# MEMORANDUM

To: e xpartecommunications@hq.doe.gov From: Douglas Johnson Date: February 21, 2013 Re: Docket No. EERE

– 2008

– BT

– STD

– 0005 , RIN 1904

– AB57 Ex parte communication Department of Energy Meeting of February 13, 2013 This memorandum for the record provides a summary of a February 13, 2013 , meeting with U.S. Department of Energy staff concerning DOE’s proposed rulemaking regarding amended energy conservation sta ndards for Class A external power supplies (EPSs) and new energy conservation standards for non

- Class A EPSs and battery chargers. Meeting attendees: John Cymbalsky (DOE Office of Energy Efficiency and Renewable Energy) Jeremy Dommu (DOE Office of Energy Efficiency and Renewable Energy) Daniel Cohen (DOE Office of General Counsel) Michael Kito (DOE Office of General Counsel) Douglas Johnson (Consumer Electronics Association) Caroline Curtin (Mi crosoft) Ric Erdheim (Philips Electronics ) Holly Evan s ( Dell ) Jim Morgan (Sony) Mark Sharp (Panasonic) Steve Whitaker ( Bose) The parties discussed issues raised in a letter submitted by the Consumer Electronics Association (CEA) to the DOE on February 7, 2013 , a copy of which is attached. Additionally, CEA attendees presented a letter to D OE dated February 13, 2013, regarding the importance of a spare parts exemption in regulation s for EPSs and battery chargers, a copy of which is attached.

# Via e

- mail

February 7 , 2013 Mr. John Cymbalsky Supervisor, Appliance Standards Analysis Office of Energy Efficiency and Renewable Energy U.S. Department of Energy EE

- 2J, Room 6172 1000 Independence Ave., S.W. Washington, DC 20585 Subject: Current consumer electronics industry recommendation on

implementation timeline for DOE regulations for battery charger systems and external power supplies
Dear Mr. Cymbalsky : On behalf of the Consumer Electronics Association (CEA) , I would like to request a Department

- industry dialogue regarding the implementation timeline for the DOE’s forthcoming regulations for battery charger systems and external power supplies , at least as they relate to consumer electronics. Until recently, CEA h ad urged the Department to act quickly specifically on battery chargers in order to minimize the time lag between California’s implementation of its regulation for battery chargers and DOE’s implementation of a federal regulation, which ultimately would preempt state requirements for battery ch argers. CEA urged fast implementation of the DOE rule because its limits were more suitably tailored to diverse battery charger classes, particularly for consumer electronics. The current scenario is that California’s regulation has entered into force a s of February 1, 2013, and manufacturers have had to invest resources and take steps in light of this California regulatory deadline. CEA recommends that DOE consult carefully with affected parties on what, at this point, would be a reasonable lead

- in or transition period prior to the effective date of a DOE energy efficiency regulation for battery chargers, given the investments in design as well as product marking that have occurred. CEA understands that the Department’s current rulemaking for battery chargers also includes proposed requirements for external power supplies. Following last year’s public meeting and comment period, there are many unanswered questions and issues awaiting the Department’s response and clarification for both battery charge rs and external power supplies. With this

# Mr. John Cymbalsky

February 7, 2013 Page 2
uncertainty, manufacturers are concerned about DOE’s issuing a final rule with a yet

- to

- be determined effective date. There is an added level of concern if DOE were to depart from the international “Level V” stan dard for Class A external power supplies, which would require a more extensive transition period. The uncertainty over the rules’ effective dates precludes manufacturers from making design decisions. Once deadlines are known, companies can begin to plan for compliance. Companies must assess the scope of products impacted by the proposed requirements and how they relate to product development timelines. Companies must also communicate to stakeholders and suppliers; manage a compliance strategy or strateg ies; conduct testing and address any failures; and manage compliance paperwork and reporting, among other actions. Due to these business requirements and the need for a sufficient implementation period , and in light of the investments that companies have made to meet California ’ s requirements for battery chargers , CEA respectfully requests a Department

- industry dialogue regarding a reasonable implementation timeline and appropriate deadline for the DOE’s forthcoming battery charger system and external power supply regulati ons as they impact consumer electronics. Please let us know how best we can inform and work with the Department in this manner. Sincerely,

Douglas Johnson Vice President, Technology Policy

cc: Mr. Jeremy Dommu, U.S. Department of Energy

# Via hand

- delivery

February 13 , 2013 Mr. John Cymbalsky Supervisor, Appliance Standards Analysis Office of Energy Efficiency and Renewable Energy U.S. Department of Energy Washington, DC 20585 Subject: Importance of a spare parts exemption in regulations for external power supplies

and battery chargers Dear Mr. Cymbalsky: On behalf of the Consumer Electronics Association (CEA), I am submitting additi onal information pursuant to CEA ’ s comments to the D e partment in May 2012 urging DOE to include an exemption for spare and service parts in its forthcoming regulations for battery charger systems and external power supplies , at least as they relate to consumer electronics. In its earlier comments, CEA argued that an exemption for service parts and spare parts would be consistent with the Energy Independence and Security Act of 2007 ( Public Law 110

– 140 ), wh ich included a seven

- year exemption for spare and service parts as part of the Class A EPS requirem ents pr omulgated at that time. CEA noted that seven years is still an appropriate period of time for such an exemption, given manufacturers’ legal and customer service obl igations to stock and supply spare parts for sale, product servicing and warranty claims for existing products using external power supplies.
With this l etter, CEA provides some examples of exter nal power supplies available for sale to consumers as spare or replacement parts

. The examples include product listings from two manufacturers as well as one online retailer. We hope these exa mples help to illustrate the importance of DOE ’ s including a spare parts e xempt ion in its forthcoming regulations. Sincerely,

Douglas Johnson Vice President, Technology Policy

cc: Mr. Jeremy Dommu, U.S. Department of E nergy

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