

phase. 14

So, with that I ‟ ll open the floor for issue 15

13. 16

MR. RABA: Are there any confidentiality 17

agreements on that last statement? 18

MR. LINGARD: Very good question. We do 19

currently have a confidentiality agreement in place 20

with NEMA and there were some obstacles leading up to 21

this. But we would like to continue that discussion 22

and see if we -- actually it was in place for 23

shipments data. I ‟ m getting ahead of myself. 24

So to your point with the price data, we ‟ ll 25Executive Court Reporters (301) 565-0064 204

certainly welcome that to help us validate pricing 1

assumptions and markup assumptions. 2

MR. ERHARDT: Bob Erhardt. Philips Lighting 3

Electronics. Are you indicating that we could have a 4

confidentiality on price as well? 5

MR. LINGARD: I would need to get back to 6

you on that. I was -- my head jumped ahead to 7

shipments and I was -- and my mouth was saying 8

pricing. So I ‟ ll get back to you on that. 9

MS. LEHR: Hello? 10

MR. RABA: Hello. Go. 11

MS. LEHR: Just in terms of the manufacturer 12

selling price data that you referenced back, as much 13

data as you can give in the public sector would be 14

helpful because then we can actually use that data in 15

our analysis. In terms of confidential data we ‟ re 16

willing to take whatever data you have is great. 17

MR. ERHARDT: Yeah, this is Bob Erhardt. 18

We ‟ ve discussed -- we ‟ ve put out a solicitation for 19

the data to the manufacturers. What we are suggesting 20

that we supply is without giving the absolute levels 21

that we give you the incremental. And that can help. 22

We thought that ‟ s what you would need for the payback 23

analysis. So that ‟ s what we ‟ re attempting to pull 24

together. 25Executive Court Reporters (301) 565-0064 205

MR. RABA: Okay. Susan. 1

MS. ANDERSON: Susan Anderson, Osram 2

Sylvania. Something that we also discussed in looking 3

at the wholesalers -- electrical wholesalers, very few 4

of them are publicly traded companies. So you find 5

very little of the SEC formed data out there for the 6

majority of the electrical wholesale distributors. 7

And when we did look up -- looked on line to see what 8

we could find, for instance, we looked at Westco, 9

that ‟ s one that I looked at, and they appeared to be 10

one of the ones that was included in the analysis 11

based on their percentage. But the market was across 12

all their product lines. They had absolutely nothing 13

specific to lighting much less to ballasts. 14

MR. LINGARD: You ‟ re correct. 15

MS. ANDERSON: So it could be very 16

misleading information. And our suggestion was that 17

you go to the National Association of Electrical 18

Distributors and see if through some of their members 19

you could get some more accurate information in terms 20

of wholesaler markups. 21

MR. LINGARD: Thank you. That ‟ s excellent - 22

- excellent suggestion. 23

MR. RABA: Thank you. More on this? 24

MR. HAKKARAINEN: Can I go back to issue 12? 25Executive Court Reporters (301) 565-0064 206

MR. RABA: Quickly. 1

MR. HAKKARAINEN: Quickly. 2

MR. RABA: Quickly. Thank you. 3

MR. HAKKARAINEN: Pekka Hakkarainen, Lutron. 4

Bob, on the issue of use of lighting controls, there 5

is some data available that I ‟ m aware of for 6

commercial buildings on energy savings. And 7

specifically to the use of occupancy centers that you 8

cited in the previously slide, we have reports that 9

indicate savings anywhere between 17 to 60 percent on 10

occupancy centers depending on the application in 11

commercial buildings. So your 30 percent sounds 12

reasonable as an average. 13

As an industry I need to comment that we 14

have -- you ‟ re asking for the residential sector, we 15

don ‟ t have good data for the energy savings data 16

currently. We are trying to develop it in residential 17

applications. 18

MR. LINGARD: We would welcome that input. 19

Certainly we were focused on the commercial sector at 20

this point. 21

MR. RABA: That was very helpful. Thank you 22

very much. 23

Anything further? 24

MR. deLASKI: Just a little follow-on. 25Executive Court Reporters (301) 565-0064 207

Andrew deLaski. 1

You know, I agree it would be great to go to 2

get additional data from the manufacturer or from the 3

wholesalers. Public data is best, obviously. We like 4

the SEC data because it ‟ s been filed with the SEC and 5

it ‟ s on public record and I guess folks do lie to the 6

SEC sometimes, but we hope they don ‟ t. And I think 7

it ‟ s good solid data in which to work the analysis. 8

So to the extent that we get concerned about data 9

that ‟ s black-boxed to stakeholders other than those 10

who actually have submitted it. So, we want to urge 11

you to try to get that data out on the record as you 12

have. 13

MR. RABA: SEC is Security and Exchange 14

Commission? 15

MR. LINGARD: Yes, sir. 16

MR. deLASKI: Think so. 17

MR. RABA: Okay. Great. Thank you. 18

Last call? 19

(No response.) 20

MR. RABA: Well, good discussion, good give 21

and take, good back and forth. Let ‟ s take a break, 22

please. We are running a little behind now. So we ‟ re 23

going to speed up a little bit more. But keep your 24

comments coming, they ‟ re very good. 25Executive Court Reporters (301) 565-0064 208

We ‟ re going to be back at a quarter past 1

three, by that clock. Let ‟ s see, my watch is 2

different. Fifteen minutes, Linda? Is that enough, 3

too much? Fifteen minutes. 4

(Brief recess taken at 3:04 p.m.) 5

MR. RABA: Okay. Let ‟ s get started. Thank 6

you. The fun is over. 7

You should find two things at your place, 8

one the evaluation sheet, pull out -- the Department 9

is most interested in your comments about today ‟ s 10

public meeting and also you should each have a copy of 11

the attendance here by business card or otherwise. 12

You didn ‟ t hear that? I ‟ ll repeat. 13

Thanks for coming back from break. We have 14

a lot to cover yet this afternoon. You ‟ ll find at 15

your places a comment sheet. You know, what can I 16

say, they call me a lot of things, but lower the 17

volume, I never heard, thank you very much. 18

And also you ‟ ll find, and hopefully if don ‟ t 19

let me know. We ‟ ll give you this attendance record 20

here for everyone who is in the room to identify. 21

Okay. 22

Let ‟ s move on now. 23

Our next presentation coming up is about the 24

life cycle cost and payback with Gavin McCormick, 25Executive Court Reporters (301) 565-0064 209

PNNL. Gavin. 1

LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSIS 2

MR. McCORMICK: Yes, I ‟ m Gavin McCormick 3

from PNNL here to present some of the economic 4

chapters today starting with the life-cycle cost and 5

payback period analysis. So the LCC and payback 6

period analyses are two different ways of combining 7

the information from the markups and energy use 8

characterization sections. And essentially what they 9

both do is take a look at the first costs of a more 10

efficient unit coming out of the markups section and 11

combine that with the cost over time coming out of the 12

energy use time characterization. More energy use at 13

a given price is of course the major component of cost 14

over time. 15

The economic evaluation in the LCC and 16

payback period analysis both take place from the point 17

of view of a single consumer. Later the national 18

impact analysis will take place from the point of view 19

of all consumers in America. And, again, there are 20

two different ways of calculating the same 21

information. So, the lifecycle cost analysis is 22

essentially the sum of all costs that a ballast 23

consumer would pay over the life of one ballast. And 24

the key input or the key output, excuse me, of that, 25Executive Court Reporters (301) 565-0064 210

is the lifecycle cost savings that you might or might 1

not experience between a base case and standards case 2

ballast. 3

The way that the LCC is calculated is a 4

fairly straightforward input. You sum up the costs in 5

each year in the base and standards case for costs 6

that occur in the future, you convert them to present 7

value at a discount rate. I ‟ ll cover that more in a 8

moment. And then you simply subtract the difference 9

between the base and standards cases. 10

The payback period analysis is only slightly 11

more complicated. It ‟ s essentially dividing the first 12

cost of the more efficient unit into the operating 13

costs. And both of those, excuse me, are the delta 14

between the base case and the standards case. So 15

classic example in the payback period would be if you 16

spend 50 extra dollars to buy a more efficient ballast 17

and it saves you $10 a year, the payback period is 50 18

over 10 or five years. 19

The payback period that we use in this 20

analysis is known as a simple payback period because 21

it does not take into account a discount rate. So you 22

could imagine other ways to calculate it, but this is 23

simply the increasing costs divided by essentially a 24

single year ‟ s operating cost change. And both of 25Executive Court Reporters (301) 565-0064 211

these are just two different ways of getting at the 1

same problem which is if in the typical situation a 2

more efficient unit costs more money initially, but 3

costs less money over time, is that or is that not a 4

good deal for a consumer? And you can imagine 5

different ways to answer that question. That ‟ s why we 6

have two independent analyses on the same subject. 7

So, the most important input probably to the 8

LCC and payback period analysis are electricity 9

consumption. And we get the energy use straight from 10

the energy use characterization so that ‟ s nothing 11

novel there. But then electricity prices are a very 12

important section here. DOE actually calculates 13

electricity prices for this purpose by combining two 14

different sources of estimates. 15

The first is EIA, Energy Information 16

Administration form 861 data and that essentially is a 17

record of prices that people have actually paid in 18

different sectors in different states in recent 19

record. So we go back 12 months and we combine the 20

most recent form 861 data. 21

You can see in this slide here we, for the 22

preliminary analysis actually just stuck with the 2007 23

form 861 data. We will update that to the very most 24

recent available 12 months of most recent information 25Executive Court Reporters (301) 565-0064 212

for the next stage and for the final rule. 1

So that very precise high detail data from 2

recent historical information is then combined with 3

estimates of growth in electricity prices over time. 4

And for that we turn to EIA ‟ s Annual Energy Outlook 5

which is one of the more sophisticated models of the 6

entire U.S. energy economy over the next 30-year 7

period. And the reason that we do this combination is 8

that the form 861 data can be pulled very, very high 9

detail and very recent information. But the annual 10

energy outlet numbers from NEMs are typically more, 11

rather are the only source for long-run energy 12

estimates. So what we do is we take the recent 13

electricity prices by state and grow them by the 14

percentage growth rates coming out of the AEO. 15

Once we have electricity prices another 16

important cost input to the LCC and payback periods 17

are insulation costs. And we actually just calculate 18

those at the moment in the same way as the 2000 19

ballast rule and the 2009 lamps rule. Those are based 20

on that information as well as RS means and labor 21

statistics data. And the basic method for that is 22

that we find a certain number of minutes that it takes 23

to relamp a ballast and lamp system or to actually 24

swap out the ballast and lamp and add up the cost of 25Executive Court Reporters (301) 565-0064 213

so and so many minutes of time for an electrician and 1

one electrician ‟ s assistant. 2

The ballast lifetime is another very 3

important input to the LCC. And actually even more so 4

later to the shipments analysis. As I ‟ ll cover in a 5

minute. 6

The ballast lifetime information that we are 7

using is the same as the 2000 ballast rule and the 8

2009 lamps rule. So we have not found a reason to 9

change that information. But we did independently 10

rederive it. And one interesting result is that 11

because of the much longer operating hours in the 12

industrial sector that my colleague Bog Lingard had 13

mentioned in the energy use characterization, because 14

of that many more hours per year, although you can see 15

the commercial and industrial sectors, both share a 16

large number of hours lifetime. You do not actually 17

see that the commercial and industrial have the 18

longest lifetimes in terms of years. Because you ‟ re 19

using the lamps in the industrial sector much more 20

intensively. So they last more hours, but that 21

translates into fewer years. And the reverse is true 22

in the residential sector. The lamps actually are not 23

typical -- I keep saying lamps, excuse me, that ‟ s not 24

right. The ballasts have shorter lifetimes in the 25Executive Court Reporters (301) 565-0064 214

residential sector, but actually end up lasting more 1

years because in the residential sector you typically 2

use your lamps and your ballasts for fewer hours in a 3

year. They ‟ re off a lot more. 4

One important thing that we do with our 5

lifetimes is that we have a fairly narrow band of 6

assumed lifetimes. One could imagine great variation 7

in ballast lifetimes. And we have a pretty narrow set 8

of assumptions that we have found around these average 9

ballast lifetimes. So something that we are looking 10

into and would be interested in input on is sources of 11

variation in estimates of ballast lifetimes. 12

But, for the most part, we are assuming that 13

all ballasts last either the average lifetime, one 14

year or two years less than that. We don ‟ t have 15

variation of ballasts lasting two years or 30 years. 16

Another very important source of input data 17

for the LCC and PBP analyses are the discount rates. 18

There are different ways to trade off current money 19

for money in the future. And the form of discount 20

rate that DOE uses in the LCC and PBP analyses is the 21

actual rate at which you could trade money now for 22

money later. So, for the commercial and industrial 23

sector, that comes to the weighted cover cost of 24

capital which is to say, a company that actually had a 25Executive Court Reporters (301) 565-0064 215

million dollars at the moment could trade that for, 1

for example, $1,700,000 next year based on the 2

interest rates that they are currently paying and 3

receiving on their own money. 4

So this is different from placing less value 5

on the future. This is a discount rate which is your 6

actual ability to trade money intertemporally. 7

And in the residential sector, the way we 8

make an analogous calculation is by looking at the 9

sources of money that residential consumers have both 10

that they are borrowing from and lending to. So, for 11

example, we have credit card rates and mortgage rates 12

which have particular rates of interest. And we look 13

at the share of money that your average residential 14

consumer has in different sources of income and 15

savings and we calculate an average rate that they are 16

either saving or spending on interest. 17

So why are we doing this? This is all a 18

calculation that lets us know, what is the rate at 19

which consumers are currently trading money now for 20

money later. This is a good way to determine the 21

tradeoff between operating cost savings that occur in 22

the future and increased costs that occur in the 23

present. 24

I ‟ m seeing a confused look or two. Should I 25Executive Court Reporters (301) 565-0064 216

clarify something there? 1

(Simultaneous conversation.) 2

(Off microphone.) 3

PARTICIPANT: Well, I ‟ ll take 1.7 million 4

next year if you ‟ re going to give it to me. 5

(Laughter.) 6

MR. McCORMICK: I meant to say 1.07. I 7

apologize, yes. 8

(Laughter.) 9

MR. McCORMICK: Thank you for clarifying 10

that. So, the key to this section is very much the 11

methodology, but I ‟ m going to present three different 12

results and these are cherry picked to show the three 13

different sorts of outcomes we can have here. And the 14

results you actually see here have been updated. So 15

if you ‟ re going to start looking at the precise 16

numbers, you ‟ ll want to look at the handout you 17

received today. Don ‟ t have a copy in front of me. 18

So a couple of the lifecycle cost numbers 19

turned out to have just a cell reference error in the 20

EXCEL spreadsheet that was calculating them. And so 21

you can see if you ‟ re going to follow the exact 22

details here, an updated table for the life cycle cost 23

information has been provided to you in today ‟ s 24

handout. And that will all be available in the 25Executive Court Reporters (301) 565-0064 217

technical support document. 1

MR. deLASKI: And just to follow-up, you ‟ re 2

going to post a new revised chapter to the TSD, or 3

what ‟ s going to happen? So we know when to look and 4

what to look for. 5

MR. McCORMICK: Right. I believe actually 6

the answer to that is for the NOPR stage we ‟ ll be 7

publishing the latest numbers. 8

Did you have something to say, Bob? 9

MR. RABA: That last question was from 10

Andrew deLaski. 11

Go ahead Bob Lingard. 12

MR. LINGARD: This is Bob Lingard with PNNL. 13

The answer to your question is, yes. We ‟ ll have 14

revised TSD materials posted shortly that correspond 15

with these revised materials you have in hard copy 16

today. 17

MR. McCORMICK: And as long as we ‟ re on that 18

subject although it ‟ s a different chapter, one of the 19

tables in the executive summary to deal with the 20

national impact analysis results disagreed with the 21

equivalent table in Chapter 10 and the Chapter 10 22

table was correct. And we are updating the executive 23

summary table to all agree. And that will happen in 24

the same document. 25Executive Court Reporters (301) 565-0064 218

MR. deLASKI: If I could just request -- 1

MR. McCORMICK: Uh-huh. 2

MR. deLASKI: -- this is Andrew deLaski -- 3

when you do that, can you somehow just mark that as 4

“revised” because those of us who downloaded the prior 5

one, you know, it would be helpful to track, this 6

thing has been changed. And I would even request that 7

if you could e-mail your list to let us know when 8

you ‟ ve done it that way we know to go check that the 9

document has been revised. The LCC chapter is a 10

critical chapter for those of us. 11

MR. McCORMICK: Certainly. I ‟ m seeing some 12

nods that that ‟ s doable. So, great. 13

Yes, apologies for that and that is just a 14

simple cell reference error in the EXCEL spreadsheet 15

unfortunately. But the methodology is unchanged. And 16

the key result that I am focusing on here are the 17

three possible outcomes of an LCC analysis. So in the 18

top bullet what we are seeing is the sort of standard 19

expected outcome from more efficient equipment that 20

the installed cost, the installed price of the 21

equipment is higher as the efficiency increases. So 22

as you go from the baseline or CSL0/1 row on this 23

table here, to higher CSLs your efficiency is 24

increasing and the installed price is increasing. So 25Executive Court Reporters (301) 565-0064 219

this is a very common and expected result. 1

The flip side of that is that the operating 2

costs are decreasing. So we have here operating cost 3

savings. They ‟ re marked in dollars and they should 4

actually be marked in dollars per year. The operating 5

cost savings also will increase although not 6

necessarily monotonically. So you ‟ re going to see 7

lower operating costs with more efficient equipment is 8

a typical outcome. It ‟ s not a necessary outcome as 9

I ‟ ll explain in a moment. 10

But a typical outcome of an LCC analysis or 11

a PBP analysis is that you have higher installed 12

costs, lower operating costs, and you can determine 13

the number of years for your PBP that it would take to 14

earn the money back that you spent in the first year. 15

And it may or may not be depending on the discount 16

that you use that you ultimately have lifecycle cost 17

savings. You could imagine a case where the installed 18

cost is so much higher that you never end up making 19

your money back. And you could imagine other cases 20

where you make quite a bit of money back from the 21

savings. 22

So that is the most standard case. We also 23

encountered the sort of two less likely cases. And we 24

encountered both of them in our preliminary results 25Executive Court Reporters (301) 565-0064 220

for this rule which is quite interesting. 1

On the lower half of this same slide, you 2

see a result of negative payback period of values. 3

And that is the result that we ‟ ve already heard NEMA 4

refer to today in which the installed price is lower 5

for more efficient equipment. So this is certainly 6

not theoretically impossible, but it ‟ s considered 7

pretty unusual. And so we ‟ ve already heard comments 8

that it will be helpful to get more access to cost 9

data to confirm, validate or possibly reexamine these 10

outputs. So in this case what we are seeing is the 11

installed price is going down as the ballasts become 12

more efficient, which, if true, is fantastic. And if 13

untrue needs to be reexamined. 14

And then -- 15

MR. deLASKI: Just a follow-up question. Do 16

you know what ‟ s going on there? What ‟ s happening in 17

the engineering? 18

MR. McCORMICK: Uh-huh. I actually don ‟ t. 19

I ‟ m an economist by training. I believe that -- I ‟ m 20

going to not answer that question. Is there someone 21

else who could jump in there? 22

MS. GUPTA: This is Mimi Gupta from Navigant 23

Consulting. That ‟ s just the outputs from the 24

teardown. We looked at the teardown results trying to 25Executive Court Reporters (301) 565-0064 221

locate exactly which part of the components or which 1

components might be more expensive, but we couldn ‟ t 2

find any trends in terms of what makes that -- I mean, 3

so for the T12 baseline we found in retail prices that 4

the T12s are actually more expensive than T8s being 5

sold. So that part is consistent in terms of the fact 6

that, no, maybe a CSL2 T8 is less expensive than a 7

CSL1 T8, that ‟ s just the result of the teardown. And, 8

you know, we were hoping to get some input from 9

manufacturers on why -- why those results came out and 10

I think hopefully we ‟ ll get some data. 11

MR. deLASKI: Okay. Thanks. 12

MR. McCORMICK: I would agree. And then an 13

additional comment on that is that if this is the case 14

you would expect to see that the market would 15

gradually shift away from the baseline technology in 16

this case, not necessarily instantaneously, but that 17

would be the direction. And that ‟ s exactly the 18

assumption that we make in the shipments analysis, 19

that although it would not happen instantaneously or 20

completely, even in the base case with no regulation, 21

the market would tend to shift away from this baseline 22

equipment because from purely cost perspective there 23

is no upside of this type of equipment given the 24

assumptions that feed into this model. 25Executive Court Reporters (301) 565-0064 222

We also saw the third possible case of a 1

payback period or LCC analysis in which the operating 2

cost does not decrease with increased efficiency. And 3

so in this case you pay a higher installed price for 4

more efficient equipment and never earn your money 5

back. So the payback periods are effectively 6

infinite. And it ‟ s worth pointing out that the only 7

case in which we saw this is a fairly particular case. 8

This is the case in which more efficient ballasts lead 9

to many more lumens. So if you are seeing a ballast 10

that produces quite a bit more light given the 11

appropriate lamps, you could imagine that you are more 12

efficiently producing more light but that actually 13

means that you are using slightly more power. 14

And so in this case we have the two 15

different purchasing events that you can imagine. My 16

colleague Bob Lingard spoke already about normalizing 17

costs and in a case where you can normalize the lumens 18

and the costs. So for example, in new construction if 19

a ballast produces 50 percent more light, you could 20

have fewer of those ballasts. And recoup your costs. 21

But, for example, if we were to try to retrofit this 22

room with more efficient ballasts, you wouldn ‟ t 23

necessarily reduce the number of lamps that you were 24

using and so you might end up using more energy, but 25Executive Court Reporters (301) 565-0064 223

having a much brighter room. And that ‟ s the case in 1

which we see higher operating costs. And from a cost 2

alone perspective never getting sort of your 3

additional price back. 4

And so -- were there any questions on that 5

before I proceed? 6

(No response.) 7

MR. McCORMICK: Great. Issue number 14 has 8

to do with demand load profiles and peak shaving. The 9

costs that I have spoken to you about so far are all 10

using average electricity prices over the course of a 11

year. But you could imagine that lamps are used at 12

particular times of day in which electricity prices 13

have particular patterns, or that there are impacts on 14

market electricity prices from the savings of more 15

efficient ballasts. And DOE is interested in any 16

comments that stakeholders might have on this effect. 17

MR. RABA: Comments on load profiles or 18

demand? 19

(No response.) 20

MR. RABA: No comments? 21

Okay. That ‟ s good. We have one from Mike, 22

please? 23

MR. McGARAGHAN: This is Mike and I actually 24

did want to go back to the last slide. And wondered 25Executive Court Reporters (301) 565-0064 224

if we could just get a little more information perhaps 1

from your engineering team on this retrofit and are 2

they -- have they determined that it ‟ s impossible to 3

maintain light level in certain situations or just 4

likely that there will be an increase in light level? 5

Provide a little more detail, please? 6

MS. LEHR: This is Ali from Navigant. This 7

product class in particular was pretty difficult. 8

This is four-foot medium bi-pin lamps in the 9

residential sector. And the reason you ‟ re seeing the 10

difference in light level was because we found 11

significant differences in ballast factor. And it ‟ s 12

also difficult to try and figure out what correct 13

representative units to use because the majority of 14

ballasts in the residential sector are shipped already 15

in fixtures. And a lot of these come from offshore 16

suppliers and it ‟ s been very hard to find catalogue 17

information about these ballasts and to figure out 18

which ones are truly the most popular representative 19

units to use because I guess we don ‟ t have 20

accompanying fixture information right now. And if 21

you have any suggestions about how to remedy that 22

problem we would welcome any suggestions. 23

MS. ANDERSON: Yeah, I think here the real 24

question is, are there going to be equal lumen 25Executive Court Reporters (301) 565-0064 225

replacements available? I think when we looked on the 1

market we didn ‟ t find that. We found, you know, 2

varying ballast factors with differences in efficiency 3

that resulted in engineering analysis in which, you 4

know, we got different lumen outputs. So is this 5

something, you know, should we expect given -- if 6

these products were regulated that manufacturers would 7

start to develop products that maintain lumen output 8

with a higher efficiency and that ‟ s just not what we 9

see on the market right now. 10

MR. RABA: I saw Charlie up first and Bob. 11

MR. STEPHENS: Charlie Stevens. As I look 12

at the residential stuff here, it occurred to me that 13

I hadn ‟ t heard anything earlier or I didn ‟ t notice 14

earlier that there ‟ s nothing in the markup analysis 15

about the residential channel. So I ‟ m kind of 16

wondering where the numbers are coming from for the 17

purchase price and everything here especially since as 18

absurd as it sounds, Home Depot and Lowe ‟ s have 50 19

percent or more of the home improvement retail market 20

combined and so they have a pretty big influence over 21

this thing. And I ‟ m not sure the notion of 22

replacement versus new is as relevant there when in 23

the residential market. 24

I mean, I ‟ m not sure too many people will 25Executive Court Reporters (301) 565-0064 226

replace the ballast. I think they tend to just 1

replace the whole fixture. And, again, 50 percent of 2

them or more, probably come from Home Depot and 3

Lowe ‟ s. And so I ‟ m kind of trying to figure out how I 4

should be understanding your analysis here in that 5

context. 6

MR. LINGARD: This is Bob Lingard with PNNL. 7

You ‟ re correct that we didn ‟ t break out a separate 8

distribution chain for residential products in the 9

preliminary analysis. I think probably the closest 10

fit we have at this point is that distribution chain 11

that includes the one on the right, the replacement 12

ballast market versus the OEM distribution chain. 13

Looking at the publicly available finance 14

data we did -- I think we did have at least one big 15

box retailer in that. But to your point, no, we 16

didn ‟ t specifically contemplate that. But that 17

replacement ballast distribution chain is, at least 18

for the preliminary analysis, the closest we came to 19

addressing your particular question. 20

MR. RABA: Bob? 21

MR. ERHARDT: Bob Erhardt, Philips Lighting 22

Electronics. I did look at your analysis of 23

residential and the reason the numbers come out like 24

this was the electromagnetic product has a .58 ballast 25Executive Court Reporters (301) 565-0064 227

factor. And if you ‟ re running an instant start T8 you 1

can ‟ t run that low, the lamp life will just take a 2

nosedive. And so if you ‟ re talking about -- and that 3

is the -- the typical low-cost electronic replacement 4

for a residential. I did see a comment in there 5

though where they thought that you could change 6

luminaire spacings in a residential to utilize the 7

extra lumen output and I highly question that because 8

I think you have one luminaire in your kitchen and 9

you ‟ re not changing spacings or you have one luminaire 10

over your work bench or in your garage and so I don ‟ t 11

know that you ‟ re going to make up that -- you ‟ re going 12

to come up with anything other than more light output. 13

If you go to a -- you know, if you go to a 14

rapid start electronic for the residential market, 15

then you open up some possibility of lower ballast 16

factor product. 17

MR. RABA: Thank you. 18

Okay. Anything on the forecasting part? 19

Mike, have something? 20

MR. McGARAGHAN: I just wanted to clarify. 21

You ‟ re saying that the ballast factor that would be 22

needed to maintain that light level with a T8 system 23

is too low to operate on? 24

MR. ERHARDT: Certainly too low for instant 25Executive Court Reporters (301) 565-0064 228

start. 1

MR. McGARAGHAN: Thank you. 2

MR. RABA: Yes. 3

MS. ANDERSON: Or you could sell dimming 4

ballasts. 5

(Laughter.) 6

MR. RABA: Susan. Okay. 7

Comment, Joanna? 8

MS. MAUER: Joanna Mauer. I had a question 9

on table 8.5.6 which is the eight-foot RDC high output 10

product class with a T12 baseline. I was just 11

confused. It looks like there are two different CSL1 12

levels, one with a BEF of 0.5 and one with a BEF of 13

0.55. 14

MR. RABA: Which slide was that, please? 15

MS. MAUER: It ‟ s actually -- it ‟ s not in the 16

slides, it ‟ s in the updated LCC tables that we were 17

given this morning. 18

MR. RABA: Okay. Thank you. 19

MR. McCORMICK: Yes. And so if you look 20

through those tables you ‟ ll actually see several 21

different product classes in which there is more than 22

one CSL0 or more than one CSL1. When there ‟ s more 23

than one CSL0, it ‟ s a fairly straightforward case that 24

you have different baselines that you might be 25Executive Court Reporters (301) 565-0064 229

considering. So from certain kinds of T12 and certain 1

kinds of T8 ballasts you can actually imagine 2

upgrading into the same more efficient equipment. 3

For the case that you ‟ re referring to in 4

which there ‟ s more than one CSL1, I believe that is 5

due to an expected change in the T12 market. But I 6

would want to get back to you with the specifics on 7

that. I think that DOE will have write a written 8

response to that. 9

MS. ANDERSON: And just a follow-up question 10

also. CSL2 has a slightly lower BEF than CSL1 so 11

CSL2 ‟ s BEF was 0.549 and then one of the CSL1 ‟ s is 12

0.55, so I was just confused about that as well. 13

MS. GUPTA: I think I can respond to that. 14

That ‟ s coming out of the engineering. This is Mimi 15

Gupta from Navigant. So, yeah, I think that eight16

foot high output product class as Ali mentioned 17

earlier this morning is one of those that we ‟ ve 18

identified for further testing. 19

We didn ‟ t have test data for all of those 20

ballasts that have been indicated. Actually the only 21

one that was actually tested was the CSL2 ballast. 22

And the reason why you have this interesting behavior 23

is that the CSL2 ballast actually had a catalogue 24

efficiency of .560. And when it was tested, it was 25Executive Court Reporters (301) 565-0064 230

tested at .549. So the expectation and hopefully will 1

be validated through further testing is that, you 2

know, when analyzing a .55 which is a catalogue BEF, 3

so that also should have been, I think probably 4

detailed a little better. But that BEF will also be 5

lowered. So, we look forward to seeing the results of 6

that analysis. 7

Any -- 8

MR. ERHARDT: Bob Erhardt, Philips Lighting 9

Electronics. Just, again, I made a comment to begin 10

with on the eight-foot HO and you do have here that 11

the mean lumen output is lower. And when you look at 12

system efficacy, a T12 with a -- I forgot what my 13

numbers were, but something like a BEF of .52 has a 14

higher system efficacy than a T8 with a .55. And if 15

you ‟ re talking -- especially if you ‟ re talking about 16

replacement market, if you have a shop -- a small 17

business that is running T12s, if he started with 110 18

watt T12s and went to 86 ‟ s he already took a small cut 19

in light output. Are you justified in cutting his 20

light output for his workspace? And so I think you 21

should take into consideration a 13 percent higher 22

lumen output of the T12 lamps or the T8 in that case. 23

MR. RABA: Thank you. 24

Nothing further, I presume on the methods 25Executive Court Reporters (301) 565-0064 231

and other data sources. Can we go on to the next 1

discussion question the general trend to smaller 2

fixtures? And ballast enclosures at issue? 3

MR. McCORMICK: Fifteen. 4

MR. RABA: Okay. 5

MR. McCORMICK: Yes. So issue 15 revolves 6

around the comments that we have heard, that more 7

efficient ballasts may operate at a cooler temperature 8

and therefore have longer lifetimes. And for the 9

preliminary analysis what DOE assumed is that given 10

the general trend towards smaller fixtures, the 11

operating temperature would not fall by as much as you 12

would expect. The smaller unit is roughly assumed to 13

be offsetting the slightly lower heat output giving 14

similar temperatures and therefore no particular 15

change in lifetimes with more efficient units. And we 16

would request any input on this assumption. 17

MR. ERHARDT: Bob Erhardt, Philips Lighting 18

Electronics. In our NEMA discussions we agree with 19

Navigant ‟ s conclusion that you ‟ re not going to see 20

appreciably better lifetime because exactly is what 21

you say, there ‟ s miniaturization in the luminaire 22

field to take advantage of the smaller ballasts and if 23

anything we are constantly being asked to operate at 24

higher temperatures. Our hotspot temperature 25Executive Court Reporters (301) 565-0064 232

specification has traditionally been 70C or so and now 1

they ‟ re asking for 80C and 90C hotspot temperatures. 2

So we agree with your conclusion. 3

MR. RABA: Great. Shall we move on then? 4

One more from Andrew deLaski. 5

MR. deLASKI: So this is a question on the 6

LCCs the part that you haven ‟ t shown today. And I 7

want to focus in a little bit on the products where 8

the savings are the greatest, you know, in the docket. 9

And I ‟ m looking at the sign ballasts, you know, which 10

based on the Department ‟ s preliminary analysis the 11

potential savings are over three quads. So it ‟ s huge. 12

It ‟ s a rulemaking unto itself in terms of looking at 13

other opportunities for the Department and for energy 14

savings. 15

So I ‟ m curious if somebody questioned from 16

industry the Department is showing savings on the 17

order of a third on those products. 18

MR. RABA: Where is that coming from, 19

please? 20

MR. deLASKI: It ‟ s from the LCC analysis. 21

MR. RABA: Okay. In the TSD. Thank you. 22

MR. deLASKI: I don ‟ t have a table 23

reference. 24

MR. RABA: Okay. 25Executive Court Reporters (301) 565-0064 233

MR. deLASKI: Do you have a table reference? 1

MR. McCORMICK: One could see that in table 2

8.5.15 on today ‟ s handout, I believe. 3

MR. deLASKI: So this drives, you know, 4

enormous national savings and I ‟ m wondering if the 5

industry has any input on that? I ‟ m curious, you 6

know, are these numbers -- do they corroborate with 7

what you ‟ re seeing in the marketplace? 8

And as you go through here, you know, you 9

see that, you know, for many of the ballast types 10

being evaluated there ‟ s savings of 2 to 6 percent, you 11

know, as Bob pointed out, the savings aren ‟ t that big, 12

you know, on a percentage basis. 13

(Simultaneous conversation.) 14

MR. deLASKI: -- here where we ‟ re seeing 15

really big savings. 16

MR. ERHARDT: Okay. This is Bob Erhardt. 17

On sign ballasts, electronic sign ballasts are a 18

relatively new development and you do pick up efficacy 19

when you run at high frequency. I have -- we didn ‟ t - 20

- there weren ‟ t any sign ballasts in the CEC data that 21

I was analyzing and so I -- we only looked at the 22

levels and saw if we had any heartburn over that. 23

In principal you will see an improvement in 24

efficacy running a T12 HO lamp on electronic ballasts 25Executive Court Reporters (301) 565-0064 234

compared with electromagnetic just going form 60 hertz 1

to 50 kilohertz you will pick up automatically on the 2

lamp. You get about 10 percent better efficacy. And 3

so it is reasonable. I don ‟ t know if it ‟ s 20 percent 4

when you consider the ballast efficiency, but it is 5

possible. 6

We were focusing primarily on our big 7

runners and in our written comments we ‟ ll address it. 8

(Simultaneous conversation.) 9

MR. deLASKI: By “big runners” you mean 10

those that sell a lot? 11

MR. ERHARDT: Right. 12

MR. deLASKI: We have this unusual 13

rulemaking where the savings are looking like they ‟ re 14

where you have things you sell fewer of. It ‟ s really 15

uncommon. 16

MR. ERHARDT: Well, yes. And we will -- 17

well, it ‟ s a high power product. In our written 18

response we will give a more accurate response than 19

I ‟ ve just given you, but there is energy to be saved 20

and I ‟ m going to electronic sign ballasts, yes. 21

MR. RABA: Thank you. Comment in the back, 22

please. 23

MR. COOK: Keith Cooks from Philips 24

Lighting. I guess I ‟ ve got a concern though with this 25Executive Court Reporters (301) 565-0064 235

significant savings in sign ballasts. My concern is 1

the fact that did you account for the conversion we ‟ re 2

seeing to solid state lighting in signs? Because we 3

do see a significant conversion here, rather rapid, 4

because of the fact that there ‟ s significant 5

improvement in maintenance and they operate much, much 6

better at low temperatures than conventional 7

fluorescent signs do. And so has that been accounted 8

for? 9

MR. McCORMICK: The Department ‟ s treatment 10

of solid-state lighting is to displace fluorescent 11

lamps entirely in many cases. So where you would see 12

that is in the shipments chapter. You would see just 13

fewer shipments of signed ballasts that are 14

fluorescents. With solid-state lighting sign ballasts 15

are not covered in this rulemaking. Did that answer 16

your question? 17

MR. COOK: Well, I guess I ‟ m not sure what 18

you ‟ ve forecast. The shipments is only history. 19

Right? 20

MR. McCORMICK: Oh, sorry. The shipments 21

chapter will also include forecasted future shipments. 22

And that takes into account assumed rates of 23

penetration for solid-state lighting. 24

MR. COOK: And what are you showing then for 25Executive Court Reporters (301) 565-0064 236

penetration of solid-state lighting in signs? 1

MR. McCORMICK: I don ‟ t know the number off 2

the top of my head, but I can direct you to the 3

technical support document which has those numbers. 4

MR. LINGARD: This is Bob Lingard with PNNL. 5

I know we did address emerging technology penetration 6

in a number of product classes in the shipments NIA. 7

To your point I would need to verify this, but I don ‟ t 8

-- yet we did not -- we did not address solid-state 9

lighting specifically in the sign ballasts. So your 10

comment is timely and welcome. Thank you. 11

MR. RABA: All good. All good. 12

Let ‟ s move on now. Let ‟ s continue and move 13

forward. We are going to start slipping here. 14

National Impact Analysis, let ‟ s move on to that, 15

please? 16

NATIONAL IMPACT ANALYSIS 17

MR. McCORMICK: So the section entitled 18

here, National Impact Analysis also includes the 19

shipments analysis which is very much part of that so 20

the two are hand in hand. And as you can see here, 21

the sort of a way to think of it is that the lifecycle 22

cost analysis provides cost information for one 23

typical ballast and the shipments analysis basically 24

tells us how many of these we need to account for, for 25Executive Court Reporters (301) 565-0064 237

the national impact analysis which, to put it crudely, 1

more or less multiplies those to get the total 2

national impact. 3

So I ‟ m going to talk about the shipments 4

analysis first. And it ‟ s worth pointing out that 5

that ‟ s also a stock analysis. So, to know the 6

incremental costs of purchasing more efficient 7

ballasts, you need to know the number of shipments 8

going forward, but to know the energy cost associated 9

with that you need to know the number of more 10

efficient units that will be on the market, not just 11

sold in any given year. 12

So the primary source of information DOE had 13

to estimate either shipments or stock was the U.S. 14

Census Industrial Reports information which covers 15

historical ballast shipments. The Department ‟ s 16

current estimates of historical stock are based 17

entirely on extrapolations from numbers about 18

historical shipments and lifetimes. So we would 19

certainly welcome any data that were available on 20

historical stock numbers, the number of ballasts in 21

operation at any given time in the United States. 22

Given this data source, however, we first 23

disaggregated historical ballast shipment numbers 24

according to product classes and efficiency types. 25Executive Court Reporters (301) 565-0064 238

One very important assumption that was made there 1

that ‟ s worth highlighting is the assumption that 69 2

percent of all ballasts in any given product class are 3

at the baseline efficiency level. We had very little 4

data to go on in terms of distribution by product 5

class, what share of ballasts are more efficient, so 6

we would welcome any information available about the 7

share in the market of more or less efficient ballasts 8

already in place in the base case. And the reason for 9

that is that for the national impact analysis we need 10

to know what the baseline share of efficient units 11

would be in order to know the impact of the rule. 12

So, DOE extrapolated from the lifetimes and 13

the shipment numbers stock estimates using a pretty 14

simple accounting framework that if you count, for 15

example, 15 years of an average ballast lifetime in 16

the commercial sector you can simply count 15 years 17

after those units ship, they ‟ re no longer in use. So 18

if you have 15 years of shipments data, you can know 19

how many units are in use at any given time in the 20

market. 21

So DOE ‟ s method was to first estimate 22

historical shipments by product class and efficiency 23

level based on the U.S. Census information. And we ‟ ve 24

already heard today we might, from NEMA, get 25Executive Court Reporters (301) 565-0064 239

additional data on shipments which would be most 1

welcome if possible. And other sources would be very 2

welcome. 3

From that we extrapolate stock and then we 4

use the historical stock records to estimate future 5

shipments and stock records -- excuse me, stock 6

numbers based on growth rates and replacement trends. 7

So, the primary growth rate we assume is the same as 8

the growth rate of the buildings stock in the Energy 9

Information Administrations NEMS model and the Annual 10

Energy Outlook. The major source of ballast shipments 11

in future then is replacements of current ballasts as 12

they expire. And there ‟ s also a certain amount of 13

growth. 14

We also have a number of scenarios, for 15

example, the emerging technology scenario covers the 16

aforementioned question of emergence of solid-state 17

lighting. The emerging technology scenario assumes 18

simply fewer shipments of fluorescents as the years go 19

on as the market is penetrated by other forms of 20

lighting which may or may not have to be LED lighting. 21

But that is certainly the most obvious example. 22

We also assumed two different scenarios in 23

terms of shipments; the rollup or shift scenarios. 24

The rollup scenario essentially says that if the 25Executive Court Reporters (301) 565-0064 240

requirement is some particular efficiency level, for 1

example, efficiency level two, then no one in the 2

market would manufacture or sell a less efficient 3

ballast. And that would be the only change. 4

The shift scenario assumes that those who 5

are currently purchasing ballasts that are more 6

efficient than the minimum baseline might choose to 7

become -- to purchase more efficient ballasts that are 8

still more efficient than a new standard. 9

So, for example, someone who is currently 10

purchasing a ballast that ‟ s roughly equivalent to CSL1 11

if the standard went to CSL1 might actually decide to 12

go CSL2 equivalent as a way of staying slightly ahead 13

of the market. And DOE provides both of those 14

scenarios and does not pick one as more likely than 15

the other. 16

So we have emerging versus existing 17

technology scenarios that cover different possible 18

rates of penetration for LEDs and other technologies. 19

And we have shift versus rollup scenarios that cover 20

whether those who purchase highly efficient ballasts 21

now might increase their efficiency in the presence of 22

a standard. 23

One of the most important results from the 24

preliminary analysis is that replacement ballasts 25Executive Court Reporters (301) 565-0064 241

dominate the shipments in the future. And a very 1

interesting pattern showed up. The cyclical shipments 2

pattern here which NEMA has already referred to in its 3

comments the pattern that you see here is roughly 4

equivalent -- is in fact, almost precisely equivalent 5

to the historical growth rate in the shipments of 6

ballast numbers that the Department was able to find. 7

So, approximately every ten to 15 years you see the 8

market having a spike or a valley which refers to what 9

was happening one lifetime ago. And you could imagine 10

different factors explaining this of which the most 11

important is that the Department assumes ballast 12

lifetimes that do not vary around an average very 13

much. So we assume, for example, that in the 14

commercial sector where ballasts last about 15 years 15

that almost every ballast lasts almost exactly 15 16

years rather than two to 30 years. 17

And what this would mean is that the every - 18

- every lifetime of a ballast the market would 19

experience a similar pattern to what happened 15 years 20

ago as a bunch of ballasts fail at the same time, 21

they ‟ re all replaced at the same time. So if you see 22

a very strong growth or fall in shipments, you would 23

see that repeated over time. And so the driving 24

effect on this -- this somewhat unusual outcome is the 25Executive Court Reporters (301) 565-0064 242

striking growth that DOE observed in historical 1

ballast shipments. So, we certainly do welcome any 2

other information on ballast shipments or stock in the 3

historical period, but what we have indicates a very 4

strong growth rate in the period, I believe it ‟ s 1992 5

to 2005 which does not seem entirely consistent with a 6

mature market. This is approximately on the order of 7

12 percent growth per year in ballast shipments which 8

seems although possible in shipments, very unlikely 9

that the number of installed ballasts in the country 10

was growing at approximately 12 percent a year. And 11

so in the current absence of other data, DOE ‟ s best 12

explanation for this phenomenon is the swap out of 13

older ballast types with newer ballast types. So what 14

we have assumed for the preliminary analysis is that 15

the stock from the period 1992 to 2005 was not growing 16

as fast as the shipments numbers. 17

The graph you see here, the higher line is 18

the total shipments observed in the historical period 19

that we have data for. And the Department has assumed 20

that 12 percent growth in stock is just not consistent 21

with what you would expect in a mature market. And we 22

would certainly welcome comments in a minute about -- 23

from stakeholders about that effect. 24

And so we ‟ ve assumed that at most the stock 25Executive Court Reporters (301) 565-0064 2 43

must have been growing by only about 2 percent a year 1

which is only slightly higher than the rate of 2

installed building space in the country. And so we 3

have essentially assumed that a large share of all 4

ballasts shipped in the historical period 1992 to 2005 5

were due to replacements of existing ballasts that had 6

not yet failed. If we did not make this assumption, 7

the shipments oscillations, that you see here, would 8

be even more dramatic. So this is a very interesting 9

issue that we would love any additional input on. 10

And I ‟ ll get to that in a moment. But one 11

of the key inputs to this unusual cyclical effect is 12

the lifetime. So DOE assumed that the average ballast 13

lifetime is a pretty good approximation of the actual 14

ballast lifetime and that there is a relatively low 15

variation around that. 16

We are certainly seeking comment on that in 17

part because if this assumption were not true, then 18

this striking cyclical pattern would be less 19

pronounced. 20

MR. THOMAS: Ed Thomas, GE Lighting. I 21

think the historical data is probably good. However, 22

predictions about what is going to happen in the near 23

future with the advent of the lead-free solder and we 24

still don ‟ t know quite what the lifetimes are going to 25Executive Court Reporters (301) 565-0064 244

be on these types of products, so we ‟ re a little bit 1

concerned about large projections for life beyond, you 2

know, the rated guidelines that we have test data for 3

at this time. 4

MR. RABA: Thank you. Bob. 5

MR. ERHARDT: Bob Erhardt, Philips Lighting 6

Electronics. This is a very large document and I saw 7

some conflicting data on historical. The graph you 8

showed here did not account for electromagnetic 9

ballasts. In 1992 our company alone shipped more 10

electromagnetic ballasts than what you showed there 11

for the total market. 12

MR. McCORMICK: That ‟ s very interesting to 13

know. 14

MR. ERHARDT: So when you showed the T8s 15

going from, I don ‟ t know, 30 million to 100 million, I 16

think it more likely that the electromagnetics went 17

from 100 million to 30 million in the same period. I 18

don ‟ t think there ‟ s been a large fluctuation. 19

Concerning ballast lifetime, I can tell you 20

that I had a question come up -- this is -- okay, this 21

is going back two years ago, but I had called out an 22

electromagnetic ballast model and I had to go all the 23

way back to 1969 to even find a reference for that 24

ballast model because it was obsolete in 1969. It 25Executive Court Reporters (301) 565-0064 245

turned out the ballast was older than I was. It was 1

over 50 years old. Electromagnetic ballasts, it ‟ s 2

still not uncommon for me to hear about ballasts from 3

the „ 60s that are over 40 years old. We don ‟ t have 4

30, 40, 50 years experience with electronic ballasts. 5

They ‟ ve only been around for about 30 years and the 6

ones we built 30 years ago weren ‟ t very good. 7

It ‟ s only within the last 25 years, I think, 8

that we ‟ ve had a rather consistently reliable product 9

and so 25 years of historical experience doesn ‟ t give 10

you a lot of data on how much the variation is around 11

the 15-year lifetime. But there are installations, I 12

think, that are over 15 years old. 13

Now, another factor that you should be 14

taking into account is not everybody waits for the 15

luminaire to die to change out -- the ballast to die 16

to change out the luminaire. 17

In the commercial sector when a building 18

space changes ownership often they ‟ ll do a redesign, 19

redecorating, and it ‟ s not uncommon to have luminaire 20

changed out at ten years just as part of renovations 21

of buildings as new tenants take occupancy in 22

buildings. 23

Maybe Fred can say something if he knows 24

something about luminaire lifetimes. But I think 25Executive Court Reporters (301) 565-0064 246

there will be significant variation. You do have the 1

installations where people have left the same 2

luminaires in place for, like I say, up to 50 years. 3

And then you have others where they ‟ re changed out 4

before anything fails at ten years or so. 5

MR. RABA: Additional data on the shipments. 6

Thank you very much. Addition data on the shipments 7

will be very helpful, written comments, and the other 8

things, but the magnetic as well, if you could. 9

Follow-on. Charlie? 10

MR. STEPHENS: Charlie Stephens. Yeah, 11

there ‟ s a few things that I think you -- and I would 12

echo what Bob said. I absolutely agree. I ‟ m finding 13

magnetic ballasts that are 35 and 40 years old that 14

are being changed out. I think they have an economic 15

lifetime rather than a physical lifetime. They get 16

changed out, as Bob suggested, because the fixture 17

gets changed or the occupant of the space gets 18

changed, or whatever. 19

In that regard there were a couple of things 20

that were going on in the „ 90s and past 2000 that are 21

absolutely reflected. I think you will find there ‟ s 22

an enormous correlation in your curves between utility 23

energy efficiency programs that were ramping up and 24

paying people to change their fixtures. And that ramp 25Executive Court Reporters (301) 565-0064 247

is still going on. I don ‟ t know how long it will go 1

on, but it is going on now. 2

The company I work part-time for is now 3

working with twice as many utilities in the United 4

States as it was three years ago in developing these 5

programs and implementing these programs. So you can 6

continue that ramp. 7

The other thing is that it ‟ s absolutely 8

consistent and I think you ‟ ll find an excellent 9

correlation with the real estate bubble. 10

MR. RABA: Fred, do you want to follow on 11

also? 12

MR. CARPENTER: No, I didn ‟ t have anything 13

to add. 14

MR. RABA: Okay. Great. That ‟ s good. 15

Fine. 16

Yes. 17

MR. NEUMANN: Justin Neumann of NEMA. There 18

are a few things I want to share in a kind of analysis 19

our NEMA biz group did over at NEMA. 20

NEMA concedes that the great difficulty 21

involved in forecasting economic variables over the 30 22

years, however NEMA disagrees with some of the 23

assumptions and methodology that DOE utilizes in 24

obtaining historical and projected ballast shipments. 25Executive Court Reporters (301) 565-0064 248

NEMA believes these factors are critical since DOE ‟ s 1

installed ballast stock estimates projections under 2

the various CSL scenarios are influenced by these 3

assumptions and methodological choices and ultimately 4

have an appreciable impact on the net energy savings 5

that stem from the rulemaking change. 6

DOE ‟ s choice of attributing the substantial 7

growth in ballast market shipments between 1990 and 8

2005 largely to retrofits rather than to absolute 9

growth in the stock of ballasts is questionable. 10

Several new technologies did evolve over 11

this 15-year time period and new federal regulatory 12

changes contributed to a significant increase in 13

retrofits. But the 1990-2005 time period also 14

contained very robust growth in non-residential 15

construction activity that would explain the larger 16

share of the new ballast demand than DOE assumes. 17

DOE should also examine how changes in this 18

assumption will affect both its historical estimates 19

and forecast projections. Variations are present in 20

the historical fluorescent ballast market data as one 21

would expect driven by economic forces and replacement 22

rates. However, DOE shipments projections show a much 23

more pronounced up and down pattern than can be 24

attributed to these factors. Even if one assumes 25Executive Court Reporters (301) 565-0064 249

slower growth overall in ballast market demand going 1

forward as DOE does, such a wavelike pattern of 2

shipments driven almost entirely by product failure 3

replacement is unlikely and not supported by the past 4

performance of ballast data or similar product 5

markets. 6

An example that NEMA Biz gave is the base 7

case existing tech scenario for four-foot T8 MBPs 8

predicts a 50 percent drop in shipments between 2017 9

and 2021. And only to return to 90 million shipment 10

units by 2030. 11

While shipments could register a decline 12

like that predicted in Figure ES2.2 it would largely 13

occur as a result of dramatic declines in commercial 14

construction activity or a significant amount of 15

business retrofitting their existing lighting systems 16

neither of which has been observed to this degree in 17

the historical ballast data. 18

MR. RABA: Are those the written comments 19

that you ‟ ve submitted? 20

MR. NEUMANN: No, these are some NEMA -- we 21

have a kind of economic business department at NEMA. 22

MR. RABA: Okay. 23

MR. NEUMANN: That prepared -- 24

MR. RABA: Will you submit them for the 25Executive Court Reporters (301) 565-0064 250

record, then? 1

MR. NEUMANN: Yeah. 2

MR. RABA: Okay. Thank you. 3

MR. NEUMANN: -- that prepared some comments 4

for us to share today. 5

MR. RABA: Okay. 6

MR. NEUMANN: Are you okay if I continue? 7

There ‟ s a little bit more. 8

MR. RABA: Briefly. Quickly. 9

MR. NEUMANN: Okay. Sorry. They gave us a 10

lot of economic info here. So -- shipments rebounding 11

to their prior levels after experiencing such a major 12

decline would also be improbable. The majority of 13

existing building owners with T8 lamps will likely 14

keep these systems in place for obvious reasons. In 15

that regard DOE ‟ s assumption about replacement demand 16

driving future shipments is correct. However, energy 17

efficient T5s are already commercially available and 18

can be more easily retrofitted into many existing 19

lighting systems without installing entirely new 20

fixtures. Consequently retrofits to T5s and other 21

existing technologies will likely dampen any 22

rebounding in future T8 shipments. 23

NEMA agrees with DOE ‟ s methods of 24

calculating lifecycle costs net present values, 25Executive Court Reporters (301) 565-0064 251

rebound rates and evaluation of environmental benefits 1

stemming from the proposed rulemaking. If it proves 2

feasible DOE should examine the applications of higher 3

discount rates on the projected values of net energy 4

savings. When consumers, businesses, or households 5

are faced with the savings that occur over a longer 6

time horizon, they will discount future benefits 7

heavily and place a much larger weight on the 8

products ‟ first costs. 9

MR. RABA: That ‟ s very beneficial. Thank 10

you and welcome those -- 11

(Simultaneous conversation.) 12

MR. NEUMANN: We are gathering more 13

information on this stuff and others. 14

MR. RABA: Excellent. Thank you. Thank you 15

very much that was well said. 16

Moving on, please? 17

I ‟ m sorry, one more quickly. Andrew? 18

MR. deLASKI: I have a question about 19

shipments. If you can go back to your graph. So 20

you ‟ re showing that the bottom line, the dotted line 21

across the bottom shows that T12 ballast shipments go 22

to zero? 23

MR. McCORMICK: That ‟ s right. So that ‟ s 24

another important element of this. There are on top 25Executive Court Reporters (301) 565-0064 252

of the replacement rate assumptions and the relatively 1

small growth assumptions for the total market certain 2

assumptions DOE makes about transitions between types 3

of product classes of which the most pronounced that 4

you ‟ re seeing is that magnetic T12 ballasts will have 5

shipments that fall very rapidly compared to their 6

current level. And those are all documented in the 7

TSD. 8

MR. deLASKI: That ‟ s due to the lamp rule 9

that the -- or just to the 2000 -- 10

(Simultaneous conversation.) 11

PARTICIPANT: (Off microphone.) 12

MR. deLASKI: Right. That ‟ s what I thought. 13

So what I ‟ m puzzled by is I ‟ m looking at the results 14

for that national impact analysis which shows in Table 15

ES.2.9 a substantial savings for T12 baseline as the 16

baseline. So I ‟ m having trouble reconciling, you 17

know, large savings for a product category that is 18

being predicted to go away in the base case. 19

(Simultaneous conversation.) 20

MR. deLASKI: What I ‟ m looking at is Table 21

ES.2.9 and in the third -- no, in the first box in the 22

third column -- third row down, two lamp -- ballast 23

factor for four-foot medium bi-pin and instant start 24

and rapid start T12 baseline predicting a large 25Executive Court Reporters (301) 565-0064 253

savings from a product that shows no sales. So I ‟ m 1

trying to understand, what am I misinterpreting? 2

MR. McCORMICK: Sure. It ‟ s first of all 3

worth pointing out these are preliminary results. But 4

more importantly, there are very large numbers of 5

shipments of that category which includes many T8s. 6

So although the baseline is T12s, the various other 7

CSLs are not T12s in that product class. So, for 8

example, CSL1, I believe is a T8. So you can imagine 9

-- 10

MR. deLASKI: Let me just follow. Let me 11

stop you there. But if a consumer has a T12 today, if 12

there is no new standard when they replace it, they ‟ re 13

going to put in a T8 because they can ‟ t get a T12. 14

MR. McCORMICK: That ‟ s right. That ‟ s 15

exactly what we assume. 16

(Simultaneous conversation.) 17

PARTICIPANT: That ‟ s not true. You can get 18

an electronic T12. 19

MR. deLASKI: So the base case is a T12 20

electronic? 21

MR. McCORMICK: I ‟ m trying to remember this 22

off the top of my head. I believe the base case is a 23

T12 magnetic. But the logical replacement will be the 24

next level up. I would want to check whether that ‟ s a 25Executive Court Reporters (301) 565-0064 254

T12 electronic or T8. 1

MR. deLASKI: But correct me if I ‟ m wrong, 2

but the T12 electronic is more expensive than T8 3

electronic in the market? 4

MR. RABA: Who are you addressing your 5

question to, across the table to Susan? 6

MS. ANDERSON: Yes, in general that would be 7

correct. 8

MR. deLASKI: So I guess it ‟ s important, you 9

know, maybe we ‟ re not going to get to this today, but 10

that it ‟ s not clear to me that in this the base case 11

needs to model what the consumer would do absent, you 12

know, regulation. So I ‟ m just not clear on how that ‟ s 13

been captured here. 14

MR. McCORMICK: Perhaps it is best to get 15

back to you in writing given time constraints. But 16

the essential overview I would suggest to you is that 17

if the consumer is assumed not to go to that precise 18

CSL level, they might not necessarily go to the 19

highest alternative CSL level. And the table you ‟ re 20

looking at, ES.2.9, I believe was calculated at the 21

max- tech. So there is actually a lot of “wiggle room” 22

if you will, between CSL1 and CSL3 for additional 23

savings. Given the large volume of shipments in that 24

product class, it doesn ‟ t take an enormous incremental 25Executive Court Reporters (301) 565-0064 255

efficiency between those to get fairly substantial 1

savings. 2

MR. deLASKI: I guess what I ‟ m suggesting is 3

that it strikes me given the realities in the market 4

today that the baseline is a T8 ballast. You know, 5

because a T12 electronic -- a T12 magnetic doesn ‟ t 6

exist anymore. That ‟ s what I just heard. And a T12 7

electronic is more expensive than T8 electronic. So 8

the market is going to move to T8. 9

MR. McCORMICK: Sure. And we will consider 10

that as an alternative. 11

MR. RABA: We may have had some 12

enlightenment over here from Mimi. 13

MS. GUPTA: Yeah. I think -- I think 14

something was misspoken before. The baseline is a T12 15

electronic. So we analyzed two baselines for this 16

product class, a T12 electronic and a T8 electronic 17

and maybe you, Bob, can explain a little bit more 18

about the base case shipments. But the lamps rule in 19

June -- July proposed standards that could potentially 20

eliminate the T12 lamp which is why, you know, we 21

think that -- which is why we basically analyzed two 22

because we don ‟ t know if it will for sure eliminate 23

the T12 lamp. So that ‟ s why we kept a T12 baseline 24

electronic ballast. I ‟ m not explaining this very 25Executive Court Reporters (301) 565-0064 256

well. But am I -- 1

MR. deLASKI: It ‟ s helping. 2

MS. GUPTA: Are you understanding? So, that 3

was my clarification. 4

MR. RABA: Thank you, Mimi. 5

Bob? 6

MR. ERHARDT: Bob Erhardt, Philips Lighting 7

Electronics. I think you make a very good point 8

though that T8 instant start is becoming the baseline 9

ballast. NEMA has some data where we can show -- and 10

actually, I think you showed in one of your graphs. I 11

saw two sets of data in two different parts of this 12

document where one did have the magnetics declining 13

and the electronics coming up which is what the 14

industry has observed. And then another that I think 15

results in this where you said electromagnetic has 16

always been 10 million or 7 to 10 million the whole 17

time. 18

Yes, it is true that the magnetic did start 19

probably at around 100 million and came down to 20

something today of 5 million or 10 million. And 21

electronic has gone from 92 probably 30 million up to 22

the 100 million. And as far as T12, T8, by far T8 23

electronic instant start is the dominant ballast sold. 24

It is the baseline, I would say, sold. 25Executive Court Reporters (301) 565-0064 257

MR. deLASKI: Then just to follow-up on 1

that. I mean, from the rulemaking last summer, you 2

know, the prediction is that, sure, there may be some 3

T12 lamps available in the market but they ‟ re going to 4

be expensive. And a T12 ballast also is going to be 5

expensive. You know, so really the cheap -- the low6

cost option is a T8 system. You know, so it strikes 7

me as -- 8

MR. ERHARDT: Yeah, I think you ‟ ll have a 9

situation where if somebody has a T12, they could -- 10

it ‟ s going to get more and more expensive for them to 11

maintain a T12 system. And somewhere along the line 12

it will pay them back to retrofit with T8. And it ‟ s 13

just a matter of what the sensibilities of the 14

business are and what their cash flow is that will 15

determine if they get nickeled and dimed by the T12 or 16

if they take the plunge and switch over to T8. 17

MR. RABA: Susan Anderson. 18

MS. ANDERSON: Well, there will be some low19

cost T12s left in the market in terms of lamps. The 20

problem with them is that they are very low lumen 21

output lamps. So, it will -- where they might be 22

suitable in a residence -- 23

MR. deLASKI: Okay. 24

MS. ANDERSON: -- I think a commercial 25Executive Court Reporters (301) 565-0064 258

establishment would find them too low output. And the 1

fact does remain that based on the 2000 ballast ruling 2

-- 2005, electronic T12 ballasts do meet those 3

standards. 4

MR. deLASKI: Okay. Thanks. 5

MR. RABA: Comment in back? Follow-on? 6

MR. COOK: Keith Cook from Philips. This 7

does require very careful analysis though. Because 8

what ‟ s going to happen is a lot of these T12s are in 9

residential. They ‟ re in basements and shop lights and 10

things like that. And a person is not going to 11

replace the ballasts. A residential person will not 12

do that. And it ‟ s going to come back through the Home 13

Depot and Lowe ‟ s channel in which case the ballast is 14

going to go through the OEM. It ‟ s going to be going 15

through acuity and those kind of places and so it ‟ s 16

not going to show up as just a replacement ballast 17

only. And if they replace them with a T8, they 18

definitely are going to be coming through with the OEM 19

channel then. 20

Whereas you got the ESCOs on the industrial 21

and commercial side which will replace a ballast only. 22

So you will see them taking the T12s and replacing 23

them with a T8. Totally different market. You need 24

to look at them independently to get a good analysis 25Executive Court Reporters (301) 565-0064 259

here. Because now all of a sudden you ‟ re payback is 1

going to change significantly when you replace the 2

entire luminaire as opposed to a ballast only for 3

residential. 4

MR. RABA: Valuable. Thank you. Susan 5

Anderson. 6

MS. ANDERSON: So basically we would say 7

when you look at the residential market the only 8

scenario you should look at is a new luminaire? 9

MR. deLASKI: I think in the -- this is 10

Andrew again -- in the standards in the lamp analysis, 11

this was the standards in retrofit. I mean, the 12

standard is driving, you know, you replace the 13

luminaire. 14

MR. RABA: Yes, in the back, please? 15

MR. PLASKON: Jeff Plaskon with GE Lighting. 16

I don ‟ t know if I quite agree. I do have a little 17

evidence that there ‟ s millions of ballasts being sold 18

in the residential channel and the split through in 19

home center could be up to about 50/50 split between 20

T12 and the T8 systems. So I would argue that many of 21

those or a portion of those are being transferred from 22

T12 to T8 systems or purchased by contractors. But it 23

is probably added up to an estimate of probably over a 24

couple million ballasts. 25Executive Court Reporters (301) 565-0064 260

MR. RABA: Back to you, Susan Anderson. 1

MS. ANDERSON: The one thing you have to 2

remember about especially when you look at the DIY 3

channel, there are a lot of small contractors that buy 4

based on credit cards with Lowe ‟ s or Home Depot or 5

Menards or whomever it is that quite frankly can ‟ t get 6

credit at the electrical wholesale distributor and 7

they buy -- or someone that ‟ s an electrician that does 8

freelance work over the weekend outside of their 9

normal job working for a contractor and, I mean, that 10

does happen that you have a lot of that particularly 11

in your Main Street, small business owner, the 12

contractor that ‟ s servicing him is very likely to buy 13

through Home Depot. So you have a good bit of 14

commercial business through Home Depot, Lowe ‟ s 15

Menards, et cetera. 16

MR. RABA: Thank you. Thank you. We should 17

move on, please. 18

We ‟ ve done well on this subject. Let ‟ s keep 19

going. 20

MR. McCORMICK: The next two issues, I 21

believe have been more or less covered so far. The 22

sub-issue -- starting on the bottom here actually is 23

the relationship between historical shipments and 24

historical stock. I believe we ‟ ve covered that well 25Executive Court Reporters (301) 565-0064 261

enough. 1

MR. RABA: She nods yes. Okay. Move on. 2

MR. McCORMICK: And now moving to the one on 3

top. DOE ‟ s method relied on disaggregating the U.S. 4

Census Bureau information according to product classes 5

and efficiency levels as best we could. And we would 6

most certainly welcome any additional data or input on 7

that approach. 8

MR. RABA: Written comments will be very 9

valuable at this point with that approach as well. 10

Next issue. Next. 11

MR. McCORMICK: The next issue is one that 12

we ‟ ve also sort of touched on already. The impact of 13

other regulatory processes going on at this time or 14

about to happen or that have just happened that would 15

influence our ballast shipment projections. So of 16

which the most interesting one is perhaps the T12 17

discussion we were just having. 18

Are there any other comments any 19

stakeholders would like to make about impacts of other 20

regulation on ballast projections? 21

MR. RABA: Cumulative effect perhaps. 22

(No response.) 23

MR. RABA: Good regulations; right? 24

Joanna. 25Executive Court Reporters (301) 565-0064 262

MS. MAUER: I actually just had a question 1

about one of the shipment tables in the TSD and how to 2

interpret the numbers. 3

MR. McCORMICK: Sure. 4

MS. MAUER: So Table 9.5.1 which is the 5

cumulative ballast shipment impacts. And it explains 6

in the text above it, it says that it ‟ s the cumulative 7

shipments impacts caused by each of the three 8

standards cases for each of the four shipment 9

scenarios. But it looks to me that both the rows and 10

the columns are labeled as CSL levels. I don ‟ t know 11

if you could help me about how to interpret the 12

numbers that are in that table. 13

MR. McCORMICK: Yes, I could. The two types 14

of CSLs that we ‟ re referring to there are the one CSL 15

is for types of equipment. So you can imagine that an 16

individual ballast could be the baseline or CSL1, 2 or 17

3. The other form of CSL is the standard that DOE 18

could set. So it could require all ballasts to be of 19

the baseline only or CLS1 or 2 or 3. 20

I don ‟ t think I have the table in front of 21

me to clarify which is which though, which is probably 22

the most important information to you. Do you have -- 23

thank you, Bob. 24

(Pause.) 25Executive Court Reporters (301) 565-0064 263

MR. McCORMICK: I believe the CSLs going 1

from left to right are types of equipment and CSLs 2

going from top to bottom are standards. But I would 3

want to clarify that by looking back at the origin of 4

the table. So we ‟ ll have to -- 5

MS. MAUER: This is Joanna again. Could you 6

say what you mean by “types of equipment”? 7

MR. McCORMICK: Yes. So, there are two 8

different ways to think about the word “CSL”. One is 9

an individual ballast, what type of equipment is it? 10

What efficiency level is that ballast? The other is 11

what is the efficiency level that -- for the purpose 12

of the analysis we are assuming DOE was requiring in 13

that scenario. So it ‟ s examining the impact of DOE 14

setting an efficiency level of CSL1 or of CSL2. 15

MR. LINGARD: Gavin, this is Bob Lingard 16

with PNNL. I think to clarify what you were just 17

saying, I believe the ones across the top underneath 18

the shipment scenarios those CSLs describe the 19

shipments. The standard scenarios that you were 20

speaking of and that the ones going down the left-hand 21

column are the product specific CLSs that you referred 22

to. 23

MR. McCORMICK: Thank you, Bob. That ‟ s 24

exactly right and that ‟ s very helpful. So you can see 25Executive Court Reporters (301) 565-0064 264

that from top to bottom zero, one, two, three are your 1

options. That ‟ s types of equipment. And since the 2

baseline scenario there ‟ s no point in presenting the 3

impacts of a baseline scenario. Going from left to 4

right where it ‟ s only one, two, three are your 5

options, those are the three possible standard levels 6

that DOE could adopt. 7

MR. RABA: That was in the TSD, Table 9.5.1 8

and 2. 9

Okay. 10

MR. McCORMICK: Great. Any other questions 11

on issue 18? Or comments on issue 18? 12

(No response.) 13

MR. McCORMICK: So that was the shipments 14

analysis which is by far the more complicated part of 15

the national impacts analysis. And the rest of it is 16

a quite straightforward calculation. Given that we 17

now have estimates of shipments and stock in the 18

future, and given that we have now gathered all the 19

economic information about the costs, one can simply 20

add up the expected costs and the expected consumer 21

financial benefits of this regulation. And you can do 22

that to get the net present value which is taking into 23

account the increased costs of many consumers 24

purchasing more efficient ballasts. And the savings 25Executive Court Reporters (301) 565-0064 265

of many consumer using more efficient ballasts and 1

therefore paying less in electricity costs and other 2

costs over time. That ‟ s your net present value. 3

The other output of the national impacts 4

analysis is the national energy savings which is 5

simply what is the reduced amount of energy used by 6

these more efficient ballasts over time. 7

And the only original input in the national 8

impacts analysis that does not flow directly out of 9

other chapters is the discount rate. This analysis 10

also uses discount rates to assume that savings in the 11

future are less valuable than savings now. But they 12

do not use the same discount rates that are in the LCC 13

analysis. That is because the discount rates that are 14

in the LCC analysis are for individual consumers, the 15

rate at which individual consumers can borrow or loan 16

money. The discount rates used for the national 17

impacts analysis are 3 and 7 percent and those are 18

considered to be society ‟ s discount rates. So they 19

are not linked to particular costs of capital. They 20

are linked to society ‟ s preference for savings now as 21

opposed to the future. And those 3 and 7 percent 22

rates are interagency rates that are use for many 23

forms of regulation. They are not specific to this 24

rule, and they are not calculated for this rule. 25Executive Court Reporters (301) 565-0064 266

Given time pressure, I don ‟ t think I need to 1

go into great detail, but this graph is a typical 2

shape that you see of net present value and national 3

energy savings. They rise over time as you have more 4

ballasts that are covered, and then they fall over 5

time due to the impacts of discounting. Meaning that 6

you value the future less than you do immediate 7

savings. 8

Having hurried through that a little bit, 9

DOE acknowledges that there may be certain 10

externalities associated with energy savings that are 11

not covered by the financial savings to consumers. 12

Environmental and energy security related benefits of 13

saving energy are often cited examples. And we invite 14

comment on the nature and magnitude of any such 15

externalities. 16

(Pause.) 17

MR. RABA: Comment? 18

MR. ERHARDT: Bob Erhardt, Philips Lighting 19

Electronics. A small comment and it comes to the T5 20

lamps and ballasts pointing out the T5 lamps and 21

ballasts and systems use significantly less raw 22

materials and less mercury than the T8 and that can be 23

a beneficial factor. 24

MR. McCORMICK: Thank you, that ‟ s very 25Executive Court Reporters (301) 565-0064 267

helpful. 1

MR. RABA: Thank you. Small comments, big 2

comments? 3

(No response.) 4

MR. RABA: Next issue. 5

MR. McCORMICK: The next issue is the 6

translation of candidate to standard level CSLs into 7

trial standard levels TSLs. A quick summary would be 8

that DOE will move from having many candidate standard 9

levels to possibly fewer trial standard levels for the 10

next round of the analysis. We are essentially 11

winnowing down the different possibilities. And we do 12

invite comment on the best method to select TSLs from 13

the current CSLs. 14

MR. deLASKI: Just a comment. 15

MR. RABA: Andrew deLaski. 16

MR. deLASKI: That you can ‟ t do much 17

winnowing because you don ‟ t have many levels. You may 18

be relative to other dockets, you may have done 19

winnowing in other dockets, but in this one you ‟ ve 20

only got three CSLs, and for most products you have 21

one. One or two. 22

MR. McCORMICK: Thanks for the comment. 23

MR. deLASKI: I hope that we will find more 24

-- I hope there are more CSLs out there, but that 25Executive Court Reporters (301) 565-0064 268

depends on what you come up with through the 1

engineering. 2

MR. RABA: Mimi Gupta. 3

MS. GUPTA: Mimi Gupta, Navigant Consulting. 4

I think an important point that the Department request 5

comment on related to this is how the combinations of 6

standard levels and how -- so the national impacts 7

analysis looks at the national impacts of setting 8

standards for all the products being considered. But 9

we ‟ ve established different standard levels for each 10

product. So, how to pare them, you know, should the 11

standard level three on T8s be or on four-foots be 12

paired with candidate standard level one with, you 13

know, T5s or -- I don ‟ t know, there ‟ s many different 14

permutations that you can make. 15

MR. deLASKI: Yeah, I think the Department - 16

- this is Andrew deLaski, I think the Department ‟ s 17

approach in the past has been an effective one which 18

is, you know, look at one CSL consist of the maximum 19

cost effective and -- and you gap fill. I think that 20

approach has been an effective approach in the past 21

and would work for this docket too. 22

I think the gap fill ones are important too, 23

to make sure that we ‟ re capturing what ‟ s in between. 24

MR. RABA: All set? 25Executive Court Reporters (301) 565-0064 269

MR. deLASKI: So on that, I do have another 1

follow-up question, Jim, before Gavin goes away. How 2

do you do shipments on sign ballasts? You know, sign 3

ballasts, as I said before is a huge piece. 4

MR. McCORMICK: Right. And you ‟ re referring 5

to the commercial versus industrial -- 6

MR. deLASKI: Shipments. The shipments -- 7

how many are shipped? How did you come up with that 8

number? 9

MR. McCORMICK: Right. So we approached it 10

the same way that we did with the other product 11

classes. And so the main source of shipments for sign 12

ballasts is replacements. And we also looked at 13

growth in the sectors in which they are installed, 14

commercial and industrial. The growth rate of the 15

building stock assuming a roughly constant intensity 16

of sign ballasts per -- I ‟ m saying building in terms 17

of square feet, but it ‟ s really the building type is - 18

- 19

(Simultaneous conversation.) 20

MR. deLASKI: Let me ask the question more 21

precisely which is, how did you get historic 22

shipments? How do we know what the shipment is 23

assigned by? Is there census data on that or is that 24

from the manufacturers or -- 25Executive Court Reporters (301) 565-0064 270

MR. McCORMICK: That ‟ s a question for -- 1

MR. LINGARD: This is Bob Lingard with PNNL. 2

That was also disaggregated from the U.S. Census data 3

based on an assumed percentage of those magnetic HO 4

type ballasts. So, again, our starting point was the 5

census data. 6

MR. deLASKI: And it gave you enough of a -- 7

you were able to tell from the census data that 8

something is a sign ballast? There ‟ s data in there? 9

MR. LINGARD: That was based on preliminary 10

assumptions. No, it wasn ‟ t identified -- it was not 11

identified in the census data as sign ballasts. So we 12

had to make some assumptions. 13

PARTICIPANT: Where did you get your 14

percentage? 15

MR. LINGARD: That was compiled from looking 16

across manufacture interviews. However, we do, again, 17

we request more precise data, suggestions. Again, we 18

were starting from a pretty broad brush with the 19

census data. 20

MR. RABA: This being preliminary data 21

analysis throughout, this sort of data, comments are 22

most welcome at this point and very valuable to look 23

at more thoroughly as we go through the rulemaking 24

process over time. 25Executive Court Reporters (301) 565-0064 271

Thank you. Let ‟ s continue, please. 1

That ‟ s all. Thank you very much, Gavin. 2

And Rob Carmichael will present now on the 3

preliminary manufacturing impact analysis. Rock and 4

roll. 5

MR. CARMICHAEL: Ninety minutes? 6

(Laughter.) 7

PRELIMINARY MANUFACTURER IMPACT ANALYSIS 8

MR. CARMICHAEL: Okay. Good afternoon. My 9

name is Rob Carmichael. I ‟ m with Navigant Consulting 10

and I ‟ m going to go over two topics today. The first 11

is DOE ‟ s normal procedure for conducting the 12

manufacturer impact analysis. And the second is a 13

review of a preliminary MIA. So our initial round of 14

interviews with manufacturers. 15

So obviously the purpose of the manufacturer 16

impact analysis with the MIA is to qualitatively and 17

quantitatively assess the impacts of amended energy 18

conservation standards on manufacturers of ballasts. 19

DOE normally does this in three phases. 20

In the first phase DOE creates an industry 21

profile that builds on the market and technology 22

assessment and uses that to inform its interviews with 23

manufacturers in subsequent discussions. And also 24

uses it to identify the key levers that will go into 25Executive Court Reporters (301) 565-0064 272

the industry cash flow analysis. 1

And that brings in phase two which is when 2

DOE conducts -- builds a strawman industry cash flow 3

model. We use the government regulatory impact model 4

or the GRIM to forecast free cash flows in the 5

industry throughout the entire analysis period and 6

then discount them back both on the base case and in 7

the standards case to calculate an industry net 8

present value or an INPV and use the comparison of 9

those two values as the output of the main output of 10

the manufacturer impacts analysis. 11

Also in phase two, DOE uses what we ‟ ve 12

learned here today and in your written comments to 13

inform and develop an interview guide that DOE will 14

use to guide its subsequent discussions with 15

manufacturers in the full-blown MIA interviews. And 16

those being in phase three. And in those interviews I 17

just want to make one point on the interviews, first 18

of all we ‟ ll begin scheduling them rather soon. And 19

also second, those are nearly always conducted under a 20

nondisclosure agreement so no proprietary information 21

is disclosed throughout the course of the rulemaking. 22

And so following the manufacturer interviews 23

DOE completes its analyses in the end of -- in phase 24

three and looks at also some qualitative analyses 25Executive Court Reporters (301) 565-0064 273

including manufacturer capacity, employment impacts, 1

and impacts on competition. 2

So, switching from process to content, this 3

is a summary. This slide shows a summary of the four 4

main issues that came up during the initial round of 5

preliminary MIA interviews. There were manufacturers 6

in general related these concerns. First there ‟ s 7

impacts on profitability from energy conservation 8

standards. That can be due to several reasons, one 9

being an inability to pass on some or all of the 10

incremental costs associated with a new standard. The 11

second being it may eliminate an up-sell opportunity 12

in the product mix of the manufacturer. And the third 13

being that it could cause some consumers to switch 14

from fluorescent technology to some other lighting 15

type, thereby reducing sales and revenue. 16

The second is a similar concern, one of the 17

diminishing returns to consumers. It ‟ s been raised 18

here today dealing with the tradeoff between a small 19

increase in efficiency versus some high conversion 20

costs that manufacturers might face. 21

And the third reason also has been raised 22

today deals with the impact on product innovation. 23

Essentially it ‟ s the opportunity costs that 24

manufacturers would lose as they devote resources to 25Executive Court Reporters (301) 565-0064 274

upgrading existing product lines rather than putting 1

those resources into product development. 2

And then lastly, regulatory burden, part of 3

the MIA is to look at the cumulative regulatory 4

burden. So those other regulations that impact 5

manufacturers of those specific products, few of those 6

have been mentioned today, RoHS, hazardous material 7

regulations and then also other international 8

standards, electromagnetic requirements as well. 9

So at this time DOE requests comment on its 10

characterization of the key issues in here and as well 11

in more detail in the TSD. 12

MR. ERHARDT: Yeah, this is Bob Erhardt 13

again. And I wish to reiterate on the industry is in 14

the middle of a market conversion, if you will, and 15

the NRE, nonrecurring engineering costs on redesigning 16

fixed output ballasts, the payback -- we expect the 17

volumes of these to be going down and there is going 18

to be significant impact in being able to recover 19

these costs because the market is shifting to control 20

systems that are different ballast type and the market 21

is shifting to solid-state lighting which is a 22

different lighting type. And unlike other more 23

constant markets, this is a market that ‟ s in a 24

dramatic transition right now. Much more so than in 25Executive Court Reporters (301) 565-0064 275

the 25 to 28 years that I ‟ ve been in this business. 1

And so you ‟ re traditional models of payback on 2

development costs probably aren ‟ t going to fit because 3

this is a mature -- I would call it an “end -of- life” 4

product category. This is a product category that in 5

the next 20 years is going to be minimized to almost 6

nothing. And the opportunity for getting payback on 7

investment is going to be severely diminished. 8

So, again, we encourage you to take into 9

consideration the costs of having to develop new 10

products to meet rules because you really need to look 11

at -- there are projections that, you know, in 20 12

years are in much less -- in five to ten years, solid13

state lighting could have 50 percent of the market. 14

And controls could have the other 45 percent. So, 15

where ‟ s the -- I ‟ m pulling these numbers out of the 16

air. But if you combined everybody ‟ s projections for 17

alternative technologies, there ‟ s a negative market 18

for this product in ten years. It ‟ s probably not 19

going to be the case, but it will be a significantly 20

diminished market in the ten to 20 year time frame. 21

PARTICIPANT: Wait and see. 22

MR. RABA: Thank you. Very interesting 23

comment. Any others, please? 24

(No response.) 25Executive Court Reporters (301) 565-0064 276

MR. RABA: Wow. Okay. That was too easy. 1

We ‟ re going to start wrapping up here. We 2

have the NOPR analysis, Bob Lingard is coming back 3

from PNNL. 4

NOPR ANALYSES 5

MR. LINGARD: Yeah, we spent all day talking 6

about what ‟ s happened already, now we get to talk 7

briefly about what ‟ s to come in the NOPR stage of the 8

rulemaking. In addition to refining and revising the 9

preliminary analyses there are a number of analyses 10

unique to the NOPR phase. I ‟ m going to give you, in 11

the interest of time, and agenda, a quick review of 12

these different analyses. 13

The first being the LCC subgroup analyses. 14

Basically a focus or a specific LCC analysis for 15

identifiable consumer subgroups and business types 16

that could be disproportionately affected by standard 17

levels. This could vary with ballast type and the 18

subgroups of energy prices. Operating hours could 19

vary from subgroup to subgroup. So, again, this is 20

well, literally what it says, a subgroup of the LCC 21

analysis. 22

The manufacturer impact analysis will 23

continue. The utility impact analysis, these are 24

effects on electric utilities. You ‟ ve heard reference 25Executive Court Reporters (301) 565-0064 277

to the NEMS, the National Energy Modeling System model 1

today looking for interactions between supply and 2

demand and forecasting how efficiency levels or 3

standards could affect capacity generation, sales and 4

prices of electricity. Another modeling analysis. 5

The employment impact analysis, we touched 6

on the MIA which speaks more to the direct effects on 7

employment. The employment impact analysis here will 8

focus more on the indirect effects on national 9

employment. This would be outside of the 10

manufacturers who are regulated, the net jobs created 11

or eliminated, looking to substitution effects, income 12

effects, that ‟ s just another way of saying, how 13

expenditures might shift among goods or how overall 14

expenditures may be affected by efficiency or standard 15

levels. 16

The environmental assessment. This is also 17

using the NEMS model. Quantifying and monetizing 18

reduced power plant emissions as a result of reduced 19

energy use. This is also the subject of an appendix 20

in this rulemaking and interagency report on the 21

monetization on the social cost of carbon. So this is 22

an emerging area and I would invite you to take a look 23

at that appendix and that we will also be requesting 24

some comment or input on monetization of reduced 25Executive Court Reporters (301) 565-0064 278

emissions. 1

And finally, regulatory impact analysis. 2

Again, where the manufacturer impact analysis would be 3

looking at existing or pending regs and their impacts. 4

This analysis will look to non-regulatory approaches. 5

To offer an example, consumer or manufacturer tax 6

incentives, rebates, bulk government purchases, and 7

these will become the basis for essentially 8

alternative scenarios, standard alternative scenarios 9

in the NIA model. And that is a very quick summary of 10

the NOPR analysis. 11

We have one specific request for comment. 12

This regards the environmental assessment. We do plan 13

on monetizing emission reductions that could result as 14

a matter of this rulemaking. You ‟ ll see some of the 15

more recent dollar per metric ton figures assigned for 16

CO2. And, again, this was the subject of the 17

interagency report and study on the social costs of 18

carbon which is part of Appendix EA-SCC in this 19

particular docket. 20

DOE invites comments on the approaches for 21

monetizing. And with that I will open the floor 22

again. 23

MR. RABA: Comments from the floor? 24

(No response.) 25Executive Court Reporters (301) 565-0064 279

MR. RABA: Written comments are welcome on 1

that. I think that ‟ s good for now. 2

Thank you, Bob. 3

Great. Last, but not least, we have Linda 4

Graves to request your final comments, questions and 5

invite final discussion on any topic we ‟ ve had today. 6

Linda. 7

FINAL QUESTIONS/DISCUSSIONS AND CLOSING 8

MR. GRAVES: You ‟ ve been a great group. 9

You ‟ ve been really cooperative, that back and forth 10

from especially among different groups stakeholders 11

has been especially appreciated. This is your last 12

chance. We ‟ ve covered a lot of specifics. This would 13

be the last chance for any other points of view you 14

want to express, any overarching comments. We ‟ re just 15

about out of time, but if there ‟ s still something you 16

would like to say, please do. 17

MS. MAUER: Joanna Mauer. Just a quick 18

question. Do you know when the analytical 19

spreadsheets might be posted to the website? 20

MR. GRAVES: Really soon. 21

MR. LINGARD: This is Bob Lingard with PNNL. 22

Those were -- the preliminary models were posted late 23

last week. So they should be available to you the 24

next time you log on. 25Executive Court Reporters (301) 565-0064 280

MR. GRAVES: Anyone? 1

MR. STEPHENS: Yes, Charlie Stephens. The 2

comment period closes in two weeks on something that I 3

think based on our conversation today is a little 4

slippery. We ‟ ve still got some ground here that looks 5

more like quicksand when it comes to trying to 6

understand what we have to chew on and whether -- and 7

how much of it is accurate and well-founded and all 8

that. And the test period comment period ends in 9

June. And that isn ‟ t firm either. Is there some 10

reason why you ‟ ve got the standards rulemaking on May 11

10th and the test procedure rulemaking, which is 12

arguably simpler, sometime in the first week in June 13

instead of the other way around? 14

I would argue it would be really helpful to 15

us if it were the other way around. 16

MR. GRAVES: Those dates -- this is Linda 17

Graves. Those dates are driven by the requirements 18

that apply to regulatory requirements, that apply to 19

public comment period. Otherwise, we might be doing 20

May 10th for everything. 21

But the point being that we ‟ re on a 22

schedule, we postponed the date of this public meeting 23

to accommodate scheduling issues. That ‟ s how we ended 24

up with this date rather than an earlier date. And in 25Executive Court Reporters (301) 565-0064 281

order for that teams to make the final rule dates and 1

have the test procedure and standards come together, 2

we really do need the comments as soon as possible. 3

And so, it ‟ s changing the dates that have been 4

published in the Federal Register is not a fun thing 5

to try to do. 6

MR. STEPHENS: Okay. I guess I will just 7

have to tell you then that based on the fact that I 8

doubt we ‟ re going to get the information back from 9

USDOE, and perhaps some better information from other 10

sources, I don ‟ t think the comments you ‟ re going to 11

get by May 10th on this particular issue are going to 12

be very complete or potentially very accurate given 13

that later will get information that would perhaps 14

cause us to want to change our comments fairly 15

substantially. So I ‟ m not sure you ‟ re helping 16

yourselves here by having it that near in the future 17

without -- while we ‟ re missing so much information. 18

MR. GRAVES: I would just say it is a 19

preliminary analysis stage. 20

MR. RABA: Preliminary there ‟ s far more to 21

do, certainly, but thank you, Charlie. We have 22

certain constraints we can ‟ t avoid. We ‟ re aware of 23

that, we ‟ re going to work on it. Thank you very much. 24

Good comment. 25Executive Court Reporters (301) 565-0064 282

Mike? 1

MR. McGARAGHAN: Mike McGarahan, first of 2

all just on behalf of California Utilities, thanks for 3

the opportunity to provide comment today and written 4

comments as well. 5

And last clarification I just wanted to make 6

that the next meeting would only address the 7

standards, NOPR and that the test procedure would not 8

be covered until the final rule is issued the 9

following year. Is that correct? 10

MR. RABA: A response to that? 11

MR. McGARAGHAN: Sure. Since we ‟ re at the 12

NOPR stage for the test procedure now, will the next 13

meeting cover the test procedure at all or will it 14

just focus on standards and we ‟ ll see a final rule for 15

test procedure -- 16

MS. GUPTA: Yeah, unless DOE decides to 17

issue a supplemental NOPR test procedure. If it 18

decides it wants to change its approach beyond the 19

scope that was discussed today, then you ‟ ll just be 20

seeing a final rule. 21

MR. RABA: Final? 22

All right. Considering you ‟ ve accomplished 23

a lot today, this has been really two days worth into 24

one. A lot of good information has passed across the 25Executive Court Reporters (301) 565-0064 283

table. Written comments are invited to our 1

preliminary analyses and DOE welcomes anything more 2

you have to add. 3

Please, the court reporter says -- a bright 4

spot, the transcript will be available this week, 5

later on. So contact Linda Graves for further 6

information on that if you wish, or just kind of watch 7

for it later either on the website or from the Court 8

Reporter. They can provide copies on the website as 9

well. 10

A couple things to wrap up before Linda ‟ s 11

closing remarks, please. Turn your comment sheets in 12

to Brenda on the way out. And also, when each of you 13

who brought laptop computers came into the room, into 14

the building, you were issued, I presume, a receipt, 15

some piece of paper saying that was your computer. 16

You can ‟ t leave that building with that machine 17

without showing the security guard that receipt you 18

got for your computer. So, make sure you have that 19

piece of paper, it ‟ s a very important valuable 20

document. Okay. Got that? 21

Final comments? Linda. 22

MR. GRAVES: I think I already made them, 23

Jim, but thank you very much everyone. And please do 24

fill out your survey forms. We very much appreciate 25Executive Court Reporters (301) 565-0064 284

your feedback on whether this compressed format is 1

working for you. 2

I ‟ ll ask my boss if he wants to say anything 3

further. 4

MR. CYMBALSKY: Yes, it was kind of my idea 5

to try to get all of this done in one day. So if it 6

felt rushed or anything like that, it ‟ s my fault. 7

But, you know, I think everyone made good comments and 8

we ‟ re going to take them all into consideration and 9

we ‟ ll move on from there. And thanks for coming. 10

MR. RABA: Thank you. Give yourself a round 11

of applause. 12

(Whereupon, at 5:03 p.m., the meeting was adjourned.) 13

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25Executive Court Reporters (301) 565-0064 285

REPORTER ’ S CERTIFICATE

This is to certify that the attached proceedings

before:

U.S. DEPARTMENT OF ENERGY

In the Matter of:

PUBLIC MEETING ON ENERGY CONSERVATION STANDARDS PRELIMINARY ANALYSIS AND TEST PROCEDURE NOPR FOR

FLUORESCENT LAMP BALLASTS

Were held as herein appears and that this is the

original transcript thereof for the file of the

Department, Commission, Board, Administrative Law Judge

or the Agency.

Further, I am neither counsel for or related to any

party to the above proceedings.



### Wendy Greene

Official Reporter

Dated: April 27, 2010