Page 1

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

 U.S. DEPARTMENT OF ENERGY 

 + + + + + 

 BATTERY CHARGERS TEST PROCEDURE 

 + + + + + 

 PUBLIC MEETING 

 + + + + + 

 TUESDAY 

 JUNE 3, 2014 

 + + + + + 

 The Public Meeting met in Room 8E-089, 

1000 Independence Avenue, S.W., Washington, 

D.C., at 9:00 a.m, Doug Brookman, Meeting 

Facilitator, presiding. 
Page 2

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

PRESENT 

DOUG BROOKMAN, Meeting Facilitator, Power 

 Solutions, Inc. 

LARRY ALBERT, Stanley Black & Decker 

JOSEPH ANDERSEN, Telecommunications Industry 

 Association 

ASHLEY ARMSTRONG, Department of Energy 

ALEX BOESENBERG, National Electrical 

 Manufacturers Association 

JENNIFER CLEARY, Association of Home 

 Appliance Manufacturers 

JOHN CYMBALSKY, Department of Energy 

DAVE DENKENBERGER, ECOVA 

JEREMY DOMMU, Department of Energy 

SANAEE IYAMA, Lawrence Berkeley National 

 Laboratory 

DOUGLAS K. JOHNSON, Consumer Electronics 

 Association 

WAYNE KELSO, Blue Sea Systems* 

MICHAEL KIDO, Department of Energy 

ROBERT KUBIK, Samsung Electronics 

JOHN KUZIN, Qualcomm Incorporated 

MICHAEL LEWAN, Blue Sea Systems 

ERICA LOGAN, Information Technology Industry 

 Council 

PETER PROTOPAPPAS, Navigant Consulting, Inc. 

DOUG RAWALD, Department of Energy 

KEN RIDER, California Energy Commission* 

MIKE RIVEST, Navigant Consulting, Inc. 

DENNY R. SALAS, National Marine 

 Manufacturers Association 

* present by telephone 
Page 3

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

 C-O-N-T-E-N-T-S 

Call to Order and Opening Remarks 6 

 Doug Brookman 

 Facilitator 

Opening Statement 6 

 Ashley Armstrong 

 Department of Energy 

Introductions 7 

Agenda Overview 11 

Opening Statement 13 

 Jeremy Dommu 

 Department of Energy 

Opening Statements from Participants 14 

 Doug Johnson 14 

 Consumer Electronics Association, 

 Information Technology Industry 

 Council, and the Telecommunications 

 Industry Association 

 John Kuzin 18 

 Alliance for Wireless Power 

 Larry Albert 23 

 Senior Technical Manager 

 Stanley Black & Decker 

 On Behalf of the Power Tool 

 Institute 

 Alex Boesenberg 31 

 Manager of Regulatory Affairs 

 National Electrical Manufacturers 

 Association 
Page 4

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

 C-O-N-T-E-N-T-S (CONTINUED) 

History of Test Procedure and Energy 34 

Conservation Standards 

 Jeremy Dommu 

 Department of Energy 

Results and Analyses Summary 42 

 Jeremy Dommu 

 Department of Energy 

 Questions and Comments 54 

 Jeremy Dommu 92 

 Department of Energy 

 Questions and Comments 93 

Lead Acid Battery Testing 104 

 Wayne Kelso 

 Blue Sea Systems 

 On behalf of the National 

 Marine Manufacturers Association 

 Questions and Comments 123 

Request for Information Topics 124 

 Jeremy Dommu 

 Department of Energy 

 Questions and Comments 127 

Testing of Wireless or Inductive 133 

Battery Charges Used in Dry 

Environments 

 Jeremy Dommu 

 Department of Energy 

 Questions and Comments 136 
Page 5

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

 C-O-N-T-E-N-T-S (CONTINUED) 

Adaptive Charging Systems 153 

 Jeremy Dommu 

 Department of Energy 

 Questions and Comments 156 

Questions/Comments and Wrap up 170 
Page 6

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

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

2 9:05 a.m. 

3 FACILITATOR BROOKMAN: Good 

4 morning, everyone. Please take your seats. 

5 Good morning, and welcome. This 

6 is the battery chargers test procedure notice 

7 of data availability public meeting. Today 

8 is June 3rd, 2014, here in the Forrestal 

9 Building in Washington, D.C. My name is Doug 

10 Brookman from Public Solutions in Baltimore. 

11 We are going to start this morning 

12 with welcoming remarks from Ashley Armstrong. 

13 MS. ARMSTRONG: Good morning. 

14 My name is Ashley Armstrong. I 

15 oversee the test procedure development coming 

16 out of the Department's regulatory program. 

17 I would just like to take the time 

18 and welcome you all to our public meeting on 

19 the test procedure for battery chargers. 

20 I do want to say a couple of things 

21 here at the outset. We have gotten a couple 

22 of questions relating to how this proceeding 
Page 7

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 corresponds to our standards rulemaking that 

2 we currently have open. 

3 I just want to say that the purpose 

4 of today's meeting is not to talk about the 

5 standards rule, not to talk about compliance 

6 with standards, not to talk about levels. We 

7 are really here to focus on the method of tests 

8 and ambiguities that may be in the method of 

9 tests. So, we are hoping that you guys will 

10 engage in that discussion and help us have that 

11 discussion. 

12 FACILITATOR BROOKMAN: Okay. 

13 MS. ARMSTRONG: Thank you. 

14 FACILITATOR BROOKMAN: As we 

15 typically do, we will start with introductions 

16 around the room. I will start to my immediate 

17 left. You can get used to turning these 

18 microphones on and off. Your name and 

19 organizational affiliation, please. 

20 MR. JOHNSON: Good morning. Doug 

21 Johnson with the Consumer Electronics 

22 Association, or CEA. 
Page 8

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 MR. KUBIK: Good morning. Rod 

2 Kubik with Samsung. I am here representing 

3 the Alliance for Wireless Power. I am the 

4 Chair of that regulatory group. 

5 MS. LOGAN: Good morning. Erica 

6 Logan with ITI, the Information Technology 

7 Industry Council. 

8 MR. ALBERT: Good morning. Larry 

9 Albert. I work for Stanley Black & Decker, 

10 and I am representing the Power Tool 

11 Institute, PTI. 

12 MR. SALAS: Denny Salas with the 

13 National Marine Manufacturers Association. 

14 MR. LEWAN: Michael Lewan, also 

15 with the National Marine Manufacturers 

16 Association. 

17 MR. BOESENBERG: Alex Boesenberg, 

18 Manager of Regulatory Affairs for the National 

19 Electrical Manufacturers Association. 

20 MS. CLEARY: Jen Cleary with the 

21 Association of Home Appliance Manufacturers. 

22 MR. KUZIN: John Kuzin with 
Page 9

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 Qualcomm. I am here representing the 

2 Alliance for Wireless Power along with Mr. 

3 Kubik who just introduced himself a few 

4 seconds ago. 

5 MR. DENKENBERGER: Dave 

6 Denkenberger, ECOVA. 

7 MR. RAWALD: I'm Doug Rawald from 

8 the Department of Energy's Office of General 

9 Counsel. 

10 MR. KIDO: Michael Kido, Office of 

11 the General Counsel in the Department of 

12 Energy. 

13 MS. ARMSTRONG: Ashley Armstrong, 

14 DOE. 

15 MR. CYMBALSKY: John Cymbalsky, 

16 DOE. 

17 MR. DOMMU: Jeremy Dommu, 

18 Department of Energy. 

19 FACILITATOR BROOKMAN: It is not 

20 on (referring to the microphone). 

21 MR. RIVEST: Mike Rivest, 

22 Navigant Consulting. 
Page 10

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 MS. IYAMA: Sanaee Lyama, 

2 Lawrence Berkeley National Lab. 

3 MR. PROTOPAPPAS: Peter 

4 Protopappas, Navigant Consulting. 

5 FACILITATOR BROOKMAN: And 

6 please, at the back of the room, please stand 

7 and introduce yourself. 

8 MR. RINGEISEN: Blake Ringeisen, 

9 Lawrence Berkeley National Lab. 

10 MS. WISE: Lauren Wise, National 

11 Marine Manufacturers Association. 

12 MR. KAHAN: Chris Skahan, 

13 Navigant Consulting. 

14 MR. TSAO: Allen Tsao, Navigant 

15 Consulting. 

16 FACILITATOR BROOKMAN: Again, 

17 welcome to all of you, and nice to have you 

18 here. 

19 And also, welcome to those joining 

20 us via the web. 

21 Emily, do we have folks joining us 

22 online? Yes? About 21? A good attendance 
Page 11

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 via the web. The Department of Energy is 

2 trying to make these meetings accessible to 

3 all via the web. 

4 All of you received a packet of 

5 information as you came in this morning. I am 

6 going to do a very brief agenda review, which 

7 is on page 2 of your packet. Immediately 

8 following this agenda review, and perhaps a 

9 few slides at the outset, there's an 

10 opportunity for brief opening remarks, brief 

11 statements about issues that you would like to 

12 bring to the fore, the issues that you think 

13 deserve to be called out here at the front-end 

14 of this meeting. 

15 And following that, we will go 

16 directly into the content that is in this 

17 packet, which is the history of test procedure 

18 and energy conservation standards. Moving on 

19 from there, results and analysis summary. 

20 We will probably take a break 

21 mid-morning-ish, round about 10:30 or so. 

22 That is not listed here. 
Page 12

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 Following that, returning from 

2 break, Request for Information topics. And 

3 then, at the end of the day, questions and 

4 comments and wrap up. 

5 There is an opportunity, whenever 

6 we get to it, again, for anybody that wishes 

7 to insert additional information, content, 

8 ask questions, get it all on the record. 

9 Okay. So, that is the purpose of that 

10 segment. 

11 Questions and comments about the 

12 agenda? 

13 (No response.) 

14 Seeing none, I would ask if you 

15 would look on page 1, the simple ground rules. 

16 Please speak one at a time, and if you would 

17 say your name for the record each time you 

18 speak. You don't need to say your 

19 organization affiliation. Some people are in 

20 the habit of doing that. Just your name will 

21 be sufficient. It's up to you. 

22 If you could be concise, share the 
Page 13

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 airtime? We are hoping to get a lively 

2 discussion going here today. Please keep the 

3 focus here. Cell phones on silent mode. 

4 Limit sidebar conversations. 

5 And webinar participants, once 

6 again, we welcome you. Please turn your 

7 telephones on mute, and raise your hand via the 

8 software to be recognized to speak. It has 

9 been pretty consistent lately. Typically, we 

10 can hear you in the room when you do speak. 

11 So, you can join the conversation. 

12 And I think that that is all that 

13 we have here at the outset. Do you want to 

14 make a few comments before we go to opening 

15 remarks? Jeremy Dommu. 

16 MR. DOMMU: Sure. Hi, everyone. 

17 I'm Jeremy Dommu. I am the Project Manager 

18 who is overseeing the test procedure 

19 rulemaking for battery chargers. 

20 Thank you all again for joining us 

21 today. I do hope we have a very lively 

22 discussion, and I welcome you all. 
Page 14

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 I will be facilitating the meeting 

2 through giving a lot of the presentation and 

3 introducing the topics for conversation, 

4 presenting some of the issues that were 

5 originally brought up in the Notice of Data 

6 Availability, which is the subject of today's 

7 meeting. 

8 So, again, please do participate 

9 and provide us with all useful information and 

10 questions. And thank you again for being 

11 here. 

12 FACILITATOR BROOKMAN: Okay. 

13 Thanks. 

14 Now let's proceed with opening 

15 statements, brief remarks here at the outset, 

16 things you wish to bring to the fore as we begin 

17 this meeting. 

18 And if you are representing an 

19 organization, if you would restate that, 

20 please, that would be helpful. 

21 Do you want to start, Doug? 

22 MR. JOHNSON: Good morning again. 
Page 15

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 I'm Doug Johnson of the Consumer 

2 Electronics Association, or CEA. On behalf 

3 of CEA and the Information Technology Industry 

4 Council, ITI, and the Telecommunications 

5 Industry Association, TIA, I wish to focus at 

6 this meeting on our basic support for DOE's 

7 decision to exempt wireless chargers from its 

8 proposed regulation for battery chargers. 

9 We agree that a wireless power 

10 product that meets the battery charger 

11 definition, whether inductive or galvanic, is 

12 a covered product. We further support DOE's 

13 proposal to create a separate product class 

14 for products that use wireless power in a dry 

15 environment to charge consumer products. 

16 DOE properly recognizes this 

17 technology as immature and that the ability to 

18 charge multiple devices simultaneously and 

19 wirelessly offers a unique ability to 

20 consumers which could be adversely affected by 

21 premature setting of standards. 

22 We support DOE's decision not to 
Page 16

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 set standards for these types of products and 

2 to defer such analysis to a later standards 

3 rulemaking as the technology matures. 

4 It is an important part of DOE's 

5 statutory mission to provide for uniform 

6 national standards and regulatory 

7 requirements for such products subject to 

8 DOE's jurisdiction. It is also critically 

9 important that DOE take action as soon as 

10 possible to issue a determination for wireless 

11 chargers under Section 629503(b) of EPCA, that 

12 establishment of a standard will not result in 

13 significant conservation of energy or that the 

14 establishment of such a standard is not 

15 technologically feasible or economically 

16 justified. 

17 This is not only an appropriate and 

18 just result; it is critical and necessary to 

19 fulfill DOE's statutory mission to provide for 

20 uniform and preemptive standards. To 

21 establish standards for certain product 

22 sub-classes while deciding not to pursue 
Page 17

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 standards for other select product classes is 

2 permissible under the law, and it is sound 

3 policy. Other products, such as kitchen 

4 ranges, have been handled in this way. 

5 A contrary approach would be this 

6 dynamic and immature wireless technology is 

7 subject to inappropriate and patchwork state 

8 regulation, with the intended result of 

9 causing far greater harm than even a premature 

10 federal standard for such a product class. 

11 Notably, existing state standards 

12 did not take into account the latest wireless 

13 charging technology when those standards were 

14 promulgated and adopted. If this incipient 

15 product class evolves and grows and becomes a 

16 significant source of energy use, then it 

17 should be considered in the future for a 

18 federal standard. 

19 In summary, given that wireless 

20 charging technology is still in the very early 

21 stages of development and deployment, DOE 

22 should act as soon as possible to finalize its 
Page 18

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 decision not to set standards for wireless 

2 chargers, as is appropriate and compelled by 

3 EPCA or Section 629503(b). 

4 FACILITATOR BROOKMAN: Thank you. 

5 Additional comments here at the 

6 outset? Yes, please. 

7 MR. KUZIN: Following on to what 

8 Mr. Johnson just testified about, I'm John 

9 Kuzin, on behalf of the Alliance for Wireless 

10 Power. 

11 The Alliance for Wireless Power 

12 was very pleased in March of 2012 when the DOE 

13 proposed to defer regulation of wireless 

14 battery charges when it put forward energy 

15 efficiency regulations for wired battery 

16 chargers. DOE chose to do so for all the right 

17 reasons that are just as relevant today. The 

18 technology is in a very early stage of design 

19 and development, and premature regulation 

20 would stymy innovation and have other 

21 unintended consequences. 

22 Wireless charging technology is 
Page 19

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 still in its infancy. Dozens of wireless 

2 charging technology developers and equipment 

3 makers, many of whom are members of the 

4 Alliance for Wireless Power. The Power 

5 Matters Alliance, the Wireless Power 

6 Consortium, and other groups are developing 

7 innovative means of wirelessly charging all 

8 types of battery-powered devices from 

9 Smartphones and Smart Watches to cell phones 

10 and tablet computers, to Bluetooth headsets 

11 and hearing aids. The list goes on and on. 

12 The technology is being designed 

13 to charge devices as efficiently and quickly 

14 as possible because charging time and battery 

15 life are key market differentiators. 

16 Wireless charging also provides consumers 

17 with ready access to easy means of recharging 

18 batteries. There is something to be said 

19 about ready access to multiple convenient 

20 charging options, for it helps to ensure that 

21 the devices are available to be used, when 

22 necessary, such as for placing an emergency 
Page 20

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 call when you are experiencing or witnessing 

2 an emergency situation. 

3 Wireless charging technology is so 

4 useful because it makes charging easy. 

5 Simply place a device on a charging pad or a 

6 properly-equipped bedroom bureau, automobile 

7 console, or office desktop, and the device 

8 charges. 

9 While plugging your electronic 

10 device into the wall is not a difficult task, 

11 many consumers forget to do so when they get 

12 to the office or home or hop in their cars. 

13 And this is not surprising because these are 

14 environments where individuals are focused on 

15 doing other things. 

16 Wireless charging also will 

17 provide environmental benefits. To the 

18 extent they replace wired chargers over time, 

19 wireless chargers will lessen the landfill 

20 impact of the many millions of wall warts that 

21 are disposed of when Americans buy new 

22 electronic devices. 
Page 21

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 For these reasons, it is 

2 critically important that the DOE issue a 

3 determination for wireless chargers under 

4 Section 629503(b) of EPCA that establishment 

5 of a standard will not result in significant 

6 conversation of energy or that the 

7 establishment of the standard is not 

8 technological feasible or economically 

9 justified. Such a determination would have 

10 preemptive effect and allow the technology to 

11 be developed and deployed without damaging 

12 state restrictions such as those presently in 

13 place in California and Oregon and in other 

14 states in the future. 

15 These state regulations were 

16 imposed on technologies such as the 

17 loosely-coupled wireless chargers that the 

18 Alliance for Wireless Power member companies 

19 are developing before these products were even 

20 on the market. 

21 The states that have imposed 

22 efficient regulations on wireless chargers 
Page 22

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 have provided informal guidance that includes 

2 two exceptions to its rules for wireless 

3 chargers. The wireless charging industry 

4 cannot rely on these exceptions because the 

5 California Energy Commission or the Oregon 

6 Department of Energy may at any time change its 

7 mind and modify its guidance without a 

8 rulemaking. Also, the guidance that these 

9 states currently follow need not be followed 

10 by future states that decide to adopt these 

11 rules in whole or in part. 

12 Either path would have a 

13 detrimental impact on the successful rollout 

14 of wireless charging technology. And 

15 regardless of the exceptions, the fact of the 

16 matter is no standard is warranted because the 

17 technology is so new. 

18 Therefore, and in conclusion, we 

19 respectfully request that DOE make a 

20 determination for wireless battery chargers 

21 pursuant to Section 629503(b) of EPCA. There 

22 is also strong precedent for making such a 
Page 23

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 determination, as we will explain in our 

2 written comments to be filed later this month. 

3 Thank you. 

4 FACILITATOR BROOKMAN: Thank you. 

5 Larry? 

6 MR. ALBERT: Thank you, Doug. 

7 My name is Larry Albert. I'm a 

8 Senior Technical Manager at Stanley Black & 

9 Decker. I am pleased to offer comments on the 

10 NODA on behalf of the Power Tool Institute. 

11 PTI is a trade association of 

12 leading power tool manufacturers in the United 

13 States. We have been very active in providing 

14 ongoing responsible advocacy, promoting 

15 meaningful rulemaking for battery-charging 

16 systems in the United States and Canada. 

17 We have been an active contributor 

18 to battery charging system standards and test 

19 procedure development from the very 

20 beginning. With respect to test procedures 

21 that this is the topic of the conversation 

22 today, we contributed to a great extent to the 
Page 24

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 CEC test procedure, which was the basis for the 

2 DOE test procedure. 

3 And it has also been my pleasure to 

4 be a member of the working group that has 

5 developed the recently-published C31.2, which 

6 is the Canadian adoption of the U.S. DOE test 

7 procedure. That standards committee that 

8 worked on it was committed to creating a 

9 faithful reproduction and standards format of 

10 the DOE regulations that could be used 

11 generally throughout any of the provinces. 

12 The DOE test procedure has been in 

13 force for three years. It has been used for 

14 compliance with the CEC Energy Standards for 

15 over a year. In addition, the use of C31.2, 

16 many of the provinces are in the process of 

17 implementing energy efficiency standards that 

18 are effectively based upon the DOE test 

19 procedure. Any revision to the test 

20 procedure at this point would have a 

21 wide-ranging disruptive impact upon both 

22 manufacturers and these jurisdictions. 
Page 25

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 With regard to the general 

2 questions about the ambiguity of the test 

3 procedure and any consequential problems with 

4 reproducibility or with the repeatability of 

5 the test procedure, our members have not 

6 experienced any issues in this regard. 

7 With respect to DOE's basis for the 

8 concern, which was the apparent discrepancy 

9 between the CEC data and the DOE data, we note 

10 that Navigant's report failed to indicate if 

11 the BCS were purchased within the State of 

12 California or, if it was, was it manufactured 

13 after the effective date of the CEC 

14 regulation? Without this information 

15 specified, there would be no expectation that 

16 the data would be from the same population of 

17 BCs and there would be no reason to question 

18 the inconsistency of the data. 

19 In any case, if there was concern 

20 about the CEC data, it is not clear why the 

21 first course of action would have been not to 

22 contact CEC and determine what the discrepancy 
Page 26

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 was and whether it could be resolved, rather 

2 than perhaps considering systemic issues with 

3 the interpretation of the test procedure. 

4 Another shortcoming of the report, 

5 from our perspective, is that it fails to 

6 mention the total number of cases investigated 

7 and what proportion of those cases actually 

8 resulted in a discrepancy between the CEC and 

9 DOE testing. That would give us an 

10 understanding as to how prevalent the issue 

11 was. 

12 Particularly with respect to the 

13 observation that Navigant made that the BE 

14 value was greater than the E24 value, Navigant 

15 noticed that this occurred in about 1 percent 

16 of the cases in the CEC data. This rate of 

17 occurrence could easily be accounted for in 

18 tests and reporting errors. It seems that any 

19 systemic issue with respect to the 

20 interpretation of the standard would result in 

21 a much larger proportion of discrepant data. 

22 Lastly, with respect to this 
Page 27

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 issue, the Department expressed concern about 

2 how the test procedure for multi-voltage, 

3 multi-capacity, and multi-chemistry, and 

4 multi-voltage and multi-capacity, BCs was 

5 implemented. The concern may have been 

6 provoked by an awareness that the test 

7 procedure requires three separate sets of 

8 data, and that the CEC website reports only 

9 one. 

10 Members report that, while all 

11 three datasets are measured, CEC only provides 

12 a single entry for data. While all three 

13 cases are required to comply under the CEC 

14 regulation, members would typically report 

15 the worst case. 

16 While we see how data reported this 

17 way might raise eyebrows, it is not itself a 

18 reflection upon any ambiguity of the test 

19 procedure, but, rather, CEC's choice on how it 

20 was reported. 

21 So, overall, with respect to DOE's 

22 concern about ambiguity, reproducibility, and 
Page 28

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 repeatability of the testing, PTI finds no 

2 basis for concern. 

3 Other questions, DOE asked other 

4 questions. PTI would like to offer comment at 

5 this time about DOE's question regarding the 

6 subject of dry wireless charging. While our 

7 members' products to the great extent do not 

8 employ these charging methodologies, we are 

9 concerned that this question may obscure more 

10 meaningful distinction; that is, the 

11 distinction between proprietary charging 

12 methods and a more universal charging 

13 standard. 

14 We see no major obstacles in 

15 applying the test procedure to products that 

16 employ this methodology as long as there can 

17 be a proper selection of the appliance with the 

18 charging base. With proprietary systems, 

19 this is a straightforward determination. 

20 However, there are wireless 

21 charging systems utilizing open standards, 

22 such as you heard today, and, in addition, the 
Page 29

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 Qi standard from the Wireless Power 

2 Consortium. These wireless charging systems 

3 provide a universal, well-defined, open 

4 wireless charging standard for both the 

5 charger base and the device to be charged that 

6 can be implemented by many products across 

7 many manufacturers. 

8 This necessarily creates issue in 

9 the selection of battery and charger in the 

10 test procedure, as this procedure currently 

11 requires selection from among those batteries 

12 or devices specifically recommended for use 

13 with the charger. In many cases, a battery 

14 charger manufacturer may not produce a product 

15 to be charged with these open standards, 

16 right, with the reverse also being true. 

17 By this same distinction, other 

18 universal methods, such as USB-based chargers 

19 and potentially other future charging 

20 methods, whether wired or wireless, should be 

21 reflected by common treatment. This 

22 certainly appears based upon early public 
Page 30

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 adoption of these methods, that this could 

2 reflect a general trend moving ahead that 

3 could have considerable positive impact on 

4 national energy usage relative to proprietary 

5 methods. It is possible that power tools may 

6 someday have such a charging method. By this 

7 perspective, the distinction is not wireless 

8 or wired, but, rather, universal versus 

9 proprietary. 

10 This also raises an important 

11 regulatory question. Would it be preferable 

12 from a national energy usage perspective to 

13 have fewer, more universal chargers in lieu of 

14 a multitude of proprietary chargers? 

15 We recommend that DOE not try to 

16 force universal charging platforms, wired or 

17 wireless, based upon a standard to be tested 

18 to the existing test procedure until it has 

19 been analyzed for the impact of any such 

20 regulation. 

21 Overall, PTI believes there is no 

22 necessity to revise the current BCS test 
Page 31

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 procedure at this time and would be very 

2 concerned with the disruptive effect that any 

3 revision might create. 

4 Thank you for affording us the 

5 opportunity to address these important 

6 issues. We will supply written comments 

7 before the end of the month. 

8 FACILITATOR BROOKMAN: Thank you, 

9 Larry. 

10 Alex Boesenberg? 

11 MR. BOESENBERG: Thank you, Doug. 

12 As I mentioned, I am Alex 

13 Boesenberg. I am the Manager of Regulatory 

14 Affairs for the National Electrical 

15 Manufacturers Association. 

16 On behalf of my member companies, 

17 we want to thank the Department for having 

18 today's meeting and for reopening an 

19 opportunity to further comment on and improve 

20 the accuracy and repeatability of the test 

21 procedure. 

22 My members' concerns are centered 
Page 32

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 on making sure that the flexibility of the test 

2 procedure allows it to be applied accurately 

3 and effectively to a wide range of products, 

4 particularly the products that we provide 

5 which are flexible, both in terms of the type 

6 of charging power or battery chemistries 

7 involved and, also, with respect to the fact 

8 that, while the devices in question might 

9 charge a battery, they also perform numerous 

10 other consumer-demanded features as part of 

11 their operation. And we hope to help improve 

12 the test procedure in those respects to make 

13 sure that we are measuring accurately and 

14 fairly the amount of power used for battery 

15 charging while taking into account there is 

16 power consumption for other services. 

17 Thank you. 

18 FACILITATOR BROOKMAN: Thank you. 

19 Additional comments here at the 

20 outset? 

21 (No response.) 

22 One or two individuals did not get 
Page 33

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 a chance to introduce themselves here at the 

2 outset. Let's do that now. Please say your 

3 name and organizational affiliation. 

4 MR. ANDERSON: Hi. Joseph 

5 Anderson with the Telecommunications Industry 

6 Association, and we will be submitting written 

7 comments. 

8 FACILITATOR BROOKMAN: Thank you. 

9 You have no opening statement? 

10 Okay, then, I guesses no 

11 additional opening statements. We are going 

12 to move on to the content in the packet. 

13 Oh, sorry, I missed you. Please. 

14 MR. LEWAN: That's all right. 

15 My name is Michael Lewan with the 

16 National Marine Manufacturers Association. 

17 We are lucky to have a technical 

18 expert join us remotely from the West Coast 

19 this morning on webinar, Wayne Kelso with Blue 

20 Sea Systems. 

21 FACILITATOR BROOKMAN: Uh-hum. 

22 MR. LEWAN: I'm not sure if Wayne 
Page 34

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 would like to chime-in right now with a brief 

2 opening statement and, then, provide more 

3 technical comments later on this morning. 

4 FACILITATOR BROOKMAN: Okay. 

5 And there will be plenty of opportunity for 

6 technical comment as we proceed through this 

7 packet. 

8 So, Wayne, it is your choice. If 

9 you like to make brief statements now, please 

10 unmute your phone and speak. 

11 He hasn't signed on yet? Okay. 

12 So, he will be joining, I presume. 

13 Okay. So, then, let's proceed 

14 with the content you see in the packet. 

15 MR. DOMMU: Hi, everyone. 

16 This is Jeremy Dommu again. 

17 So, thank you all for your opening 

18 remarks and we could proceed into some of the 

19 agenda items for today's public meeting. 

20 Doug has already gone through many 

21 of the agenda items that we plan to tackle 

22 during the meeting this morning, but you could 
Page 35

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 see them up here again on the screen, and they 

2 are also included in the packets that you all 

3 have in front of you. 

4 Listening via the webinar, I think 

5 Doug covered most of these issues of 

6 stakeholders who are participating via the 

7 webinar. So, I welcome all of you as well, and 

8 I am glad that you have had the opportunity to 

9 participate remotely. 

10 So, that brings us here to really 

11 the purpose of today's public meeting. So, as 

12 Ashley started off in the beginning, the focus 

13 of today's public meeting is on the test 

14 procedure, and we want to ensure that the test 

15 procedure is being applied in a uniform 

16 method, and that it is unambiguous and it is 

17 clear, and it is repeatable, representative, 

18 and reproducible. 

19 So, kind of throughout the meeting 

20 today, we are going to present some of the data 

21 that we have come across through our own 

22 testing and explore a number of other issues, 
Page 36

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 in the hopes of getting feedback and comment 

2 to ensure that the test procedure is meeting 

3 our objectives. 

4 So, we will present some of our own 

5 test data that is based on testing that we 

6 conducted and compared to the 

7 publicly-available data. And we did note 

8 some discrepancies between our test data and 

9 what is publicly available, specifically for 

10 multi-voltage, multi-capacity battery 

11 chargers. So, we hope to explore that issue 

12 with you and uncover any reason or ambiguities 

13 on why some of our test data may be different, 

14 as a result of the way the test procedure is 

15 being applied. 

16 We also want to make sure and 

17 ensure that the test procedure is clear, 

18 followed in the same way; that if multiple 

19 entities are testing the same battery, that 

20 the results are similar, as to be expected. 

21 And if they are not, we want to explore the 

22 reasons why they aren't. We hope to really 
Page 37

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 have a level playing field. So, when a 

2 battery is being tested by multiple entities, 

3 that the same test results are being achieved. 

4 So, we will be inviting comment on 

5 that test data, on a number of other issues 

6 that were presented in the Notice of Data 

7 Availability. And we invite participants to 

8 provide any summary comments or statements. 

9 And also, we will have an opportunity to raise 

10 additional items for discussion. So, that is 

11 the purpose of the meeting. 

12 So, I will jump now into some of the 

13 history of the test procedure and the energy 

14 conservation standards, and really explain 

15 how we got here. So, originally, the Energy 

16 Policy and Conservation Act, which was first 

17 enacted in 1975, although subsequently 

18 amended a number of times, established the 

19 Energy Conservation Program for Consumer 

20 Products Other Than Automobiles. Subsequent 

21 amendments to EPCA authorized DOE to regulate 

22 the energy efficiency of additional types of 
Page 38

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 consumer products, which include battery 

2 chargers. 

3 So, from that law, DOE began its 

4 rulemaking with a test procedure, as we 

5 typically do to establish a way to measure the 

6 energy consumption or energy efficiency of a 

7 consumer product, in this case the battery 

8 charger. 

9 So, the final rule which 

10 established the battery charger test 

11 procedure was finalized in December of 2006 

12 and has subsequently been amended in June 2011 

13 to add additional tests, such as an 

14 active-mode energy consumption test. So, 

15 that was the last time in June 2011 that the 

16 test procedure was amended. 

17 So, here is kind of the history of 

18 both the test procedure and the standards 

19 rulemaking. As I just mentioned, the test 

20 procedure was finalized in 2011. It was 

21 finalized initially in 2006 and, then, amended 

22 in 2011. 
Page 39

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 And then, on the standards side, we 

2 have been engaged in rulemaking to consider 

3 the promulgation of energy conservation 

4 standards for battery chargers. That effort 

5 began in 2009 with a standards framework 

6 document, continued in 2010 with a standards 

7 preliminary analysis. 

8 In 2012, March 2012, and we have 

9 already heard a couple of stakeholders allude 

10 to the State DOE had proposed efficiency 

11 standards for battery chargers at that time. 

12 But, to date, those standards have not yet been 

13 finalized, and DOE continues to defer and 

14 consider if and when and how we would continue 

15 that rulemaking. 

16 We did, however, request 

17 information in 2006 on any potential market 

18 changes that may have impacted the initial 

19 analysis that we performed when we first 

20 proposed conservation standards of battery 

21 chargers. 

22 In 2014, we finalized a rulemaking 
Page 40

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 for external power supplies. And that is 

2 noteworthy because, up until that point, we 

3 were considering both external power supplies 

4 and battery chargers with the same rulemaking. 

5 And just a few months ago, in February of 2014, 

6 we finalized the external power supply portion 

7 of that rule while deferring for further 

8 consideration the promulgation of standards 

9 for battery chargers. 

10 So now, it is June 2014 and we are 

11 here to discuss the Notice of Data 

12 Availability on the battery charger test 

13 procedure. So, we can ascertain whether the 

14 test procedure remains repeatable and 

15 accurate and unambiguous. 

16 It should be noted that in February 

17 of 2013 manufacturers were required to begin 

18 meeting standards for battery chargers in the 

19 State of California. And these California 

20 Energy Commission standards rely on DOE's test 

21 procedure for their testing and 

22 certification. 
Page 41

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 So, this slide here is on the test 

2 procedure objectives. And I think this is an 

3 important slide to consider because this is 

4 the objectives that we look at. 

5 When we go about our process of 

6 considering a test procedure, we want to 

7 ensure that a test procedure meets these 

8 objectives: 

9 That it is repeatable, meaning 

10 that when it is performed multiple times, that 

11 you are getting the same results, and that it 

12 is reproducible. When various different 

13 entities perform the test procedure, they 

14 would also receive the same results. 

15 That it is representative, meaning 

16 that it actually represents the energy 

17 consumption or efficiency of the product being 

18 tested. 

19 That it does not create any undue 

20 burden in terms of time or money to conduct the 

21 test. 

22 That we anticipate technology 
Page 42

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 changes. That the test procedure remains 

2 applicable, even as technology changes. 

3 That it discourages 

4 circumvention, so manufacturers do not have 

5 any loopholes or other means to obtain results 

6 that will not be applicable under the test 

7 procedure. 

8 That it is unambiguous. That it 

9 is clear. That everyone understands how it 

10 should be followed. 

11 Where applicable, we aim to 

12 harmonize with any related test procedures. 

13 And then, finally, that it is 

14 consistent with our statutory authority. 

15 So, today we really want to make 

16 sure and ensure that these objectives are 

17 being met, and, if not, we are seeking input 

18 on how it can be improved or clarified to meet 

19 all of these objectives. 

20 So, that is our introduction. And 

21 I now will proceed into the next phase of our 

22 public meeting, where we will go over some of 
Page 43

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 our own test results that we have achieved and 

2 tested, specifically for multi-voltage, 

3 multi-capacity battery chargers. 

4 So, as we have stated, when DOE 

5 originally proposed standards for battery 

6 chargers in 2012, we proposed standards that 

7 would achieve the maximum improvement in 

8 energy efficiency that is 

9 technologically-feasible and 

10 economically-justified. But, since the time 

11 of that analysis, the California Energy 

12 Commission standards have come into effect, 

13 and they have now been in effect for over a 

14 year. 

15 So, we did some testing to see if 

16 any revision to our analysis is necessary. 

17 So, we tested a couple of battery chargers to 

18 just get a better understanding of if any 

19 technology has changed or if things are new, 

20 to help us determine whether if that analysis 

21 needed to be revised. 

22 So, when we did that testing, we 
Page 44

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 noted some ambiguities, and we put out this 

2 notice in order to present our test data 

3 compared to the test data that is available in 

4 the California Energy Commission database, so 

5 we could see if stakeholders could enlighten 

6 us at all and provide information to us on 

7 where the test procedure may be ambiguous or 

8 if clarity needs to be provided to make sure 

9 that the test procedure is being applied 

10 across the board in a similar manner. 

11 So, we looked at the CEC database 

12 and we selected some models for testing. And 

13 we purchased those models and tested them, 

14 based on the model numbers that appeared in the 

15 CEC database. 

16 So, the way that we tested these 

17 batteries, when we did our testing, and the way 

18 that we reported it was the model was for a 

19 battery charger only. And this battery 

20 charger unit may be sold on its own, a la carte, 

21 like the way we purchased it, but it is also 

22 possible that this same battery charger could 
Page 45

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 be sold in a variety of other methods, like in 

2 a kit that includes an end-use application and 

3 a battery or multiple end-use applications and 

4 multiple batteries. 

5 So, given that we selected the 

6 battery and purchased the battery for testing 

7 a la carte, we followed how we believed the 

8 test procedure is written to test this 

9 battery. And that section refers to the 

10 method for battery selection based on the 

11 sections in the test procedure and the tables 

12 in the test procedure that deal with testing 

13 these types of batteries. 

14 And we realized that battery 

15 selection does have a significant impact on 

16 testing. So, we are interested in learning 

17 whether the discrepancies in our test results 

18 are potentially related to which battery was 

19 selected to test these battery chargers. 

20 So, when applicable, we purchased 

21 battery chargers with detachable batteries a 

22 la carte, and therefore, we purchased the 
Page 46

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 batteries separately. 

2 So, here on the next slide, this is 

3 an excerpt from the test procedure. And the 

4 test procedure, I think there are copies of it 

5 in front of all of you, if you are not familiar 

6 with it off the top of your head. But it is 

7 also in the Code of Federal Regulations. It 

8 is on regulations.gov, and you could find a 

9 link to the test procedure on our website. 

10 But what it essentially says here 

11 is, for battery chargers with integral 

12 batteries, which means that the battery is not 

13 removable from the battery charger, then you 

14 would test the battery package with the 

15 charger. Simple enough. 

16 But the issue comes up of how to 

17 select the battery when there is a detachable 

18 battery, and that depends, according to the 

19 test procedure, on whether there are any 

20 batteries packaged with the battery charger. 

21 So, the test procedure here says 

22 that, if batteries are packaged with the 
Page 47

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 charger, batteries for testing shall be 

2 selected from the batteries packaged with the 

3 battery charger, according to the procedure in 

4 4.3.b, which essentially refers you to Table 

5 4.1 to select batteries. And I will show you 

6 4.1 on the next slide. 

7 But, in bold here, No. 2 under 

8 4.3.a.2, it says, "If no batteries are 

9 packaged with the charger" -- and that was the 

10 case with the battery charger that we 

11 selected -- "but the instructions that 

12 accompany the battery charger specify or 

13 recommend batteries for use of the charger, 

14 batteries for testing shall be selected from 

15 those recommended or specified under the 

16 instructions, according to the procedure in 

17 4.3.b," which refers you to Table 4.1. 

18 And then, it goes on and explains, 

19 "If no batteries are packaged with the charger 

20 and the instructions don't recommend or 

21 specify what batteries to use, then you would 

22 test with any batteries that are suitable for 
Page 48

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 use with the charger." And again, you would 

2 use this Table 4.1, which I will show you right 

3 now. 

4 Here's Table 4.1. So, this table 

5 is really used if the charger is either 

6 multi-voltage, multi-port, multi-capacity, 

7 depending on whether it has those features, 

8 meaning multi-voltage means it could charge a 

9 battery with multiple voltages. Multi-port 

10 means it could charge multiple batteries at 

11 once. Multi-capacity means that it is 

12 capable of charging batteries in multiple 

13 capacities. 

14 Depending on that, you would refer 

15 to this chart, and each row here on this chart 

16 is mutually-exclusive. So, any single 

17 battery charger only one row should apply. 

18 So, in this case we tested, the 

19 battery that we tested was a multi-voltage, 

20 multi-capacity battery. And because of that, 

21 we would go down to the last line on this table, 

22 which would instruct us to conduct three 
Page 49

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 tests. And the three tests would be to test 

2 the battery charger of the batteries with the 

3 lowest voltage that the battery charger could 

4 test; use the one with the lowest charge 

5 capacity, using only one port. 

6 Of the batteries with the highest 

7 voltage, use the one with the lowest charge 

8 capacity, using only one port. 

9 And then, finally, the third test 

10 would be to use all ports and use the 

11 configuration of the batteries with the 

12 highest total rated energy capacity. 

13 And so, those were the three tests 

14 that this Table 4.1 would specify for a 

15 multi-voltage, multi-capacity battery 

16 charger. 

17 And here are our test results. 

18 So, you could see here on this slide the test 

19 results that we got. 

20 First, actually, on the top is the 

21 CEC database data. This is the data that is 

22 from the CEC database for this battery 
Page 50

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 charger, noting the 24-hour energy, the power 

2 and maintenance mode, the power and standby 

3 mode, and the battery energy. 

4 And then, here's our data below. 

5 And you could see our data here aligns to the 

6 different tests that we conducted. So, it 

7 says "Battery 1," which happened to be a 

8 nickel-cadmium battery, a NiCd battery. That 

9 is the battery with the lowest voltage and the 

10 lowest charge capacity. 

11 And then, Battery 2 is the battery 

12 with the highest voltage and lowest charge 

13 capacity. 

14 And Battery 3 was the battery we 

15 selected that met the criteria use all ports 

16 and use the battery or configuration of 

17 batteries with the highest total rated energy 

18 capacity. 

19 And it should be noted that this 

20 battery charger specifically is also capable 

21 of charging multi-chemistry batteries. So, 

22 that means that the battery charger control 
Page 51

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 could charge batteries of multiple 

2 chemistries. 

3 And the test procedure in the table 

4 doesn't exactly specify what to do here. So, 

5 we tested both a NiCd and a lithium ion battery 

6 that met the criteria for using all ports and 

7 testing the battery or the configuration of 

8 batteries with the highest total rated energy 

9 capacity. 

10 So, when we compared the results of 

11 those three different tests, although the 

12 third one we tested two different batteries, 

13 we compared them to the CEC database, and we 

14 were not able to determine based on our test 

15 data or replicate the data that was available 

16 in the CEC database. 

17 So, we, then, tested a couple of 

18 additional batteries, just to see if we could 

19 also come close. And you can see the results 

20 in front of you here for the data that we got 

21 from our testing compared to the CEC data. 

22 So, this was one model of testing. 
Page 52

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 This is the results for Model 1 that we tested, 

2 and it is replicated from the Notice of Data 

3 Availability. 

4 We, then, tested a second model. 

5 In this case it was essentially a similar 

6 battery charger in that it also was 

7 multi-voltage, multi-capacity. The one 

8 difference here is, of the batteries that were 

9 recommended to be used with this battery 

10 charger, the battery with the highest voltage 

11 and the lowest charge capacity happened to 

12 also be the battery that had the highest total 

13 rated energy capacity. And, as such, that 

14 battery met the criteria for both that second 

15 and third test. And that is why you only see 

16 two of the tests, because one of those 

17 batteries that we tested met both criteria. 

18 And again, you could see here the differences 

19 in the test data from our tests and the data 

20 that was available in the CEC database for this 

21 battery. 

22 So, those are our test results. I 
Page 53

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 think at this time we are going to have a couple 

2 of questions that I want to open up to the floor 

3 to see if we can get some insight on. And 

4 there are a couple. I think maybe it would 

5 make the most sense to just kind of go through 

6 these issues, and then, I could open up the 

7 floor for comment on any specific one or 

8 multiple ones that anyone may have. 

9 So, the one question we have is how 

10 a battery is being selected when testing 

11 multi-voltage, multi-capacity chargers. It 

12 is a potential that that is a reason why we were 

13 not able to replicate the results in our 

14 testing. So, we want to just learn a little 

15 bit more about how manufacturers may be 

16 charging these types of batteries. We would 

17 hope that that information could help get at 

18 some of the differences that may have resulted 

19 in the way that we applied the test procedure. 

20 So, we are just really looking for that 

21 feedback. 

22 The multi-chemistry issue of, you 
Page 54

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 know, if the battery charger is capable of 

2 charging multi-chemistry batteries, are there 

3 any differences that we would need to consider 

4 in that case for testing a battery charger? 

5 So, that is within Issue 1. 

6 FACILITATOR BROOKMAN: Jeremy, 

7 let's take them one at a time. 

8 MR. DOMMU: Okay, sure. 

9 FACILITATOR BROOKMAN: Yes, 

10 there's a lot of content here, potentially at 

11 least. 

12 And so, do you wish to start? Yes. 

13 MR. DENKENBERGER: Dave 

14 Denkenberger, ECOVA. 

15 And sorry, I neglected earlier to 

16 mention that I am representing the California 

17 Investor-Owned Utilities. 

18 If you could go back to the first 

19 one, could you tell us how many ports? 

20 MR. DOMMU: Yes. My 

21 understanding is that there was only a single 

22 port in this battery charger. 
Page 55

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 MR. DENKENBERGER: Okay. Is that 

2 true for the second one as well? 

3 MR. DOMMU: Yes. 

4 MR. DENKENBERGER: Okay. 

5 FACILITATOR BROOKMAN: I am 

6 noting that the consultant from Navigant is 

7 nodding his head yes. Yes. 

8 So, there you see the question. 

9 How are the batteries being selected? How is 

10 the test procedure being applied for chargers 

11 capable of capable of charging 

12 multi-chemistry batteries? 

13 The data does seem to suggest that 

14 there is a lot of variability here. How do we 

15 explain this? 

16 Larry, do you want to start? 

17 MR. ALBERT: Just the question 

18 that has been posed, though, is just how are 

19 batteries being selected under multiple 

20 capacity. I think Jeremy's answer before is 

21 clear, that there is a defined and 

22 mutually-exclusive selection criteria that is 
Page 56

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 already in the test procedure. And I don't 

2 see that there is any ambiguity in applying the 

3 rule. 

4 FACILITATOR BROOKMAN: So, you 

5 think that the rates described in the test 

6 procedure, that there is no ambiguity? It is 

7 really clear how people are going to come to 

8 choose these batteries? 

9 MR. ALBERT: I think, given a 

10 population of batteries, there is one and only 

11 battery for each of those cases, unless you 

12 just happen to meet, as in the second case, the 

13 requirements for both. 

14 With respect to the second part of 

15 that question, with respect to chemistry, 

16 there is no mention of chemistry in the test 

17 procedure, right? And so, therefore, it is 

18 essentially blind to chemistry. So, reason 

19 to make a distinction on one basis or another, 

20 the way the test procedure is written today. 

21 FACILITATOR BROOKMAN: Ashley 

22 Armstrong? 
Page 57

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 MS. ARMSTRONG: This is Ashley 

2 from the Department. 

3 To your last point, I think that 

4 gets to DOE's question of, is there a need to 

5 distinguish? Because, clearly, what we have 

6 shown by our test results are that we get 

7 different answers for different chemistry 

8 batteries. And so, how is that being applied? 

9 Are those being reported differently? It 

10 seemed to us that they were under the same 

11 model number. How should those be paired for 

12 testing? What are you doing now? You are 

13 reporting to California. So, what are you 

14 doing now to either pair them or test them or 

15 get your representative values? 

16 MR. ALBERT: Just to be clear, we 

17 follow the test procedure. I think most 

18 people would follow the test procedure, and 

19 whichever ones fulfill those requirements, 

20 independent of chemistry, would be the one 

21 that you would test with, right? I don't 

22 think there is any ambiguity about it, right? 
Page 58

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 The test procedure wasn't written 

2 being sensitive to chemistry, right? It was 

3 a clear decision at the time that the test 

4 procedure was written, and then, the 

5 subsequent NOPR, right, that there was not 

6 going to be any distinction with respect to 

7 chemistry? 

8 And so, since we don't have a 

9 standard at this point, right, there is no way 

10 of interpreting how test results could affect 

11 whether a product complies or doesn't comply 

12 with an efficiency standard. So, the only 

13 efficiency standard we have is the CEC 

14 standard, right? And, you know, their 

15 determination as to whether a product complies 

16 or not is based upon the results that they 

17 obtain when they accept test data from 

18 manufacturers to test themselves. 

19 Sorry, I am not quite 

20 understanding what specifically what the 

21 issue is. 

22 FACILITATOR BROOKMAN: Okay. 
Page 59

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 Well, we are interested in getting additional 

2 comments related to Issue 1. Any thoughts? 

3 Maybe they diverge from Larry's experience on 

4 how batteries are being selected and how the 

5 test procedure is being applied. Because, 

6 clearly, there is a lot of variability in the 

7 test results. 

8 Alex Boesenberg? 

9 MR. BOESENBERG: Alex Boesenberg 

10 from NEMA. 

11 To answer your question, 

12 Larry -- right? 

13 MR. ALBERT: Yes. 

14 MR. BOESENBERG: -- and I 

15 apologize if I cannot speak deeply technically 

16 about this, because we have only had the 

17 opportunity to speak about it a few times. 

18 And I am not a battery charger expert, but I 

19 am an engineer. 

20 FACILITATOR BROOKMAN: Which gets 

21 you points in this room. 

22 MR. BOESENBERG: Thank you. 
Page 60

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 My members have alerted me to a 

2 condition where, depending on the selection 

3 and pairing of the battery and the charger, and 

4 the way the test procedure is written, 

5 particularly in specifying discharge and 

6 charge cutoffs, there are cases where, due to 

7 protection circuitry in a battery, you can 

8 create a condition that causes the battery to 

9 self-terminate. It is a safety feature. 

10 That may or may not indicate a 

11 misapplication of the test procedure. I am 

12 still sort of ferreting that out. It may end 

13 up being an issue more so for the standard at 

14 that time when we simply specify that, if the 

15 battery self-terminates, you have to run the 

16 test again a different way. We particularly 

17 don't want to see that as a failure of the test. 

18 That is a proper application of the safety 

19 feature. 

20 However, if I can identify a way 

21 that satisfies my different members, and we 

22 will also be coordinating with ITI and others, 
Page 61

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 if we think we can come up with a solution that 

2 avoids self-termination, of course, we will 

3 submit that in our written comments. 

4 Thank you. 

5 FACILITATOR BROOKMAN: Okay, 

6 Alex. Thank you. That's a start on what 

7 appears to be the mystery at this point. 

8 Additional comments on how we 

9 might describe these ambiguities, this 

10 variability? 

11 I am looking over at you, Erica. 

12 You have nothing to add at this point? 

13 MS. LOGAN: No, unfortunately 

14 not. I'm in a similar situation to Alex, that 

15 we are just starting to analyze this further, 

16 but we have similar concerns about the battery 

17 self-terminating. 

18 But looking at the data that Jeremy 

19 presented, there is a wide range there for 

20 sure, and that is disconcerting. So, there 

21 must be something related to battery chemistry 

22 as well. 
Page 62

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 FACILITATOR BROOKMAN: Yes. 

2 MS. LOGAN: But, anyway, we need 

3 to analyze it further. Concern, you know, 

4 intellectual property and protection of 

5 confidential business information, if we try 

6 to parse chemistries, is, of course going to 

7 be an issue. But, somehow, we have got to make 

8 this reproducible. So, we need to come up 

9 with a recommendation. 

10 FACILITATOR BROOKMAN: Thank you. 

11 Thank you. The Department certainly welcomes 

12 that. 

13 Larry? 

14 MR. ALBERT: So, the question was, 

15 when this discrepancy was observed, did the 

16 Department contact CEC and ask to resolve the 

17 discrepancy between the data they had reported 

18 and the data that the Department had measured? 

19 That seemed to be an obvious first step. 

20 Okay? 

21 MR. KIDO: Michael Kido, DOE. 

22 I am not going to comment on what 
Page 63

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 communications, if any, we might have had with 

2 CEC. Just in terms of looking at the data and 

3 our intentions to try to understand how the 

4 test procedure is actually be applied kind of 

5 raised these particular questions, which is 

6 kind of why we are here. 

7 So, I am not going to speak to how 

8 CEC might have interpreted any of these data 

9 points. I am sure someone from CEC is 

10 listening right now. So, I am not going to 

11 speak to their views on this. 

12 MR. ALBERT: And the Department 

13 only investigates attached pack battery 

14 chargers or did you look at other battery 

15 charger systems in your survey? I mean, how 

16 many different systems did you actually survey 

17 during your data collection process? 

18 MR. KIDO: I am going to defer to 

19 some of our technical folks. I think, based 

20 on the information that we already disclosed, 

21 I think that is the universe of what we did 

22 examine. 
Page 64

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 MR. ALBERT: Two charging 

2 systems? 

3 MR. KIDO: I think so, but I am not 

4 sure if there are others. 

5 FACILITATOR BROOKMAN: Peter? 

6 MR. PROTOPAPPAS: We selected -- 

7 FACILITATOR BROOKMAN: By the 

8 microphone, Peter. Say your name for the 

9 record. 

10 MR. PROTOPAPPAS: This is Peter. 

11 Okay. We selected over 60 units 

12 to apply the DOE test procedure to. Of those 

13 60, there was a lot of variability between the 

14 DOE test results and the CEC database. These 

15 are the most egregious. There may be a few 

16 more we could pick out, but these were a good 

17 example of the concerns that we have. 

18 MR. ALBERT: These were all 

19 detachable battery pack cases? 

20 MR. PROTOPAPPAS: No, they are 

21 integral systems, detachable systems. They 

22 range a wide range of product classes, Product 
Page 65

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 Class 2 through 6. 

2 MR. PROTOPAPPAS: Okay. So, the 

3 general data has not been published by 

4 Navigant or the Department, right, of the 

5 entire survey of data? 

6 MR. PROTOPAPPAS: That's correct. 

7 I mean, we could publish it. 

8 MR. ALBERT: Okay. So, you only 

9 focused on these two cases, right? 

10 FACILITATOR BROOKMAN: Alex 

11 Boesenberg? 

12 MR. BOESENBERG: This is Alex 

13 Boesenberg from NEMA. 

14 I wonder if you considered or asked 

15 the question, or I would suggest that you look 

16 into the concept that the CEC database, since 

17 it is input by manufacturers, they may have 

18 been conservative in their reporting. And an 

19 actual tested unit may not reflect what is in 

20 the database. Ideally, an actual tested unit 

21 will have better results, and there is some 

22 variation in self-reporting because of the 
Page 66

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 business decisions, et cetera. 

2 MS. ARMSTRONG: Alex, I think that 

3 would be one possible explanation, if that is 

4 the trend we are seeing. We are seeing the 

5 other way. 

6 MR. BOESENBERG: Okay. 

7 MS. ARMSTRONG: And so, you are 

8 seeing, as Peter -- so, these examples that we 

9 are showing highlight what we think are some 

10 of the largest ambiguities potentially in our 

11 test procedure, which is why we want to have 

12 a conversation about what combinations you 

13 guys are choosing to test and, then, report to 

14 California, and how that maps up with the 

15 multiple tests that have to be done pursuant 

16 to our test procedure. 

17 Because when we execute the tests, 

18 we are not -- I mean, even if you were to 

19 conservatively rate, we are not coming up with 

20 those numbers. The number in the CEC is lower 

21 than is supported by the testing at this point 

22 in time. 
Page 67

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 So, the Department potentially 

2 there was some test procedure interpretation 

3 issues and some clarity that need to be gained. 

4 We also get a number of questions from a number 

5 of different stakeholders. So, we are trying 

6 to just learn here. What is being done now? 

7 How are people coming up with the data that 

8 they input? 

9 It is our understanding that all 

10 our battery chargers that we have purchased 

11 and subsequently tested were supposed to be 

12 compliant with the California standards, to 

13 your question earlier; did match the model 

14 numbers being reported in the database, and 

15 were manufactured after the compliancy of the 

16 California standard. 

17 MR. ALBERT: And were purchased in 

18 the State of California? 

19 MS. ARMSTRONG: Like I said, it is 

20 my understanding that they were supposed to be 

21 compliant with the CEC standards, and I'll 

22 leave it at that. 
Page 68

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 FACILITATOR BROOKMAN: That's 

2 Larry. 

3 Mike Rivest, do you want to comment 

4 here? 

5 MR. RIVEST: Yes. I think one of 

6 the reasons for not putting all the data is we 

7 want to use a few examples to see legitimately 

8 if there are areas of misunderstanding before 

9 creating all sorts of issues and alarming 

10 people, right? I mean, it may be that out of 

11 the issues that we find a lot of the so-called 

12 discrepancies will be quickly resolved. And 

13 then, we can focus on what remains. So, for 

14 a lot of them, there are not big differences 

15 in start with. It may be that by the end of 

16 this meetings we will know what the causes are. 

17 MR. BOESENBERG: Alex Boesenberg, 

18 NEMA. 

19 Ashley, thank you for that extra 

20 information. I appreciate that expanded 

21 awareness that provides. 

22 And I should state NEMA tends to 
Page 69

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 favor commercial products. As a result, a lot 

2 of my members have not yet completed redesigns 

3 because commercial products are not required 

4 to meet the California standard yet. So, with 

5 respect to California, I will shut up now. 

6 FACILITATOR BROOKMAN: Okay. 

7 Yes, Larry, please. 

8 MR. ALBERT: Larry Albert again. 

9 So, the question, then, is that 

10 within the State of California the requirement 

11 is to comply with the requirement of the 

12 standards, right, the regulation? And the 

13 regulation requires that the products offered 

14 for sale in the State of California have to 

15 meet the requirements. 

16 I am a little concerned about the 

17 notion that what the database represents is a 

18 rating of energy efficiency, right? Because 

19 I don't think it was ever intended or stated 

20 that way. It was just stated that CEC is 

21 providing all the different model numbers, for 

22 whatever reason that they saw fit, but the 
Page 70

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 requirement is that we comply. 

2 And clearly, in the case of the 

3 charging you measured that would not comply 

4 with the batteries that you selected within 

5 the State of California. That is not to say 

6 that that charger with the batteries that are 

7 available in the State of California would not 

8 comply, right? 

9 And so, if this is a surveillance, 

10 I guess, of compliance, right, that is one 

11 thing. If it is a question about whether 

12 ratings are adhered to, there is no 

13 anticipation that there is a rating of energy 

14 efficiency associated with these chargers. 

15 So, I guess that is one of the 

16 concerns here, and that ties in a little bit 

17 sort of tangentially with Issue No. 2. When 

18 we use the term "rating," right, what are we 

19 talking about here? Because I don't think 

20 there is any expectation that there is ratings 

21 applied. 

22 FACILITATOR BROOKMAN: I don't 
Page 71

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 think we are done with one yet. I want to stay 

2 on one because no one yet has described, I 

3 don't think, any of the variability. 

4 And, Larry, as we were waiting to 

5 get through security this morning, you told me 

6 you were an electrical engineer. 

7 MR. ALBERT: That is true. 

8 (Laughter.) 

9 FACILITATOR BROOKMAN: I don't 

10 want to put you on the spot, but what about 

11 Alex's idea that discharge and charge cutoff 

12 could skew these results? 

13 MR. ALBERT: Discharge/cutoff is 

14 addressed in the test proceeding, right? 

15 FACILITATOR BROOKMAN: It is. 

16 MR. ALBERT: Yes, it is addressed 

17 under 5.8.c(3), right? And then, where 

18 specifically it addresses, if the current 

19 continues to be drawn -- when the discharge 

20 bolt is used the circuitry terminates the 

21 discharge, right? So, I mean, in several 

22 cases it does address the reality that modern 
Page 72

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 battery systems have end-of-discharge-type 

2 termination circuitry, if that is what Alex is 

3 referring to or if he is referring to charge 

4 termination circuitry. 

5 FACILITATOR BROOKMAN: So, just 

6 to be clear, the purpose of this meeting today 

7 is to see if we can get to the bottom of all 

8 this variation in these results. So, I am 

9 really hoping that we can just really explore 

10 that as best we can. 

11 I have a comment from Daniel Baston 

12 who has joined us online. And he says, "One 

13 of the largest variances is the actual 

14 battery. From all of my testing, I have seen 

15 well over 10 percent delta between batteries 

16 of the same manufacturer and model." Ten 

17 percent. 

18 Additional thoughts on Issue No. 

19 1? 

20 (No response.) 

21 Then, let's move to Issue No. 2. 

22 "What rating is used for battery energy when 
Page 73

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 multiple batteries are tested?" 

2 Doug? 

3 MR. RAWALD: This is Doug Rawald. 

4 If we could follow up from what you 

5 mentioned before, Larry, I would like to 

6 explore that a little bit more. 

7 So, just to give you some 

8 framework, the Department of Energy has our 

9 database that we have for products that we 

10 cover where we collect information for 

11 products that are certified as compliant. As 

12 part of that, the manufacturer who certifies 

13 compliance reports to us their rated value for 

14 what their product will perform at. 

15 As Alex mentioned, manufacturers 

16 can rate conservatively. So, your product 

17 can be better performing than you would say to 

18 us, but you want to rate conservatively 

19 because you want your product line to perform 

20 at least as well as what you are telling us it 

21 is going to perform at. 

22 So, our understanding is the 
Page 74

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 values reported to California would, 

2 similarly, be ratings of what the product that 

3 they are saying is compliant will perform at. 

4 And it sounds to me like you are saying that 

5 is not the case. So, I would like to explore 

6 that a little bit more with you. 

7 MR. ALBERT: This is Larry Albert 

8 again. 

9 So, I don't think in the California 

10 Energy Commission regulation there is any 

11 obligation to report a rated value. The 

12 obligation is to comply with the limits, 

13 right? And there is an obligation to report 

14 your test data, right? 

15 So, unless the DOE develops a 

16 standard, right, that, in fact, requires 

17 manufacturers to rate and report the rated 

18 value, right, then there would be no 

19 expectation that the numbers that you are 

20 reading in the CEC database represented 

21 anything close to a rating. 

22 MS. ARMSTRONG: So, can I ask you 
Page 75

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 a question then? 

2 FACILITATOR BROOKMAN: Ashley 

3 Armstrong. 

4 MS. ARMSTRONG: This is Ashley 

5 from DOE. 

6 What are you putting in the 

7 database? What is that number? 

8 MR. ALBERT: Whatever the CEC 

9 tells us to report, which I believe is the test 

10 data. 

11 MS. ARMSTRONG: So, that should 

12 match -- I mean, we are comparing that number 

13 to test data that we tested ourselves, 

14 correct? So, there will be some variances, 

15 but it should be similar, in the ballpark. 

16 MR. ALBERT: This is Larry again. 

17 But Doug's question before was 

18 related to DOE's past experience with 

19 establishing energy efficiency ratings, which 

20 could be conservatively reported, right? It 

21 is not necessarily test data. Test data has 

22 to be within the ratings, correct? 
Page 76

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 MR. RAWALD: So, I guess I want to 

2 make my terminology really clear because I 

3 definitely don't want to cause confusion. 

4 So, what we consider to be your 

5 rating is what the manufacturer reports to be 

6 the fullness of their product. So, the 

7 standard, which requires a minimal rating of 

8 some sort or a maximum for a consumption-type 

9 item, but what you rate your product is not 

10 what we say the standard is in our estimation. 

11 So, a manufacturer, say, reports 

12 their product is 95 percent efficient. The 

13 standard could be 90 percent, but the rating 

14 that the manufacturer has said to us is 95, if 

15 I am making myself clear on that point. 

16 MR. ALBERT: It's Larry again. 

17 It is clear that the question 

18 really is that you are applying sort of the DOE 

19 sensibility to another jurisdiction which has 

20 its own rules established, right, for how the 

21 information is to be presented and what 

22 constitutes compliance on the part of the 
Page 77

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 people being regulated. 

2 So, if the CEC regulation doesn't 

3 require any of that, there is no expectation 

4 on your part that what you are seeing reported 

5 is a rating. And so, if that is what you want, 

6 then I think you need to write a standard that 

7 says we want a rating, right, and do it that 

8 way. But that is not necessarily what CEC is 

9 requiring, right? So, if you are 

10 interpreting it that way, you may be 

11 misinterpreting it, right? 

12 FACILITATOR BROOKMAN: I 

13 understand that Ken Rider, who is online, has 

14 a comment at this point. 

15 Ken, unmute your phone, and I think 

16 we probably can hear you. 

17 MR. RIDER: Can you hear me all 

18 right? 

19 FACILITATOR BROOKMAN: You sound 

20 great. 

21 MR. RIDER: Yes, this is Ken Rider 

22 from the California Energy Commission. I 
Page 78

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 just wanted to add a couple of things to this 

2 conversation. 

3 The first is in terms of the test 

4 results that we collect in the database. The 

5 idea is to inject three separate tests for 

6 these types of products. In test mode, it's 

7 important to collect, we set up, post some of 

8 the regulations, we need our code there for 

9 manufacturers to submit. 

10 I believe that the highest 

11 results, and to speak the under- and 

12 over-reporting, it does allow padding of 

13 results toward numbers that would show less 

14 efficiency or higher energy consumption. It 

15 is not what, I think the DOE's additional test 

16 data shows. 

17 With our variety, I think it is 

18 pretty clear, at least from I think Example 1, 

19 that the test was not run correctly. I mean, 

20 we can see -- and we will get to this later, 

21 I think, about the battery energy was larger 

22 than the charger energy. 
Page 79

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 The other thing I see in both 

2 examples is that the standby power is 

3 different, significantly different, way 

4 outside of the normal areas, and that doesn't 

5 even have every chemistry or some variant as 

6 to what it contributes to differences between. 

7 And that, to me, is a more alarming result and 

8 more red flags to me about inconsistency in 

9 applying the federal test procedure. And 

10 maybe that was incorrectly run. 

11 One thing that I have come across 

12 in looking at the report is an inconsistency 

13 in how the discharge test is run to measure the 

14 battery energy. In some cases the battery was 

15 conditioned and, then, also, initially 

16 discharged, and it was not consistent with the 

17 federal testing procedure, but what some 

18 manufacturers have done that, or test labs, is 

19 to actually do the initial discharge before 

20 the charge using the product itself to 

21 discharge rather than battery analyzer, as 

22 required by the test procedure. 
Page 80

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 And so, that led to some 

2 inconsistent measurements of battery energy 

3 and charged energy. And I will get more into 

4 that when we get into that issue of differences 

5 of energy where the battery energy was larger 

6 than the 24-hour energy. 

7 FACILITATOR BROOKMAN: Okay. 

8 Ken, thank you. And I should note that you 

9 were kind of breaking up intermittently as you 

10 were speaking. So, I am not sure quite what 

11 that is. But, anyway, I'm not sure quite what 

12 that was, but maybe when you join us later, you 

13 can get a -- I don't know whether you are doing 

14 voice-over-internet or what. Anyway, maybe 

15 you can find a clearer land line or something. 

16 MR. RIDER: We will try. 

17 FACILITATOR BROOKMAN: Larry, it 

18 looks like you were leafing through your 

19 papers. Do you have some additional thoughts 

20 on this? 

21 MR. ALBERT: I would just like to 

22 ask, can Ken hear me if I ask him a question? 
Page 81

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 FACILITATOR BROOKMAN: Yes, Ken 

2 can hear you, yes. 

3 MR. ALBERT: So, Ken, you 

4 mentioned that you have an observation that 

5 some of the differences may be as a result of 

6 how the battery is discharged, and it is not 

7 being done in accordance with the test 

8 procedure? 

9 MR. RIDER: Yes, there's been a 

10 few cases of that. I mean, we are trying to 

11 keep our data clean. And when we see things 

12 like the issue by the DOE in trying to look into 

13 what are the issues with our manufacturers. 

14 MS. ARMSTRONG: Just to be 

15 clear -- this is Ashley from DOE -- I think he 

16 is saying, indeed, in data he collects for CEC 

17 there are instances where he has found his own 

18 issues, not necessarily in the specific data 

19 we presented on the fly for DOE testing. 

20 FACILITATOR BROOKMAN: Okay. 

21 MR. RIDER: Correct. 

22 FACILITATOR BROOKMAN: Yes. Okay. 
Page 82

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 Thank you for that clarification, Ashley, and 

2 also you, Ken. 

3 Back to you, Larry. 

4 MR. ALBERT: No, that's fine. 

5 FACILITATOR BROOKMAN: That's 

6 enough? Okay. 

7 MS. ARMSTRONG: So, I do want to 

8 follow up on something that both Larry 

9 mentioned and Ken mentioned on the phone. 

10 And this is Ashley. 

11 It seems to me that you guys are 

12 both indicating that the test data that you end 

13 up entering into the California database 

14 should be representative of the number of 

15 tests pursuant to Table 4.1, the most 

16 conservative number or the highest energy 

17 consumption combination of the tests that you 

18 are required to do for a given model that is 

19 sold in the State of California. Do I have 

20 that correct? Is that what manufacturers are 

21 currently doing? 

22 FACILITATOR BROOKMAN: Larry? 
Page 83

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 MR. ALBERT: So, Larry. 

2 So, as you can see in the case of 

3 the last line of the table, you are required 

4 to do three independent, three separate tests, 

5 right? And so, there is only one line for 

6 recording that data in the sheet that CEC 

7 provides. And so, we have to comply with all 

8 three cases. So, the question of compliance 

9 is not at issue, just the question of 

10 reporting, right? 

11 We choose what we would call the 

12 worst case, right, and that's what we will 

13 report, right? But it doesn't mean that we 

14 don't comply with the other two cases. 

15 FACILITATOR BROOKMAN: Is that 

16 specified in the test procedure, that you just 

17 choose the worst case? 

18 MR. ALBERT: No, it's not. 

19 Again, the test procedure tells you how to test 

20 it. CEC has rules for both the regulation, 

21 which says you have to comply, and they, 

22 additionally, have requirements for people 
Page 84

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 who register their products with CEC in terms 

2 of how they want to report it, right, which 

3 falls outside of the test procedure, right. 

4 So, it is a very different kind of 

5 thing, right? And, again, if CEC has issues 

6 with manufacturers and how they are reporting 

7 it, then that is an agreement between CEC and 

8 those manufacturers, right? So, it is not 

9 necessarily a misapplication of the test 

10 procedure. 

11 FACILITATOR BROOKMAN: So, if you 

12 are testing three batteries and you are only 

13 reporting one, do you think that accounts for 

14 the discrepancies or it contributes to the 

15 discrepancies we are observing here? 

16 MR. ALBERT: No. Well, I am just 

17 saying that one obvious question that DOE 

18 might have asked themselves is, obviously, you 

19 need to test three. Why is there only one, 

20 right? And so, that alone would have probably 

21 raised the flag, right, and so, independent of 

22 the question of whether the numbers match up 
Page 85

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 or anything else like that. 

2 FACILITATOR BROOKMAN: Okay. 

3 MR. RAWALD: Doug Rawald. This 

4 is Doug. 

5 I do want to say that is a question 

6 that came up, and we were able to find out from 

7 the web page that that is an input issue that 

8 we were aware of from our office point of view. 

9 I do want to get back to the rating 

10 discussion that we had earlier. Because what 

11 I heard from Ken seemed to marry up with what 

12 I was saying that we thought, which is that 

13 manufacturers report to us a value, and they 

14 report to CEC a value they obtain from the test 

15 data. And they can, of course, as he called 

16 it "padding," we call it "conservatively 

17 rate". So, you can say, "Oh, it performed 

18 less well than my test data showed." 

19 But what we are concerned about is 

20 when we see data that is better than what our 

21 testing would show. In this case what we have 

22 here, as Ashley pointed out, is data from the 
Page 86

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 CEC database seems to be better than what we 

2 can achieve from testing. And so, we would 

3 consider that to be a rating, devoid of there 

4 being a standard out, we consider a rating test 

5 what you get from your testing or you lower 

6 rate to pad it a little bit. So, that is kind 

7 of where we are coming from. 

8 MR. ALBERT: And again, I don't 

9 want to belabor the point, but our 

10 understanding is that, just even from what Ken 

11 said, while that may be an option, it is not 

12 a requirement, right? Manufacturers may or 

13 may not just simply report the data they 

14 receive from testing, right, so that they can 

15 show a clear line from the test results that 

16 they acquired in the laboratory to what they 

17 reported to CEC. 

18 CEC, as far as I understand it, has 

19 not established a requirement that you have a 

20 rating and that all subsequent testing falls 

21 within that rating, which may be the case with 

22 other rules within DOE, right? 
Page 87

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 So, again, I don't know if your 

2 expectation is what you are seeing in the 

3 website, is that that's rating data, and 

4 therefore, you expect all field-tested units 

5 to fall within that, right. I don't believe 

6 that is a reasonable expectation based upon 

7 how CEC has arranged their -- and I don't want 

8 to speak for them because, obviously, I don't 

9 work for them, right. 

10 MR. RAWALD: So, if I can just ask 

11 one follow up? I think I am seeing where we 

12 are here. 

13 It is that the value reported to 

14 CEC doesn't necessarily, in the opinion 

15 of -- that's what I hear you expressing -- have 

16 to be representative of the actual model line, 

17 that tested units can perform worse than that 

18 value that is being reported to CEC as long as 

19 they have test data supporting that they got 

20 that value in testing one unit of that model 

21 and to report to the CEC. 

22 MR. ALBERT: My understanding of 
Page 88

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 our relationship with CEC, right, is that we 

2 measure data within the laboratory and report 

3 that data, right, as accurately as possible, 

4 right. And so, while there is a provision 

5 perhaps that that data could be padded, as Ken 

6 would say, right, manufacturers are not 

7 obliged to follow that. They can fulfill 

8 their obligation to CEC just by the 

9 straightforward reporting of whatever they 

10 measured, providing that that data is, in 

11 fact, measured of the proper unit, and so on, 

12 and is compliant with the standard. 

13 Of course, CEC conducts, I'm sure, 

14 field surveillance, right, in which case they 

15 take units from the manufacturers in the State 

16 of California and determine whether those 

17 units also comply. I don't know that there is 

18 an implied obligation that the data that they 

19 record from their testing matches the data 

20 that is reported in the database. At least 

21 they have never explicitly stated that to us, 

22 right? 
Page 89

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 It is just that the product needs 

2 to comply in the field. It needs to comply 

3 with the reported data. There is no explicit 

4 statement on the part of CEC, as I understand 

5 it, right, that that constitutes what DOE 

6 would normally consider a rating. 

7 MR. RAWALD: Right. And this is 

8 Doug. 

9 So, just to give a number for this, 

10 if the standard was 70 and the manufacturer 

11 reported 90 and the CEC result was an 80, that 

12 would be not a problem in their mind because 

13 it is still above the 70. That is what we are 

14 getting at, I think, in our discussion. 

15 MR. ALBERT: Yes, that is my 

16 understanding, yes. 

17 MR. RAWALD: Okay. Okay. Now I 

18 understand what you're saying. Thank you. 

19 FACILITATOR BROOKMAN: Okay. 

20 John? Oh, pardon me. Dave? 

21 MR. DENKENBERGER: Dave 

22 Denkenberger. 
Page 90

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 Maybe to make this concrete as 

2 well, just looking at the battery 1 result, 

3 battery energy being 8.68 watt hours and 

4 24-hour energy being 39.56, I am pretty sure 

5 that would not be in compliance with the CEC 

6 regulation. 

7 FACILITATOR BROOKMAN: Doug 

8 Rawald? 

9 MR. RAWALD: And this is Doug. 

10 I want to be very sensitive to the 

11 fact that we don't want to delve into whether 

12 folks are complying or not with the California 

13 standard because, first of all, it is not our 

14 bailiwick, and secondly, that is not the focus 

15 of this. 

16 We just want to understand how 

17 there could be differences in the results from 

18 what we are getting from our testing versus 

19 what is reported in that CEC database. So, I 

20 do want to not go down the path of compliance 

21 with the California standards. 

22 MR. DENKENBERGER: Okay, but just 
Page 91

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 as an example, you know, that is an example of 

2 being the opposite of conservative. That is, 

3 if the true case were that first line, it is 

4 not consistent with reporting to the CEC. 

5 FACILITATOR BROOKMAN: Larry? 

6 MR. ALBERT: Larry again. 

7 So, yes, I agree, obviously, 

8 right? 

9 MR. DENKENBERGER: Okay. 

10 MR. ALBERT: But, then, as we 

11 mentioned earlier on, it is not clear that the 

12 unit that was acquired by DOE was, in fact, 

13 purchased within the State of California and 

14 manufactured after the effective date, right? 

15 If it wasn't, then there is no expectation that 

16 they would be compliant, right? If it was, 

17 then perhaps the manufacturer was 

18 non-compliant and should be reported, right? 

19 But, in any case, it doesn't 

20 necessarily reflect on a shortcoming of the 

21 test procedure with respect to its R&R, right? 

22 Because the differences are so great here, 
Page 92

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 right, that it would be hard to believe we are 

2 talking about, in fact, the same product, 

3 right? 

4 FACILITATOR BROOKMAN: Okay. 

5 Thank you, Larry. 

6 Should we move on to Issue 2? 

7 Three? 

8 Do you want to cue up Issue 3? 

9 MR. DOMMU: Sure, yes. 

10 So, Issue 3 is really we are 

11 asking, how do we solve this? Is the test 

12 procedure okay to test these type of 

13 batteries? Are changes needed? Do the 

14 results of the test procedure ensure that we 

15 are going to get accurate, consistent results 

16 when testing these types of batteries? Or are 

17 there any specific recommendations that would 

18 be necessary to accommodate testing of these 

19 types of battery charges to make sure that the 

20 testing is repeatable; it is being conducted 

21 in the same manner by all labs? 

22 So, here we are just really opening 
Page 93

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 up the floor and asking, what could we do 

2 better? How could we improve the test 

3 procedure to make it so we are not finding 

4 these type of variability’s? 

5 FACILITATOR BROOKMAN: And, 

6 Larry, so far, you have said you have implied 

7 you thought it was sufficient. This is your 

8 opportunity to improve it. 

9 MR. ALBERT: So, the first 

10 question is the word "accurate," right? 

11 Generally, when we look at test procedures and 

12 their application, we look at repeatability 

13 and reproducibility, right? 

14 The question of accuracy is a 

15 question as to whether, I guess, does the 

16 number that you derive from the testing, is it 

17 meaningful with respect to whatever ultimate 

18 standards you create, right? 

19 So, if the question really is about 

20 what we would call R&R, right, that is 

21 repeatability and reproducibility, right, we 

22 believe that the test procedures sufficiently 
Page 94

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 need to show that with the same population of 

2 charger and battery pack. In the case of 

3 detachable systems, right, you would always 

4 select the same ones, right? You would always 

5 test it the same way. 

6 In terms of repeatability of the 

7 testing, that would be if you had exactly the 

8 same unit and battery packs, would you get the 

9 same numbers if you repeated the test over and 

10 over again? The answer is that has been our 

11 experience. You get that within the normal 

12 experimental error associated with the 

13 standard, right? 

14 Variation from unit to unit is 

15 another question entirely, right, which is not 

16 addressed in the test procedure. And the 

17 question of accuracy is really the question 

18 that Jeremy introduced earlier on with, is the 

19 test procedure representative, right? But 

20 that is really more of a question of what is 

21 the standard that is going to be used, what is 

22 the standard ultimately that will use the data 
Page 95

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 from the test procedure? That would be the 

2 only way of establishing, is the question of 

3 whether it is representative or not. 

4 MS. ARMSTRONG: This is Ashley 

5 from DOE. 

6 I am going to take it back to Doug's 

7 point earlier. So, I don't think DOE at this 

8 point is concerned with is it accurate 

9 compared to a given standard level, but do we 

10 have a method of test that provides enough 

11 guidance, enough specificity for 

12 manufacturers to come up with a rating? 

13 And I realize there seems to be 

14 some disagreement about whether or not the 

15 representations being made to California do 

16 actually represent ratings or not. But, 

17 then, the question becomes, is the method 

18 accurate in determining the rating? It is not 

19 about a standard level. It is about the 

20 number you choose to represent your product's 

21 efficiency. And I think there is a very clear 

22 difference there. 
Page 96

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 MR. ALBERT: This is Larry again. 

2 If the Department were to 

3 establish a requirement that manufacturers 

4 state a rating, right, in which case the 

5 manufacturer would say, "We have this 

6 efficiency level," right, then the test 

7 procedure would be satisfactory in being able 

8 to achieve that because manufacturers would 

9 ensure that all of the products that they would 

10 produce, right, even though they might have 

11 some part-to-part variation, right, would 

12 fall within that rating, right? 

13 However, that is not the 

14 requirement right now at the federal level, 

15 and it does not appear to be the case at the 

16 California level, right? So, the question 

17 right now is, if I take a particular unit and 

18 I test it, and I test that same unit again, do 

19 we get the same numbers? And our experience 

20 has been, yes, that is the case, right? 

21 FACILITATOR BROOKMAN: So, you 

22 don't see any real opportunities for 
Page 97

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 improvement that you would like to see, since 

2 we have an open question about how the testing 

3 is done, how variability could or would be 

4 diminished? You don't see any potential for 

5 improvement in the test procedure? That 

6 doesn't sound like an engineer to me. 

7 (Laughter.) 

8 MR. ALBERT: I would say that the 

9 ultimate requirement for the test procedure is 

10 does it satisfy the requirements of the 

11 standard, right? We don't have a standard. 

12 And so, it is hard to judge the suitability of 

13 the test procedure in the absence of that, 

14 right? 

15 FACILITATOR BROOKMAN: Doug 

16 Rawald? 

17 MR. RAWALD: So, I want to talk 

18 about this from a level devoid of the standard. 

19 I think the existence of a standard shouldn't 

20 affect the ability of a test procedure to come 

21 up with a representative value for the actual 

22 model itself. 
Page 98

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 So, we rely upon testing of 

2 individual units to come to an assessment of 

3 how does the actual overall model line 

4 perform. And so, the question is, does the 

5 test procedure that we currently have in place 

6 get to a number that represents how the entire 

7 model itself functions and performs? And it 

8 sounds like you are saying in your experience 

9 it does, but it is not necessarily a 

10 requirement that it does. Now I want to be 

11 clear about that first. 

12 MR. ALBERT: Okay. So, to be 

13 clear -- this is Larry again -- the test 

14 procedure does not require you to establish a 

15 rating. It just requires you to conduct the 

16 test. Okay? 

17 You come up with a number. If you 

18 test a bunch of different units of the same 

19 model number, you are going to going to get 

20 variation, just because of manufacturing 

21 variation, right? 

22 If there was a requirement that you 
Page 99

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 had to fulfill a certain standards level, 

2 right, then the manufacturer would have to 

3 make sure that that variation was constrained 

4 enough, right, that all of the units that they 

5 were to produce would fall within the 

6 limitations of the standard, right? 

7 If the Department said, "You have 

8 to come up with a rating and you can never 

9 exceed that rating," right, then that is 

10 another requirement, right? And again, 

11 manufacturers could comply with that using 

12 this test procedure. 

13 All the test procedure does is 

14 test, right? It doesn't itself make the 

15 representation, right? 

16 The question of representation, 

17 which I believe is a question of, does it 

18 represent a meaningful representation of the 

19 energy efficiency or consumption of energy, 

20 right, is truly not what this test procedure 

21 does, right? It just generates some numbers 

22 which can be used subsequently in a standard, 
Page 100

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 right, to establish whether you comply or you 

2 don't comply. 

3 That standard, for example, the 

4 standard that was offered up to the NOPR, 

5 right, does not yet exist, right? CEC has 

6 their own standard that uses the same test 

7 procedure, right, but uses it in a way 

8 differently than what the NOPR had conceived, 

9 right? 

10 And neither of them seem to require 

11 at this point, anyway, the declaration on the 

12 part of the manufacturer of a rating, right? 

13 And if that was the requirement, then 

14 manufacturers would comply, right? 

15 FACILITATOR BROOKMAN: Yes, we 

16 have a comment or a question from Spencer 

17 Stock, who asks, "It was maintained earlier 

18 that 60 models were tested and that these two 

19 models were the most `egregious,'" 

20 quote/unquote. "Were most of the other 58 

21 models more in line with DOE testing, and these 

22 two models are a case of mis-testing or 
Page 101

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 misreporting by the manufacturers?" 

2 We are just about due for a break. 

3 So, let's take a break. And when we return 

4 from the break, Wayne Kelso has a comment. 

5 So, it is now 10:30. Let's take a 

6 break for 15 minutes. 

7 Let me remind you -- most of you are 

8 familiar with the protocol here -- you must 

9 wear a badge while you're walking around. 

10 There are restrooms on both ends of 

11 the hall. There is coffee shop on the ground 

12 floor, if you get on the elevator, go down to 

13 the ground floor, just about beneath us on the 

14 other side of the hall. 

15 So, we made a good start on it, and 

16 we will see you back here. We will resume at 

17 10:45. 

18 (Whereupon, the foregoing matter 

19 went off the record at 10:31 a.m. and went back 

20 on the record at 10:47 a.m.) 

21 FACILITATOR BROOKMAN: Okay, 

22 let's resume. 
Page 102

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 Thanks, all of you, for a good 

2 start this morning. 

3 Just before we broke, Spencer 

4 Stock asked this question, and I am going to 

5 read it again. 

6 "It was mentioned earlier that 60 

7 models were tested and that these two models 

8 were the most," quote, "`egregious,'" 

9 unquote. "Were most of the other 58 models 

10 more in line with DOE testing, and these two 

11 models are a case of mis testing or 

12 misreporting by the manufacturers?" 

13 Ashley Armstrong? 

14 MS. ARMSTRONG: So, this is 

15 Ashley. 

16 So, the data from the 60-model 

17 suggests variances across the board. There 

18 were some that were pretty closely aligned 

19 with the data we saw reported. There were 

20 some that were slightly different, either 

21 above or below. There were some that were 

22 further off. We just picked these two 
Page 103

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 examples they highlight some of the larger 

2 questions or the larger potential ambiguities 

3 in our test procedure as discussion points. 

4 So, I don't have the data in front 

5 of me to tell you "X" number were off by this 

6 much, but the data was kind of all over the map, 

7 I think, is the less technical way to say it. 

8 FACILITATOR BROOKMAN: Okay. 

9 So, I guess, then, did you get the information 

10 you needed? Thank you. 

11 Then, when we left, we were on 

12 Issue No. 3, and Jeremy Dommu said this is an 

13 opportunity to generally speak to the test 

14 procedure, talk about ways to improve it, talk 

15 about ways you do the test, and how that could 

16 be different, or how DOE should be doing the 

17 test procedure that it is not doing now. 

18 And before we leave Issue No. 3, 

19 let's see if we have any additional comments 

20 in that direction. 

21 (No response.) 

22 Nothing additional. Okay. So, I 
Page 104

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 guess we will move on, then, with the content. 

2 MR. DOMMU: Okay. So, welcome 

3 back everybody. We are going to move on in the 

4 public meeting to talk about three other 

5 issues that we are soliciting -- yes? 

6 MR. SALAS: Sorry, before the 

7 break, I know Wayne wanted to submit a comment 

8 and question. 

9 FACILITATOR BROOKMAN: Oh, thank 

10 you, and I forgot that. I apologize. Wayne 

11 Kelso, I apologize to you. You have a 

12 comment, and please unmute your phone and 

13 speak. 

14 MR. KELSO: Good morning. 

15 FACILITATOR BROOKMAN: Good 

16 morning. 

17 MR. KELSO: Wayne Kelso, Blue Sea 

18 Systems and the National Marine Manufacturers 

19 Association. 

20 I prepared a short presentation 

21 which we may or may not have an opportunity to 

22 look at, specifically with lead acid 
Page 105

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 batteries. But the discrepancies you were 

2 seeing with NiCd suggest some of the same 

3 effects are in play. So, this is very 

4 nuts-and-bolts technology. 

5 But the issues are that, when we 

6 tested a la carte chargers certainly, but all 

7 of the tests are not testing battery chargers. 

8 They are testing battery chargers and 

9 batteries as a system. That may or may not be 

10 the intention, but it is the effect. 

11 And when you get to an a la carte 

12 charger, the manufacturer has no influence 

13 over the source and type of battery, you would 

14 introduce a host of variables. In the case of 

15 lead acid batteries, they are very ill-suited 

16 to being discharged in five hours to a power 

17 level of zero. 

18 They are very sensitive to their 

19 prior handling, so as we see, may be 

20 introducing huge variables, how long they have 

21 been stored, how they have been treated prior 

22 to that. 
Page 106

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 And finally, there is a big 

2 discrepancy in the power at the tail. And if 

3 you go back to your table with concern on the 

4 NiCd batteries, I think we are seeing the same 

5 effect. 

6 If you notice, there is -- well, 

7 you are correct there. That is good. 

8 If we look at the largest NiCd 

9 battery, suddenly the maintenance power is 

10 going way up. Depending on the nature of the 

11 charger, with lead acid batteries we would 

12 look at that and say, "Well, we probably 

13 haven't achieved maintenance mode yet," on the 

14 tail of a charging performance and staking 

15 that for maintenance power. And 24 hours, 

16 depending on the charger, may not be enough to 

17 pull this battery completely up and satisfy it 

18 and put it into its maintenance mode. 

19 So, the upside is kind of the gist 

20 of -- I have some slides that are with lead 

21 acid, right? 

22 MR. DOMMU: Yes, you do have the 
Page 107

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 slides. Do you want to go through them now? 

2 MR. KELSO: I will take that, yes, 

3 it is your pleasure. I would be happy to walk 

4 through them. I will try to keep it brief for 

5 everybody because it sounds like there is a 

6 huge diversity of interest. But if you are 

7 willing to do that, this would probably be a 

8 good time. 

9 MR. DOMMU: Yes, sure. Why don't 

10 we give you a couple of minutes to run through 

11 the slide presentation? That would be fine. 

12 MR. KELSO: Okay. So, my 

13 specific interest is lead acid batteries. We 

14 are in the marine battery charger business, 

15 but marine battery chargers, RVs, and police 

16 fire/safety equipment generally end up using 

17 very similar equipment. 

18 And we spoke earlier about the 

19 tests. We said that one of the issues here is 

20 that we support active loads while we are 

21 charging. Charging and discharging are not 

22 so easily distinguished because we are 
Page 108

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 permanently connected to our loads and 

2 permanently connected to the battery charger. 

3 When AC appears, the battery charger takes 

4 over things like alarms and bilge pumps and 

5 refrigerators, and so forth, and goes into a 

6 mode as also being a power supply. 

7 So, we don't get the luxury of 

8 shutting up and going away after the battery 

9 is charged. There's a lot of circuits that 

10 need to keep alive, and that differentiates us 

11 from other applications. 

12 But lead acid batteries are 

13 extremely dominant in this area. I would say 

14 that the lithium and other battery chemistry 

15 made some entry into marine, but it is a little 

16 like saying Lamborghini is a big mention to the 

17 automotive market. They are not on every 

18 corner. 

19 So, the point here, lead acid 

20 batteries are designed and rated for slower 

21 discharge rates in the test methodology, and 

22 few lead acid batteries are designed for full 
Page 109

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 discharge. I would say that none really like 

2 it. 

3 And the charge and discharge rates 

4 have a profound impact on measurable capacity. 

5 So, you end up with your BE number wandering 

6 around when you have a high charge and 

7 discharge rate. 

8 And then, the final charge can be 

9 this slow process where you are actually still 

10 charging the battery. And under the 

11 provisions of the test, we are invited to 

12 assume that we are a maintenance mart, and that 

13 that would represent the power we would use for 

14 the next two weeks if we have been connected. 

15 Next slide, please. 

16 Lead acid batteries are sensitive 

17 to charge and discharge testing. So, I think 

18 these batteries, as we see flaws in there, it 

19 is probably a great source of variability 

20 because different manufacturer, transport, 

21 storage; they seldom arrive fully charged at 

22 the lab. 
Page 110

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 And because they have got some 

2 memory and these are porous surfaces, you have 

3 some of those spaces deep in that structure of 

4 porosity that may not be fully charged and may 

5 not be fully charged at the time that you begin 

6 your first discharge test, and may not readily 

7 recharge when you do your recharge cycle. 

8 They are designed for slower 

9 rates. If you look at standard Battery 

10 Council ratings, they are typically 

11 three-hour discharge, and you can get even 

12 more energy if you discharge more slowly than 

13 that. But their fast discharge leads to a 

14 less-predictable interval recovery. AGM 

15 batteries tolerate that better than flooded 

16 cells, and classic flooded cells are designed 

17 for long, long life in, say, telecomm 

18 applications. 

19 And then, once you apply the 

20 charging period is an issue. And all three of 

21 those can be addressed with relatively-minor 

22 changes in the test. 
Page 111

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 Next. 

2 Okay. First, I think we would 

3 make our batteries preconditioning optional. 

4 I think we need to discuss what constraints we 

5 would put on that preconditioning, but, 

6 basically, you want to begin that test after 

7 having a long and thorough charge because of 

8 the deep porosity in these batteries if you are 

9 going to be predictable. You don't know how 

10 well-charged some of those sites are in the 

11 lead. And my guess is it would be multiple 

12 cycles. 

13 The other thing about the "as 

14 received" problem says that these reusable 

15 batteries become single-use batteries. They 

16 are only as received once. And if you have to 

17 do multiple battery tests, going out and 

18 buying multiple batteries to do those is a 

19 burden. 

20 So, laboratories should at least 

21 set their own quality control to determine the 

22 fitness of batteries. Batteries generally 
Page 112

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 improve over the first 20 to 100 cycles and, 

2 then, become a long, slow deterioration, 

3 depending on the battery, out to the 500 to 

4 thousands of cycles that are typically 

5 recorded at the provision of partial 

6 discharge; they would be worse at zero 

7 discharge. 

8 But the test result will get 

9 progressively worse as the battery wears out. 

10 At some point a laboratory needs to know when 

11 to turn over their inventory of batteries. 

12 Secondly, when we go through that 

13 discharge cycle, we should allow, at least 

14 optionally, the longer period. I heard in the 

15 previous discussion that the five-hour was 

16 chosen to be convenient for the laboratory. 

17 It is not very convenient for a manufacturer 

18 who is now being penalized for the poor 

19 performance of the battery that he didn't 

20 build. 

21 So, alternatively, allow the 

22 discharge out to 20 hours, and I will show a 
Page 113

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 graph that shows that, once you put your 

2 discharge rate out that long, then differences 

3 in how long you take, the difference between 

4 20 hours and 24 hours is relatively minor in 

5 terms of its impact on the tests. So, you take 

6 away one of the variables again. 

7 And so, the best practice in the 

8 marine industry, a recommended battery bank 

9 size is for house batteries to be able to 

10 handle loads for 24 to 48 hours; for the 

11 discharge, for about 85 percent SOC to 45 

12 percent. This is for cruising vessels that 

13 are dependent on their power for some period 

14 before they go back into the marina. 

15 That is only using 40 percent of 

16 battery capacity. If we get over those hours, 

17 the actual way we would use our larger battery 

18 packs of discharge rates where we are C over 

19 60, C over 100. Now most people don't buy 

20 quite that big a battery, but C over 20 is 

21 pretty short. It means that you have to start 

22 up your engine and recharge that battery in the 
Page 114

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 morning. Most people want more than that. 

2 Next, please. 

3 Okay. So, low discharge rates are 

4 superior. They are more repeatable and 

5 generate more accurate results. And how much 

6 loss depends on an exponential function and, 

7 as a result, is difficult to predict. 

8 And I think the engineers in the 

9 room will be familiar with Puekert's equation. 

10 It describes the phenomena that the exponent 

11 is never published. You have your work to 

12 discover it. It varies from battery to 

13 battery, but it shows a dramatic decrease in 

14 power availability if you go to the five-hour 

15 discharge. It gives you a much lower Ebatt 

16 figure than you would actually get under the 

17 application. And that is going to be a whole 

18 lot less Ebatt than the battery manufacturer's 

19 label is going to suggest. 

20 Next. 

21 This somewhat crude-looking curve 

22 I captured from Home Power magazine, 1989, 
Page 115

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 looking at data that is historic, but this is 

2 for lead acid golf cart batteries. 

3 Briefly on that, I direct your 

4 attention down to the lower left corner which 

5 shows discharge curves. And the higher rate 

6 that you would discharge, the higher state of 

7 charge residue you still have in the battery 

8 which you reach the 10.5-volt threshold. So, 

9 if you are stare across the 10.5, you can see 

10 that it is acting at different states of 

11 charge, which is, say, the point of making your 

12 Ebatt affordable, because that shape of that 

13 curve varies dramatically battery-to-battery 

14 and over the battery's life when you are 

15 pushing these high rates and the short 

16 discharge times. 

17 If we look in the upper right 

18 corner, we are looking at the charging regime. 

19 And it really shows that the fellow probably 

20 burned up some batteries, being able to take 

21 this data. But it shows the terrible energy 

22 effects if you, then, control source battery 
Page 116

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 charger up there. 

2 And most modern battery chargers 

3 for lead acid are constant current up to about 

4 the 80 percent charge level, and then, 

5 constant voltage thereafter. So, they take 

6 the trajectory that does not run into that 

7 super-inefficient area. 

8 The distance between these two 

9 curves represents the voltage inefficiency of 

10 the battery. It represents a loss the battery 

11 itself contributes. 

12 And you can see quite a span there. 

13 We are seeing on the order of 2 volts between 

14 the charge and discharge voltage out of 12. 

15 So, right away, you are looking at a 

16 12-to-15-percent loss of battery not in the 

17 charger when you are considering the lead acid 

18 battery. 

19 Next, please. 

20 Okay. So, here specifically I 

21 wanted to look at the discharge efficiency 

22 that we are doing here in the standard. And 
Page 117

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 there is a later flap or later article which 

2 I sent to Jeremy out of this series. This 

3 seems like kind of a faulty technical source, 

4 but people will take in a lot of data that is 

5 very, very useful and well-presented. 

6 The average loss at capacity over 

7 5, the five-hour discharge, is around 7.5 

8 percent. The average loss at C over 20 for 

9 this same class of battery is 1.8 percent. 

10 The average loss with the partial discharges 

11 at, say, 7 over 3 are using the upper half of 

12 the SOC curve, the state-of-charge curve. 

13 In our application the efficiency 

14 of discharge gets to be more on the order of 

15 1 percent loss, 99 percent, but that doesn't 

16 agree whatsoever with the test methodology. 

17 We will take you over to the next 

18 slide, please. 

19 What I did is extracted from a 

20 similar set of graphs that you have been 

21 looking at. Just look at the discharge 

22 behavior, and what I have here is the 
Page 118

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 efficiency of the battery and discharge mode. 

2 This just graphically shows what I spoke 

3 about, a five-hour discharge with a 7.4 loss 

4 from zero percent state of charge up to 100. 

5 And while we are working C over 20 

6 from 100, down in the lower right of that graph 

7 indicates our working zone. Our order of 

8 efficiency is more like 99 percent efficient 

9 for that battery. 

10 And if we perform the test at C over 

11 20, you are going to show 1.3 percent loss or 

12 a partial. We will end up showing about, I 

13 think -- I didn't put the number up here from 

14 my spreadsheet -- but, roughly, 2 percent 

15 loss, which means that over-variation in that 

16 2 percent won't greatly contribute to our 

17 uncertainty and our unpredictability of 

18 results. 

19 Next, please. 

20 Okay. Now the last part of 

21 it -- and this is well-observed in the 

22 industry, but I really need to go in the lab 
Page 119

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 and create some data for you, or you can create 

2 your own -- is to go ahead and charge a battery 

3 through a total charging cycle. And when it 

4 goes into its maintenance mode, just leave it 

5 that way and check that current into the 

6 battery itself every, oh, four to eight hours 

7 for the next three days. And you will find in 

8 some cases you will have a battery that is 

9 continuing to charge, and the maintenance 

10 current will fall until it reaches a steady 

11 state. 

12 And the way the math works for the 

13 energy standard is you really care about that 

14 maintenance mode power because a lot of these 

15 chargers, like ours, are not allowed really to 

16 be shut off, is where some of the gold is when 

17 we go out trying to save energy. But we need 

18 to know that we are measuring the right stuff. 

19 And frankly, with the lead acid 

20 batteries I have observed, we probably won't 

21 be sure that we are in the maintenance mode 

22 until we have let that charge not go for 
Page 120

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 24-hour cycle, but maybe let it go out to 48. 

2 So, I need to do technical work to 

3 go ahead and come up with a recommendation on 

4 here. We know we have got a question. We 

5 don't know what the final answer is. 

6 So, next slide, please. 

7 Okay. So, yes, this is a summary 

8 of what I just said. Basically, the tentative 

9 solution is to extend out that period, observe 

10 that, see what we learn from it, and see if some 

11 of our great discrepancies on maintenance mode 

12 come from us trying to take the data. 

13 Next, please. 

14 Okay. So, generally, my 

15 recommendation, as an a la carte battery 

16 charger manufacturer, I would rather just test 

17 the charger. 

18 In terms of testing with the 

19 battery, generally, you could say, with the 

20 same instrumentation, the test sequence, 

21 allow a preconditioning at the tester or 

22 manufacturer's option; extend the discharge 
Page 121

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 time target out to a 20-to-24-hour window 

2 option. Again, this is specific to lead acid, 

3 but we may find that it uncovers some more 

4 truth for us with some other batteries. And 

5 extend the duration of the charge cycle until 

6 the charging amperage is stable, which I am 

7 thinking is going to mean, especially if we 

8 have a large battery and a small charger to 

9 begin, is going to be quite a bit longer. We 

10 might be barely finishing your part of the 

11 charge cycle in 24 hours. 

12 Now I am suggesting that all of 

13 these points be made optional. If someone is 

14 able to select batteries and align batteries 

15 to their charger and recommend a window of 

16 batteries for that, and can work within the 

17 current standard, it certainly takes less time 

18 to do it that way. But the extended time is 

19 well worth it in terms of predictability, from 

20 the experience I have got in my lab. 

21 I think that is the last of it. 

22 Thank you. 
Page 122

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 FACILITATOR BROOKMAN: Well, 

2 Wayne, thank you very much for that 

3 presentation and for preparing those slides. 

4 So, that was a lot of good information. 

5 Also, I would encourage you -- you 

6 probably know the drill -- the Department 

7 loves to see these kinds of comments in 

8 writing. 

9 Ashley reminds me that your 

10 PowerPoint slides will be inserted in the 

11 docket. 

12 MR. DOMMU: Great. So, thank you 

13 very much for that, Wayne. This is Jeremy 

14 Dommu again. 

15 So, you made a number of very 

16 specific recommendations for the way that the 

17 test procedure could be improved to speculate 

18 the specifications on preconditioning that 

19 occurs before testing, on extending the 

20 discharge time rate, extending iteration of 

21 the test charge cycle as well. And these 

22 recommendations, as I understand, are being 
Page 123

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 made specifically for lead acid batteries. 

2 I guess before we move on, I would 

3 love to open up the floor to see if anyone 

4 agrees or has comments on these 

5 recommendations for lead acid batteries and, 

6 also, if any of these recommendations may be 

7 applicable to other battery chemistries as 

8 well. 

9 Is there any feedback? 

10 MR. DENKENBERGER: This is Dave 

11 Denkenberger. 

12 So, I was trying to find it in the 

13 test procedure, but there is some language in 

14 the test procedure to ensure that the battery 

15 has gone into maintenance mode, and there is 

16 provision for going more than 24 hours, if that 

17 is required. 

18 FACILITATOR BROOKMAN: Okay. 

19 Thank you. 

20 No additional comments? I was 

21 thinking that those specific suggestions 

22 might spur some additional thoughts about how 
Page 124

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 the current test procedure could be improved 

2 for other than lead acid batteries. 

3 There is this balancing act, 

4 right, between not burdening, overburdening 

5 the manufacturer or the tester and also 

6 providing a result that is sufficient, 

7 adequate, repeatable, reproducible, all of 

8 that. 

9 So, any additional thoughts on 

10 that? 

11 (No response.) 

12 Okay. Nothing additional. I 

13 guess we will move on. 

14 MR. DOMMU: All right. Great. 

15 So, we will move on to a number of topics that 

16 we also brought up in the Notice of Data 

17 Availability, where we are also seeking 

18 information and thoughts on how the test 

19 procedure is being applied to a number of new 

20 and different and various battery-charging 

21 technologies. So, I will go ahead and kind of 

22 cue-up these topics that were brought forward 
Page 125

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 in the Notice of Data Availability, give a very 

2 brief overview, and then, we could open up the 

3 floor to get some feedback from everyone on how 

4 the test procedure is being applied and 

5 whether improvements need to be made to the 

6 test procedure for testing specific types of 

7 battery chargers. 

8 So, the first issue is testing a 

9 unit that has a battery used exclusively for 

10 backup power. So, this would be a unit that 

11 has a battery and a battery charger in it that 

12 is only used in the event that main power is 

13 lost. 

14 So, if power is out, the battery 

15 will kick in and we will maintain some or all 

16 functionality of that end-use application 

17 until such time as main power is retired. 

18 Because of this usage, you would typically 

19 expect that the battery is fully charged and 

20 it is in maintenance mode at most times, and 

21 it would only be in an active charging state 

22 when that backup power had been used and main 
Page 126

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 power is restored to bring that battery up to 

2 charge again. 

3 So, we have tested/investigated 

4 units with these integral batteries that are 

5 used for backup power. With some of them, the 

6 primary function cannot be shut off during 

7 testing, and there are some provisions in the 

8 test procedure that state, if you can turn off 

9 primary functions that are not associated with 

10 the battery-charging functionality, that you 

11 should go ahead and do so, or at the very least, 

12 switch them into the lowest energy-consuming 

13 mode of operation before conducting the test. 

14 But if you cannot shut off any 

15 additional function, then you would proceed 

16 with the DOE test procedure. And because of 

17 that, the test procedure, it is possible and 

18 potentially likely that it will capture energy 

19 use from non-battery-charging functionality 

20 when conducting this test. 

21 So, in the unit that we have 

22 tested, you know, we have noticed with the 
Page 127

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 lithium ion battery, that once the battery 

2 charger is fully charged, that there was no 

3 noted drop in power which would be typical of 

4 such a battery, which certainly leads to a 

5 potential belief that we are capturing energy 

6 that is not associated with the 

7 battery-charger functionality in the test 

8 procedure. 

9 So, we want to explore that area a 

10 little bit more, learn how the test procedure 

11 is being applied when testing applications 

12 with batteries that are solely used when main 

13 power is lost; i.e, backup batteries. 

14 And then, the other issue is, is 

15 the test procedure sufficiently detailed to 

16 ensure accurate, repeatable, representative, 

17 consistent results when testing applications 

18 that are equipped with backup batteries? And 

19 are any specific modifications necessary in 

20 order to accumulate testing of these types of 

21 battery chargers? 

22 FACILITATOR BROOKMAN: Larry, 
Page 128

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 please. 

2 MR. ALBERT: Just a couple of 

3 questions, Jeremy. 

4 FACILITATOR BROOKMAN: Larry, 

5 will you get that a little closer to your face 

6 (referring to the microphone)? 

7 MR. ALBERT: Sorry. 

8 Why is your question focused on 

9 just integral battery chargers and, also, 

10 focused on solely used when main power is lost? 

11 So, for example, cordless applications where 

12 there might be battery -- where the AC mains 

13 may be powering other functions of the product 

14 and charging the battery at the same time, and 

15 you can't switch off the non-battery-charging 

16 functions; that is not what you are trying to 

17 address? 

18 MR. DOMMU: No, I wouldn't 

19 necessarily say that. I think we are using 

20 this as an example of a case when there is an 

21 integral battery and you are unable to shut off 

22 any or all functionality. 
Page 129

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 I guess while I use the example of 

2 it is only being used when the main power is 

3 lost, I think the same line of 

4 questioning -- and we certainly would love to 

5 solicit comments on any suggestions you have 

6 for these types of battery chargers. So, by 

7 all means, please provide us with anything 

8 that may be useful. 

9 FACILITATOR BROOKMAN: So, you 

10 see both the issues boxes there. Comments 

11 here? 

12 (No response.) 

13 Nothing here? 

14 Is the test procedure sufficiently 

15 detailed to ensure accurate results when 

16 testing applications are equipped with backup 

17 batteries? Surely, we can answer that one. 

18 Alex? 

19 MR. BOESENBERG: This is Alex 

20 Boesenberg from NEMA. 

21 I can't answer yes or no. I can 

22 say that we are preparing written comments on 
Page 130

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 this. 

2 FACILITATOR BROOKMAN: Okay. 

3 That's helpful. Thanks, Alex. 

4 MR. BOESENBERG: Particularly to 

5 the solely used when main power is lost versus, 

6 as I stated before, most of our products are 

7 integrated with other features. 

8 FACILITATOR BROOKMAN: Yes. 

9 Thank you, Alex. 

10 MR. BOESENBERG: Okay. 

11 FACILITATOR BROOKMAN: Any 

12 additional comments on these two issues? 

13 Ashley? 

14 MS. ARMSTRONG: So, Alex, as for 

15 you, for both of you, actually, and anyone 

16 else, if and when you do submit comments 

17 indicating that this is or is not an issue, it 

18 would be very helpful if you would also suggest 

19 a potential methodology or changes to the 

20 methodology that would be needed to 

21 accommodate. Because, when DOE has done some 

22 of its investigative testing around these 
Page 131

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 types of systems, and albeit, it is limited in 

2 nature, but we were at the point where we would 

3 need to modify circuitry and stuff like that 

4 to isolate the battery-charging function 

5 alone. And that is not necessarily -- you 

6 know, that is one option. That is one option 

7 that DOE could consider, but that is not 

8 consistent necessarily with test procedures 

9 that we have adopted for other products. 

10 MR. BOESENBERG: This is Alex. 

11 Absolutely, Ashley, I am trying to 

12 do that. I have tried to do this in a 

13 different industry, and it wasn't as easy as 

14 it sounded, due to proprietary circuit designs 

15 and everything else. 

16 MS. ARMSTRONG: Exactly. 

17 MR. BOESENBERG: But we 

18 understand the concern and I am trying to find 

19 a way that makes everybody happy on our end. 

20 FACILITATOR BROOKMAN: Thank you. 

21 Larry? 

22 MR. ALBERT: I just want to point 
Page 132

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 out that in the development of some of these 

2 test procedures, particularly in California, 

3 and the regulations, this issue is hotly 

4 debated, right, which was basically, when is 

5 the product a battery charger and when is it 

6 just something that charges batteries sort of 

7 incidentally to whatever its main function is? 

8 And should that, then, be also included under 

9 regulations that cover battery chargers? 

10 And a lot of the question revolved 

11 around your issue, which is, how do you go into 

12 a product and discriminate in terms of 

13 circuitry and, then, also, physically, how do 

14 you actually conduct the test, right, when the 

15 interrelationship between the battery 

16 charging and the other functionality is 

17 intertwined, right. 

18 And, you know, I think what 

19 happened at the time is we offered a potential 

20 solution. It was rejected, right? And we 

21 can go back and offer that again, although with 

22 respect to members' products, probably this is 
Page 133

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 only limited to things such as our radio 

2 chargers, as we call them, right? So, they 

3 are principally radios that also charge 

4 batteries, right? 

5 FACILITATOR BROOKMAN: Okay. 

6 Thank you. 

7 Additional comments here? 

8 (No response.) 

9 Okay. 

10 MR. DOMMU: Okay. So, we will go 

11 ahead and move on to the next topic, which is 

12 the testing of wireless or inductive battery 

13 charges used in dry environments. 

14 So, we have certainly become aware 

15 over the past several years of new wireless 

16 charging platforms for dry environments, such 

17 as charging pads for SmartPhones or charging 

18 docks that allow the charging of batteries 

19 wirelessly through inductive 

20 battery-charging technology. 

21 When we initially developed the 

22 test procedure -- and as I explained in the 
Page 134

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 beginning, I mean, this happened in 2006, and 

2 it was updated in 2011 -- we did not 

3 contemplate or consider how wireless battery 

4 chargers would be tested according to the test 

5 procedure. That is not to say one way or 

6 another whether they can or cannot be tested 

7 according to the procedure, just that we did 

8 not consider them at the time. 

9 And as also noted in many of the 

10 opening comments this morning, in 2012, when 

11 we originally proposed standards for battery 

12 chargers, we deferred for further 

13 consideration the promulgation and proposal 

14 of standards for wireless battery chargers. 

15 So, at this point we have a number 

16 of questions on how we would go about testing 

17 wireless battery chargers. Should we update 

18 the test procedure? If so, how? What 

19 technologies are out there that would have 

20 wireless battery charging? We would love to 

21 get a better understanding of them, so we could 

22 make a better assessment on the suitability of 
Page 135

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 the test procedure for wireless battery 

2 chargers. 

3 And finally, interested in any 

4 changes that could be made. You know, we 

5 understand there's a lot of different ways 

6 that these battery chargers could be 

7 configured or used in multiple types of 

8 end-use applications. So, we want to get a 

9 sense of that, and we also want to explore the 

10 current metrics and outputs from the test 

11 procedure. 

12 Are those metrics and outputs that 

13 are currently recorded applicable? Do they 

14 make sense for wireless battery chargers? 

15 And are there any new metrics that we should 

16 consider that would make more sense or be in 

17 addition to what is currently in there, 

18 specifically for this type of technology? 

19 So, that is a very brief summary of 

20 these three issues. I think maybe we could 

21 handle them one-by-one, the first being the 

22 issue of, can the current test procedure be 
Page 136

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 applied to wireless battery chargers to ensure 

2 the accurate, repeatable, consistent results? 

3 If not, are there recommendations for changes 

4 that could be made to ensure that the test 

5 procedure could test these products in a 

6 repeatable manner and produce accurate 

7 results? 

8 FACILITATOR BROOKMAN: Yes, 

9 please, John. 

10 MR. KUZIN: Sure. John Kuzin for 

11 the Alliance for Wireless Power. 

12 Basically, our view is it is not 

13 possible at this time to provide a detailed 

14 test procedure. Is it possible that the 

15 current test procedure could be used? 

16 Perhaps. But at this point we just don't know 

17 how the products are going to be deployed. 

18 As I touched on earlier, some of 

19 the technologies being looked at will quickly 

20 charge a device within a very short period of 

21 time by putting it into like, let's say, a 

22 pocket in the back of a chair; just drop the 
Page 137

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 device in and it charges. 

2 Is a 24-hour test period 

3 appropriate? I don't know. 

4 The other thing is, with regard to 

5 wireless power, the specific technology that 

6 the Alliance for Wireless Power works on is a 

7 surface that is equipped with a charging coil 

8 where you could put all sorts of devices, 

9 disparate devices, disparate battery 

10 chemistries, within this area, and they will 

11 charge. They will charge at different rates. 

12 So, there is all of that. 

13 There is also the Alliance for 

14 Wireless Power uses a charging frequency of 

15 6.78 megahertz. Other standards use much 

16 lower frequencies. So, basically, there's a 

17 lot of unknowns. I won't quote Donald 

18 Rumsfeld and say, "No unknowns and unknown 

19 knowns," and so forth. 

20 (Laughter.) 

21 But there is just so much that we 

22 do not know to be able to definitively provide 
Page 138

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 feedback at this time and say this is the test 

2 procedure, because the products are still in 

3 the lab. 

4 FACILITATOR BROOKMAN: Uh-hum. 

5 MR. KUZIN: And we will be 

6 providing comments on this in our written 

7 comments. 

8 FACILITATOR BROOKMAN: Okay. 

9 Thank you. Thanks for the written comments, 

10 too. 

11 Larry? 

12 MR. ALBERT: Just a point of 

13 clarification here. So, what John is 

14 speaking about is essentially some kind of a 

15 standard that the Alliance for Wireless Power 

16 is creating or has created, right, where many 

17 manufacturers can create products to this 

18 standard, and there could be manufacturers 

19 creating battery-charging pads, right, also 

20 for this standard, very similar to what the 

21 Wireless Power Consortium also has a similar 

22 sort of setup, right? 
Page 139

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 This is distinct in our opinion 

2 from the situation such as a cordless 

3 toothbrush, right, which has a base and a 

4 toothbrush sold by the same manufacturer. 

5 They are intended to go together. They 

6 wirelessly charge, right? 

7 So, when you say "wireless 

8 charging," are you talking about what John and 

9 what the WPC do? Or are we just talking about 

10 an extension of toothbrushes? 

11 MR. DOMMU: Yes, we are talking 

12 about wireless inductive chargers designed 

13 for dry environments. I think I could have 

14 made that clearer, which I think is more in the 

15 line of what John is talking about. 

16 Wireless chargers for wet 

17 environments, we actually had proposed, well, 

18 such as electronic toothbrushes, we had 

19 proposed standards for those in 2012, and, no, 

20 we have not finalized those. 

21 MR. ALBERT: I think the 

22 distinction here is that in the standard such 
Page 140

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 as the Alliance for Wireless Power, right, 

2 this is a case where you are going to have 

3 chargers and products to be charged that come 

4 from different manufacturers, right? 

5 MR. DOMMU: Uh-hum. 

6 MR. ALBERT: And so, there won't 

7 necessarily be a clear indication of what the 

8 suitability is of one to the other. Whereas, 

9 if you have a toothbrush or anything else, even 

10 if it was designed for a dry environment, but 

11 it was proprietary, right, it would be very 

12 clear as to what selection criteria you would 

13 have to use. 

14 MR. DOMMU: Sure. 

15 FACILITATOR BROOKMAN: Doug 

16 Rawald? 

17 MR. RAWALD: Right. And very 

18 quickly, going back to what you brought up in 

19 the beginning today, the difference between 

20 universal versus proprietary, and that being 

21 what you think is the actual distinction we 

22 should be making her rather than wireless 
Page 141

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 versus non-wired, or that the important 

2 consideration at least is the proprietary 

3 versus the universal nature of the charger. 

4 So, if the charger is paired to a 

5 particular battery and sold with that battery, 

6 the test procedure may be more applicable than 

7 if that's a universal charger and you don't 

8 know what the battery is going to be used on 

9 that particular device. 

10 MR. ALBERT: That's right. I 

11 think that is an important distinction. 

12 MR. RAWALD: Right. And I think 

13 it would be very helpful if the folks from 

14 Qualcomm, if you could provide some 

15 information and response to Larry's point. 

16 That would help us kind of analyze the issue 

17 a little better. I think it would be helpful. 

18 MR. ALBERT: Because I think it 

19 does introduce this overall selection issue, 

20 right? 

21 MR. RAWALD: Uh-hum. 

22 MR. ALBERT: Which independent of 
Page 142

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 all the other technological issues, right, it 

2 is sort of an overwhelming consideration. 

3 MR. RAWALD: Right. How do you 

4 select the battery for -- and this is Doug 

5 Rawald again -- how do you select the battery 

6 for your initial charger when it could be many 

7 different things? 

8 MR. ALBERT: That's correct. 

9 MR. RAWALD: Okay. 

10 FACILITATOR BROOKMAN: Good. 

11 Thank you. 

12 Alex Boesenberg? 

13 MR. BOESENBERG: This is Alex 

14 Boesenberg from NEMA. 

15 Talking about battery selection, I 

16 am just curious because I don't know this 

17 section, but, Larry, you probably know. Is 

18 there an ANSI standard reference battery? I 

19 have reference lamps and reference ballasts, 

20 but what about batteries? 

21 MR. ALBERT: There's ANSI 

22 standards and IEC standards for battery 
Page 143

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 performance requirements, but there's not 

2 necessarily, as far as I know, at least for the 

3 batteries we deal with, a standard battery. 

4 FACILITATOR BROOKMAN: Okay. 

5 Thanks, Larry. 

6 MS. ARMSTRONG: Right. So, Alex 

7 just gave an example of how DoD deals with this 

8 in other products. And it is not to say they 

9 are one and the same, but if we were at some 

10 time in the future, whether it be short-term 

11 future or long-term future -- obviously, that 

12 will be informed by the comments -- were to go 

13 down a pathway of dealing with whether you call 

14 them proprietary or just universal-type 

15 charging systems where the end-use battery may 

16 not be known to the person making the charging 

17 system, we could explore that as an option in 

18 terms of specifying either a nominal-type 

19 battery or a reference battery, to assess the 

20 performance of that charger in a 

21 test-procedure-like setting. 

22 FACILITATOR BROOKMAN: Doug 
Page 144

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 Rawald? 

2 MR. RAWALD: Just one final point, 

3 I think, because this is really interesting to 

4 me. And now, you have really triggered a lot 

5 of thoughts here for me. 

6 It is that some of these unknowns 

7 with a proprietary charger, if it is wireless, 

8 are taken out because the battery selection 

9 becomes much clearer, right, when it is a 

10 proprietary system. And so, is there a way 

11 for you folks to kind of describe -- and I am 

12 talking once again to the Qualcomm folks -- if 

13 you could describe, what would be the concerns 

14 with a test procedure for things that are 

15 proprietary where you know what the battery 

16 selection would be prior to using this test 

17 procedure as currently drafted for that kind 

18 of wireless system? 

19 MR. KUZIN: I don't believe 

20 that -- 

21 FACILITATOR BROOKMAN: This is 

22 John speaking. 
Page 145

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 MR. KUZIN: Yes. Rob, do you want 

2 to touch on it? 

3 I don't believe that our system is 

4 designed to operate in that proprietary mode. 

5 So that it would be, you know, there is a 

6 standard that says, if you want to have a 

7 product that is charged by the Alliance for 

8 Wireless Power, there will be a process for 

9 certifying products that comply with this 

10 standard. 

11 So, you're right, separate vendors 

12 can sell a phone, and a furniture manufacturer 

13 could sell a piece of equipment, a table, that 

14 you would put in your house, and that would be 

15 an Alliance for Wireless Power equipped table, 

16 and they would work. 

17 But your point as to, how would you 

18 limit the amount of testing you would need to 

19 do, because, in theory, if and when this takes 

20 off, hopefully, you could have any and all 

21 sorts of combinations of testing. So, 

22 something to think about is -- and I don't 
Page 146

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 think we have thought much about it -- is, what 

2 is the reference test that you are going to 

3 want? Is it three phones? Is it two phones 

4 and a hearing aid? But that is a good point. 

5 FACILITATOR BROOKMAN: Rob has a 

6 comment. 

7 MR. KUBIK: Yes, this is Robert 

8 Kubik. 

9 Just to expand on what John is 

10 saying, our technology right now is not in the 

11 market, but I fully expect this year you will 

12 start seeing some products come out. 

13 But the concept is you would have 

14 one charging pad. You would be able to 

15 charge, say, a Bluetooth device and a phone at 

16 the same time on that same pad. That is what 

17 I think you will see initially, but you will 

18 see it expand to include multiple products, 

19 multiple devices. 

20 Maybe the recommendation here is 

21 we need to have a closed discussion based on 

22 our technology and our standard and how we 
Page 147

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 define the classes for the charging units and 

2 the classes for the receiving units, to see if 

3 there is a way to narrow down this test. 

4 But, you know, we are still in the 

5 process of maturing our standard, and we have 

6 the hooks in there for handling the phones, for 

7 example. But expanding it to include 

8 higher-power devices, such as laptops, and 

9 charging more devices at once is still in the 

10 works. So, it is still very early for 

11 development of a standard. But I think 

12 working directly with the organization that is 

13 responsible for developing the specification 

14 is the right route here. 

15 FACILITATOR BROOKMAN: Okay. 

16 Thank you. 

17 Yes, Dave? 

18 MR. DENKENBERGER: Yes, Dave 

19 Denkenberger. 

20 So, we have done some work, ECOVA, 

21 through Natural Resources Canada, to 

22 investigate this issue. We found that the 
Page 148

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 test procedure is set up to find, say, for 

2 multi-port, multi-capacity batteries, to 

3 search within the universe of batteries that 

4 are compatible with that device and meet those 

5 requirements. 

6 So, it does take work, but we think 

7 that the test procedure does provide guidance 

8 for better selection. 

9 FACILITATOR BROOKMAN: Okay. 

10 MR. DENKENBERGER: For the case of 

11 a pad charger that was commercial available, 

12 we do recognize that new technologies are on 

13 the horizon. 

14 FACILITATOR BROOKMAN: Okay. 

15 Ken Rider has a comment. 

16 Ken, unmute your phone and speak. 

17 MR. RIDER: Yes. Hi. This is 

18 Ken. 

19 I just wanted to make a couple of 

20 comments about the way the Energy Commission 

21 infers this. So, a lot of these products that 

22 came up during the standards process were not 
Page 149

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 what we considered to be the battery chargers. 

2 We are talking about things that might charge 

3 like three phones. And really, what you are 

4 doing is you are adding battery chargers to 

5 that pad. The phone itself contains the 

6 charge circuitry and the control and how the 

7 battery is going to get charged. 

8 And so, a lot of these pads are more 

9 like external power supplies. Like a 

10 four-port USB charger, if you wanted to call 

11 that a charger, you would have a problem in 

12 selecting what products to connect to the USB 

13 charger, but that is because that is an 

14 external power supply. 

15 The test procedure already 

16 contains methodology for selecting the power 

17 source for charging. And so, I think the only 

18 time that these would get selected for testing 

19 with a battery charger is when you would have 

20 a like proprietary situation which, as the 

21 test procedure already applies to wet 

22 inductive charger systems, we already know 
Page 150

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 that it works in proprietary systems like 

2 toothbrushes. 

3 And so, I would say that it is our 

4 opinion, and it is also in the standards that 

5 we had, that it would be appropriate for these 

6 proprietary systems. And then, for 

7 non-proprietary systems where they are more 

8 like can charge anything, that those aren't 

9 really battery chargers. 

10 MR. KUZIN: And this is John 

11 Kuzin. 

12 And, Ken, are you saying that you 

13 have addressed that by your definition of what 

14 a battery charger system is, and the fact that 

15 in the non-proprietary system, if you will, 

16 which is not typically used, but in the 

17 scenario where you would buy a pad and, then, 

18 perhaps later get a battery pack that you could 

19 charge on that pad, because those are 

20 separately sold, the rules that California put 

21 in place would not apply. Is that what you are 

22 referring to? 
Page 151

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 MR. RIDER: Well, I would say that 

2 the battery pack that you purchase later, that 

3 is going to have the charge circuitry, and that 

4 is what is going to get regulated. 

5 And so, also, when you look at the 

6 applicability of the test procedure, you are 

7 going to follow the instructions provided 

8 along with that unit to figure out how to power 

9 it, how to get it charged, and do it 

10 appropriately. 

11 So, unless that product points 

12 back to the pad, the pad would never really get 

13 incorporated into the test procedure. 

14 FACILITATOR BROOKMAN: Okay, Ken. 

15 Thank you. 

16 MR. DOMMU: All right. Was there 

17 anything else on wireless chargers before we 

18 move on? 

19 (No response.) 

20 It doesn't sound like it, but I 

21 just want to give one more opportunity. 

22 FACILITATOR BROOKMAN: Larry? 
Page 152

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 MR. ALBERT: Just a follow-on to 

2 Ken's comment, which is to think about this in 

3 your proprietary business. Probably the 

4 opportunity also exists with systems that are 

5 USB-charged, right? Whereas, even lots of 

6 time today, they are sold without -- 

7 THE REPORTER: Sir, I don't think 

8 your microphone is on. 

9 MR. ALBERT: I'm sorry. 

10 They are sold with not a separate 

11 charger, but just a USB cable, if that, and the 

12 consumer is expected to plug it into whatever 

13 USB source there is, right, to charge it? 

14 So, you know, that maybe is a more 

15 general question. It has less to do with it 

16 being wireless and more to do with being 

17 something that is governed by a standard that 

18 reflects the interaction between the thing to 

19 be charged and the charging sources. 

20 FACILITATOR BROOKMAN: 

21 Additional comments on wireless battery 

22 chargers? 
Page 153

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 (No response.) 

2 Okay. 

3 MR. DOMMU: All right. Thank you 

4 all. 

5 So, we will move on to the next 

6 topic, and I believe this is the last topic 

7 that we want to present here today, although 

8 we will open it up at the conclusion for any 

9 other issues at all that people want to bring 

10 forward. 

11 But the last one was specifically, 

12 bringing it up, is on adaptive charging 

13 systems. So, we become aware of what we are 

14 referring to as adaptive charging systems. I 

15 think they may also be referred to as quick 

16 charging systems that charge batteries more 

17 quickly when they are paired with a specific 

18 power supply. 

19 So, as we understand them -- and we 

20 are still trying to learn a lot more about 

21 these -- the system have battery chargers that 

22 could communicate with the power supply. So, 
Page 154

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 the power supply delivers varying voltages and 

2 current conditions, depending on the state of 

3 the battery, how fully charged the battery is, 

4 and it also depends on which fixed general 

5 power supply is connected. 

6 So, as we understand it, if it is 

7 paired with that one specific external power 

8 supply, it may charge quickly and there's this 

9 communication that occurs to vary the voltage 

10 and current. If it is capable of being 

11 charged with an external power supply that is 

12 not capable of that communication, it may 

13 charge at a different rate. 

14 So, we are uncertain how the 

15 battery chargers in these systems would be 

16 identified or rated or advertised according to 

17 the applicable standards for voltage and 

18 current, due to the charge control systems 

19 that are part of the system. 

20 So, we want to learn how 

21 manufacturers are testing and rating these 

22 types of products. If there is more 
Page 155

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 information about what this technology is and 

2 how it is applied, and how the voltage and 

3 current vary, we would love to hear more about 

4 it in the context of battery chargers, as we 

5 also do on the standard. There could be 

6 issues with testing external power supplies 

7 that have the communication, but, obviously, 

8 for today we are really focused on the test for 

9 the battery chargers. 

10 So, the question that we have here 

11 is, does the test procedure account for any of 

12 the efficiency advantages or efficiency 

13 disadvantages that occur when testing an 

14 adaptive charging system? Are these types of 

15 battery chargers sold with that specific power 

16 supply that allows for the adaptive charging 

17 system? Does the power supply need to be 

18 bought separately? How are they packaged? 

19 What happens when it is tested with one power 

20 supply versus another? And does the 

21 efficiency change when testing with a 

22 different power supply? 
Page 156

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 And then, the other issue is, how 

2 should the test procedure be applied to 

3 battery charger systems with adaptive power 

4 supplies? Are there any changes that need to 

5 be made -- maybe and maybe not -- to ensure a 

6 repeatable, accurate test result? 

7 So, adaptive charging systems is 

8 what we are currently asking about and really 

9 interested in learning more about this 

10 technology and how it can or cannot be tested. 

11 FACILITATOR BROOKMAN: John? 

12 Oh, pardon me. Dave? 

13 MR. DENKENBERGER: Dave 

14 Denkenberger. 

15 The term "adaptive power" might 

16 have multiple meanings. I have seen it used 

17 in like an automotive application, that the 

18 charger will vary the voltage and the current. 

19 Could you clarify whether you are interested 

20 in that? 

21 MR. DOMMU: Yes, that is exactly 

22 it. So, I imagine when the battery is 
Page 157

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 completely drained, that it would be at a 

2 higher voltage and current. And then, as the 

3 battery becomes more and more charged and 

4 increases the capacity, it may change the 

5 voltage and current condition which is 

6 operating, which I suspect would allow it to 

7 charge more quickly. 

8 MR. DOMMU: Okay. My 

9 understanding is that is more an established 

10 technology. Could other people comment? 

11 MR. ALBERT: Yes. Larry here. 

12 So, I mean, what you just 

13 described, which is the reduction in current 

14 as the voltage goes up and the battery is being 

15 charged is the characteristic performance of 

16 sort of the classic battery charger for nickel 

17 cadmium and lead acid, and so on, right, where 

18 essentially a source impedance, using the 

19 passive case, a source impedance then supplies 

20 a higher current, right, during low states of 

21 charge. And as the battery charges up, the 

22 voltage differential across the source 
Page 158

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 impedance reduces and the current reduces. 

2 So, that is sort of the classic charging 

3 methodology, right? 

4 So, I was also unclear as to what 

5 specifically we are addressing here because 

6 this kind of adaptability occurs in even 

7 passive cases, right? 

8 FACILITATOR BROOKMAN: It occurs 

9 in what kind of -- 

10 MR. ALBERT: Passive. 

11 FACILITATOR BROOKMAN: Oh, 

12 passive? 

13 MR. ALBERT: Yes, and the 

14 implication in the question, at least the way 

15 I took it, was that there's active 

16 communication, handshaking, or some other 

17 kind of back-and-forth between the power 

18 supply and the charging circuitry when you put 

19 in a higher, I am assuming a higher-capacity 

20 power supply in, such as some laptops I think 

21 you can buy like a super-power-supply for 

22 them, and they will charge faster, or 
Page 159

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 something like that. 

2 If that is what you are talking 

3 about, that is a little bit different than just 

4 sort of the characteristic voltage/current 

5 relationship that occurs in -- 

6 MR. DOMMU: Sure. Yes. I mean, 

7 as it has been explained -- and again, we are 

8 trying to learn more about this -- but it is 

9 the focus is on that communication that 

10 happens between the power supply and the 

11 battery-charging system, that that 

12 communication could result in charging 

13 methods that are atypical of traditional 

14 battery-charging systems. And learning more 

15 about that interaction between the external 

16 power supply and the battery charger is what 

17 we are really focusing on here. 

18 FACILITATOR BROOKMAN: Yes, 

19 Larry, please. 

20 MR. ALBERT: Could I ask for just 

21 more clarification? Is this concern around 

22 the communication that might exist between the 
Page 160

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 battery charger and the detachable battery or 

2 between, let's say, an integral battery 

3 product and its separate EPS, right? Where is 

4 most of your focus in terms of your interest? 

5 FACILITATOR BROOKMAN: I see 

6 Peter is queued to speak. Go for it. 

7 MR. PROTOPAPPAS: This is Peter 

8 Protopappas. 

9 The focus is, for example, you 

10 could buy a third-party charger and an EPS; 

11 that's paired with the same mobile device. 

12 That mobile device communicates with that 

13 third-party charger. It is going to charge at 

14 a different rate than the EPS that was sold 

15 with the mobile device. 

16 MR. ALBERT: Peter, Larry. 

17 So, is this a case where the -- you 

18 said "third party". So, this battery power 

19 supply is not being sold by -- for example, 

20 let's say that it is a Dell laptop and a Dell 

21 charger, right? This is sold by somebody 

22 else, right, other than -- 
Page 161

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 MR. PROTOPAPPAS: Correct. 

2 MR. ALBERT: But it interacts 

3 using whatever that communication protocol is 

4 between the laptop and the power supply, 

5 right? 

6 MR. PROTOPAPPAS: Correct. 

7 MR. ALBERT: Okay. 

8 FACILITATOR BROOKMAN: Okay. 

9 Dave? 

10 MR. DENKENBERGER: So, just to 

11 clarify here, if you had an automotive battery 

12 that could be charged by multiple chargers, is 

13 that the same issue? Because it could charge 

14 at a different rate, and there is usually some 

15 communication, the charger has to find out 

16 what type of battery it is charging? 

17 MR. DOMMU: I mean, it sounds like 

18 that is a similar issue to what we are asking 

19 about, and perhaps that has been addressed or 

20 how to test those types of chargers. But we 

21 are just asking really about that 

22 communication that may occur and how the 
Page 162

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 battery charging would be affected when paired 

2 with one type of EPS versus another. 

3 FACILITATOR BROOKMAN: Larry? 

4 MR. ALBERT: So, in a way, maybe 

5 this is -- you know, when Peter introduced the 

6 issue about it being a third party, in a way 

7 it kind of gets to the earlier question perhaps 

8 about some of those issues that surrounded 

9 wireless charging, which is there is some sort 

10 of communication protocol that exists between 

11 the power supply and the object being charged. 

12 And so, the third party just sort of adopted 

13 that? 

14 MR. DOMMU: Sure. 

15 MR. ALBERT: And so, I guess if you 

16 are regulating that as an EPS, you wouldn't 

17 capture it as a battery charger perhaps unless 

18 they specifically mentioned this class of 

19 laptops, or whatever, that it was supposed to 

20 charge? I mean, it really has to do, again, 

21 with sort of the selection issue. I don't 

22 think it has anything to do with the testing 
Page 163

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 per se. That's my observation. 

2 MR. DOMMU: Okay. 

3 MS. ARMSTRONG: Okay. So, can I 

4 try to -- this is Ashley -- clarify something? 

5 You know, I think one issue is how you make 

6 pairings. And you will have to excuse me; I 

7 am not an electrical engineer here. 

8 But, as I understand one of the 

9 issues, it is that we have seen some products 

10 recently come on the market that, when 

11 employed -- and let's take away the test 

12 procedure for a minute -- but when employed in 

13 the field, based on the conditions, use 

14 different rates to charge the battery. In 

15 other words, they are communicating with the 

16 battery, and depending upon the specifics of 

17 the state of the battery, it may charge faster; 

18 it may charge slower. 

19 And so, what we are really asking 

20 is, you know, we understand that happens in the 

21 field. And our test procedure is setting 

22 specific conditions under test. And that 
Page 164

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 performance, whether it results in a higher 

2 energy consumption or a lower energy 

3 consumption, one could argue that 

4 differential performance is not captured by 

5 our test procedure because we set those 

6 conditions. 

7 And the question really is, should 

8 it be? Should we be acknowledging that, when 

9 employed in the field, those what I am going 

10 to call adaptive control systems that actually 

11 change the rate of charge coming from the 

12 battery charger to the battery, based on 

13 specific field conditions, should that be 

14 reflected in our test procedure? Does that 

15 make sense? 

16 FACILITATOR BROOKMAN: Larry? 

17 MS. ARMSTRONG: A little more? 

18 MR. ALBERT: One more 

19 clarification. These field conditions, do 

20 they imply that there is some aging of the 

21 battery or there is some balance of the battery 

22 or other things that are happening where the 
Page 165

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 battery at that point in time is not 

2 representative of the way it would be in the 

3 as-received condition? 

4 MS. ARMSTRONG: That is not my 

5 understanding at least. My understanding of 

6 the issue is that, when employed in the field 

7 as received, that, you know, either the 

8 battery is almost fully discharged or maybe it 

9 is just at 10 percent, or maybe it is hard to 

10 add a different rate between those two 

11 conditions. 

12 In other words, 10 percent 

13 discharge versus 90 percent discharge, does it 

14 charge at a different rate? And if it 

15 does -- I am simplifying this probably 

16 grossly -- but if it does, should our test 

17 procedure capture that difference in charging 

18 for a given battery charger and battery 

19 system? Does that make sense? 

20 It is acknowledging that battery 

21 chargers may charge devices differently 

22 depending on their state. And it is not meant 
Page 166

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 to be aging, but it is the as-received 

2 condition. 

3 MR. ALBERT: Larry again. 

4 So, in terms of battery charge 

5 rates, they are almost always a function of 

6 state of charge of the battery. At low states 

7 of charge, you would expect to have in the sort 

8 of classic case higher charge rates. As you 

9 reach end of charge, frequently, battery 

10 chargers, whether it is done passively or 

11 actively, or whatever, reduce their charge 

12 rates. 

13 I don't believe that there is any 

14 issue with this because the way the test 

15 procedure is designed is it doesn't look at 

16 charge rate; it looks at charge energy, right? 

17 And it looks at recovered energy from the 

18 battery, right? So, in a way, variations in 

19 charge rate, it is essentially taken out of the 

20 equation, right? So, there are going to be 

21 multiple variations over the charge period, 

22 and none of which really have an ultimate 
Page 167

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 bearing upon it because you are essentially 

2 looking over a long span of time and measuring 

3 energy and comparing it to energy. Yes. 

4 FACILITATOR BROOKMAN: Dave? 

5 MR. DENKENBERGER: Yes, so I agree 

6 with what Larry is saying, that there is going 

7 to be variation, I think, in any 

8 battery-charging system. But I think what 

9 Jeremy was saying more is the communication 

10 with the EPS and getting different results 

11 with different EPSs. 

12 And you mentioned, Ashley, that 

13 the products were on the market. And I was 

14 wondering if you could list specific model 

15 numbers, so that we can all investigate more? 

16 MS. ARMSTRONG: We do not do that. 

17 Sorry. 

18 FACILITATOR BROOKMAN: Jeremy, 

19 can you confirm what Dave was saying about how 

20 we interpreted your statement? 

21 MR. DOMMU: Yes, I mean, I do think 

22 there is an interaction between the EPS and the 
Page 168

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 battery-charging system in this case. But I 

2 think to Ashley's point, what we are really 

3 trying to focus on is the battery-charger 

4 system itself and the questions that we are 

5 asking of how and whether the test is 

6 appropriate to measure the energy consumed 

7 when charging a battery when it changes 

8 voltages and currents, depending on its charge 

9 condition. 

10 FACILITATOR BROOKMAN: Dave? 

11 MR. DENKENBERGER: This is Dave 

12 Denkenberger. 

13 So, maybe another example is a 

14 laptop battery that is considered a smart 

15 battery. So, that has the charge control. 

16 And you could substitute a different EPS. 

17 That would, again, be conventional 

18 technology, right? So, it is not what you are 

19 interested in? 

20 MR. DOMMU: I mean, I think we 

21 certainly would welcome comments on all 

22 aspects of the battery charger test procedure. 
Page 169

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 I think we are somewhat getting into a 

2 territory of now talking a little bit more 

3 about the way to test the external power 

4 supply. So, we do want to focus this more on 

5 the battery-charging system. 

6 But, certainly, I mean, any 

7 comment that you want to provide on the 

8 battery-charging system and how the test would 

9 be different, depending on the way it is paired 

10 with an EPS, would certainly be encouraged. 

11 FACILITATOR BROOKMAN: 

12 Additional comments on how the test would be 

13 modified, how it would be changed, improved? 

14 Larry? 

15 MR. ALBERT: I guess, in general, 

16 our position would be, based upon what we have 

17 heard, that we don't see any compelling 

18 reason, based upon the information provided, 

19 for why you would need to modify the test 

20 procedure to accommodate communication 

21 between these different elements, right? I 

22 think it is accommodated within the test 
Page 170

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 procedure. 

2 FACILITATOR BROOKMAN: Okay. 

3 Thank you. 

4 You can see Issue Box 9 and 10. 

5 Please take a peek at it one more time, see if 

6 there are any additional comments here. 

7 (No response.) 

8 MR. DOMMU: Okay. So, that, 

9 essentially, concludes the areas that we are 

10 specifically opening it up for comment. We do 

11 have another couple of slides to just wrap up 

12 on how to submit comments, when the comment 

13 period ends, which is June 30th, and the next 

14 couple of slides will go through that final 

15 concluding information. 

16 But, before we get there, we do 

17 want to open it up to any other issues, any 

18 other questions, anything else that anybody 

19 here in person or via the webinar wants to 

20 bring up during this meeting. 

21 FACILITATOR BROOKMAN: Dave. 

22 MR. DENKENBERGER: Dave 
Page 171

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 Denkenberger. 

2 Getting back to the variability on 

3 charge testing, could you clarify how many 

4 units were tested? Because I believe the test 

5 procedure doesn't have guidance on that, but 

6 there is another part of federal regulations 

7 that would say how many units have to be 

8 tested, given the variability, and whether you 

9 did that? 

10 MS. ARMSTRONG: Right. This is 

11 Ashley. 

12 Currently, we don't have 

13 provisions for battery chargers. So, if that 

14 is something you have an opinion, especially 

15 toward variability or feel there is a need for 

16 them, we would welcome comments about the 

17 number of units that should be tested to get 

18 a representative value for a production sample 

19 of a given model, as well as what tolerances 

20 may or may not be appropriate. 

21 For the test data you are seeing 

22 here, this is just wall testing a single 
Page 172

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 unit -- 

2 FACILITATOR BROOKMAN: Thank you. 

3 MS. ARMSTRONG: -- at least for 

4 the summary here. Yes. 

5 FACILITATOR BROOKMAN: Okay. 

6 Yes, Jen? 

7 MS. CLEARY: Jen Cleary. 

8 At the beginning of the meeting 

9 today, DOE mentioned that it is considering if 

10 and when to continue the battery-charger 

11 standards rulemaking. And I guess I was a 

12 little confused by that because EPCA requires 

13 DOE to either issue a standard or a 

14 determination that no standard is justified. 

15 And I think, as we are all well aware, the 

16 deadline for that determination has long since 

17 passed. 

18 So, I guess I am assuming that 

19 comment was in error, but I just want to 

20 confirm that. And if it is not in error, I 

21 would like to know a little bit more about how 

22 DOE would make that statement. 
Page 173

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 MR. KIDO: I will just clarify 

2 that -- this is Michael Kido, DOE -- we are 

3 still examining what our next steps are going 

4 to be with the standards for better charges. 

5 And as part of this whole exercise, we need to, 

6 I think as was indicated earlier, we need to 

7 perhaps reexamine our analysis, and in doing 

8 so, looking at some of the aspects related to 

9 the test procedure that are going to feed into 

10 that. 

11 MS. CLEARY: But you do still plan 

12 to make a determination as to whether or not 

13 standards are warranted, correct? 

14 MR. KIDO: We will act in 

15 accordance with the statute. 

16 MS. CLEARY: Okay. Except for 

17 the deadline, which has already been missed? 

18 MR. KIDO: Obviously. 

19 MS. CLEARY: Okay. 

20 (Laughter.) 

21 FACILITATOR BROOKMAN: Thank you. 

22 Thank you, Jen. 
Page 174

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 Larry, please. 

2 MR. ALBERT: So, to follow on to 

3 Jen's question, can we perceive this NODA as 

4 essentially the opening volley in reopening 

5 the rulemaking with respect to the test 

6 procedure? 

7 MR. KIDO: All I am going to say at 

8 this point is it is what it is. It is a Notice 

9 of Data Availability. We had some questions 

10 regarding the test procedure. And so, we are 

11 going to try to learn a little bit more about 

12 the test procedure before we go forward with 

13 anything. 

14 FACILITATOR BROOKMAN: Of course, 

15 the Department really appreciates your 

16 detailed written comments. And as you look at 

17 the content that was presented here, and 

18 specifically the questions that are listed in 

19 the comment boxes, to respond to those in great 

20 detail, that would be good. They would 

21 appreciate it. 

22 Additional comments here as we 
Page 175

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 move toward closure? Closing remarks of any 

2 sort, questions? 

3 (No response.) 

4 Then, the final slides. 

5 MR. DOMMU: Okay. Great. So, 

6 this slide provides the information that you 

7 need to submit written comments. They are due 

8 on June 30th, 2014. All this information on 

9 this slide is also available in the Notice of 

10 Data Availability. 

11 When you send in comments, there's 

12 a number of ways to do it: via email, via 

13 hand-delivery, via postal, via 

14 regulations.gov. 

15 So, here is the information on how 

16 to submit comments and what information should 

17 be included on the comments that you do submit. 

18 So, we do encourage all interested parties to 

19 submit comments by the close of this comment 

20 period on June 30th. 

21 Here are some relevant URLs, so you 

22 could find links to the Notice, the report with 
Page 176

202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

1 the test data, an overview of the rulemaking, 

2 and the product page, and the docket as well, 

3 which has all correspondences associated with 

4 this rulemaking. 

5 And finally, here is contact 

6 information for myself. If you have any 

7 follow-up questions, please do feel free to 

8 reach out; and, also, to Michael Kido in our 

9 General Counsel Office. 

10 So, thank you all again so much for 

11 joining us today. I think it was a very 

12 productive meeting, and we appreciate all your 

13 participation and input that you were able to 

14 provide. And we thank you in advance for all 

15 the information that you will be submitting in 

16 writing. 

17 FACILITATOR BROOKMAN: Safe 

18 travels. 

19 (Whereupon at 11:58 a.m., the 

20 meeting was adjourned.) 

21 

22
202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

Page 177

A

a.m 1:13 6:2

101:19,20 176:19

ability 15:17,19

97:20

able 51:14 53:13

85:6 96:7 113:9

115:20 121:14

137:22 146:14

176:13

absence 97:13

Absolutely 131:11

AC 108:3 128:12

accept 58:17

access 19:17,19

accessible 11:2

accommodate

92:18 130:21

169:20

accommodated

169:22

accompany 47:12

account 17:12

32:15 155:11

accounted 26:17

accounts 84:13

accumulate 127:20

accuracy 31:20

93:14 94:17

accurate 40:15

92:15 93:10 95:8

95:18 114:5

127:16 129:15

136:2,6 156:6

accurately 32:2,13

88:3

achieve 43:7 86:2

96:8

achieved 37:3 43:1

106:13

acid 4:10 104:22

105:15 106:11,21

107:13 108:12,19

108:22 109:16

115:2 116:3,17

119:19 121:2

123:1,5 124:2

157:17

acknowledging

164:8 165:20

acquired 86:16

91:12

act 17:22 37:16

124:3 173:14

acting 115:10

action 16:9 25:21

active 23:13,17

107:20 125:21

158:15

active-mode 38:14

actively 166:11

actual 65:19,20

72:13 87:16 97:21

98:3 113:17

140:21

adaptability 158:6

adaptive 5:2

153:12,14 155:14

155:16 156:3,7,15

164:10

add 38:13 61:12

78:1 165:10

adding 149:4

addition 24:15

28:22 135:17

additional 12:7

18:5 32:19 33:11

37:10,22 38:13

51:18 59:1 61:8

72:18 78:15 80:19

103:19,22 123:20

123:22 124:9,12

126:15 130:12

133:7 152:21

169:12 170:6

174:22

additionally 83:22

address 31:5 71:22

128:17

addressed 71:14,16

94:16 110:21

150:13 161:19

addresses 71:18

addressing 158:5

adequate 124:7

adhered 70:12

adjourned 176:20

adopt 22:10

adopted 17:14

131:9 162:12

adoption 24:6 30:1

advance 176:14

advantages 155:12

adversely 15:20

advertised 154:16

advocacy 23:14

Affairs 3:19 8:18

31:14

affect 58:10 97:20

affiliation 7:19

12:19 33:3

affordable 115:12

affording 31:4

agenda 3:7 11:6,8

12:12 34:19,21

aging 164:20 166:1

AGM 110:14

ago 9:4 40:5

agree 15:9 91:7

117:16 167:5

agreement 84:7

agrees 123:4

ahead 30:2 119:2

120:3 124:21

126:11 133:11

aid 146:4

aids 19:11

aim 42:11

airtime 13:1

alarming 68:9 79:7

alarms 108:4

albeit 131:1

Albert 2:3 3:16 8:8

8:9 23:6,7 55:17

56:9 57:16 59:13

62:14 63:12 64:1

64:18 65:8 67:17

69:8,8 71:7,13,16

74:7,7 75:8,16

76:16 80:21 81:3

82:4 83:1,18

84:16 86:8 87:22

89:15 91:6,10

93:9 96:1 97:8

98:12 128:2,7

131:22 138:12

139:21 140:6

141:10,18,22

142:8,21 152:1,9

157:11 158:10,13

159:20 160:16

161:2,7 162:4,15

164:18 166:3

169:15 174:2

alerted 60:1

Alex 2:5 3:19 8:17

31:10,12 59:8,9

61:6,14 65:10,12

66:2 68:17 72:2

73:15 129:18,19

130:3,9,14 131:10

142:12,13 143:6

Alex's 71:11

align 121:14

aligned 102:18

aligns 50:5

alive 108:10

Allen 10:14

Alliance 3:15 8:3

9:2 18:9,11 19:4,5

21:18 136:11

137:6,13 138:15

140:1 145:7,15

allow 21:10 78:12

112:13,21 120:21

133:18 157:6

allowed 119:15

allows 32:2 155:16

allude 39:9

alternatively

112:21

ambiguities 7:8

36:12 44:1 61:9

66:10 103:2

ambiguity 25:2

27:18,22 56:2,6

57:22

ambiguous 44:7

amended 37:18

38:12,16,21

amendments 37:21

Americans 20:21

amount 32:14

145:18

amperage 121:6

Analyses 4:5

analysis 11:19 16:2

39:7,19 43:11,16

43:20 173:7

analyze 61:15 62:3

141:16

analyzed 30:19

analyzer 79:21

ANDERSEN 2:3

Anderson 33:4,5

ANSI 142:18,21

answer 55:20 59:11

94:10 120:5

129:17,21

answers 57:7

anticipate 41:22

anticipation 70:13

anybody 12:6

170:18

anyway 62:2 80:11

80:14 100:11

apologize 59:15

104:10,11

apparent 25:8

appear 96:15

appeared 44:14

appears 29:22 61:7

108:3

appliance 2:6 8:21

28:17

applicability 151:6

applicable 42:2,6

42:11 45:20 123:7

135:13 141:6

154:17

application 45:2

60:18 93:12

114:17 117:13

125:16 156:17

applications 45:3
202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

Page 178

108:11 110:18

127:11,17 128:11

129:16 135:8

applied 32:2 35:15

36:15 44:9 53:19

55:10 57:8 59:5

63:4 70:21 124:19

125:4 127:11

136:1 155:2 156:2

applies 149:21

apply 48:17 64:12

110:19 150:21

applying 28:15

56:2 76:18 79:9

appreciate 68:20

174:21 176:12

appreciates 174:15

approach 17:5

appropriate 16:17

18:2 137:3 150:5

168:6 171:20

appropriately

151:10

area 108:13 116:7

127:9 137:10

areas 68:8 79:4

170:9

argue 164:3

Armstrong 2:4 3:5

6:12,13,14 7:13

9:13,13 56:22

57:1 66:2,7 67:19

74:22 75:3,4,11

81:14 82:7 95:4

102:13,14 130:14

131:16 143:6

163:3 164:17

165:4 167:16

171:10 172:3

arranged 87:7

arrive 109:21

article 117:1

as-received 165:3

166:1

ascertain 40:13

Ashley 2:4 3:5 6:12

6:14 9:13 35:12

56:21 57:1 68:19

75:2,4 81:15 82:1

82:10 85:22 95:4

102:13,15 122:9

130:13 131:11

163:4 167:12

171:11

Ashley's 168:2

asked 28:3 65:14

84:18 102:4

asking 92:11 93:1

156:8 161:18,21

163:19 168:5

asks 100:17

aspects 168:22

173:8

assess 143:19

assessment 98:2

134:22

associated 70:14

94:12 126:9 127:6

176:3

association 2:4,5,6

2:10,16 3:12,13

3:20 4:12 7:22

8:13,16,19,21

10:11 15:2,5

23:11 31:15 33:6

33:16 104:19

assume 109:12

assuming 158:19

172:18

attached 63:13

attendance 10:22

attention 115:4

atypical 159:13

authority 42:14

authorized 37:21

automobile 20:6

Automobiles 37:20

automotive 108:17

156:17 161:11

availability 6:7

14:6 37:7 40:12

52:3 114:14

124:17 125:1

174:9 175:10

available 19:21

36:9 44:3 51:15

52:20 70:7 148:11

175:9

Avenue 1:12

average 117:6,8,10

avoids 61:2

aware 85:8 133:14

153:13 172:15

awareness 27:6

68:21

B

back 10:6 54:18

82:3 85:9 95:6

101:16,19 104:3

106:3 113:14

132:21 136:22

140:18 151:12

171:2

back-and-forth

158:17

backup 125:10,22

126:5 127:13,18

129:16

badge 101:9

bailiwick 90:14

balance 164:21

balancing 124:3

ballasts 142:19

ballpark 75:15

Baltimore 6:10

bank 113:8

barely 121:10

base 28:18 29:5

139:3

based 24:18 29:22

30:17 36:5 44:14

45:10 51:14 58:16

63:19 87:6 146:21

163:13 164:12

169:16,18

basic 15:6

basically 111:6

120:8 132:4

136:12 137:16

basis 24:1 25:7

28:2 56:19

Baston 72:11

batteries 19:18

29:11 44:17 45:4

45:13,21 46:1,12

46:20,22 47:1,2,5

47:8,13,14,19,21

47:22 48:10,12

49:2,6,11 50:17

50:21 51:1,8,12

51:18 52:8,17

53:16 54:2 55:9

55:12,19 56:8,10

57:8 59:4 70:4,6

72:15 73:1 84:12

92:13,16 105:1,9

105:15 106:4,11

107:13 108:12,20

108:22 109:16,18

110:15 111:3,8,15

111:15,18,22,22

112:11 113:9

115:2,20 119:20

121:4,14,14,16

123:1,5 124:2

126:4 127:12,13

127:18 129:17

132:6 133:4,18

142:20 143:3

148:2,3 153:16

battery 1:3 4:10,18

6:6,19 13:19 15:8

15:10 18:14,15

19:14 22:20 23:18

29:9,13 32:6,9,14

36:10,19 37:2

38:1,7,10 39:4,11

39:20 40:4,9,12

40:18 43:3,5,17

44:19,19,22 45:3

45:6,6,9,10,14,18

45:19,21 46:11,12

46:13,14,17,18,20

47:3,10,12 48:9

48:17,19,20 49:2

49:3,15,22 50:3,7

50:8,8,9,11,11,14

50:14,16,20,22

51:5,7 52:6,9,10

52:12,14,21 53:10

54:1,4,22 56:11

59:18 60:3,7,8,15

61:16,21 63:13,14

64:19 67:10 72:1

72:14,22 78:21

79:14,14,21 80:2

80:5 81:6 90:2,3

92:19 94:2,8

105:7,8,13 106:9

106:17 107:14,15

108:2,3,8,14

109:10 110:9

111:17 112:3,9,19

113:8,16,17,20,22

114:12,13,18

115:7,22 116:2,10

116:10,16,18

117:9 118:1,9

119:2,6,8 120:15

120:19 121:8

123:7,14 125:7,9

125:11,11,14,19

126:1 127:1,1,4

127:21 128:9,12

128:14,21 129:6

132:5,9,15 133:12

134:3,11,14,17,20

135:1,6,14 136:1

137:9 141:5,5,8

142:4,5,15,18,22

143:3,15,19,19

144:8,15 149:1,4

149:7,19 150:9,14

150:18 151:2

152:21 153:21

154:3,3,15 155:4

155:9,15 156:3,22

157:3,14,16,21

159:16 160:1,1,2

160:18 161:11,16

162:1,17 163:14

163:16,17 164:12

164:12,21,21

165:1,8,18,18,20

166:4,6,9,18
202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

Page 179

168:7,14,15,22

171:13

battery's 115:14

battery-charger

127:7 168:3

172:10

battery-charging

23:15 124:20

126:10 131:4

133:20 138:19

159:11,14 167:8

168:1 169:5,8

battery-powered

19:8

battery-to-battery

115:13

BCs 25:11,17 27:4

30:22

bearing 167:1

bedroom 20:6

began 38:3 39:5

beginning 23:20

35:12 134:1

140:19 172:8

behalf 3:17 4:12

15:2 18:9 23:10

31:16

behavior 117:22

belabor 86:9

belief 127:5

believe 75:9 78:10

87:5 92:1 93:22

99:17 144:19

145:3 153:6

166:13 171:4

believed 45:7

believes 30:21

beneath 101:13

benefits 20:17

Berkeley 2:8 10:2,9

best 72:10 113:7

better 43:18 65:21

73:17 85:20 86:1

93:2 110:15

134:21,22 141:17

148:8 173:4

big 68:14 106:1

108:16 113:20

bilge 108:4

bit 53:15 70:16

73:6 74:6 86:6

121:9 127:10

159:3 169:2

172:21 174:11

Black 2:3 3:17 8:9

23:8

Blake 10:8

blind 56:18

Blue 2:10,12 4:11

33:19 104:17

Bluetooth 19:10

146:15

board 44:10 102:17

Boesenberg 2:5

3:19 8:17,17

31:10,11,13 59:8

59:9,9,14,22

65:11,12,13 66:6

68:17,17 129:19

129:20 130:4,10

131:10,17 142:12

142:13,14

bold 47:7

bolt 71:20

bottom 72:7

bought 155:18

Box 170:4

boxes 129:10

174:19

break 11:20 12:2

101:2,3,4,6 104:7

breaking 80:9

brief 11:6,10,10

14:15 34:1,9

107:4 125:2

135:19

Briefly 115:3

bring 11:12 14:16

126:1 153:9

170:20

bringing 153:12

brings 35:10

broke 102:3

Brookman 1:13 2:2

3:3 6:3,10 7:12,14

9:19 10:5,16

14:12 18:4 23:4

31:8 32:18 33:8

33:21 34:4 54:6,9

55:5 56:4,21

58:22 59:20 61:5

62:1,10 64:5,7

65:10 68:1 69:6

70:22 71:9,15

72:5 75:2 77:12

77:19 80:7,17

81:1,20,22 82:5

82:22 83:15 84:11

85:2 89:19 90:7

91:5 92:4 93:5

96:21 97:15

100:15 101:21

103:8 104:9,15

122:1 123:18

127:22 128:4

129:9 130:2,8,11

131:20 133:5

136:8 138:4,8

140:15 142:10

143:4,22 144:21

146:5 147:15

148:9,14 151:14

151:22 152:20

156:11 158:8,11

159:18 160:5

161:8 162:3

164:16 167:4,18

168:10 169:11

170:2,21 172:2,5

173:21 174:14

176:17

brought 14:5

124:16,22 140:18

build 112:20

Building 6:9

bunch 98:18

burden 41:20

111:19

burdening 124:4

bureau 20:6

burned 115:20

business 62:5 66:1

107:14 152:3

buy 20:21 113:19

150:17 158:21

160:10

buying 111:18

C

C 113:18,19,20

117:8 118:5,10

C-O-N-T-E-N-T-S

3:1 4:1 5:1

C31.2 24:5,15

cable 152:11

cadmium 157:17

California 2:15

21:13 22:5 25:12

40:19,19 43:11

44:4 54:16 57:13

66:14 67:12,16,18

69:4,5,10,14 70:5

70:7 74:1,9 77:22

82:13,19 88:16

90:12,21 91:13

95:15 96:16 132:2

150:20

call 3:2 20:1 83:11

85:16 93:20 133:2

143:13 149:10

164:10

called 11:13 85:15

Canada 23:16

147:21

Canadian 24:6

capable 48:12

50:20 54:1 55:11

55:11 154:10,12

capacities 48:13

capacity 49:5,8,12

50:10,13,18 51:9

52:11,13 55:20

109:4 113:16

117:6 157:4

capture 126:18

162:17 165:17

captured 114:22

164:4

capturing 127:5

care 119:13

cars 20:12

cart 115:2

carte 44:20 45:7,22

105:6,11 120:15

case 25:19 27:15

38:7 47:10 48:18

52:5 54:4 56:12

70:2 74:5 83:2,12

83:17 85:21 86:21

88:14 91:3,19

94:2 96:4,15,20

100:22 102:11

105:14 128:20

140:2 148:10

157:19 160:17

166:8 168:1

cases 26:6,7,16

27:13 29:13 56:11

60:6 64:19 65:9

71:22 79:14 81:10

83:8,14 119:8

158:7

cause 76:3

causes 60:8 68:16

causing 17:9

CEA 7:22 15:2,3

CEC 24:1,14 25:9

25:13,20,22 26:8

26:16 27:8,11,13

44:11,15 49:21,22

51:13,16,21 52:20

58:13 62:16 63:2

63:8,9 64:14

65:16 66:20 67:21

69:20 74:20 75:8

77:2,8 81:16 83:6

83:20 84:1,5,7

85:14 86:1,17,18

87:7,14,18,21

88:1,8,13 89:4,11

90:5,19 91:4

100:5

CEC's 27:19

cell 13:3 19:9

cells 110:16,16

centered 31:22
202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

Page 180

certain 16:21 99:1

certainly 29:22

62:11 105:6

121:17 127:4

129:4 133:14

168:21 169:6,10

certification 40:22

certified 73:11

certifies 73:12

certifying 145:9

cetera 66:1

chair 8:4 136:22

chance 33:1

change 22:6 155:21

157:4 164:11

changed 43:19

169:13

changes 39:18 42:1

42:2 92:13 110:22

130:19 135:4

136:3 156:4 168:7

characteristic

157:15 159:4

charge 15:15,18

19:13 32:9 48:8

48:10 49:4,7

50:10,12 51:1

52:11 60:6 71:11

72:3 79:20 109:3

109:6,8,17 111:7

115:7,11 116:4,14

118:4 119:2,9,22

121:5,11 122:21

126:2 133:3

136:20 137:11,11

139:6 146:15

149:2,6 150:8,19

151:3 152:13

153:16 154:8,13

154:18 157:7,21

158:22 160:13

161:13 162:20

163:14,17,18

164:11 165:14,21

166:4,6,7,8,9,11

166:16,16,19,21

168:8,15 171:3

charged 29:5,15

80:3 108:9 109:21

110:4,5 125:19

127:2 140:3 145:7

149:7 151:9

152:19 154:3,11

157:3,15 161:12

162:11

charger 15:10 29:5

29:9,13,14 38:8

38:10 40:12 44:19

44:20,22 46:13,15

46:20 47:1,3,9,10

47:12,13,19 48:1

48:5,17 49:2,3,16

50:1,20,22 52:6

52:10 54:1,4,22

59:18 60:3 63:15

70:6 78:22 94:2

105:12 106:11,16

107:14 108:2,3

116:1,17 120:16

120:17 121:8,15

125:11 127:2

132:5 141:3,4,7

142:6 143:20

144:7 148:11

149:10,11,13,19

149:22 150:14

152:11 156:3,18

157:16 159:16

160:1,10,13,21

161:15 162:17

164:12 165:18

168:22

chargers 1:3 6:6,19

13:19 15:7,8

16:11 18:2,16

20:18,19 21:3,17

21:22 22:3,20

29:18 30:13,14

36:11 38:2 39:4

39:11,21 40:4,9

40:18 43:3,6,17

45:19,21 46:11

53:11 55:10 63:14

67:10 70:14 105:6

105:7,8 107:15

116:2 119:15

125:7 127:21

128:9 129:6 132:9

133:2 134:4,12,14

134:17 135:2,6,14

136:1 139:12,16

140:3 149:1,4

150:9 151:17

152:22 153:21

154:15 155:4,9,15

161:12,20 165:21

166:10 171:13

charges 4:18 18:14

20:8 92:19 132:6

133:13 137:1

157:21 173:4

charging 5:2 17:13

17:20 18:22 19:2

19:7,14,16,20

20:3,4,5,16 22:3

22:14 23:18 28:6

28:8,11,12,18,21

29:2,4,19 30:6,16

32:6,15 48:12

50:21 53:16 54:2

55:11 64:1 70:3

106:14 107:21,21

109:10 110:20

115:18 119:3

121:6 125:21

128:14 132:16

133:16,17,17,18

134:20 137:7,14

139:8 143:15,16

146:14 147:1,9

149:17 152:19

153:12,14,16

155:14,16 156:7

158:2,18 159:12

161:16 162:1,9

165:17 168:7

chart 48:15,15

check 119:5

chemistries 32:6

51:2 62:6 123:7

137:10

chemistry 56:15,16

56:18 57:7,20

58:2,7 61:21 79:5

108:14

chime-in 34:1

choice 27:19 34:8

choose 56:8 83:11

83:17 95:20

choosing 66:13

chose 18:16

chosen 112:16

Chris 10:12

circuit 131:14

circuitry 60:7

71:20 72:2,4

131:3 132:13

149:6 151:3

158:18

circuits 108:9

circumvention

42:4

clarification 82:1

138:13 159:21

164:19

clarified 42:18

clarify 156:19

161:11 163:4

171:3 173:1

clarity 44:8 67:3

class 15:13 17:10

17:15 65:1 117:9

162:18

classes 17:1 64:22

147:1,2

classic 110:16

157:16 158:2

166:8

clean 81:11

clear 25:20 35:17

36:17 42:9 55:21

56:7 57:16 58:3

72:6 76:2,15,17

78:18 81:15 86:15

91:11 95:21 98:11

98:13 140:7,12

clearer 80:15

139:14 144:9

clearly 57:5 59:6

70:2

Cleary 2:6 8:20,20

172:7,7 173:11,16

173:19

close 51:19 74:21

175:19

closed 146:21

closely 102:18

closer 128:5

Closing 175:1

closure 175:1

Coast 33:18

code 46:7 78:8

coffee 101:11

coil 137:7

collect 73:10 78:4,7

collection 63:17

collects 81:16

combination 82:17

combinations

66:12 145:21

come 35:21 43:12

51:19 56:7 61:1

62:8 79:11 95:12

97:20 98:2,17

99:8 120:3,12

140:3 146:12

163:10

comes 46:16

coming 6:15 66:19

67:7 86:7 164:11

comment 28:4

31:19 34:6 36:1

37:4 53:7 62:22

68:3 72:11 77:14

100:16 101:4

104:7,12 146:6

148:15 152:2

157:10 169:7

170:10,12 172:19

174:19 175:19

comments 4:7,9,13

4:16,20 5:4 12:4

12:11 13:14 18:5

23:2,9 31:6 32:19

33:7 34:3 37:8
202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

Page 181

59:2 61:3,8

103:19 122:7

123:4,20 129:5,10

129:22 130:12,16

133:7 134:10

138:6,7,9 143:12

148:20 152:21

168:21 169:12

170:6,12 171:16

174:16,22 175:7

175:11,16,17,19

commercial 69:1,3

148:11

Commission 2:15

22:5 40:20 43:12

44:4 74:10 77:22

148:20

committed 24:8

committee 24:7

common 29:21

communicate

153:22

communicates

160:12

communicating

163:15

communication

154:9,12 155:7

158:16 159:9,12

159:22 161:3,15

161:22 162:10

167:9 169:20

communications

63:1

companies 21:18

31:16

compared 36:6

44:3 51:10,13,21

95:9

comparing 75:12

167:3

compatible 148:4

compelled 18:2

compelling 169:17

completed 69:2

completely 106:17

157:1

compliance 7:5

24:14 70:10 73:13

76:22 83:8 90:5

90:20

compliancy 67:15

compliant 67:12,21

73:11 74:3 88:12

91:16

complies 58:11,15

comply 27:13

58:11 69:11 70:1

70:3,8 74:12 83:7

83:14,21 88:17

89:2,2 99:11

100:1,2,14 145:9

complying 90:12

computers 19:10

conceived 100:8

concept 65:16

146:13

concern 25:8,19

27:1,5,22 28:2

62:3 106:3 131:18

159:21

concerned 28:9

31:2 69:16 85:19

95:8

concerns 31:22

61:16 64:17 70:16

144:13

concise 12:22

concludes 170:9

concluding 170:15

conclusion 22:18

153:8

concrete 90:1

condition 60:2,8

157:5 165:3 166:2

168:9

conditioned 79:15

conditions 154:2

163:13,22 164:6

164:13,19 165:11

conduct 41:20

48:22 98:15

132:14

conducted 36:6

50:6 92:20

conducting 126:13

126:20

conducts 88:13

confidential 62:5

configuration

49:11 50:16 51:7

configured 135:7

confirm 167:19

172:20

confused 172:12

confusion 76:3

connect 149:12

connected 108:1,2

109:14 154:5

consequences

18:21

consequential 25:3

conservation 4:3

11:18 16:13 37:14

37:16,19 39:3,20

conservative 65:18

82:16 91:2

conservatively

66:19 73:16,18

75:20 85:16

consider 39:2,14

41:3 54:3 76:4

86:3,4 89:6 131:7

134:3,8 135:16

considerable 30:3

consideration 40:8

134:13 141:2

142:2

considered 17:17

65:14 149:1

168:14

considering 26:2

40:3 41:6 116:17

172:9

consistent 13:9

42:14 79:16 91:4

92:15 127:17

131:8 136:2

console 20:7

Consortium 19:6

29:2 138:21

constant 116:3,5

constitutes 76:22

89:5

constrained 99:3

constraints 111:4

consultant 55:6

Consulting 2:14,15

9:22 10:4,13,15

consumed 168:6

consumer 2:9 3:12

7:21 15:1,15

37:19 38:1,7

152:12

consumer-dema...

32:10

consumers 15:20

19:16 20:11

consumption 32:16

38:6,14 41:17

78:14 82:17 99:19

164:2,3

consumption-type

76:8

contact 25:22

62:16 176:5

contains 149:5,16

contemplate 134:3

content 11:16 12:7

33:12 34:14 54:10

104:1 174:17

context 155:4

continue 39:14

172:10

continued 4:1 5:1

39:6

continues 39:13

71:19

continuing 119:9

contrary 17:5

contribute 118:16

contributed 23:22

contributes 79:6

84:14 116:11

contributor 23:17

control 50:22

111:21 115:22

149:6 154:18

164:10 168:15

convenient 19:19

112:16,17

conventional

168:17

conversation 13:11

14:3 21:6 23:21

66:12 78:2

conversations 13:4

coordinating 60:22

copies 46:4

cordless 128:11

139:2

corner 108:18

115:4,18

correct 65:6 75:14

75:22 81:21 82:20

106:7 142:8 161:1

161:6 173:13

correctly 78:19

correspondences

176:3

corresponds 7:1

Council 2:13 3:13

8:7 15:4 110:10

Counsel 9:9,11

176:9

couple 6:20,21 39:9

43:17 51:17 53:1

53:4 78:1 107:10

128:2 148:19

170:11,14

course 25:21 61:2

62:6 85:15 88:13

174:14

cover 73:10 132:9

covered 15:12 35:5

create 15:13 31:3

41:19 60:8 93:18

119:1,1 138:17

created 138:16

creates 29:8

creating 24:8 68:9

138:16,19

criteria 50:15 51:6

52:14,17 55:22

140:12
202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

Page 182

critical 16:18

critically 16:8 21:2

crude-looking

114:21

cruising 113:12

cue 92:8

cue-up 124:22

curious 142:16

current 30:22

71:18 116:3 119:5

119:10 121:17

124:1 135:10,22

136:15 154:2,10

154:18 155:3

156:18 157:2,5,13

157:20 158:1

currently 7:2 22:9

29:10 82:21 98:5

135:13,17 144:17

156:8 171:12

currents 168:8

curve 114:21

115:13 117:12,12

curves 115:5 116:9

cutoff 71:11

cutoffs 60:6

cycle 110:7 112:13

119:3 120:1 121:5

121:11 122:21

cycles 111:12 112:1

112:4

Cymbalsky 2:7

9:15,15

D

D.C 1:13 6:9

damaging 21:11

Daniel 72:11

data 6:7 14:5 25:9

25:9,16,18,20

26:16,21 27:8,12

27:16 35:20 36:5

36:7,8,13 37:5,6

40:11 44:2,3

49:21,21 50:4,5

51:15,15,20,21

52:2,19,19 55:13

58:17 61:18 62:17

62:18 63:2,8,17

65:3,5 67:7 68:6

74:14 75:10,13,21

75:21 78:16 81:11

81:16,18 82:12

83:6 85:15,18,20

85:22 86:13 87:3

87:19 88:2,3,5,10

88:18,19 89:3

94:22 102:16,19

103:4,6 115:1,21

117:4 119:1

120:12 124:16

125:1 171:21

174:9 175:10

176:1

database 44:4,11

44:15 49:21,22

51:13,16 52:20

64:14 65:16,20

67:14 69:17 73:9

74:20 75:7 78:4

82:13 86:1 88:20

90:19

datasets 27:11

date 25:13 39:12

91:14

Dave 2:7 9:5 54:13

89:20,21 123:10

147:17,18 156:12

156:13 161:9

167:4,19 168:10

168:11 170:21,22

day 12:3

days 119:7

deadline 172:16

173:17

deal 45:12 143:3

dealing 143:13

deals 143:7

debated 132:4

December 38:11

decide 22:10

deciding 16:22

decision 15:7,22

18:1 58:3

decisions 66:1

Decker 2:3 3:17 8:9

23:9

declaration 100:11

decrease 114:13

deep 110:3 111:8

deeply 59:15

defer 16:2 18:13

39:13 63:18

deferred 134:12

deferring 40:7

define 147:1

defined 55:21

definitely 76:3

definition 15:11

150:13

definitively 137:22

delivers 154:1

Dell 160:20,20

delta 72:15

delve 90:11

Denkenberger 2:7

9:5,6 54:13,14

55:1,4 89:21,22

90:22 91:9 123:10

123:11 147:18,19

148:10 156:13,14

161:10 167:5

168:11,12 170:22

171:1

Denny 2:16 8:12

Department 1:1

2:4,7,8,11,14 3:5

3:9 4:4,6,8,15,19

5:3 9:8,11,18 11:1

22:6 27:1 31:17

57:2 62:11,16,18

63:12 65:4 67:1

73:8 96:2 99:7

122:6 174:15

Department's 6:16

dependent 113:13

depending 48:7,14

60:2 106:10,16

112:3 154:2

163:16 165:22

168:8 169:9

depends 46:18

114:6 154:4

deployed 21:11

136:17

deployment 17:21

derive 93:16

describe 61:9

144:11,13

described 56:5

71:2 157:13

describes 114:10

deserve 11:13

design 18:18

designed 19:12

108:20,22 110:8

110:16 139:12

140:10 145:4

166:15

designs 131:14

desktop 20:7

detachable 45:21

46:17 64:19,21

94:3 160:1

detail 174:20

detailed 127:15

129:15 136:13

174:16

deterioration 112:2

determination

16:10 21:3,9

22:20 23:1 28:19

58:15 172:14,16

173:12

determine 25:22

43:20 51:14 88:16

111:21

determining 95:18

detrimental 22:13

developed 21:11

24:5 133:21

developers 19:2

developing 19:6

21:19 147:13

development 6:15

17:21 18:19 23:19

132:1 147:11

develops 74:15

device 20:5,7,10

29:5 136:20 137:1

141:9 146:15

148:4 160:11,12

160:15

devices 15:18 19:8

19:13,21 20:22

29:12 32:8 137:8

137:9 146:19

147:8,9 165:21

devoid 86:3 97:18

difference 52:8

95:22 113:3

140:19 165:17

differences 52:18

53:18 54:3 68:14

79:6 80:4 81:5

90:17 91:22 113:2

different 36:13

41:12 50:6 51:11

51:12 57:7,7

60:16,21 63:16

67:5 69:21 79:3,3

84:4 98:18 102:20

103:16 109:20

115:10 124:20

131:13 135:5

137:11 140:4

142:7 154:13

155:22 159:3

160:14 161:14

163:14 165:10,14

167:10,11 168:16

169:9,21

differential 157:22

164:4

differentiates

108:10

differentiators

19:15

differently 57:9

100:8 165:21

difficult 20:10

114:7

diminished 97:4

direct 115:3

direction 103:20

directly 11:16
202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

Page 183

147:12

disadvantages

155:13

disagreement

95:14

discharge 60:5

71:11,19,21 79:13

79:19,21 108:21

109:1,3,7,17

110:6,11,12,13

112:6,7,13,22

113:2,11,18 114:3

114:15 115:5,6,16

116:14,21 117:7

117:14,21 118:1,3

120:22 122:20

165:13,13

Discharge/cutoff

71:13

discharged 79:16

81:6 105:16 165:8

discharges 117:10

discharging 107:21

disclosed 63:20

disconcerting

61:20

discourages 42:3

discover 114:12

discrepancies 36:8

45:17 68:12 84:14

84:15 105:1

120:11

discrepancy 25:8

25:22 26:8 62:15

62:17 106:2

discrepant 26:21

discriminate

132:12

discuss 40:11 111:4

discussion 7:10,11

13:2,22 37:10

85:10 89:14 103:3

112:15 146:21

disparate 137:9,9

disposed 20:21

disruptive 24:21

31:2

distance 116:8

distinct 139:1

distinction 28:10

28:11 29:17 30:7

56:19 58:6 139:22

140:21 141:11

distinguish 57:5

distinguished

107:22

diverge 59:3

diversity 107:6

docket 122:11

176:2

docks 133:18

document 39:6

DoD 143:7

DOE 9:14,16 15:16

16:9 17:21 18:12

18:16 21:2 22:19

24:2,6,10,12,18

25:9 26:9 28:3

30:15 37:21 38:3

39:10,13 43:4

62:21 64:12,14

74:15 75:5 76:18

81:12,15,19 84:17

86:22 89:5 91:12

95:5,7 100:21

102:10 103:16

126:16 130:21

131:7 172:9,13,22

173:2

DOE's 15:6,12,22

16:4,8,19 25:7

27:21 28:5 40:20

57:4 75:18 78:15

doing 12:20 20:15

57:12,14 80:13

82:21 103:16,17

116:22 149:4

173:7

dominant 108:13

Dommu 2:8 3:9 4:3

4:5,8,15,19 5:3

9:17,17 13:15,16

13:17 34:15,16

54:8,20 55:3 92:9

103:12 104:2

106:22 107:9

122:12,14 124:14

128:18 133:10

139:11 140:5,14

151:16 153:3

156:21 157:8

159:6 161:17

162:14 163:2

167:21 168:20

170:8 175:5

Donald 137:17

Doug 1:13 2:2,14

3:3,11 6:9 7:20

9:7 14:21 15:1

23:6 31:11 34:20

35:5 73:2,3 85:3,4

89:8 90:7,9 97:15

140:15 142:4

143:22

Doug's 75:17 95:6

DOUGLAS 2:9

Dozens 19:1

drafted 144:17

drained 157:1

dramatic 114:13

dramatically

115:13

drawn 71:19

drill 122:6

drop 127:3 136:22

dry 4:18 15:14 28:6

133:13,16 139:13

140:10

due 60:6 101:2

131:14 154:18

175:7

duration 121:5

dynamic 17:6

E

E24 26:14

earlier 54:15 67:13

85:10 91:11 94:18

95:7 100:17 102:6

107:18 136:18

162:7 173:6

early 17:20 18:18

29:22 147:10

easily 26:17 107:22

easy 19:17 20:4

131:13

Ebatt 114:15,18

115:12

economically 16:15

21:8

economically-jus...

43:10

ECOVA 2:7 9:6

54:14 147:20

effect 21:10 31:2

43:12,13 105:10

106:5

effective 25:13

91:14

effectively 24:18

32:3

effects 105:3

115:22

efficiency 18:15

24:17 37:22 38:6

39:10 41:17 43:8

58:12,13 69:18

70:14 75:19 78:14

95:21 96:6 99:19

116:21 117:13

118:1,8 155:12,12

155:21

efficient 21:22

76:12 118:8

efficiently 19:13

effort 39:4

egregious 64:15

100:19 102:8

eight 119:6

either 22:12 48:5

57:14 102:20

143:18 165:7

172:13

electrical 2:5 3:20

8:19 31:14 71:6

163:7

electronic 20:9,22

139:18

Electronics 2:9,11

3:12 7:21 15:2

elements 169:21

elevator 101:12

email 175:12

emergency 19:22

20:2

Emily 10:21

employ 28:8,16

employed 163:11

163:12 164:9

165:6

enacted 37:17

encourage 122:5

175:18

encouraged 169:10

end-of-discharge...

72:1

end-use 45:2,3

125:16 135:8

143:15

ends 101:10 170:13

energy 1:1 2:4,7,8

2:11,14,15 3:5,9

4:2,4,6,8,15,19

5:3 9:12,18 11:1

11:18 16:13 17:16

18:14 21:6 22:5,6

24:14,17 30:4,12

37:13,15,19,22

38:6,6,14 39:3

40:20 41:16 43:8

43:11 44:4 49:12

50:1,3,17 51:8

52:13 69:18 70:13

72:22 73:8 74:10

75:19 77:22 78:14

78:21,22 79:14

80:2,3,5,5,6 82:16

90:3,4 99:19,19

110:12 115:21

119:13,17 126:18

127:5 148:20

164:2,2 166:16,17

167:3,3 168:6

Energy's 9:8

energy-consuming

126:12
202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

Page 184

engage 7:10

engaged 39:2

engine 113:22

engineer 59:19

71:6 97:6 163:7

engineers 114:8

enlighten 44:5

ensure 19:20 35:14

36:2,17 41:7

42:16 92:14 96:9

123:14 127:16

129:15 136:1,4

156:5

entering 82:13

entire 65:5 98:6

entirely 94:15

entities 36:19 37:2

41:13

entry 27:12 108:15

environment 15:15

140:10

environmental

20:17

environments 4:18

20:14 133:13,16

139:13,17

EPCA 16:11 18:3

21:4 22:21 37:21

172:12

EPS 160:3,10,14

162:2,16 167:10

167:22 168:16

169:10

EPSs 167:11

equation 114:9

166:20

equipment 19:2

107:16,17 145:13

equipped 127:18

129:16 137:7

145:15

Erica 2:13 8:5

61:11

error 94:12 172:19

172:20

errors 26:18

especially 121:7

171:14

essentially 46:10

47:4 52:5 56:18

138:14 157:18

166:19 167:1

170:9 174:4

establish 16:21

38:5 96:3 98:14

100:1

established 37:18

38:10 76:20 86:19

157:9

establishing 75:19

95:2

establishment

16:12,14 21:4,7

estimation 76:10

et 66:1

event 125:12

everybody 104:3

107:5 131:19

evolves 17:15

exactly 51:4 94:7

131:16 156:21

examine 63:22

examining 173:3

example 64:17

78:18 91:1,1

100:3 128:11,20

129:1 143:7 147:7

160:9,19 168:13

examples 66:8 68:7

79:2 103:1

exceed 99:9

exceptions 22:2,4

22:15

excerpt 46:3

exclusively 125:9

excuse 163:6

execute 66:17

exempt 15:7

exercise 173:5

exist 100:5 159:22

existence 97:19

existing 17:11

30:18

exists 152:4 162:10

expand 146:9,18

expanded 68:20

expanding 147:7

expect 87:4 125:19

146:11 166:7

expectation 25:15

70:20 74:19 77:3

87:2,6 91:15

expected 36:20

152:12

experience 59:3

75:18 94:11 96:19

98:8 121:20

experienced 25:6

experiencing 20:1

experimental 94:12

expert 33:18 59:18

explain 23:1 37:14

55:15

explained 133:22

159:7

explains 47:18

explanation 66:3

explicit 89:3

explicitly 88:21

explore 35:22

36:11,21 72:9

73:6 74:5 127:9

135:9 143:17

exponent 114:10

exponential 114:6

expressed 27:1

expressing 87:15

extend 120:9,22

121:5

extended 121:18

extending 122:19

122:20

extension 139:10

extent 20:18 23:22

28:7

external 40:1,3,6

149:9,14 154:7,11

155:6 159:15

169:3

extra 68:19

extracted 117:19

extremely 108:13

eyebrows 27:17

F

face 128:5

facilitating 14:1

Facilitator 1:14 2:2

3:3 6:3 7:12,14

9:19 10:5,16

14:12 18:4 23:4

31:8 32:18 33:8

33:21 34:4 54:6,9

55:5 56:4,21

58:22 59:20 61:5

62:1,10 64:5,7

65:10 68:1 69:6

70:22 71:9,15

72:5 75:2 77:12

77:19 80:7,17

81:1,20,22 82:5

82:22 83:15 84:11

85:2 89:19 90:7

91:5 92:4 93:5

96:21 97:15

100:15 101:21

103:8 104:9,15

122:1 123:18

127:22 128:4

129:9 130:2,8,11

131:20 133:5

136:8 138:4,8

140:15 142:10

143:4,22 144:21

146:5 147:15

148:9,14 151:14

151:22 152:20

156:11 158:8,11

159:18 160:5

161:8 162:3

164:16 167:4,18

168:10 169:11

170:2,21 172:2,5

173:21 174:14

176:17

fact 22:15 32:7

74:16 88:11 90:11

91:12 92:2 150:14

failed 25:10

fails 26:5

failure 60:17

fairly 32:14

faithful 24:9

fall 87:5 96:12 99:5

119:10

falls 84:3 86:20

familiar 46:5 101:8

114:9

far 17:9 86:18 93:6

143:2

fast 110:13

faster 158:22

163:17

faulty 117:3

favor 69:1

feasible 16:15 21:8

feature 60:9,19

features 32:10 48:7

130:7

February 40:5,16

federal 17:10,18

46:7 79:9,17

96:14 171:6

feed 173:9

feedback 36:1

53:21 123:9 125:3

138:1

feel 171:15 176:7

fellow 115:19

ferreting 60:12

fewer 30:13

field 37:1 88:14

89:2 163:13,21

164:9,13,19 165:6

field-tested 87:4

figure 114:16 151:8

filed 23:2

final 38:9 109:8

120:5 144:2

170:14 175:4

finalize 17:22

finalized 38:11,20

38:21 39:13,22

40:6 139:20

finally 42:13 49:9

106:1 135:3 176:5
202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

Page 185

find 46:8 68:11

80:15 85:6 119:7

121:3 123:12

131:18 148:1

161:15 175:22

finding 93:3

finds 28:1

fine 82:4 107:11

finishing 121:10

fire/safety 107:16

first 25:21 37:16

39:19 49:20 54:18

62:19 78:3 90:13

91:3 93:9 98:11

110:6 111:2 112:1

125:8 135:21

fit 69:22

fitness 111:22

five 105:16

five-hour 112:15

114:14 117:7

118:3

fixed 154:4

flag 84:21

flags 79:8

flap 117:1

flaws 109:18

flexibility 32:1

flexible 32:5

flooded 110:15,16

floor 53:2,7 93:1

101:12,13 123:3

125:3

fly 81:19

focus 7:7 13:3 15:5

35:12 68:13 90:14

159:9 160:4,9

168:3 169:4

focused 20:14 65:9

128:8,10 155:8

focusing 159:17

folks 10:21 63:19

90:12 141:13

144:11,12

follow 22:9 57:17

57:18 73:4 82:8

87:11 88:7 151:7

174:2

follow-on 152:1

follow-up 176:7

followed 22:9

36:18 42:10 45:7

following 11:8,15

12:1 18:7

force 24:13 30:16

fore 11:12 14:16

foregoing 101:18

forget 20:11

forgot 104:10

format 24:9

Forrestal 6:8

forth 108:5 137:19

forward 18:14

124:22 153:10

174:12

found 81:17 147:22

four 119:6

four-port 149:10

framework 39:5

73:8

frankly 119:19

free 176:7

frequencies 137:16

frequency 137:14

frequently 166:9

front 35:3 46:5

51:20 103:4

front-end 11:13

fulfill 16:19 57:19

88:7 99:1

full 108:22

fullness 76:6

fully 109:21 110:4

110:5 125:19

127:2 146:11

154:3 165:8

function 114:6

126:6,15 131:4

132:7 166:5

functionality

125:16 126:10,19

127:7 128:22

132:16

functions 98:7

126:9 128:13,16

furniture 145:12

further 15:12

31:19 40:7 61:15

62:3 102:22

134:12

future 17:17 21:14

22:10 29:19

143:10,11,11

G

gained 67:3

galvanic 15:11

general 9:8,11 25:1

30:2 65:3 152:15

154:4 169:15

176:9

generally 24:11

93:11 103:13

107:16 111:22

120:14,19

generate 114:5

generates 99:21

getting 36:1 41:11

59:1 89:14 90:18

167:10 169:1

171:2

gist 106:19

give 26:9 73:7 89:9

107:10 125:1

151:21

given 17:19 45:5

56:9 82:18 95:9

165:18 171:8,19

gives 114:15

giving 14:2

glad 35:8

go 11:15 13:14 41:5

42:22 48:21 53:5

54:18 90:20

101:12 106:3

107:1 112:12

113:14 114:14

118:22 119:2,17

119:22 120:1,3

124:21 126:11

132:11,21 133:10

134:16 139:5

143:12 160:6

170:14 174:12

goes 19:11 47:18

108:5 119:4

157:14

going 6:11 11:6

13:2 33:11 35:20

53:1 56:7 58:6

62:6,22 63:7,10

63:18 73:21 92:15

94:21 95:6 98:19

98:19 102:4 104:3

106:10 108:8

111:9,17 114:17

114:19 118:11

121:7,9 123:16

136:17 140:2,18

141:8 146:2 149:7

151:3,4,7 160:13

164:9 166:20

167:6 173:3,9

174:7,11

gold 119:16

golf 115:2

good 6:3,5,13 7:20

8:1,5,8 10:22

14:22 64:16

101:15 102:1

104:14,15 106:7

107:8 122:4

142:10 146:4

174:20

gotten 6:21

governed 152:17

graph 113:1 118:6

graphically 118:2

graphs 117:20

great 23:22 28:7

77:20 91:22

109:19 120:11

122:12 124:14

174:19 175:5

greater 17:9 26:14

greatly 118:16

grossly 165:16

ground 12:15

101:11,13

group 8:4 24:4

groups 19:6

grows 17:15

guess 70:10,15 76:1

93:15 103:9 104:1

111:11 123:2

124:13 129:1

162:15 169:15

172:11,18

guesses 33:10

guidance 22:1,7,8

95:11 148:7 171:5

guys 7:9 66:13

82:11

H

habit 12:20

half 117:11

hall 101:11,14

hand 13:7

hand-delivery

175:13

handle 113:10

135:21

handled 17:4

handling 105:19

147:6

handshaking

158:16

happen 56:12

happened 50:7

52:11 132:19

134:1

happening 164:22

happens 155:19

159:10 163:20

happy 107:3

131:19

hard 92:1 97:12

165:9

harm 17:9

harmonize 42:12

head 46:6 55:7

headsets 19:10

hear 13:10 77:16

77:17 80:22 81:2

87:15 155:3

heard 28:22 39:9
202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

Page 186

85:11 112:14

169:17

hearing 19:11

146:4

help 7:10 32:11

43:20 53:17

141:16

helpful 14:20 130:3

130:18 141:13,17

helps 19:20

Hi 13:16 33:4 34:15

148:17

high 109:6 115:15

higher 78:14 115:5

115:6 157:2,20

158:19 164:1

166:8

higher-capacity

158:19

higher-power

147:8

highest 49:6,12

50:12,17 51:8

52:10,12 78:10

82:16

highlight 66:9

103:1

historic 115:1

history 4:2 11:17

37:13 38:17

home 2:6 8:21

20:12 114:22

hooks 147:6

hop 20:12

hope 13:21 32:11

36:11,22 53:17

hopefully 145:20

hopes 36:1

hoping 7:9 13:1

72:9

horizon 148:13

host 105:14

hotly 132:3

hours 90:3 105:16

106:15 112:22

113:4,4,10,16

119:6 121:11

123:16

house 113:9 145:14

huge 105:20 107:6

I

i.e 127:13

idea 71:11 78:5

Ideally 65:20

identified 154:16

identify 60:20

IEC 142:22

ill-suited 105:15

imagine 156:22

immature 15:17

17:6

immediate 7:16

Immediately 11:7

impact 20:20 22:13

24:21 30:3,19

45:15 109:4 113:5

impacted 39:18

impedance 157:18

157:19 158:1

implemented 27:5

29:6

implementing

24:17

implication 158:14

implied 88:18 93:6

imply 164:20

important 16:4,9

21:2 30:10 31:5

41:3 78:7 141:1

141:11

imposed 21:16,21

improve 31:19

32:11 93:2,8

103:14 112:1

improved 42:18

122:17 124:1

169:13

improvement 43:7

97:1,5

improvements

125:5

inappropriate 17:7

incidentally 132:7

incipient 17:14

include 38:1

146:18 147:7

included 35:2

132:8 175:17

includes 22:1 45:2

inconsistency

25:18 79:8,12

inconsistent 80:2

incorporated 2:12

151:13

incorrectly 79:10

increases 157:4

Independence 1:12

independent 57:20

83:4 84:21 141:22

indicate 25:10

60:10

indicated 173:6

indicates 118:7

indicating 82:12

130:17

indication 140:7

individual 98:2

individuals 20:14

32:22

inductive 4:17

15:11 133:12,19

139:12 149:22

industry 2:3,13

3:12,13 8:7 15:3,5

22:3 33:5 113:8

118:22 131:13

inefficiency 116:9

infancy 19:1

infers 148:21

influence 105:12

informal 22:1

information 2:13

3:12 4:14 8:6

11:5 12:2,7 14:9

15:3 25:14 39:17

44:6 53:17 62:5

63:20 68:20 73:10

76:21 103:9 122:4

124:18 141:15

155:1 169:18

170:15 175:6,8,15

175:16 176:6,15

informed 143:12

initial 39:18 79:19

142:6

initially 38:21

79:15 133:21

146:17

inject 78:5

innovation 18:20

innovative 19:7

input 42:17 65:17

67:8 85:7 176:13

insert 12:7

inserted 122:10

insight 53:3

instances 81:17

Institute 3:18 8:11

23:10

instruct 48:22

instructions 47:11

47:16,20 151:7

instrumentation

120:20

integral 46:11

64:21 126:4 128:9

128:21 160:2

integrated 130:7

intellectual 62:4

intended 17:8

69:19 139:5

intention 105:10

intentions 63:3

interaction 152:18

159:15 167:22

interacts 161:2

interest 107:6,13

160:4

interested 45:16

59:1 135:3 156:9

156:19 168:19

175:18

interesting 144:3

intermittently 80:9

interpretation 26:3

26:20 67:2

interpreted 63:8

167:20

interpreting 58:10

77:10

interrelationship

132:15

intertwined 132:17

interval 110:14

introduce 10:7

33:1 105:14

141:19

introduced 9:3

94:18 162:5

introducing 14:3

105:20

introduction 42:20

introductions 3:6

7:15

inventory 112:11

investigate 147:22

167:15

investigated 26:6

investigates 63:13

investigative

130:22

Investor-Owned

54:17

invite 37:7

invited 109:11

inviting 37:4

involved 32:7

ion 51:5 127:1

isolate 131:4

issue 16:10 21:2

26:10,19 27:1

29:8 36:11 46:16

53:22 54:5 58:21

59:2 60:13 62:7

70:17 72:18,21

80:4 81:12 83:9

85:7 92:6,8,10

103:12,18 110:20

125:8 127:14

130:17 132:3,11

135:22 141:16,19

147:22 156:1

161:13,18 162:6

162:21 163:5

165:6 166:14
202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

Page 187

170:4 172:13

issues 11:11,12

14:4 25:6 26:2

31:6 35:5,22 37:5

53:6 67:3 68:9,11

81:13,18 84:5

104:5 105:5

107:19 129:10

130:12 135:20

142:1 153:9 155:6

162:8 163:9

170:17

item 76:9

items 34:19,21

37:10

iteration 122:20

ITI 8:6 15:4 60:22

IYAMA 2:8 10:1

J

Jen 8:20 172:6,7

173:22

Jen's 174:3

JENNIFER 2:6

Jeremy 2:8 3:9 4:3

4:5,8,15,19 5:3

9:17 13:15,17

34:16 54:6 61:18

94:18 103:12

117:2 122:13

128:3 167:9,18

Jeremy's 55:20

John 2:7,12 3:14

8:22 9:15 18:8

89:20 136:9,10

138:13 139:8,15

144:22 146:9

150:10 156:11

Johnson 2:9 3:11

7:20,21 14:22

15:1 18:8

join 13:11 33:18

80:12

joined 72:12

joining 10:19,21

13:20 34:12

176:11

Joseph 2:3 33:4

judge 97:12

jump 37:12

June 1:7 6:8 38:12

38:15 40:10

170:13 175:8,20

jurisdiction 16:8

76:19

jurisdictions 24:22

justified 16:16 21:9

172:14

K

K 2:9

KAHAN 10:12

keep 13:2 81:11

107:4 108:10

Kelso 2:10 4:11

33:19 101:4

104:11,14,17,17

107:2,12

Ken 2:15 77:13,15

77:21 80:8,22

81:1,3 82:2,9

85:11 86:10 88:5

148:15,16,18

150:12 151:14

Ken's 152:2

key 19:15

kick 125:15

Kido 2:11 9:10,10

62:21,21 63:18

64:3 173:1,2,14

173:18 174:7

176:8

kind 35:19 38:17

53:5 63:4,6 80:9

84:4 86:6 103:6

106:19 117:3

124:21 138:14

141:16 144:11,17

158:6,9,17 162:7

kinds 122:7

kit 45:2

kitchen 17:3

know 54:1 58:14

62:3 68:16 80:13

87:1 88:17 91:1

104:7 111:9

112:10 119:18

120:4,5 122:6

126:22 131:6

132:18 135:4

136:16 137:3,22

141:8 142:16,17

143:2 144:15

145:5 147:4

149:22 152:14

162:5 163:5,20

165:7 172:21

known 143:16

knowns 137:19

Kubik 2:11 8:1,2

9:3 146:7,8

Kuzin 2:12 3:14

8:22,22 18:7,9

136:10,10 138:5

144:19 145:1

150:10,11

L

la 44:20 45:7,22

105:6,11 120:15

lab 10:2,9 109:22

118:22 121:20

138:3

label 114:19

laboratories

111:20

laboratory 2:9

86:16 88:2 112:10

112:16

labs 79:18 92:21

Lamborghini

108:16

lamps 142:19

land 80:15

landfill 20:19

language 123:13

laptop 160:20

161:4 168:14

laptops 147:8

158:20 162:19

large 121:8

larger 26:21 78:21

80:5 103:1,2

113:17

largest 66:10 72:13

106:8

Larry 2:3 3:16 8:8

23:5,7 31:9 55:16

59:12 62:13 68:2

69:7,8 71:4 73:5

74:7 75:16 76:16

80:17 82:3,8,22

83:1 91:5,6 92:5

93:6 96:1 98:13

127:22 128:4

131:21 138:11

142:17 143:5

151:22 157:11

159:19 160:16

162:3 164:16

166:3 167:6

169:14 174:1

Larry's 59:3

141:15

Lastly 26:22

lately 13:9

latest 17:12

Laughter 71:8 97:7

137:20 173:20

Lauren 10:10

law 17:2 38:3

Lawrence 2:8 10:2

10:9

lead 4:10 104:22

105:15 106:11,20

107:13 108:12,19

108:22 109:16

111:11 115:2

116:3,17 119:19

121:2 123:1,5

124:2 157:17

leading 23:12

leads 110:13 127:4

leafing 80:18

learn 53:14 67:6

120:10 127:10

153:20 154:20

159:8 174:11

learning 45:16

156:9 159:14

leave 67:22 103:18

119:4

led 80:1

left 7:17 103:11

115:4

legitimately 68:7

less-predictable

110:14

lessen 20:19

let's 14:14 33:2

34:13 54:7 72:21

101:3,5,22 103:19

136:21 160:2,20

163:11

level 37:1 95:9,19

96:6,14,16 97:18

99:1 105:17 116:4

levels 7:6

Lewan 2:12 8:14

8:14 33:14,15,22

lieu 30:13

life 19:15 110:17

115:14

limit 13:4 145:18

limitations 99:6

limited 131:1 133:1

limits 74:12

line 48:21 73:19

80:15 83:3,5

86:15 87:16 91:3

98:3 100:21

102:10 129:3

139:15

link 46:9

links 175:22

list 19:11 167:14

listed 11:22 174:18

listening 35:4

63:10

lithium 51:5

108:14 127:1

little 53:14 69:16

70:16 73:6 74:6

86:6 108:15

127:10 128:5

141:17 159:3

164:17 169:2

172:12,21 174:11
202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

Page 188

lively 13:1,21

loads 107:20 108:1

113:10

Logan 2:13 8:5,6

61:13 62:2

long 28:16 87:18

105:20 110:17,17

111:7 112:2 113:2

113:3 167:2

172:16

long-term 143:11

longer 112:14

121:9

look 12:15 41:4

63:14 65:15 81:12

93:11,12 104:22

106:8,12 110:9

115:17 116:21

117:21 151:5

166:15 174:16

looked 44:11

136:19

looking 53:20

61:11,18 63:2

79:12 90:2 115:1

115:18 116:15

117:21 167:2

173:8

looks 80:18 166:16

166:17

loopholes 42:5

loosely-coupled

21:17

loss 114:6 116:10

116:16 117:6,8,10

117:15 118:3,11

118:15

lost 125:13 127:13

128:10 129:3

130:5

lot 14:2 54:10

55:14 59:6 64:13

68:11,14 69:1

108:9 114:18

117:4 119:14

122:4 132:10

135:5 137:17

144:4 148:21

149:8 153:20

lots 152:5

love 123:3 129:4

134:20 155:3

loves 122:7

low 114:3 157:20

166:6

lower 66:20 86:5

114:15 115:4

118:6 137:16

164:2

lowest 49:3,4,7

50:9,10,12 52:11

126:12

lucky 33:17

luxury 108:7

Lyama 10:1

M

magazine 114:22

main 125:12,17,22

127:12 128:10

129:2 130:5 132:7

mains 128:12

maintain 125:15

maintained 100:17

maintenance 50:2

106:9,13,15,18

109:12 119:4,9,14

119:21 120:11

123:15 125:20

major 28:14

makers 19:3

making 22:22 32:1

76:15 115:11

140:22 143:16

Manager 3:16,19

8:18 13:17 23:8

31:13

manner 44:10

92:21 136:6

manufactured

25:12 67:15 91:14

manufacturer

29:14 72:16 73:12

76:5,11,14 89:10

91:17 96:5 99:2

100:12 105:12

109:20 112:17

120:16 124:5

139:4 145:12

manufacturer's

114:18 120:22

manufacturers 2:5

2:6,16 3:20 4:12

8:13,15,19,21

10:11 23:12 24:22

29:7 31:15 33:16

40:17 42:4 53:15

58:18 65:17 73:15

74:17 78:9 79:18

81:13 82:20 84:6

84:8 85:13 86:12

88:6,15 95:12

96:3,8 99:11

100:14 101:1

102:12 104:18

138:17,18 140:4

154:21

manufacturing

98:20

map 103:6

maps 66:14

March 18:12 39:8

marina 113:14

marine 2:16 4:12

8:13,15 10:11

33:16 104:18

107:14,15 108:15

113:8

market 19:15

21:20 39:17

108:17 146:11

163:10 167:13

marry 85:11

mart 109:12

match 67:13 75:12

84:22

matches 88:19

math 119:12

matter 22:16

101:18

Matters 19:5

matures 16:3

maturing 147:5

maximum 43:7

76:8

mean 63:15 65:7

66:18 68:10 71:21

75:12 78:19 81:10

83:13 121:7 134:1

157:12 159:6

161:17 162:20

167:21 168:20

169:6

meaning 41:9,15

48:8

meaningful 23:15

28:10 93:17 99:18

meanings 156:16

means 19:7,17 42:5

46:12 48:8,10,11

50:22 113:21

118:15 129:7

meant 165:22

measurable 109:4

measure 38:5

79:13 88:2 168:6

measured 27:11

62:18 70:3 88:10

88:11

measurements

80:2

measuring 32:13

119:18 167:2

meet 42:18 56:12

69:4,15 148:4

meeting 1:5,11,13

2:2 6:7,18 7:4

11:14 14:1,7,17

15:6 31:18 34:19

34:22 35:11,13,19

36:2 37:11 40:18

42:22 72:6 104:4

170:20 172:8

176:12,20

meetings 11:2

68:16

meets 15:10 41:7

megahertz 137:15

member 21:18 24:4

31:16

members 19:3 25:5

27:10,14 28:7

31:22 60:1,21

69:2 132:22

memory 110:2

mention 26:6 54:16

56:16 108:16

mentioned 31:12

38:19 73:5,15

81:4 82:9,9 91:11

102:6 162:18

167:12 172:9

met 1:11 42:17

50:15 51:6 52:14

52:17

method 7:7,8 30:6

35:16 45:10 95:10

95:17

methodologies 28:8

methodology 28:16

108:21 117:16

130:19,20 149:16

158:3

methods 28:12

29:18,20 30:1,5

45:1 159:13

metrics 135:10,12

135:15

Michael 2:11,12

8:14 9:10 33:15

62:21 173:2 176:8

microphone 9:20

64:8 128:6 152:8

microphones 7:18

mid-morning-ish

11:21

Mike 2:15 9:21

68:3

millions 20:20

mind 22:7 89:12

minimal 76:7

minor 113:4

minute 163:12

minutes 101:6

107:10

mis 102:11
202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

Page 189

mis-testing 100:22

misapplication

60:11 84:9

misinterpreting

77:11

misreporting 101:1

102:12

missed 33:13

173:17

mission 16:5,19

misunderstanding

68:8

mobile 160:11,12

160:15

mode 13:3 50:2,3

78:6 106:13,18

108:6 118:1 119:4

119:14,21 120:11

123:15 125:20

126:13 145:4

model 44:14,18

51:22 52:1,4

57:11 67:13 69:21

72:16 82:18 87:16

87:20 97:22 98:3

98:7,19 167:14

171:19

models 44:12,13

100:18,19,21,22

102:7,7,9,11

modern 71:22

116:2

modifications

127:19

modified 169:13

modify 22:7 131:3

169:19

money 41:20

month 23:2 31:7

months 40:5

morning 6:4,5,11

6:13 7:20 8:1,5,8

11:5 14:22 33:19

34:3,22 71:5

102:2 104:14,16

114:1 134:10

move 33:12 72:21

92:6 104:1,3

123:2 124:13,15

133:11 151:18

153:5 175:1

moving 11:18 30:2

multi-capacity

27:3,4 36:10 43:3

48:6,11,20 49:15

52:7 53:11 148:2

multi-chemistry

27:3 50:21 53:22

54:2 55:12

multi-port 48:6,9

148:2

multi-voltage 27:2

27:4 36:10 43:2

48:6,8,19 49:15

52:7 53:11

multiple 15:18

19:19 36:18 37:2

41:10 45:3,4 48:9

48:10,12 51:1

53:8 55:19 66:15

73:1 111:11,17,18

135:7 146:18,19

156:16 161:12

166:21

multitude 30:14

mute 13:7

mutually-exclusive

48:16 55:22

mystery 61:7

N

name 6:9,14 7:18

12:17,20 23:7

33:3,15 64:8

narrow 147:3

national 2:5,8,16

3:20 4:12 8:13,15

8:18 10:2,9,10

16:6 30:4,12

31:14 33:16

104:18

Natural 147:21

nature 106:10

131:2 141:3

Navigant 2:14,15

9:22 10:4,13,14

26:13,14 55:6

65:4

Navigant's 25:10

necessarily 29:8

75:21 77:8 81:18

84:9 87:14 91:20

98:9 128:19 131:5

131:8 140:7 143:2

necessary 16:18

19:22 43:16 92:18

127:19

necessity 30:22

need 12:18 22:9

54:3 57:4 62:2,8

67:3 77:6 78:8

84:19 94:1 108:10

111:4 118:22

119:17 120:2

125:5 131:3

145:18 146:21

155:17 156:4

169:19 171:15

173:5,6 175:7

needed 43:21 92:13

103:10 130:20

needs 44:8 89:1,2

112:10

neglected 54:15

neither 100:10

NEMA 59:10 65:13

68:18,22 129:20

142:14

never 88:21 99:8

114:11 151:12

new 20:21 22:17

43:19 124:19

133:15 135:15

148:12

NiCd 50:8 51:5

105:2 106:4,8

nice 10:17

nickel 157:16

nickel-cadmium

50:8

NODA 23:10 174:3

nodding 55:7

nominal-type

143:18

non-battery-char...

126:19 128:15

non-compliant

91:18

non-proprietary

150:7,15

non-wired 141:1

NOPR 58:5 100:4,8

normal 79:4 94:11

normally 89:6

Notably 17:11

note 25:9 36:7 80:8

noted 40:16 44:1

50:19 127:3 134:9

noteworthy 40:2

notice 6:6 14:5 37:6

40:11 44:2 52:2

106:6 124:16

125:1 174:8 175:9

175:22

noticed 26:15

126:22

noting 50:1 55:6

notion 69:17

number 26:6 35:22

37:5,18 57:11

66:20 67:4,4 75:7

75:12 82:14,16

89:9 93:16 95:20

98:6,17,19 103:5

109:5 118:13

122:15 124:15,19

134:15 171:17

175:12

numbers 44:14

66:20 67:14 69:21

74:19 78:13 84:22

94:9 96:19 99:21

167:15

numerous 32:9

nuts-and-bolts

105:4

O

object 162:11

objectives 36:3

41:2,4,8 42:16,19

obligation 74:11,12

74:13 88:8,18

obliged 88:7

obscure 28:9

observation 26:13

81:4 163:1

observe 120:9

observed 62:15

119:20

observing 84:15

obstacles 28:14

obtain 42:5 58:17

85:14

obvious 62:19

84:17

obviously 84:18

87:8 91:7 143:11

155:7 173:18

occur 155:13

161:22

occurred 26:15

occurrence 26:17

occurs 122:19

154:9 158:6,8

159:5

offer 23:9 28:4

132:21

offered 69:13 100:4

132:19

offers 15:19

office 9:8,10 20:7

20:12 85:8 176:9

oh 33:13 85:17

89:20 104:9 119:6

156:12 158:11

okay 7:12 12:9

14:12 33:10 34:4

34:11,13 54:8

55:1,4 58:22 61:5

62:20 64:11 65:2

65:8 66:6 69:6

80:7 81:20,22

82:6 85:2 89:17

89:17,19 90:22

91:9 92:4,12

98:12,16 101:21
202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

Page 190

103:8,22 104:2

107:12 111:2

114:3 116:20

118:20 120:7,14

123:18 124:12

130:2,10 133:5,9

133:10 138:8

142:9 143:4

147:15 148:9,14

151:14 153:2

157:8 161:7,8

163:2,3 170:2,8

172:5 173:16,19

175:5

once 13:5 48:11

110:19 111:16

113:1 127:1

144:12 147:9

one-by-one 135:21

ones 53:8 57:19

94:4

ongoing 23:14

online 10:22 72:12

77:13

open 7:2 28:21 29:3

29:15 53:2,6 97:2

123:3 125:2 153:8

170:17

opening 3:2,4,8,10

11:10 13:14 14:14

33:9,11 34:2,17

92:22 134:10

170:10 174:4

operate 145:4

operating 157:6

operation 32:11

126:13

opinion 87:14

139:1 150:4

171:14

opportunities

96:22

opportunity 11:10

12:5 31:5,19 34:5

35:8 37:9 59:17

93:8 103:13

104:21 151:21

152:4

opposite 91:2

option 86:11

120:22 121:2

131:6,6 143:17

optional 111:3

121:13

optionally 112:14

options 19:20

order 3:2 44:2

116:13 117:14

118:7 127:20

Oregon 21:13 22:5

organization 12:19

14:19 147:12

organizational

7:19 33:3

originally 14:5

37:15 43:5 134:11

outputs 135:10,12

outset 6:21 11:9

13:13 14:15 18:6

32:20 33:2

outside 79:4 84:3

over-reporting

78:12

over-variation

118:15

overall 27:21 30:21

98:3 141:19

overburdening

124:4

oversee 6:15

overseeing 13:18

overview 3:7 125:2

176:1

overwhelming

142:2

P

P-R-O-C-E-E-D-...

6:1

pack 63:13 64:19

94:2 150:18 151:2

package 46:14

packaged 46:20,22

47:2,9,19 155:18

packet 11:4,7,17

33:12 34:7,14

packets 35:2

packs 94:8 113:18

pad 20:5 86:6

146:14,16 148:11

149:5 150:17,19

151:12,12

padded 88:5

padding 78:12

85:16

pads 133:17 138:19

149:8

page 11:7 12:15

85:7 176:2

pair 57:14

paired 57:11 141:4

153:17 154:7

160:11 162:1

169:9

pairing 60:3

pairings 163:6

papers 80:19

pardon 89:20

156:12

parse 62:6

part 16:4 22:11

32:10 56:14 73:12

76:22 77:4 89:4

100:12 118:20

121:10 154:19

171:6 173:5

part-to-part 96:11

partial 112:5

117:10 118:12

participants 3:10

13:5 37:7

participate 14:8

35:9

participating 35:6

participation

176:13

particular 63:5

96:17 141:5,9

particularly 26:12

32:4 60:5,16

130:4 132:2

parties 175:18

party 160:18 162:6

162:12

passed 172:17

passive 157:19

158:7,10,12

passively 166:10

patchwork 17:7

path 22:12 90:20

pathway 143:13

peek 170:5

penalized 112:18

people 12:19 56:7

57:18 67:7 68:10

77:1 83:22 113:19

114:1 117:4 153:9

157:10

perceive 174:3

percent 26:15

72:15,17 76:12,13

113:11,12,15

116:4 117:8,9,15

117:15 118:4,8,11

118:14,16 165:9

165:12,13

perform 32:9 41:13

73:14,19,21 74:3

87:17 98:4 118:10

performance

106:14 112:19

143:1,20 157:15

164:1,4

performed 39:19

41:10 85:17

performing 73:17

performs 98:7

period 110:20

112:14 113:13

120:9 136:20

137:2 166:21

170:13 175:20

permanently 108:1

108:2

permissible 17:2

person 143:16

170:19

perspective 26:5

30:7,12

Peter 2:14 10:3

64:5,8,10 66:8

160:6,7,16 162:5

phase 42:21

phenomena 114:10

phone 34:10 77:15

82:9 104:12

145:12 146:15

148:16 149:5

phones 13:3 19:9

146:3,3 147:6

149:3

physically 132:13

pick 64:16

picked 102:22

piece 145:13

place 20:5 21:13

98:5 150:21

placing 19:22

plan 34:21 173:11

platforms 30:16

133:16

play 105:3

playing 37:1

please 6:4 7:19

10:6,6 12:16 13:2

13:6 14:8,20 18:6

33:2,13 34:9 69:7

104:12 109:15

114:2 116:19

117:18 118:19

120:6,13 128:1

129:7 136:9

159:19 170:5

174:1 176:7

pleased 18:12 23:9

pleasure 24:3

107:3

plenty 34:5

plug 152:12

plugging 20:9

pocket 136:22

point 24:20 40:2

57:3 58:9 61:7,12

66:21 76:15 77:14

85:8 86:9 95:7,8

100:11 108:19
202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

Page 191

112:10 115:11

131:2,22 134:15

136:16 138:12

141:15 144:2

145:17 146:4

165:1 168:2 174:8

pointed 85:22

points 59:21 63:9

103:3 121:13

151:11

police 107:15

policy 17:3 37:16

poor 112:18

population 25:16

56:10 94:1

porosity 110:4

111:8

porous 110:2

port 49:5,8 54:22

portion 40:6

ports 49:10 50:15

51:6 54:19

posed 55:18

position 169:16

positive 30:3

possible 16:10

17:22 19:14 30:5

44:22 66:3 88:3

126:17 136:13,14

post 78:7

postal 175:13

potential 39:17

53:12 97:4 103:2

127:5 130:19

132:19

potentially 29:19

45:18 54:10 66:10

67:1 126:18

power 2:2 3:15,17

8:3,10 9:2 15:9,14

18:10,11 19:4,4,5

21:18 23:10,12

29:1 30:5 32:6,14

32:16 40:1,3,6

50:1,2 79:2

105:16 106:2,9,15

108:6 109:13

113:13 114:14,22

119:14 125:10,12

125:14,17,22

126:1,5 127:3,13

128:10 129:2

130:5 136:11

137:5,6,14 138:15

138:21 140:1

145:8,15 149:9,14

149:16 151:8

153:18,22 154:1,5

154:7,11 155:6,15

155:17,19,22

156:3,15 158:17

158:20 159:10,16

160:18 161:4

162:11 169:3

powering 128:13

PowerPoint 122:10

practice 113:7

precedent 22:22

preconditioning

111:3,5 120:21

122:18

predict 114:7

predictability

121:19

predictable 111:9

preemptive 16:20

21:10

preferable 30:11

preliminary 39:7

premature 15:21

17:9 18:19

prepared 104:20

preparing 122:3

129:22

present 2:1,17

35:20 36:4 44:2

153:7

presentation 14:2

104:20 107:11

122:3

presented 37:6

61:19 76:21 81:19

174:17

presenting 14:4

presently 21:12

presiding 1:14

presume 34:12

pretty 13:9 78:18

90:4 102:18

113:21

prevalent 26:10

previous 112:15

primary 126:6,9

principally 133:3

prior 105:19,21

144:16

probably 11:20

77:16 84:20

106:12 107:7

109:19 115:19

119:20 122:6

132:22 142:17

152:3 165:15

problem 89:12

111:14 149:11

problems 25:3

procedure 1:3 4:2

6:6,15,19 11:17

13:18 23:19 24:1

24:2,7,12,19,20

25:3,5 26:3 27:2,7

27:19 28:15 29:10

29:10 30:18 31:1

31:21 32:2,12

35:14,15 36:2,14

36:17 37:13 38:4

38:11,16,18,20

40:13,14,21 41:2

41:6,7,13 42:1,7

44:7,9 45:8,11,12

46:3,4,9,19,21

47:3,16 51:3

53:19 55:10 56:1

56:6,17,20 57:17

57:18 58:1,4 59:5

60:4,11 63:4

64:12 66:11,16

67:2 79:9,17,22

81:8 83:16,19

84:3,10 91:21

92:12,14 93:3

94:16,19 95:1

96:7 97:5,9,13,20

98:5,14 99:12,13

99:20 100:7 103:3

103:14,17 122:17

123:13,14 124:1

124:19 125:4,6

126:8,16,17 127:8

127:10,15 129:14

133:22 134:5,7,18

135:1,11,22 136:5

136:14,15 138:2

141:6 144:14,17

148:1,7 149:15,21

151:6,13 155:11

156:2 163:12,21

164:5,14 165:17

166:15 168:22

169:20 170:1

171:5 173:9 174:6

174:10,12

procedures 23:20

42:12 93:11,22

131:8 132:2

proceed 14:14 34:6

34:13,18 42:21

126:15

proceeding 6:22

71:14

process 24:16 41:5

63:17 109:9 145:8

147:5 148:22

produce 29:14

96:10 99:5 136:6

product 15:10,12

15:13 16:21 17:1

17:10,15 29:14

38:7 41:17 58:11

58:15 64:22,22

73:14,16,19 74:2

76:6,9,12 79:20

89:1 92:2 128:13

132:5,12 145:7

151:11 160:3

176:2

product's 95:20

production 171:18

productive 176:12

products 15:14,15

16:1,7 17:3 21:19

28:7,15 29:6 32:3

32:4 37:20 38:1

69:1,3,13 73:9,11

78:6 84:1 96:9

130:6 131:9

132:22 136:5,17

138:2,17 140:3

143:8 145:9

146:12,18 148:21

149:12 154:22

163:9 167:13

profound 109:4

program 6:16

37:19

progressively

112:9

Project 13:17

promoting 23:14

promulgated 17:14

promulgation 39:3

40:8 134:13

proper 28:17 60:18

88:11

properly 15:16

properly-equipped

20:6

property 62:4

proportion 26:7,21

proposal 15:13

134:13

proposed 15:8

18:13 39:10,20

43:5,6 134:11

139:17,19

proprietary 28:11

28:18 30:4,9,14

131:14 140:11,20

141:2 143:14

144:7,10,15 145:4

149:20 150:1,6

152:3

protection 60:7

62:4

protocol 101:8
202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

Page 192

161:3 162:10

Protopappas 2:14

10:3,4 64:6,10,20

65:2,6 160:7,8

161:1,6

provide 14:9 16:5

16:19 20:17 29:3

32:4 34:2 37:8

44:6 129:7 136:13

137:22 141:14

148:7 169:7

176:14

provided 22:1 44:8

151:7 169:18

provides 19:16

27:11 68:21 83:7

95:10 175:6

providing 23:13

69:21 88:10 124:6

138:6

provinces 24:11,16

provision 88:4

112:5 123:16

provisions 109:11

126:7 171:13

provoked 27:6

PTI 8:11 23:11

28:1,4 30:21

public 1:5,11 6:7

6:10,18 29:22

34:19 35:11,13

42:22 104:4

publicly 36:9

publicly-available

36:7

publish 65:7

published 65:3

114:11

Puekert's 114:9

pull 106:17

pumps 108:4

purchase 151:2

purchased 25:11

44:13,21 45:6,20

45:22 67:10,17

91:13

purpose 7:3 12:9

35:11 37:11 72:6

pursuant 22:21

66:15 82:15

pursue 16:22

pushing 115:15

put 18:14 44:1

71:10 106:18

111:5 113:1

118:13 137:8

145:14 150:20

158:18

putting 68:6 75:6

136:21

Q

Qi 29:1

Qualcomm 2:12

9:1 141:14 144:12

quality 111:21

question 25:17

28:5,9 30:11 32:8

53:9 55:8,17

56:15 57:4 59:11

62:14 65:15 67:13

69:9 70:11 75:1

75:17 76:17 80:22

83:8,9 84:17,22

85:5 93:10,14,15

93:19 94:15,17,17

94:20 95:2,17

96:16 97:2 98:4

99:16,17 100:16

102:4 104:8 120:4

128:8 132:10

152:15 155:10

158:14 162:7

164:7 174:3

questioning 129:4

questions 4:7,9,13

4:16,20 5:4 6:22

12:3,8,11 14:10

25:2 28:3,4 53:2

63:5 67:4 103:2

128:3 134:16

168:4 170:18

174:9,18 175:2

176:7

Questions/Com...

5:5

queued 160:6

quick 153:15

quickly 19:13

68:12 136:19

140:18 153:17

154:8 157:7

quite 58:19 80:10

80:11 113:20

116:12 121:9

quote 102:8 137:17

quote/unquote

100:20

R

R 2:16

R&R 91:21 93:20

radio 133:1

radios 133:3

raise 13:7 27:17

37:9

raised 63:5 84:21

raises 30:10

range 32:3 61:19

64:22,22

ranges 17:4

rate 26:16 66:19

73:16,18 74:17

76:9 85:17 86:6

109:7 113:2 115:5

122:20 154:13

160:14 161:14

164:11 165:10,14

166:16,19

rated 49:12 50:17

51:8 52:13 73:13

74:11,17 108:20

154:16

rates 56:5 108:21

109:3 110:9

113:18 114:3

115:15 137:11

163:14 166:5,8,12

rating 69:18 70:13

70:18 72:22 74:21

76:5,7,13 77:5,7

85:9 86:3,4,20,21

87:3 89:6 95:12

95:18 96:4,12

98:15 99:8,9

100:12 154:21

ratings 70:12,20

74:2 75:19,22

95:16 110:10

Rawald 2:14 9:7,7

73:3,3 76:1 85:3,3

87:10 89:7,17

90:8,9 97:16,17

140:16,17 141:12

141:21 142:3,5,9

144:1,2

reach 115:8 166:9

176:8

reaches 119:10

read 102:5

readily 110:6

reading 74:20

ready 19:17,19

real 96:22

reality 71:22

realize 95:13

realized 45:14

really 7:7 35:10

36:22 37:14 42:15

48:5 53:20 56:7

72:9,9 76:2,18

92:10,22 93:19

94:17,20 109:1

115:19 118:22

119:13,15 144:3,4

149:3 150:9

151:12 155:8

156:8 159:17

161:21 162:20

163:19 164:7

166:22 168:2

174:15

reason 25:17 36:12

53:12 56:18 69:22

169:18

reasonable 87:6

reasons 18:17 21:1

36:22 68:6

receive 41:14 86:14

received 11:4

111:14,16 165:7

receiving 147:2

recently-published

24:5

recharge 110:7,7

113:22

recharging 19:17

recognize 148:12

recognized 13:8

recognizes 15:16

recommend 30:15

47:13,20 121:15

recommendation

62:9 120:3,15

146:20

recommendations

92:17 122:16,22

123:5,6 136:3

recommended

29:12 47:15 52:9

113:8

record 12:8,17 64:9

88:19 101:19,20

recorded 112:5

135:13

recording 83:6

recovered 166:17

recovery 110:14

red 79:8

redesigns 69:2

reduce 166:11

reduces 158:1,1

reduction 157:13

reexamine 173:7

refer 48:14

reference 142:18

142:19,19 143:19

146:2

referred 153:15

referring 9:20 72:3

72:3 128:6 150:22

153:14

refers 45:9 47:4,17

reflect 30:2 65:19

91:20

reflected 29:21

164:14
202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

Page 193

reflection 27:18

reflects 152:18

refrigerators 108:5

regard 25:1,6

137:4

regarding 28:5

174:10

regardless 22:15

regime 115:18

register 84:1

regulate 37:21

regulated 77:1

151:4

regulating 162:16

regulation 15:8

17:8 18:13,19

25:14 27:14 30:20

69:12,13 74:10

77:2 83:20 90:6

regulations 18:15

21:15,22 24:10

46:7 78:8 132:3,9

171:6

regulations.gov

46:8 175:14

regulatory 3:19

6:16 8:4,18 16:6

30:11 31:13

rejected 132:20

related 42:12 45:18

59:2 61:21 75:18

173:8

relating 6:22

relationship 88:1

159:5

relative 30:4

relatively 113:4

relatively-minor

110:21

relevant 18:17

175:21

rely 22:4 40:20

98:1

remains 40:14 42:1

68:13

remarks 3:2 6:12

11:10 13:15 14:15

34:18 175:1

remind 101:7

reminds 122:9

remotely 33:18

35:9

removable 46:13

reopening 31:18

174:4

repeatability 25:4

28:1 31:20 93:12

93:21 94:6

repeatable 35:17

40:14 41:9 92:20

114:4 124:7

127:16 136:2,6

156:6

repeated 94:9

replace 20:18

replicate 51:15

53:13

replicated 52:2

report 25:10 26:4

27:10,14 66:13

74:11,13,17 75:9

79:12 83:13 84:2

85:13,14 86:13

87:21 88:2 175:22

reported 27:16,20

44:18 57:9 62:17

67:14 74:1 75:20

77:4 86:17 87:13

87:18 88:20 89:3

89:11 90:19 91:18

102:19

REPORTER 152:7

reporting 26:18

57:13 65:18 83:10

84:6,13 88:9 91:4

reports 27:8 73:13

76:5,11

represent 95:16,20

99:18 109:13

representation

99:15,16,18

representations

95:15

representative

35:17 41:15 57:15

82:14 87:16 94:19

95:3 97:21 127:16

165:2 171:18

represented 74:20

representing 8:2

8:10 9:1 14:18

54:16

represents 41:16

69:17 98:6 116:9

116:10

reproducibility

25:4 27:22 93:13

93:21

reproducible 35:18

41:12 62:8 124:7

reproduction 24:9

request 4:14 12:2

22:19 39:16

require 77:3 98:14

100:10

required 27:13

40:17 69:3 79:22

82:18 83:3 123:17

requirement 69:10

69:11 70:1 86:12

86:19 96:3,14

97:9 98:10,22

99:10 100:13

requirements 16:7

56:13 57:19 69:15

83:22 97:10 143:1

148:5

requires 27:7 29:11

69:13 74:16 76:7

98:15 172:12

requiring 77:9

residue 115:7

resolve 62:16

resolved 26:1 68:12

Resources 147:21

respect 23:20 25:7

26:12,19,22 27:21

32:7 56:14,15

58:6 69:5 91:21

93:17 132:22

174:5

respectfully 22:19

respects 32:12

respond 174:19

response 12:13

32:21 72:20

103:21 124:11

129:12 133:8

141:15 151:19

153:1 170:7 175:3

responsible 23:14

147:13

restate 14:19

restored 126:1

restrictions 21:12

restrooms 101:10

result 16:12,18

17:8 21:5 26:20

36:14 69:1 79:7

81:5 89:11 90:2

112:8 114:7 124:6

156:6 159:12

resulted 26:8 53:18

results 4:5 11:19

36:20 37:3 41:11

41:14 42:5 43:1

45:17 49:17,19

51:10,19 52:1,22

53:13 57:6 58:10

58:16 59:7 64:14

65:21 71:12 72:8

78:4,11,13 86:15

90:17 92:14,15

114:5 118:18

127:17 129:15

136:2,7 164:1

167:10

resume 101:16,22

retired 125:17

return 101:3

returning 12:1

reusable 111:14

reverse 29:16

review 11:6,8

revise 30:22

revised 43:21

revision 24:19 31:3

43:16

revolved 132:10

Rider 2:15 77:13

77:17,21,21 80:16

81:9,21 148:15,17

151:1

right 18:16 29:16

33:14 34:1 48:2

56:17 57:21,22

58:2,5,9,14 59:12

63:10 65:4,9

68:10 69:12,18

70:8,10,18 71:14

71:17,21 74:13,14

74:16,18 75:20

76:20 77:7,9,11

77:18 83:5,10,12

83:13 84:2,3,5,8

84:20,21 86:12,14

86:22 87:5,9 88:1

88:3,4,6,14,22

89:5,7 91:8,14,16

91:18,21 92:1,3

93:10,13,18,20,21

94:3,4,13,15,19

96:4,6,10,11,12

96:14,16,17,20

97:11,14 98:21

99:2,4,6,9,10,14

99:15,20,21 100:1

100:5,5,7,9,12,14

106:21 115:17

116:15 118:6

119:18 124:4,14

132:4,14,17,20

133:2,4 138:16,19

138:22 139:3,6

140:1,4,11,17

141:10,12,20

142:1,3 143:6

144:9 145:11

146:10 147:14

151:16 152:5,13

153:3 157:17,20

158:3,7 160:3,21

160:22 161:5

166:16,18,20

168:18 169:21
202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

Page 194

171:10

Ringeisen 10:8,8

Rivest 2:15 9:21,21

68:3,5

Rob 145:1 146:5

Robert 2:11 146:7

Rod 8:1

rollout 22:13

room 1:11 7:16

10:6 13:10 59:21

114:9

roughly 118:14

round 11:21

route 147:14

row 48:15,17

rule 7:5 38:9 40:7

56:3

rulemaking 7:1

13:19 16:3 22:8

23:15 38:4,19

39:2,15,22 40:4

172:11 174:5

176:1,4

rules 12:15 22:2,11

76:20 83:20 86:22

150:20

Rumsfeld 137:18

run 60:15 78:19

79:10,13 107:10

116:6

RVs 107:15

S

S.W 1:12

Safe 176:17

safety 60:9,18

Salas 2:16 8:12,12

104:6

sale 69:14

sample 171:18

Samsung 2:11 8:2

Sanaee 2:8 10:1

satisfactory 96:7

satisfies 60:21

satisfy 97:10

106:17

save 119:17

saw 69:22 102:19

saying 74:3,4 81:16

84:17 85:12 89:18

98:8 108:16

146:10 150:12

167:6,9,19

says 46:10,21 47:8

50:7 72:12 77:7

83:21 111:14

145:6

scenario 150:17

screen 35:1

se 163:1

Sea 2:10,12 4:11

33:20 104:17

search 148:3

seats 6:4

second 52:4,14

55:2 56:12,14

secondly 90:14

112:12

seconds 9:4

section 16:11 18:3

21:4 22:21 45:9

142:17

sections 45:11

security 71:5

see 27:16 28:14

34:14 35:1 43:15

44:5 49:18 50:5

51:18,19 52:15,18

53:3 55:8 56:2

60:17 68:7 72:7

78:20 79:1 81:11

83:2 85:20 96:22

97:1,4 101:16

103:19 105:19

109:18 115:9

116:12 120:10,10

122:7 123:3

129:10 146:17,18

147:2 160:5

169:17 170:4,5

seeing 12:14 66:4,4

66:8 77:4 87:2,11

105:2 106:4

116:13 146:12

171:21

seeking 42:17

124:17

seen 72:14 156:16

163:9

segment 12:10

seldom 109:21

select 17:1 46:17

47:5 94:4 121:14

142:4,5

selected 44:12 45:5

45:19 47:2,11,14

50:15 53:10 55:9

55:19 59:4 64:6

64:11 70:4 149:18

selecting 149:12,16

selection 28:17

29:9,11 45:10,15

55:22 60:2 140:12

141:19 142:15

144:8,16 148:8

162:21

self-reporting

65:22

self-terminate 60:9

self-terminates

60:15

self-terminating

61:17

self-termination

61:2

sell 145:12,13

send 175:11

Senior 3:16 23:8

sense 53:5 135:9,14

135:16 164:15

165:19

sensibility 76:19

sensitive 58:2

90:10 105:18

109:16

sent 117:2

separate 15:13

27:7 78:5 83:4

145:11 152:10

160:3

separately 46:1

150:20 155:18

sequence 120:20

series 117:2

services 32:16

set 16:1 18:1 78:7

111:21 117:20

148:1 164:5

sets 27:7

setting 15:21

143:21 163:21

setup 138:22

shape 115:12

share 12:22

sheet 83:6

shop 101:11

short 104:20

113:21 115:15

136:20

short-term 143:10

shortcoming 26:4

91:20

show 47:5 48:2

78:13 85:21 86:15

94:1 112:22

118:11

showed 85:18

showing 66:9

118:12

shown 57:6

shows 78:16 113:1

114:13 115:5,19

115:21 118:2

shut 69:5 119:16

126:6,14 128:21

shutting 108:8

side 39:1 101:14

sidebar 13:4

signed 34:11

significant 16:13

17:16 21:5 45:15

significantly 79:3

silent 13:3

similar 36:20 44:10

52:5 61:14,16

75:15 107:17

117:20 138:20,21

161:18

similarly 74:2

simple 12:15 46:15

simplifying 165:15

simply 20:5 60:14

86:13

simultaneously

15:18

single 27:12 48:16

54:21 171:22

single-use 111:15

Sir 152:7

sites 111:10

situation 20:2

61:14 139:2

149:20

size 113:9

Skahan 10:12

skew 71:12

slide 41:1,3 46:2

47:6 49:18 107:11

109:15 117:18

120:6 175:6,9

slides 11:9 106:20

107:1 122:3,10

170:11,14 175:4

slightly 102:20

slow 109:9 112:2

slower 108:20

110:8 163:18

slowly 110:12

small 121:8

smart 19:9 168:14

Smartphones 19:9

133:17

so-called 68:11

SOC 113:11 117:12

software 13:8

sold 44:20 45:1

82:19 139:4 141:5

150:20 152:6,10

155:15 160:14,19

160:21

solely 127:12

128:10 130:5

solicit 129:5

soliciting 104:5

solution 61:1 120:9

132:20
202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

Page 195

Solutions 2:2 6:10

solve 92:11

somebody 160:21

someday 30:6

somewhat 114:21

169:1

soon 16:9 17:22

sorry 33:13 54:15

58:19 104:6 128:7

152:9 167:17

sort 60:12 70:17

76:8,18 132:6

138:22 142:2

157:16 158:2

159:4 162:9,12,21

166:7 175:2

sorts 68:9 137:8

145:21

sound 17:2 77:19

97:6 151:20

sounded 131:14

sounds 74:4 98:8

107:5 161:17

source 17:16

105:13 109:19

115:22 117:3

149:17 152:13

157:18,19,22

sources 152:19

spaces 110:3

span 116:12 167:2

speak 12:16,18

13:8,10 34:10

59:15,17 63:7,11

78:11 87:8 103:13

104:13 148:16

160:6

speaking 80:10

138:14 144:22

specific 53:7 81:18

92:17 107:13

121:2 122:16

123:21 125:6

127:19 137:5

153:17 154:7

155:15 163:22

164:13 167:14

specifically 29:12

36:9 43:2 50:20

58:20 71:18

104:22 116:20

123:1 135:18

153:11 158:5

162:18 170:10

174:18

specification

147:13

specifications

122:18

specificity 95:11

specifics 163:16

specified 25:15

47:15 83:16

specify 47:12,21

49:14 51:4 60:14

specifying 60:5

143:18

speculate 122:17

Spencer 100:16

102:3

spoke 107:18 118:2

spot 71:10

spreadsheet 118:14

spur 123:22

stable 121:6

stage 18:18

stages 17:21

stakeholders 35:6

39:9 44:5 67:5

staking 106:14

stand 10:6

standard 16:12,14

17:10,18 21:5,7

22:16 26:20 28:13

29:1,4 30:17 58:9

58:12,13,14 60:13

67:16 69:4 74:16

76:7,10,13 77:6

86:4 88:12 89:10

90:13 94:13,21,22

95:9,19 97:11,11

97:18,19 99:6,22

100:3,4,6 110:9

116:22 119:13

121:17 138:15,18

138:20 139:22

142:18 143:3

145:6,10 146:22

147:5,11 152:17

155:5 172:13,14

standards 4:3 7:1,5

7:6 11:18 15:21

16:1,2,6,20,21

17:1,11,13 18:1

23:18 24:7,9,14

24:17 28:21 29:15

37:14 38:18 39:1

39:4,5,6,11,12,20

40:8,18,20 43:5,6

43:12 67:12,21

69:12 90:21 93:18

99:1 134:11,14

137:15 139:19

142:22,22 148:22

150:4 154:17

172:11 173:4,13

standby 50:2 79:2

Stanley 2:3 3:17

8:9 23:8

stare 115:9

start 6:11 7:15,16

14:21 54:12 55:16

61:6 68:15 101:15

102:2 113:21

146:12

started 35:12

starting 61:15

state 17:7,11 21:12

21:15 25:11 39:10

40:19 67:18 68:22

69:10,14 70:5,7

82:19 88:15 91:13

96:4 115:6 118:4

119:11 125:21

126:8 154:2

163:17 165:22

166:6

state-of-charge

117:12

stated 43:4 69:19

69:20 88:21 130:6

statement 3:4,8

33:9 34:2 89:4

167:20 172:22

statements 3:10

11:11 14:15 33:11

34:9 37:8

states 21:14,21

22:9,10 23:13,16

115:10 157:20

166:6

statute 173:15

statutory 16:5,19

42:14

stay 71:1

steady 119:10

step 62:19

steps 173:3

Stock 100:17 102:4

storage 109:21

stored 105:21

straightforward

28:19 88:9

strong 22:22

structure 110:3

stuff 119:18 131:3

stymy 18:20

sub-classes 16:22

subject 14:6 16:7

17:7 28:6

submit 61:3 78:9

104:7 130:16

170:12 175:7,16

175:17,19

submitting 33:6

176:15

subsequent 37:20

58:5 86:20

subsequently 37:17

38:12 67:11 99:22

substitute 168:16

successful 22:13

suddenly 106:9

sufficient 12:21

93:7 124:6

sufficiently 93:22

127:15 129:14

suggest 55:13

65:15 105:2

114:19 130:18

suggesting 121:12

suggestions 123:21

129:5

suggests 102:17

suitability 97:12

134:22 140:8

suitable 47:22

summary 4:5 11:19

17:19 37:8 120:7

135:19 172:4

super-inefficient

116:7

super-power-sup...

158:21

superior 114:4

supplies 40:1,3

149:9 155:6 156:4

157:19

supply 31:6 40:6

108:6 149:14

153:18,22 154:1,5

154:8,11 155:16

155:17,20,22

158:18,20 159:10

159:16 160:19

161:4 162:11

169:4

support 15:6,12,22

107:20

supported 66:21

supporting 87:19

supposed 67:11,20

162:19

sure 13:16 32:1,13

33:22 36:16 42:16

44:8 54:8 61:20

63:9 64:4 80:10

80:11 88:13 90:4

92:9,19 99:3

107:9 119:21

136:10 140:14

159:6 162:14

Surely 129:17

surface 137:7

surfaces 110:2
202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

Page 196

surprising 20:13

surrounded 162:8

surveillance 70:9

88:14

survey 63:15,16

65:5

suspect 157:6

switch 126:12

128:15

system 23:18 105:9

143:17 144:10,18

145:3 150:14,15

153:21 154:19

155:14,17 159:11

165:19 167:8

168:1,4 169:5,8

systemic 26:2,19

systems 2:10,12

4:11 5:2 23:16

28:18,21 29:2

33:20 63:15,16

64:2,21,21 72:1

94:3 104:18 131:1

143:15 149:22

150:1,6,7 152:4

153:13,14,16

154:15,18 156:3,7

159:14 164:10

T

table 47:4,17 48:2

48:4,4,21 49:14

51:3 82:15 83:3

106:3 145:13,15

tables 45:11

tablet 19:10

tackle 34:21

tail 106:2,14

take 6:4,17 11:20

16:9 17:12 54:7

88:15 95:6 96:17

101:3,5 107:2

113:3,5 115:20

116:5 117:4,17

120:12 148:6

163:11 170:5

taken 144:8 166:19

takes 108:3 121:17

145:19

talk 7:4,5,6 97:17

103:14,14 104:4

talking 70:19 92:2

139:8,9,11,15

142:15 144:12

149:2 159:2 169:2

tangentially 70:17

target 121:1

task 20:10

technical 3:16 23:8

33:17 34:3,6

63:19 103:7 117:3

120:2

technically 59:15

technological 21:8

142:1

technologically

16:15

technologically-f...

43:9

technologies 21:16

124:21 134:19

136:19 148:12

technology 2:13

3:12 8:6 15:3,17

16:3 17:6,13,20

18:18,22 19:2,12

20:3 21:10 22:14

22:17 41:22 42:2

43:19 105:4

133:20 135:18

137:5 146:10,22

155:1 156:10

157:10 168:18

telecomm 110:17

Telecommunicat...

2:3 3:13 15:4

33:5

telephone 2:17

telephones 13:7

tell 54:19 103:5

telling 73:20

tells 75:9 83:19

Ten 72:16

tends 68:22

tentative 120:8

term 70:18 156:15

terminates 71:20

termination 72:2,4

terminology 76:2

terms 32:5 41:20

63:2 78:3 84:1

94:6 113:5 120:18

121:19 132:12

143:18 160:4

166:4

terrible 115:21

territory 169:2

test 1:3 4:2 6:6,15

6:19 11:17 13:18

23:18,20 24:1,2,6

24:12,18,19 25:2

25:5 26:3 27:2,6

27:18 28:15 29:10

30:18,22 31:20

32:1,12 35:13,14

36:2,5,8,13,14,17

37:3,5,13 38:4,10

38:14,16,18,19

40:12,14,20 41:1

41:6,7,13,21 42:1

42:6,12 43:1 44:2

44:3,7,9 45:8,8,11

45:12,17,19 46:3

46:4,9,14,19,21

47:22 49:1,4,9,17

49:18 51:3,14

52:15,19,22 53:19

55:10 56:1,5,16

56:20 57:6,14,17

57:18,21 58:1,3

58:10,17,18 59:5

59:7 60:4,11,16

60:17 63:4 64:12

64:14 66:11,13,16

67:2 71:14 74:14

75:9,13,21,21

78:3,6,15,19 79:9

79:13,18,22 81:7

82:12 83:16,19,19

84:3,9,19 85:14

85:18 86:4,15

87:19 91:21 92:11

92:12,14 93:2,11

93:22 94:5,9,16

94:19 95:1,10

96:6,18,18 97:5,9

97:13,20 98:5,13

98:16,18 99:12,13

99:14,20 100:6

103:3,13,15,17

108:21 109:11

110:6,22 111:6

112:8 117:16

118:10 120:16,20

122:17,21 123:13

123:14 124:1,18

125:4,6 126:8,13

126:16,17,20

127:7,10,15

129:14 131:8

132:2,14 133:22

134:4,18 135:1,10

135:22 136:4,5,14

136:15 137:2

138:1 141:6

144:14,16 146:2

147:3 148:1,7

149:15,21 151:6

151:13 155:8,11

156:2,6 161:20

163:11,21,22

164:5,14 165:16

166:14 168:5,22

169:3,8,12,19,22

171:4,21 173:9

174:5,10,12 176:1

test-procedure-li...

143:21

tested 30:17 37:2

41:18 43:2,17

44:13,16 48:18,19

51:5,12,17 52:1,4

52:17 65:19,20

67:11 73:1 75:13

87:17 100:18

102:7 105:6

126:22 134:4,6

155:19 156:10

171:4,8,17

tested/investigated

126:3

tester 120:21 124:5

testified 18:8

testing 4:10,17 26:9

28:1 35:22 36:5

36:19 40:21 43:15

43:22 44:12,17

45:6,12,16 47:1

47:14 51:7,21,22

53:10,14 54:4

57:12 66:21 72:14

79:17 81:19 84:12

85:21 86:2,5,14

86:20 87:20 88:19

90:18 92:16,18,20

93:16 94:7 97:2

98:1 100:21

102:10,11 105:7,8

109:17 120:18

122:19 125:6,8

126:7 127:11,17

127:20 129:16

130:22 133:12

134:16 145:18,21

149:18 154:21

155:6,13,21

162:22 171:3,22

tests 7:7,9 26:18

38:13 49:1,1,13

50:6 51:11 52:16

52:19 66:15,17

78:5 82:15,17

83:4 105:7 107:19

111:17 113:5

thank 7:13 13:20

14:10 18:4 23:3,4

23:6 31:4,8,11,17

32:17,18 33:8

34:17 59:22 61:4

61:6 62:10,11

68:19 80:8 82:1

89:18 92:5 103:10

104:9 121:22

122:2,12 123:19

130:9 131:20

133:6 138:9
202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

Page 197

142:11 147:16

151:15 153:3

170:3 172:2

173:21,22 176:10

176:14

Thanks 14:13

102:1 130:3 138:9

143:5

theory 145:19

thing 70:11 79:1,11

84:5 111:13 137:4

152:18

things 6:20 14:16

20:15 43:19 78:1

81:11 108:4 133:1

142:7 144:14

149:2 164:22

think 11:12 13:12

35:4 41:2 46:4

53:1,4 55:20 56:5

56:9 57:3,17,22

61:1 63:19,21

64:3 66:2,9 68:5

69:19 70:19 71:1

71:3 74:9 77:6,15

78:15,17,18,21

81:15 84:13 87:11

89:14 95:7,21

97:19 103:7 106:4

109:17 111:2,4

114:8 118:13

121:21 128:19

129:3 132:18

135:20 139:13,14

139:21 140:21

141:11,12,17,18

144:3 145:22

146:1,17 147:11

148:6 149:17

152:2,7 153:15

158:20 162:22

163:5 167:7,8,21

168:2,20 169:1,22

172:15 173:6

176:11

thinking 121:7

123:21

third 49:9 51:12

52:15 160:18

162:6,12

third-party 160:10

160:13

thorough 111:7

thought 85:12 93:7

146:1

thoughts 59:2

72:18 80:19

123:22 124:9,18

144:5

thousands 112:4

three 24:13 27:7,11

27:12 48:22 49:1

49:13 51:11 78:5

83:4,4,8 84:12,19

92:7 104:4 110:20

119:7 135:20

146:3 149:3

three-hour 110:11

threshold 115:8

TIA 15:5

ties 70:16

time 6:17 12:16,17

19:14 20:18 22:6

28:5 31:1 38:15

39:11 41:20 43:10

53:1 54:7 58:3

60:14 66:22 107:8

110:5 121:1,17,18

122:20 125:17

128:14 132:19

134:8 136:13,21

138:1 143:10

146:16 149:18

152:6 165:1 167:2

170:5

times 37:18 41:10

59:17 115:16

125:20

today 6:7 13:2,21

18:17 23:22 28:22

35:20 42:15 56:20

72:6 140:19 152:6

153:7 155:8 172:9

176:11

today's 7:4 14:6

31:18 34:19 35:11

35:13

told 71:5

tolerances 171:19

tolerate 110:15

tool 3:17 8:10

23:10,12

tools 30:5

toothbrush 139:3,4

140:9

toothbrushes

139:10,18 150:2

top 46:6 49:20

topic 23:21 133:11

153:6,6

topics 4:14 12:2

14:3 124:15,22

total 26:6 49:12

50:17 51:8 52:12

119:3

touch 145:2

touched 136:18

trade 23:11

traditional 159:13

trajectory 116:6

transport 109:20

travels 176:18

treated 105:21

treatment 29:21

trend 30:2 66:4

tried 131:12

triggered 144:4

true 29:16 55:2

71:7 91:3

truly 99:20

truth 121:4

try 30:15 62:5 63:3

80:16 107:4 163:4

174:11

trying 11:2 67:5

81:10,12 119:17

120:12 123:12

128:16 131:11,18

153:20 159:8

168:3

Tsao 10:14,14

TUESDAY 1:7

turn 13:6 112:11

126:8

turning 7:17

two 22:2 32:22

51:12 52:16 64:1

65:9 83:14 100:18

100:22 102:7,10

102:22 109:14

116:8 130:12

146:3 165:10

type 32:5 92:12

93:4 105:13

135:18 161:16

162:2

types 16:1 19:8

37:22 45:13 53:16

78:6 92:16,19

125:6 127:20

129:6 131:1 135:7

154:22 155:14

161:20

typical 127:3

typically 7:15 13:9

27:14 38:5 110:10

112:4 125:18

150:16

U

U.S 1:1 24:6

Uh-hum 33:21

138:4 140:5

141:21

ultimate 93:17 97:9

166:22

ultimately 94:22

unable 128:21

unambiguous

35:16 40:15 42:8

uncertain 154:14

uncertainty 118:17

unclear 158:4

uncover 36:12

uncovers 121:3

understand 63:3

77:13 86:18 89:4

89:18 90:16

122:22 131:18

135:5 153:19

154:6 163:8,20

understanding

26:10 43:18 54:21

58:20 67:9,20

73:22 86:10 87:22

89:16 134:21

157:9 165:5,5

understands 42:9

undue 41:19

unfortunately

61:13

uniform 16:5,20

35:15

unintended 18:21

unique 15:19

unit 44:20 65:19,20

87:20 88:11 91:12

94:8,14,14 96:17

96:18 125:9,10

126:21 151:8

172:1

United 23:12,16

units 64:11 87:4,17

88:15,17 98:2,18

99:4 126:4 147:1

147:2 171:4,7,17

universal 28:12

29:3,18 30:8,13

30:16 140:20

141:3,7

universal-type

143:14

universe 63:21

148:3

unknown 137:18

unknowns 137:17

137:18 144:6

unmute 34:10

77:15 104:12

148:16

unpredictability

118:17

unquote 102:9

update 134:17

updated 134:2

upper 115:17
202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

Page 198

117:11

upside 106:19

URLs 175:21

usage 30:4,12

125:18

USB 149:10,12

152:11,13

USB-based 29:18

USB-charged

152:5

use 15:14 17:16

24:15 29:12 47:13

47:21 48:1,2 49:4

49:7,10,10 50:15

50:16 68:7 70:18

94:22 109:13

113:17 126:19

129:1 137:15

140:13 163:13

useful 14:9 20:4

117:5 129:8

uses 100:6,7 137:14

usually 161:14

Utilities 54:17

utilizing 28:21

V

value 26:14,14

73:13 74:11,18

85:13,14 87:13,18

87:20 97:21

171:18

values 57:15 74:1

variability 55:14

59:6 61:10 64:13

71:3 97:3 109:19

171:2,8,15

variability’s 93:4

variables 105:14

105:20 113:6

variances 72:13

75:14 102:17

variant 79:5

variation 65:22

72:8 94:14 96:11

98:20,21 99:3

167:7

variations 166:18

166:21

varies 114:12

115:13

variety 45:1 78:17

various 41:12

124:20

vary 154:9 155:3

156:18

varying 154:1

vendors 145:11

versus 30:8 90:18

130:5 140:20

141:1,3 155:20

162:2 165:13

vessels 113:12

view 85:8 136:12

views 63:11

voice-over-intern...

80:14

volley 174:4

voltage 49:3,7 50:9

50:12 52:10 116:5

116:9,14 154:9,17

155:2 156:18

157:2,5,14,22

voltage/current

159:4

voltages 48:9 154:1

168:8

volts 116:13

W

waiting 71:4

walk 107:3

walking 101:9

wall 20:10,20

171:22

wandering 109:5

want 6:20 7:3

13:13 14:21 31:17

35:14 36:16,21

41:6 42:15 53:2

53:14 55:16 60:17

66:11 68:3,7 71:1

71:10 73:18,19

76:1,3 77:5,7 82:7

84:2 85:5,9 86:9

87:7 90:10,11,16

90:20 92:8 97:17

98:10 107:1 111:6

114:1 127:9

131:22 135:8,9

145:1,6 146:3

151:21 153:7,9

154:20 169:4,7

170:17 172:19

wanted 78:1 104:7

116:21 148:19

149:10

wants 170:19

warranted 22:16

173:13

warts 20:20

Washington 1:12

6:9

wasn't 58:1 91:15

131:13

Watches 19:9

watt 90:3

way 17:4 27:17

36:14,18 38:5

44:16,17,21 53:19

56:20 58:9 60:4

60:16,20 66:5

69:20 77:8,10

79:3 94:5 95:2

100:7 103:7

106:10 113:17

119:5,12 121:18

122:16 131:19

134:5 144:10

147:3 148:20

158:14 162:4,6

165:2 166:14,18

169:3,9

Wayne 2:10 4:11

33:19,22 34:8

101:4 104:7,10,17

122:2,13

ways 103:14,15

135:5 175:12

wear 101:9

wears 112:9

web 10:20 11:1,3

85:7

webinar 13:5 33:19

35:4,7 170:19

website 27:8 46:9

87:3

weeks 109:14

welcome 6:5,18

10:17,19 13:6,22

35:7 104:2 168:21

171:16

welcomes 62:11

welcoming 6:12

well-charged

111:10

well-defined 29:3

well-observed

118:21

well-presented

117:5

went 101:19,19

West 33:18

wet 139:16 149:21

whatsoever 117:16

whichever 57:19

wide 32:3 61:19

64:22

wide-ranging

24:21

willing 107:7

window 121:1,15

wired 18:15 20:18

29:20 30:8,16

wireless 3:15 4:17

8:3 9:2 15:7,9,14

16:10 17:6,12,19

18:1,9,11,13,22

19:1,4,5,16 20:3

20:16,19 21:3,17

21:18,22 22:2,3

22:14,20 28:6,20

29:1,2,4,20 30:7

30:17 133:12,15

134:3,14,17,20

135:1,14 136:1,11

137:5,6,14 138:15

138:21 139:7,12

139:16 140:1,22

144:7,18 145:8,15

151:17 152:16,21

162:9

wirelessly 15:19

19:7 133:19 139:6

Wise 10:10,10

wish 14:16 15:5

54:12

wishes 12:6

witnessing 20:1

wonder 65:14

wondering 167:14

word 93:10

words 163:15

165:12

work 8:9 87:9

114:11 120:2

121:16 145:16

147:20 148:6

worked 24:8

working 24:4 118:5

118:7 147:12

works 119:12

137:6 147:10

150:1

worse 87:17 112:6

112:9

worst 27:15 83:12

83:17

worth 121:19

wouldn't 128:18

162:16

WPC 139:9

wrap 5:5 12:4

170:11

write 77:6

writing 122:8

176:16

written 23:2 31:6

33:6 45:8 56:20

58:1,4 60:4 61:3

129:22 138:6,9

174:16 175:7

X

X 103:5

Y

year 24:15 43:14
202-234-4433 Washington DC www.nealrgross.com

Neal R. Gross and Co., Inc.

Page 199

146:11

years 24:13 133:15

Z

zero 105:17 112:6

118:4

zone 118:7

0

1

1 12:15 26:15 50:7

52:1 54:5 59:2

72:19 78:18 90:2

117:15

1.3 118:11

1.8 117:9

10 72:15 165:9,12

170:4

10.5 115:9

10.5-volt 115:8

10:30 11:21 101:5

10:31 101:19

10:45 101:17

10:47 101:20

100 112:1 113:19

118:4,6

1000 1:12

104 4:10

11 3:7

11:58 176:19

12 116:14

12-to-15-percent

116:16

123 4:13

124 4:14

127 4:16

13 3:8

133 4:17

136 4:20

14 3:10,11

15 101:6

153 5:2

156 5:4

170 5:5

18 3:14

1975 37:17

1989 114:22

2

2 11:7 47:7 50:11

65:1 70:17 72:21

92:6 116:13

118:14,16

20 112:1,22 113:4

113:20 117:8

118:5,11

20-to-24-hour

121:1

2006 38:11,21

39:17 134:1

2009 39:5

2010 39:6

2011 38:12,15,20

38:22 134:2

2012 18:12 39:8,8

43:6 134:10

139:19

2013 40:17

2014 1:7 6:8 39:22

40:5,10 175:8

21 10:22

23 3:16

24 106:15 113:4,10

121:11 123:16

24-hour 50:1 80:6

90:4 120:1 137:2

3

3 1:7 50:14 92:8,10

103:12,18 117:11

30th 170:13 175:8

175:20

31 3:19

34 4:2

39.56 90:4

3rd 6:8

4

4.1 47:5,6,17 48:2,4

49:14 82:15

4.3.a.2 47:8

4.3.b 47:4,17

40 113:15

42 4:5

45 113:11

48 113:10 120:1

5

5 117:7

5.8.c(3) 71:17

500 112:3

54 4:7

58 100:20 102:9

6

6 3:2,4 65:1

6.78 137:15

60 64:11,13 100:18

102:6 113:19

60-model 102:16

629503(b) 16:11

18:3 21:4 22:21

7

7 3:6 117:11

7.4 118:3

7.5 117:7

70 89:10,13

8

8.68 90:3

80 89:11 116:4

85 113:11

8E-089 1:11

9
NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS 

1323 RHODE ISLAND AVE., N.W. 

(202) 234-4433 WASHINGTON, D.C. 20005-3701 www.nealrgross.com 

C E R T I F I C A T E

This is to certify that the foregoing transcript 

In the matter of: 

Before: 

Date: 

Place: 

was duly recorded and accurately transcribed under 

my direction; further, that said transcript is a 

true and accurate record of the proceedings. 

 

 ----------------------- Court Reporter 

200

Battery Chargers Test Procedure

US DOE

06-03-14

Washington, DC