### Battery Chargers | Electrical Power Conversion and Storage 625 West A Street | Lincoln, NE 68522

- 1794 | LesterElectrical.com

P: 402.477.8988 | F: 402.441.3727, 402.474.1769 (Sales) MEMORANDUM

TO: United States Department of Energy (DOE), V ia E mail

, expartecommunications@hq.doe.gov

FROM : Spencer Stock, Product Marketing Manager, Lester Electrical

DATE: June 18, 2012

RE: Ex Parte C ommunications, Docket Number EERE

– 2008

– BT

– STD

– 0005, RIN 1904

– AB57

On Monday, June 11, 2012, representatives from Lester Electrical and Ingersoll Rand met with DOE to

discuss the Notice of Proposed Rulemaking (NOPR) for Energy Conse rvation Standards for Battery Chargers and External Power Supplies, Docket Number EERE

– 2008

– BT

– STD

– 0005, RIN 1904

– AB57

.

The following participants were present.

John Cymbalsky, DOE Jeremy Dommu, DOE Michael Kido, DOE

Luke Prussa, Lester Electrical Spencer Stock, Lester Electrical

Jordan Doria

, Ingersoll Rand

The following topics were discussed during the meeting.

1. DOE staff stated that they had reviewed the written comments submitted by Lester Electrical. They requested the submittal of additional data regarding the Lester Electrical claim that the NOPR Average Installed Price data for Product Class 7 CSL 0 is incorrect, as well as data regarding product lifetimes, product reliability, and consumer utility.

2. Lester Electrical reiterated their commen ts from the public meeting and written comments that they believe that golf car battery charger systems are not consumer products and, as such

, should not be regula ted by the proposed standards.

3. Lester Electrical discussed the fact that golf car battery ch arger systems are much closer in design and constru ction to battery charger systems for use with other commercial or industrial equipment, such as material handling equipment (e.g., lift trucks), industrial/utility vehicles, aerial work platforms (e.g., sc issor lifts and boom lifts), and floor machi nes , than battery charger systems sold primarily and principally for personal use or consumption.

4. Lester Electrical discussed the fact that golf cars themselves share very few similarities in design

and construct ion with the battery

- powered products regulated by the proposed standards that are sold primarily and principally for personal use or consumption. However, golf cars are almost indistinguishable in design and construction from low

- speed vehicle s (LSV s ), which are specifically excluded from the proposed standards. In fact, the additional safety features that are required for a vehicle to be c lassified as an LSV can optionally be added to golf car s as factory option s or in the aftermarket.

5. DOE staff reite rated their position that they consider golf car battery charger systems to be

consumer products pri marily because approximately 10 percent of new golf cars are sold to individuals for personal use.

6. Ingersoll Rand reiterated their written comments that t hey believe that if the four (4) factors outlined in the DOE FAQ on the topic are evaluated for golf cars

, only one (1) of which is distribution of shipments of the pr oduct type and the basic model, that golf cars are not “of a type ”

that make them a consumer product.Ex Parte Communications

Docket Number EERE

– 2008

– BT

– STD

– 0005

, RIN 1904

– AB57

June 18, 2012

Page 2



### Battery Chargers | Electrical Power Conversion and Storage

625 West A Street | Lincoln, NE 68522

- 1794 | LesterElectrical.com
P: 402.477.8988 | F: 402.441.3727, 402.474.1769 (Sales) 7. Lester Electrical asked that DOE carefully consider the case of LSVs, as well as the fact that

other commercial/industrial electric vehicles, such a lift trucks, are also sold in some quantity to

individuals for personal use, though they a re primarily distributed to commercial/industrial businesses, in a very similar manner to golf cars

. 8. In response to the question from Lester Electrical, DOE staff acknowledged that there is no mandate from Congress, or any st atutes, that state that golf cars are th emselves consumer products. This determination will be made by DOE.

9. Both Lester Electrical and Ingersoll Rand reiterated their written comments that, if DOE continues to classify golf car battery charger systems as consumer products, they believe that ade quate implementation time must be given from the final rule to the effectiveness date, which, at a minimum, would be 2 years.

10. Lester Electrical stated that the NOPR includes language that indicates that DOE has te ntatively

concluded that a 2

- year window between the announcement of the final rule and compliance with

the standards is sufficient for battery charger manufacturers to meet the efficiencies proposed in

the NOPR

.

Respectfully Submitted

,

Spencer Stock Product Marketing Manager

Lester Electrical

402.477.8988