f 

 UNITED STATES OF AMERICA 

 DEPARTMENT OF ENERGY 

 

PUBLIC MEETING ON THE ENERGY CONSERVATION STANDARD 

FRAMEWORK DOCUMENT FOR 

HIGH-INTENSITY DISCHARGE LAMPS 

 

 

U.S. Department of Energy 

1000 Independence Ave., SW 

Washington, D.C. 20585 

 Room 8E-089 Review Center 

 

 Thursday 

March 29, 2012 

 

Facilitator: 

Doug Brookman 

Public Solutions 

Baltimore, MD 
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Participants Identified: 

Joe Halley 

Manager of Industry Relations 

GE Lighting, 

Chairman, NEMA lamp section 

Susan Anderson 

Manager of Energy Relations 

Osram Sylvania 

Keith Cook 

Phillips Electronics 

Tom Harding 

Venture Lighting 

John Green 

Cooper Lighting 

Joanna Mauer 

Appliance Standards Awareness Project 

Daniel Young 

California Investor-Owned Utilities, Pacific Gas and 

Electric, Southern California Edison and Semper 

Utilities 

Alex Boesenberg 

NEMA 

 

Participants from DOE:

Lucy deButts 

Project Manager, Lighting Team 

DOE 

Betsy Kohl 

General Counsel’s Office 

DOE 

Brenda Edwards 

Department of Energy 

 
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Participants from Consultants:

Scott Morris 

Pacific Northwest National Laboratory 

Mike Myer 

Pacific Northwest National Laboratory 

Matthew Walker 

Navigant Consulting 

Merry Walker 

Navigant Consulting 

Nancy Tucker 

Navigant Consulting 

Matt Chester 

Navigant Consulting 

Mansi Thakkar 

Navigant Consulting 

Ali McDonald 

Navigant Consulting 

Hayden Cook 

Navigant Consulting 

Mimi Gupta 

Navigant Consulting 
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AGENDA

 ITEM PAGE 

 

Welcome, Doug Brookman 5 

Welcome for DOE, Ms. deButts 5 

Introductions 7 

Agenda Review, Doug Brookman 8 

Introductory Remarks and Purpose 

 Ms. deButts 11 

Regulatory History, Rulemaking Overview, 

 And Scope of Coverage, Mr. Walker 16 

Market & Technological Assessment 45 

 And Screening Analysis, Mr. Walker 

 

Engineering Analysis, Ms. Walker 70 

 

Energy Use and Markup Analysis, Mr. Myer 95 

Life Cycle Cost and Payback Period 

 Analysis, Mr. Morris 106 

Shipments Analysis, Mr. Myer 114 

National Impact Analysis, Mr. Myer 125 

NOPR Analyses, Mr. Morris 138 

Manufacturer Impact Analysis, Ms. Walker 142 

Downstream Analyses, Mr. Myer 148 

Final Comments 162 

Closing Remarks, Ms. deButts 169 
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1 P R O C E E D I N G S

2 MR. BROOKMAN: Let’s start. Just take 

3 your seats. Good morning everyone and welcome. 

4 This is the U.S. Department of Energy’s public 

5 meeting on Energy Conservation Standard Framework 

6 Document for High-Intensity Discharge Lamps. Today 

7 is Thursday, March 29, 2012 here in the Forrestal 

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

9 Brookman from Public Solutions in Baltimore. So 

10 happy to see you here this morning. 

11 We’re going to start off with welcoming 

12 remarks from Lucy deButts. 

13 Welcoming Remarks 

14 MS. deBUTTS: Hi everyone. I am Lucy 

15 deButts, Project Manager for DOE’s lighting team. 

16 Some of you may have already talked to me and some 

17 not, but Tina Carlsburg, the previous manager is on 

18 detail, so currently I am leading the team. Again, 

19 welcome to our public meeting today. I’d like to 

20 start by reminding everyone that the Notice of the 

21 Public Meeting and the availability of framework 

22 document was published in the Federal Register on 

February 28th 23 . We also have it on DOE’s website for 
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1 stakeholders to review, so feel free to go to the 

2 website and read the documents. 

3 We will provide an overview of the HID 

4 approach today. We will talk about the history a 

5 little bit of HID standards and scope of coverage 

6 and analyses that DOE is planning on taking. So 

7 looking forward to industry’s input and hoping for 

8 your collaboration in this -- and cooperation in 

9 this process. So at this time, I’d like to give it 

10 back to Doug for further introductions. He is the 

11 meeting facilitator and he will set some ground 

12 rules and go over the meeting agenda. 

13 MR. BROOKMAN: Thank you. Let’s start 

14 over here. Give your name, and organizational 

15 affiliation, and give you practice at turning these 

16 microphones on and off. The little green button 

17 needs to be illuminated. 

18 Introductions 

19 MR. HALLEY: Thanks, Doug. This is Joe 

20 Halley, Manager of Industry Relations for GE 

21 Lighting, and also chairman of the NEMA lamp 

22 section. 

23 MS. ANDERSON: Susan Anderson, Osram 

24 Sylvania and I’m the Manager of Energy Relations. 

25 MR. COOK: Keith Cook, Phillips 
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1 Electronics. 

2 MR. HARDING: Tom Harding, Venture 

3 Lighting. 

4 MR. GREEN: John Green, Cooper Lighting. 

5 MS. MAUER: Joanna Mauer, Appliance 

6 Standards Awareness Project. 

7 MR. YOUNG: Daniel Young, California 

8 Investor-Owned Utilities, Pacific Gas and Electric, 

9 Southern California Edison and Semper Utilities 

10 MR. MORRIS: Scott Morris, Pacific 

11 Northwest National Laboratory. 

12 MR. MYER: Mike Myer, Pacific Northwest 

13 National Laboratory. 

14 MR. BROOKMAN: You can just stand up, 

15 that’ll be sufficient. 

16 MR. WALKER: Matthew Walker, Navigant 

17 Consulting. 

18 MS. WALKER: Merry Walker, Navigant 

19 Consulting. 

20 MS. EDWARDS: Brenda Edwards, Department 

21 of Energy. 

22 MR. BROOKMAN: Please. 

23 MS. TUCKER: Nancy Tucker, Navigant 

24 Consulting. 

25 MS. KOHL: Betsy Kohl, DOE, GC. 
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1 MR. CHESTER: Matt Chester, Navigant 

2 Consulting. 

3 MR. BROOKMAN: Okay. Thanks to all of you 

4 for being here. 

5 Agenda Review

6 MR. BROOKMAN: All of you received a 

7 packet of information as you came into the room. In 

8 there was a copy of the agenda, and the PowerPoint 

9 slides that will be the basis for both presentation 

10 and discussion today. And also a copy of the 

11 Federal Register Notice. 

12 I’ll give you a very brief agenda review. 

13 You can see that following this agenda review and a 

14 few preparatory slides, there’s an opportunity for 

15 anyone that wishes to do so, to make opening 

16 remarks, brief summary statements about issues that 

17 matter to you. 

18 Following that we’ll dive straight into 

19 the detail content, the regulatory history, 

20 rulemaking overview, scope of coverage. 

21 We’ll take a break mid-morning, round 

22 about 10:15 or 10:30 or so. Following that, market 

23 and technology assessment, screening analysis, 

24 engineering analysis. We’ll break for lunch around 

25 about noon. Energy use analysis, immediately 
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1 following lunch. Markup analysis, life cycle cost 

2 and payback period analysis. Moving on directly to 

3 shipments analysis, national impacts analysis, life 

4 cycle cost subgroup analysis. 

5 We’ll break mid afternoon as required and 

6 needed. Following the break, or whenever we get 

7 there, manufacture impact analysis, utility impact 

8 analysis, employment analysis, environmental 

9 assessment, regulatory impact analysis. 

10 You can see as listed in the agenda, yet 

11 another opportunity for comment at the end of the 

12 day, any issues you think have not been covered 

13 sufficiently from your perspective. I see a few 

14 things here at the outset, both Keith and Susan. 

15 MR. COOK: Doug, I just want to ask, is 

16 there anybody on the line? 

17 MR. BROOKMAN: I’m certain there is. We -

18 - the Department anticipated that there would be 

19 folks on the line. 

20 MR. COOK: Should we ask for them to 

21 introduce themselves? 

22 MR. BROOKMAN: I’m not sure we have the 

23 capacity to do that. We know who they are, because 

24 they signed on, and their comments and questions 

25 will be inserted in the record of the meeting. The 
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1 Department’s trying to make that happen effectively. 

2 Susan. 

3 MS. ANDERSON: I’d just like to confirm if 

4 Susan Callahan from Osram Sylvania is on the line. 

5 MR. BROOKMAN: Okay. Let me look to see. 

6 Do we -- yes. 

7 MS. ANDERSON: Thank you. 

8 MR. BROOKMAN: Yes, our web mistress says 

9 yes. Okay. 

10 MR. COOK: Can she read off the names? 

11 MR. BROOKMAN: Can you read off the names? 

12 Let’s get you so you can be heard. 

13 MS. EDWARDS: We have Austin Gilder, Carl 

14 Abramson, Dan Csorsky (ph), David Ellis, James Carl, 

15 Larry Liepso (ph), Brenda Wilson, Rachel Dixon, Rich 

16 Osanich (ph), Ronald Darbauch (ph), Susan Callahan. 

17 MR. BROOKMAN: Okay. So the Department is 

18 trying hard to make these meetings accessible via 

19 the web. So, finally, I’d ask for your 

20 consideration. Please during the course of this 

21 meeting today, speak one at a time. Say your name 

22 for the record each time you speak. You don’t need 

23 to say your organizational affiliation unless that’s 

24 what you would like to do. I’m going to be cuing 

25 individuals by name to speak. I also wish to 
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1 encourage follow on comments, particularly the back 

2 and forth is useful to the Department as they 

3 consider these issues. 

4 If you can, keep the focus here. Please 

5 turn your cell phones on silent mode, and limit 

6 sidebar conversations. Make sure to turn the 

7 microphone on, be concise, share the air time. 

8 There’s a lot to be said and we want to be efficient 

9 here today. So that’s all I have to say at the 

10 outset, then back to Lucy. 

11 Introductory Remarks and Purpose 

12 MS. deBUTTS: So I just wanted to confirm 

13 to everyone that we are broadcasting this over the 

14 internet for those participants that cannot attend 

15 in person. They can listen in, they can review the 

16 slides. They can’t really talk to us at this point, 

17 but they can provide their comments. Webinar 

18 provides that feature, so we will try to address 

19 their comments and questions as they come in. We 

20 have over 30 participants registered for this 

21 webinar so far, so we’ll try to answer them, time 

22 permitting. They will be treated as a secondary 

23 though, to the group that is here. So your 

24 questions are going to be addressed first. However, 

25 as I said, we will try to answer all questions and 
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1 comments. 

2 MS. ANDERSON: Are you saying they can’t 

3 comment? 

4 MS. deBUTTS: They can comment via the 

5 comment feature within the webinar. 

6 MS. ANDERSON: In the past, we’ve been 

7 able to hear them, and quite frankly, our technical 

8 people are the ones that are on the web, so really 

9 need that feature of their being able to speak and 

10 us being able to hear them as a group. 

11 MR. BROOKMAN: I see. 

12 MS. ANDERSON: Because they’ll be the 

13 appropriate people to comment and answer some 

14 questions. 

15 MR. BROOKMAN: So, thank you Susan, for 

16 that. Do we have the capacity for them to speak and 

17 be heard here in the room? We do have that 

18 capacity. 

19 MS. deBUTTS: So we will try to do so, 

20 then. 

21 MR. BROOKMAN: So let’s see how that 

22 works. Let’s try and make that work. 

23 MS. ANDERSON: Because we did do that last 

24 time. 

25 MR. BROOKMAN: Yes, it’s been done several 
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1 different ways during the course of these meetings. 

2 MS. deBUTTS: But regardless, it’s like 

3 Doug said, anything that they comment on via the 

4 webinar feature, you know, typing in questions, will 

5 be attached to the transcript and will be treated as 

6 the normal written comments. 

7 MR. BROOKMAN: And for those joining us 

8 via the web, welcome. I’m glad to have you with us. 

9 If you could try to either in written form, or 

10 orally, if that succeeds, try and be brief, concise 

11 in your comments. That would be helpful to all of 

12 us. 

13 MS. deBUTTS: All right. So and as a last 

14 reminder, the transcript itself, including the 

15 comments that were received today from the webinar 

16 participants, and the presentation slides, are going 

17 to be posted on DOE’s website shortly after this 

18 meeting, so as soon as we get the transcript ready, 

19 we’ll post it on the web. 

20 As for the purpose of this public meeting, 

21 it’s of course to review the HID framework document 

22 that we issued. The PNNL and Navigant staff will 

23 assist DOE in presenting the procedural and 

24 analytical approaches to the evaluation of HID 

25 standard. We will be discussing the rulemaking 
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1 process itself, and the next steps that we’re 

2 planning on taking, so once again, you are invited 

3 to comment on those. 

4 In addition, we would like to get any data 

5 or information or summary comments you may wish to 

6 add for us to consider while we are working on the 

7 rulemaking. 

8 So, comment boxes. You will see the 

9 comment boxes like on this slide throughout the 

10 presentation. These comment boxes highlight the 

11 specific issues we are seeking comments on. The 

12 item numbers in these comment boxes correspond to 

13 the list of items that were listed in the framework 

14 document. Obviously, we have more issues that could 

15 be addressed, so please feel free to comment on any 

16 aspects of the materials that we’re going to be 

17 presenting today. 

18 As far as for the comment period 

19 submission, I just wanted to mention that the due 

date is April 12th 20 , which is an extension from the 

21 originally published date in the framework. The 

22 extension -- comment period extension published this 

23 morning, so we would like to get your remarks by 

April 12th 24 if possible. 

25 And last, but not least, we will discuss 
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1 the avenues of submitting the comments at the end of 

2 this presentation so everyone’s aware on how to 

3 submit them, where to submit them via docket, e4 mail, or by mail. 

5 So at this time, I think my part of 

6 introductions is pretty much over, I will turn back 

7 to Doug for opening remarks. 

8 MR. BROOKMAN: Thank you. Now is the 

9 opportunity for brief summary remarks, issues that 

10 are important to you. Who’d like to start? Joe? 

11 Alex? 

12 MR. BOESENBERG: We are ready to comment 

13 on the individual items. We have no opening 

14 statement. 

15 MR. BROOKMAN: Okay. Thank you. Other 

16 comments here at the outset? No additional opening 

17 remarks. Okay. So then let’s go right into the 

18 content. 

19 Regulatory History, Rulemaking Overview 

20 And Scope of Coverage 

21 MR. WALKER: Good morning. I’m with 

22 Navigant and my name is Matthew Walker. Let’s get 

23 started with the regulatory history for this 

24 rulemaking. So the Energy Policy Act of 1992 added 

25 HIV lamps to the covered equipment of the appliance 
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1 standards program here at DOE. EPCA 1992 specified 

2 three requirements that are relevant to these 

3 products. The first was to conduct a determination 

4 to decide whether standards would be technologically 

5 feasible, economically justified, and have the 

6 potential to save significant energy. And DOE has 

7 completed this determination by publishing a 

8 publication on July 1, 2010, and this document 

9 concluded standards would be feasible. 

10 The second requirement is that DOE must 

11 complete a test procedure, final rule within 30 

12 months of completing the determination document, and 

13 DOE has initiated this process with a test procedure 

14 Notice of Proposed Rulemaking that was published on 

15 December 15, 2011. 

16 And finally, the third requirement of EPCA 

17 1992, which is the subject of today’s presentation, 

18 is that DOE is directed to prescribe an energy 

19 conservation standard within 18 months of completing 

20 the test procedure final rule. So the time 

21 intervals put forth by EPCA bring us to the 

22 rulemaking schedule. 

23 This slide presents the projected schedule 

24 for the intermediate stages of this rulemaking. 

25 Like we said before, the framework document was 
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1 published in February of this year, and DOE is 

2 anticipating an interim analysis being available 

3 September this year, followed by a NOPR in June 

4 2013, and a final rule by July 2014. The compliance 

5 date for this rulemaking would be about three years 

6 after -- or would be three years after the 

7 publication of the final rule, so approximately July 

8 2017. 

9 I should also point out, there have been 

10 comments in both the HID determination and the metal 

11 halide lamp fixtures rulemakings that those two 

12 rulemakings should be combined in some fashion. So 

13 at this time, DOE intends to regulate each product 

14 separately, both with separate metrics and with 

15 separate rulemaking documents, but does intend to 

16 share data and decisions between the two rulemakings 

17 to coordinate the analysis and the adopted 

18 standards. 

19 So, at the bottom of this slide, in item 

20 two, DOE is welcoming comments on any specific ways 

21 it should coordinate the development of the final 

22 rules for these two products. 

23 MS. ANDERSON: We, NEMA, -- 

24 MR. BROOKMAN: Susan. 

25 MS. ANDERSON: Susan Anderson, Osram 
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1 Sylvania. NEMA does agree that they should be kept 

2 separately, handled separately, and what we’d like 

3 to point out is that in the luminaire rulemaking 

4 you’re only covering ballasts for new metal halide 

5 luminaries, so you’re not covering anything there 

6 relative to mercury vapor or high pressure sodium. 

7 So in that respect, the rulemakings don’t coincide. 

8 MR. BROOKMAN: Okay. Thank you. Joanna 

9 Mauer. 

10 MS. MAUER: Joanna Mauer. Just a question 

11 about the schedule. Is the interim analysis that 

12 DOE plans to publish is that different than what a 

13 typical preliminary TSD would be? 

14 MR. WALKER: It is. It’s very related. 

15 It has some distinctions. There will be a more 

16 substantial executive summary document, and a less 

17 substantial Chapter 2, which is usually where 

18 there’s a response to public comments and discussion 

19 of decisions. And the way it’s been described in 

20 the framework document is that the public comments 

21 would be saved until the NOPR for an official 

22 discussion, but of course the comments that come out 

23 in the framework document, both from this meeting 

24 and in written form, would be informing the interim 

25 analysis that’s published later this year. 
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1 MS. MAUER: Thank you. 

2 MR. BROOKMAN: Other comments on the 

3 schedule? Okay. 

4 MR. WALKER: So between now and July 2014, 

5 DOE will consider the following seven factors in its 

6 analysis: 

7  It looks at individual impacts on consumers 

8  Individual economic impacts on consumers in the 

9 life cycle cost analysis 

10  It then looks at energy savings and economic 

11 impacts on consumers as a whole in the national 

12 impact analysis 

13  It looks at economic impacts on manufacturers 

14 in the manufacturer impact analysis 

15  And DOE also looks at impacts on utility or 

16 performance, as well as any other factors the 

17 Secretary considers relevant. 

18 Scope of Coverage

19 So now we’ll discuss the scope of coverage 

20 that’s under consideration in the framework 

21 document. 

22 HID lamps have not been previously been 

23 regulated to this rulemaking establishes the first 

24 scope of coverage for these products. EPCA’s 
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1 definition of HID lamp includes mercury vapor, high2 pressure sodium, and metal halide lamps. And while 

3 low-pressure sodium lamps are often included in the 

4 HID family, they’re not included in the EPCA 

5 definition or this rulemaking. 

6 There’s also another lamp technology 

7 referred to as an electrodeless HID lamp or light8 emitting plasma. These lamps emit light through a 

9 process that’s related to HID lamps and have a gas 

10 composition that seems the most similar to metal 

11 halide. So in item three on this slide, DOE is 

12 welcoming comment on whether these electrodeless HID 

13 lamps should be considered a subcategory of HID 

14 lamps. 

15 MR. BROOKMAN: Susan. 

16 MS. ANDERSON: Susan Anderson, speaking 

17 for NEMA. We do not consider them a subgroup. 

18 They’re most similar to metal halide, but we 

19 consider them to be their own unique technology, and 

20 right now there are no standards at all for these 

21 lamps, and there are none in development. So there 

22 would be no reference standards for evaluating these 

23 products. And our recommendation would be that you 

24 not include them in this rulemaking. 

25 MR. BROOKMAN: Is there a test procedure? 
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1 No test procedure. 

2 MS. ANDERSON: Not anything across the 

3 industry. 

4 MR. BROOKMAN: Interesting. 

5 MS. ANDERSON: And very limited 

6 manufacturing of these products. 

7 MR. BROOKMAN: Okay. Thank you. That was 

8 clear. Do you have any follow up questions from 

9 that? 

10 MR. WALKER: I would just maybe ask if 

11 there was an agreed upon definition of those types 

12 of lamps that would help us understand the 

13 distinction between the two. 

14 MS. ANDERSON: Tom, I’m going to defer to 

15 you, but not that I know of. 

16 MR. BROOKMAN: Tom. Tom, turn the mic on. 

17 MR. HARDING: Tom Harding. No, they’re a 

18 new technology. They’re electrodeless. The biggest 

19 feature is they’re electrodeless, they’re driven by 

20 radio frequency to heat up and then emit light. But 

21 it’s done much differently than a ballast, for 

22 example, running current through electrodes. So 

23 it’s kind of an altogether different technology. 

24 Been around and the analogy would be fluorescent has 

25 systems where they have electrodeless lamps, so 
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1 they’re similar to that, but there are no standards, 

2 no technology work being done, simply a few 

3 companies are doing these. 

4 MR. BROOKMAN: One thing that would be of 

5 interest to the Department is the trajectory of this 

6 product, if you think it’s going to be -- there’s 

7 going to be more of them, it’s going to go 

8 mainstream, that sort of thing. 

9 MR. HARDING: I wish I knew. I don’t 

10 actually know, there’s so few of them right now. 

11 MR. BROOKMAN: Joe. 

12 MR. HALLEY: It appears to be a niche 

13 product right now, very few manufacturers, very few 

14 product sales. It’s going to be competing against 

15 some other technologies. It doesn’t seem to be 

16 widespread investment in this technology by the 

17 major manufacturers. So it appears to be a niche 

18 product right now that doesn’t offer a lot of 

19 opportunity for either energy use or energy savings 

20 at this point. 

21 MR. BROOKMAN: Okay. Thank you. 

22 PARTICIPANT: Can we have the microphone? 

23 MR. BROOKMAN: The mic’s on. 

24 PARTICIPANT: Maybe closer? 

25 MR. BROOKMAN: Okay. I’ll speak up. I’ll 
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1 do that. Alex, do you want to -- 

2 MR. BOESENBERG: Just one last point. 

3 These are operated on electronic ballasts and in our 

4 scope discussions we were -- the DOE is planning to 

5 exclude those products, so this wouldn’t fall under 

6 the scope then. 

7 MR. BROOKMAN: Okay. Other comments 

8 related to the scope and these definitions? Okay, 

9 we’re going to keep going. 

10 MR. WALKER: So two of the more 

11 significant parameters considered in the framework 

12 document for the scope of coverage are lamp input 

13 wattage and correlated color temperature, or CCT. 

14 So, HID lamps span a wide range of input wattages 

15 and CCTs, and these ranges vary according to the 

16 lamp technology. So DOE is considering a subset of 

17 the available input wattages and CCTs for its scope 

18 in the framework, and those lamps that are outside 

19 of the subset have a -- represent a very small 

20 number of available products according to catalog 

21 availability, and as a result, a limited potential 

22 for energy savings. 

23 So in summary, DOE is considering 

24 including the lamps on the table on this slide: 
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1  metal halide lamps between 50 and 2000 watts 

2 and between 2500 and 6999 Kelvin; 

3  mercury vapor lamps between 50 and 1000 watts 

4 and between 3200 and 6800 Kelvin; 

5  and high pressure sodium lamps, 50 to 1000 

6 watts and between 1900 and 2700 Kelvin. 

7 Then from this table, DOE is considering 

8 excluding certain types of lamps, and those include: 

9  HID lamps designed and labeled for use with 

10 electronic ballast only; 

11  Directional HID lamps 

12  Self-ballast HID lamps 

13  Colored HID lamps, and 

14  Specialty application mercury vapor lamps. 

15 And similar to what I just said a few 

16 minutes ago, these lamp types represent a very small 

17 portion of the available products according to 

18 catalog availability, and therefore a limited 

19 potential for energy savings. 

20 So this brings us to two items for comment 

21 on the scope of coverage. In item four, DOE is 

22 welcoming comment on its decision to define the 

23 scope of coverage using rated wattage instead of 

24 lumen output, as well as the specific range of 
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1 wattages included in coverage. I’ll go ahead -- 

2 we’ll just leave it at that and pause for that one. 

3 MR. BROOKMAN: Yes, Joe. 

4 MR. HALLEY: In terms of the ranges of 

5 products to be covered, we believe that the 50 to 

6 1000 watt category in all three products represents 

7 the high volume, general lighting use category, so 

8 that would include metal halide as well. Although 

9 there are metal halide products that are over 1000 

10 watts, these tend to be niche products for specialty 

11 applications, such as sports lighting, which are 

12 operated for fairly low periods of time, and they 

13 have relatively short lives as well because of the 

14 high lumen output requirements. We don’t believe 

15 that that particular specialty product category 

16 should be regulated above 1000 watts. 

17 Would you like me to comment on item five 

18 as well? 

19 MR. BROOKMAN: Why don’t you read it, 

20 Matthew? 

21 MR. WALKER: Sure I’ll read it. So in 

22 item five, DOE is welcoming comments on the decision 

23 to exclude certain types of lamps and specifically, 

24 on unique characteristics of colored HID lamps that 

25 can be used to characterize and define that 
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1 exclusion. 

2 MR. HALLEY: And we would agree that these 

3 do represent niche product categories and they 

4 should be exempted. The areas that you have listed 

5 here, certainly would qualify. There may be some 

6 additional categories as well, such as high CRI, low 

7 color temperature lamps, such as the high CRI, high 

8 pressure sodium lamps that are on the market. We’d 

9 also recommend they be treated as a niche exempted 

10 category. We may have further comments as well as 

11 we review this a little more carefully. 

12 MR. BROOKMAN: Okay. Thanks, Joe. Yes, 

13 Susan. 

14 MS. ANDERSON: Yes, we also had a comment 

15 on the color temperature range covered for metal 

16 halide. We would stop it at 6000 Kelvin, because 

17 any lamps that are available that are at higher 

18 color temperatures, are for very specialized 

19 applications, like aquarium lighting. They’re not 

20 used for general application lighting. 

21 And then the other thing to note is that 

22 there are specialty application metal halide lamps 

23 that also need to be taken into consideration. 

24 MR. BROOKMAN: They wouldn’t be included 

25 in these? 
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1 MS. ANDERSON: No. 

2 MR. BROOKMAN: Oh. So what would the 

3 definition of -- what would be their specifications? 

4 MS. ANDERSON: We actually have comments 

5 on that further on. We plan to provide some 

6 definitions to help guide the DOE on what would 

7 include specialty versus general lighting. 

8 MR. BROOKMAN: Okay. Thank you. That’s 

9 good. Other comments on these scope of coverage 

10 issues? Yes, Daniel. 

11 MR. YOUNG: Yes, Daniel Young. With 

12 regards to electronic ballasts, our understanding is 

13 that the trajectory of the market is trending 

14 towards st... metal halide electronically ballasted 

15 products, and within three or five years this may 

16 represent a much larger share of the market. Does 

17 DOE or other manufacturers have any other comments 

18 on that? 

19 MR. BROOKMAN: Susan. 

20 MS. ANDERSON: Most of the electronic 

21 ballasts are being developed right now are for the 

22 metal halide family, and typically right now they 

23 are very low wattage, though we have some higher 

24 wattage ones on the market. How fast they become 

25 adopted by the market may depend very much on the 
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1 metal halide luminaire rulemaking, and what ballast 

2 efficiency standards are set there. 

3 MR. BROOKMAN: That means you don’t know. 

4 Keith. 

5 MR. COOK: Keith Cook. You have -- 

6 basically the problem, I think, is the fact that we 

7 have such a huge installed base already with 

8 magnetic ballast, that even as this grows and the 

9 growth has not been huge, it’s still going to be a 

10 very, very small percentage of the installed base, 

11 even going forward. 

12 MR. BROOKMAN: Thank you. Those are all 

13 very useful comments. Final comments before we move 

14 on? 

15 MR. WALKER: I was going to ask a follow 

16 on. 

17 MR. BROOKMAN: Please. 

18 MR. WALKER: I was going to say one thing 

19 if it was possible, if NEMA was able to provide 

20 specific shipment percentages of some of these 

21 excluded lamp types to support the niche application 

22 and limited potential for energy savings. 

23 MR. BROOKMAN: Alex. 

24 MR. BOESENBERG: For this subject and a 

25 few others on the list of items, NEMA is open to 
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1 discussing if we can reach an arrangement to provide 

2 data, yes. I can’t promise it. It depends what you 

3 ask, how you ask it and what data we have and how we 

4 can parse it up. But we’re open to that discussion. 

5 MR. BROOKMAN: You’ll be the point of 

6 contact -- 

7 MR. BOESENBERG: Yes. 

8 MR. BROOKMAN: -- for that discussion? 

9 Yes. Joanna. Oh, you want to -- yes. 

10 MS. deBUTTS: We received a question from 

11 the webinar participant, and Larry Liepso (ph) -- I 

12 apologize for not pronouncing the name correctly -- 

13 he’s asking why self-ballast energy lamps are not 

14 included, because they’re fairly efficient. 

15 MR. BROOKMAN: What’s the category again? 

16 MS. deBUTTS: The self-ballasted energy 

17 lamps. 

18 MR. WALKER: Self-ballasted HID lamps? 

19 MR. BROOKMAN: Susan? 

20 MS. ANDERSON: Susan Anderson. I mean the 

21 two families where you have self-ballasted lamps, 

22 the original ones are self-ballasted mercury vapor 

23 lamps that were basically incandescent replacement, 

24 and the volume is very, very low. It’s been dying 

25 for years. The other, a couple of companies, my 
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1 company being one, we have self-ballasted metal 

2 halide that’s actually a replacement for halogen, 

3 and the main market for that is retail. But it’s 

4 long-lived and much more efficient than the halogen. 

5 But once again, it’s a small market application. 

6 Niche market. 

7 MR. BROOKMAN: Okay. 

8 MS. deBUTTS: Thank you. 

9 MR. WALKER: I think that’s all. 

10 MR. BROOKMAN: All with that. Yes, 

11 Joanna. 

12 MS. MAUER: Joanna Mauer. I think, Joe, 

13 you were mentioning the high CRI HPS lamps. Do they 

14 provide some different utility than metal halide 

15 lamps, or what’s the application for these types of 

16 lamps? 

17 MR. HALLEY: It just gives architects or 

18 landscape designers a different color palette to 

19 paint with light, if you will, so it’s a very low 

20 chromaticity, so it’s only 2200 degrees Kelvin. It 

21 still has a very large yellow component, but it 

22 provides a high color rendering index at a very low 

23 chromaticity. It is -- there’s very few 

24 applications for it. There’s a few applications for 

25 it, but it would definitely qualify as a niche 
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1 product category. It’s not growing. It’s used in a 

2 few, mostly outdoor -- specialty outdoor kind of 

3 applications for highlighting various finishes. 

4 Provides a different effect. 

5 MS. MAUER: Okay. 

6 MR. BROOKMAN: Yes, Daniel. 

7 MR. YOUNG: Daniel Young. Just a follow 

8 on question to that. What’s, I guess, kind of the 

9 efficiency penalty for going up to a higher CRI? Is 

10 it a big difference? 

11 MR. HALLEY: I’d have to look at the 

12 catalog, but I -- they’re still very efficient. 

13 It’s still high pressure sodium, so it still has a 

14 very high efficiency relative to other light 

15 sources. 

16 MR. BROOKMAN: Additional comments before 

17 we move on? Okay. 

18 MR. WALKER: All right, so item six 

19 continues with comments on exclusions and this one 

20 is welcoming comments on whether lamps for special 

21 applications have defining characteristics that 

22 differentiate them from lamps used for general 

23 illumination purposes, and in addition, whether the 

24 specialty applications that are relevant to mercury 

25 vapor technology can be served by high pressure 
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1 sodium metal halide technology. 

2 MS. ANDERSON: Susan Anderson, speaking 

3 for NEMA. I want to start with the mercury vapor 

4 versus metal halide and high pressure sodium first. 

5 You cannot substitute metal halide or high pressure 

6 sodium for mercury vapor in those applications, 

7 because it is the UV output of the mercury vapor 

8 that is essential in those applications. 

9 MR. BROOKMAN: Pardon me, Susan. Are you 

10 getting her? Just a little closer. You’re coming 

11 across great here. 

12 MS. ANDERSON: All right. So there really 

13 isn’t an exchange possible there. You don’t get the 

14 same output. And then in terms of other specialty 

15 application lamps, both when you look at mercury 

16 vapor and metal halide, they’re generally short arc 

17 tube lamps, very short arcs, so you get very 

18 precise, optical control and very high internal 

19 pressures. In fact many of them can’t even be 

20 shipped unless they’re within a protective container 

21 and the way the equipment maintains them that 

22 utilizes them, it has protective coverings around 

23 them because they can experience non-passive 

24 failures. So they are very specialized. 

25 In other cases, they have very short 
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1 usable life because they’re required to have very 

2 high lumen output for the applications where they’re 

3 used, so when you get into lumen maintenance, they 

4 can’t be used in applications where the general 

5 lighting lamps are. In many cases, in fact Alan 

6 found one base in common for most of those lamps. 

7 And others that you run into -- specialty 

8 -- we’ve mentioned plant growth, we’ve mentioned 

9 color-corrected high pressure sodium, we mentioned 

10 aquarium lighting. So for like for plant growth, 

11 they’re lamps that give you light output in the blue 

12 spectrum and the red spectrum, because that’s all 

13 that plants care about, so they’re not really 

14 suitable for general lighting applications. 

15 Aquarium is very high color temperature that’s not 

16 acceptable in general lighting applications. So 

17 there are specialized features about them, and NEMA 

18 plans to provide you with definition guidance to 

19 help you exclude those items and make it clear so 

20 that it’s much -- so there’s no confusion as to 

21 what’s general lighting versus what’s specialty. 

22 MR. BROOKMAN: Okay. 

23 MS. ANDERSON: The one family where there 

24 may be some issue are the clear mercury vapor lamps 

25 with medium screw bases and mogul (ph) screw bases 
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1 and medium skirted screw bases. They are used, you 

2 see them used, for outdoor illumination. They’re 

3 the ones that turn green as they get older. But 

4 they also have a utility as a UV curing, and for 

5 inspection purposes. So that’s the one family that 

6 there may be some -- we need to very closely define 

7 or label the lamps in some way. 

8 MR. BROOKMAN: Should they be included or 

9 excluded? 

10 MS. ANDERSON: In the sense that they can 

11 be used for general lighting applications, which 

12 would typically be outdoors, in less color-critical 

13 applications, they should be covered. But I think 

14 there needs to be some provision for the UV curing 

15 and the inspection applications, because they are 

16 widely used for that. 

17 MR. BROOKMAN: And it would be a separate 

18 definition? 

19 MS. ANDERSON: We’ll try to work out 

20 something, try to work with DOE and Navigant and 

21 PNNL. 

22 MR. BROOKMAN: Okay. Well, thank you, 

23 that was very helpful. Daniel. 

24 MR. YOUNG: Daniel Young. Just a follow 

25 on question to that. Is there -- what about LEDs? 
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1 Could those be used in the specialty applications? 

2 MS. ANDERSON: You have some LEDs with UV 

3 output, but really the UV output of LEDs is pretty 

4 limited at this point, and not sufficient for those 

5 applications. You have short arc to high pressure 

6 mercury vapor lamps, for example, that are used to 

7 etch the circuitry on silicon chips, and you would 

8 never get the output from LEDs at this point in time 

9 for that type of application. 

10 MR. BROOKMAN: Okay. 

11 MR. YOUNG: Thanks. 

12 MR. BROOKMAN: Joanna. 

13 MS. MAUER: Joanna Mauer. Just another 

14 clarification question. Susan, all of these types 

15 of mercury vapor lamps that you’re talking about, 

16 these are ones that are used with ballasts that are 

17 exempted from the -- 

18 MS. ANDERSON: In the case of mercury 

19 vapor, they are exempted based on, if we go back to 

20 ESA 2007, but metal halide was never considered at 

21 that point, because it was only mercury vapor 

22 ballasts that had been eliminated. 

23 MS. MAUER: Okay. So it’s mercury vapor 

24 lamps that are using ballasts that are exempted from 

25 the -- 
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1 MS. ANDERSON: The ballasts are specially 

2 labeled right now, for specialty application only, 

3 so I’m thinking we could do something similar for 

4 clear mercury vapor lamps that are used for the UV 

5 curing and the inspection processes. 

6 MR. BROOKMAN: Okay. There are several 

7 distinct pieces of information that the Department 

8 is asking about in item six and seven, particularly 

9 I call your attention to item seven, “any additional 

10 lamps that should be excluded from the scope of 

11 coverage.” Yes, Keith. 

12 MR. COOK: Keith Cook. Basically, the one 

13 thing that was in the written text which is not 

14 included so far in this is whether or not standby 

15 mode should be included. And standby mode does not 

16 apply, really, to lamps. It’s an electronic driver 

17 which is excluded anyway. We also, though, agree 

18 with the current coverage except as Joe pointed out 

19 earlier, we think it should be stopped at 1000 watts 

20 - above 1000 watts is -- should be also excluded, 

21 because it’s not a general lighting. 

22 MR. BROOKMAN: Okay. Additional comments 

23 on these two. Look at them. Defining 

24 characteristics and also specialty applications, and 

25 then in seven, exclusions. Nothing additional. 
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1 Okay. 

2 MR. WALKER: All right, so we’ll move on 

3 to metrics. DOE is considering several metrics for 

4 assessing the performance of HID lamps. The first 

5 will be initial lamp efficacy. Initial lamp 

6 efficacy is the ratio of light output to input power 

7 at the beginning of the life of the lamp. An 

8 alternative metric could be a maximum input power, 

9 or maximum input wattage. In this case, DOE would 

10 establish a maximum input wattage for a given light 

11 output or range of light outputs. 

12 So these metrics cover omni-directional 

13 lamps, which are lamps that cast light in all 

14 directions. But if DOE were to include directional 

15 lamps in the scope of coverage, it would plan to 

16 pursue a different metric. 

17 So this slide goes over possible metrics 

18 that could be employed if directional lamps were 

19 included. Center beam candle power and beam ... 

20 lumens could be possibilities. Center beam candle 

21 power or CBCP measures the intensity of light at the 

22 center of the beam angle, and DOE could require a 

23 minimum CBCP for a given lamp shape diameter or 

24 input power. And alternatively, for beam lumens, 

25 DOE could require a minimum beam lumens or zonal 
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1 lumens per watt for a particular lumen output, or 

2 input power range. 

3 So this slide provides opportunities for 

4 comment on the metrics. In item 13, DOE is asking 

5 for comments on the use of efficacy as a metric for 

6 omni-directional lamps, and then item 14, essential 

7 metrics that could be used if directional lamps were 

8 to be included. Though from the discussion that 

9 we’ve had so far, the interest seems to be for them 

10 to be excluded. 

11 MR. BROOKMAN: Okay. We’d like to get 

12 further confirmation, I believe. Susan. 

13 MS. ANDERSON: Well, I notice that you 

14 skipped over several items. 

15 MR. BROOKMAN: Oh. 

16 MR. WALKER: You mean in terms of the 

17 numbering? 

18 MS. ANDERSON: Yes. 

19 MR. WALKER: The numbering doesn’t match 

20 the framework document. The numbering matches the 

21 comments that you would have seen in the framework 

22 document, but are not necessarily in the same order. 

23 MR. BROOKMAN: But everything in the 

24 framework document you’ll cover rather 

25 systematically? 
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1 MR. WALKER: There may be one or two 

2 exceptions where an item is left out, but there’s 

3 still an opportunity for that to be done in a 

4 written comment. 

5 MR. BROOKMAN: So I don’t want to -- it 

6 looks like you’re very well prepared. We don’t want 

7 to mess you up. 

8 MS. ANDERSON: We can -- so long as we 

9 have the opportunity to comment there. 

10 MR. BROOKMAN: Great. We’ll make sure 

11 you’ve got that. Okay. Let’s try and -- I think 

12 it’s useful to make the comments as they fit with 

13 the order of the slides. It’s better for the 

14 record, I think. 

15 So you can see item 13 and 14, potential 

16 metrics in HID lamp conservation standards and also, 

17 let me see, differentiating between center beam -- 

18 well, the center beam intensity metric. Susan. 

19 MS. ANDERSON: Susan Anderson. We 

20 absolutely agree that the lamps should be measured 

21 based on initial lumen output. Our standards are, 

22 Tom, I believe, you measure them at 100 hours, so 

23 you have achieved lamp stability. We also had, in 

24 our earlier comments when we did the test and 

25 measurement procedures, we had recommended that you 
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1 use the definition for lamp efficacy that’s in IES 

2 RP16. On double checking it, we find that they 

3 don’t define lamp efficacy. They define luminous 

4 efficacy, which is the lumen output of the lamps 

5 divided by the input wattage, which is what you’re 

6 going after. So our recommendation would be that 

7 you still use the definition in RP16, but perhaps 

8 you should use the term lamp luminous efficacy as 

9 the appropriate term. 

10 Then in terms of other measurements, say 

11 for directional lamps, the DOE has already suggested 

12 discarding these and excluding them from this 

13 particular rulemaking, and NEMA definitely agrees 

14 with that. And if that’s the case, then you don’t 

15 need to come up with metrics for those, specific to 

16 those lamp types. 

17 MR. BROOKMAN: Joe. 

18 MR. HALLEY: Yes. We would agree with 

19 that, that there is very limited use of directional 

20 lamps in the HID area, and it certainly -- new 

21 metrics based on zonal lumen, center beam candle 

22 power, would be complex to develop. They have not 

23 been developed yet and don’t think it would be 

24 appropriate to develop them in the HID family. We 

25 recognize there’s other rulemakings going on that 
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1 deal more with directional lamps that might be more 

2 appropriate to develop such metrics, but we wouldn’t 

3 recommend developing them here. 

4 MR. BROOKMAN: Susan, you were speaking on 

5 behalf of NEMA, and Joe as chair of that section, 

6 you’re reinforcing what she said. 

7 MR. HALLEY: Yes, that’s correct. 

8 MR. BROOKMAN: Thank you. Okay. So then 

9 any additional questions you have about this? No? 

10 No additional. Joanna. 

11 MS. MAUER: Joanna Mauer. My 

12 understanding is that lighting designers typically 

13 use mean lumens when choosing lamps and fixtures, 

14 and then if you have a lamp that has poor lumen 

15 maintenance that you’d have to use lamps with higher 

16 wattages or use more fixtures. And so that lumen 

17 maintenance has a direct relationship to energy use 

18 in the field. So I’m wondering if DOE is 

19 considering including or incorporating lumen 

20 maintenance somehow in the standards? 

21 MR. WALKER: For now the plan per the 

22 framework document is that when considering more 

23 efficacious and lower energy-consuming replacements, 

24 and when considering the effects of standards, that 

25 those replacements would be -- make sure that those 
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1 replacements could have the same lumen appreciation, 

2 LLD, mean lumen output. I don’t know if that 

3 answers your question exactly. Maybe a manufacturer 

4 could speak to the relationship between initial 

5 efficacy and mean efficacy. 

6 MR. BROOKMAN: Let’s let Joe try. Joe, go 

7 ahead. 

8 MR. HALLEY: Yes, just want to make a 

9 comment that lighting designers do consider that but 

10 recognize that this standard is for all HID lamps in 

11 all applications. New construction, new design 

12 represents just a small percentage of sales in any 

13 one year. So when you’re considering the 95 percent 

14 or more of installed base that these lamps would go 

15 into, it doesn’t really have any effect because the 

16 user would have to use a lamp that’s appropriate for 

17 that fixture. HID lamps are very difficult -- 

18 systems are very difficult to use other sources. 

19 You’re typically locked into to a certain HID system 

20 once that’s designed and installed. 

21 With regard to new installation, there is 

22 a separate rulemaking going on with the ballast that 

23 will more directly affect those new installations, 

24 as opposed to this rulemaking, which is going to 

25 have a much bigger effect on existing installed 
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1 base, which is really how we should be looking at 

2 this rulemaking. 

3 MS. MAUER: This is Joanna Mauer again. 

4 And in the existing installations, would lumen 

5 maintenance affect the wattage of lamps that you 

6 would install? 

7 MR. HALLEY: No, it only affects how fast 

8 you lose light output, but the wattage is the same, 

9 so there’s no energy impact on that. 

10 MS. MAUER: But if you’re moving towards a 

11 lamp that’s much more efficacious, you might kind of 

12 go a step down in wattage to account for the extra 

13 lumens you’re getting at the same wattage? 

14 MR. HALLEY: If that was possible, but it 

15 often requires a different fixture, a different 

16 ballast to do that, and in some cases -- there may 

17 be a few opportunities where that’s possible, but 

18 it’s limited right now, and most HID systems, the 

19 user really doesn’t have a lot of options. 

20 MR. BROOKMAN: Because of the installed 

21 base. 

22 MR. HALLEY: Well, yeah, they’re just 

23 technically not a lot of options for the user to say 

24 if they’re using a 250 watt metal halide, they 

25 really don’t have the option of putting 175 watt 
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1 metal halide lamp in there. It’s not like 

2 incandescent. The ballast is driving that lamp at a 

3 specific wattage. If you put 175 watt lamp in 

4 there, the ballast will try to drive it at 250 

5 watts, will overdrive it and give you very short 

6 lamp life if they try to do that. And probably 

7 violate UL ratings and other things if you tried to 

8 do that. So it -- it’s much more difficult for 

9 users of existing systems to lower the wattage of 

10 those systems. 

11 MR. BROOKMAN: Susan, you want to add on? 

12 No. Okay. Alex. 

13 MR. BOESENBERG: Alex Boesenberg, NEHI. I 

14 just wanted to point out that we will include some 

15 comments relative to this under item 38 and 39 where 

16 questions are asked about group relamping and 

17 relamping practices as well as maintenance and 

18 repair of HID lamps, ballasts, and fixtures. And 

19 it’s pretty much the same answer. No, we don’t 

20 think anything’s going to change, and no, it’s not 

21 economical often, to repair one of these devices, 

22 you just replace them. 

23 MR. BROOKMAN: Okay. Thank you. Final 

24 comments here? 

25 MR. WALKER: Okay. So we had a break on 
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1 the agenda, but we’re doing pretty well. 

2 MR. BROOKMAN: We’ve only been at this for 

3 about 50 minutes. So keep going. 

4 MR. WALKER: Okay. Keep on going. 

5 Market and Technology Assessment, Screening Analysis 

6 MR. WALKER: Let’s start with the 

7 discussion of the Market and Technology Assessment, 

8 followed by the Screening Analysis. You can see on 

9 this flow chart that decisions and information 

10 thought about in these two steps flow through to the 

11 rest of the interim analysis. 

12 So in the market technology assessment, it 

13 serves two main functions. First would be to 

14 determine equipment classes and the second to 

15 identify technology options that can be used to 

16 increase efficacy. And in the screening analysis, 

17 DOE examines its list of technology options from the 

18 technology assessment, and determines which ones 

19 should and should not be considered in the 

20 engineering analysis. 

21 So we’ll move into the first output of the 

22 market and technology assessment, which is equipment 

23 classes. And equipment class establishes the 

24 category of lamps that are subject to the same 

25 standard, and so in considering potential groupings, 
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1 DOE looks at criteria such as capacity of the 

2 product, type of energy use, and other performance3 related features such as those that affect consumer 

4 utility. 

5 So in the framework document DOE outlined 

6 equipment classes on the basis of CCT and initial 

7 light output, and DOE did not consider separating 

8 equipment classes based on lamp technology because 

9 it determined CCT effectively segregated those 

10 groups, or segregated high pressure sodium from 

11 metal halide or mercury vapor. 

12 If we look at CCT in a little more detail, 

13 HID lamps are available with a variety of CCTs, but 

14 equipment usage indicates that consumers specify 

15 lamps of particular CCTs for certain applications. 

16 For example, the higher CCT of metal halide lamp is 

17 preferred to the lower CCT of a high pressure sodium 

18 lamp in an indoor warehouse application where people 

19 would be moving about. And so this indicates 

20 consumer utility on the factor of CCT. And then 

21 based on a review of catalog information, it does 

22 indicate that initial efficacy varies with CCT. 

23 So based on the difference in efficacy and 

24 the presence of consumer utility, DOE is considering 

25 establishing equipment class on the basis of CCT. 
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1 So the table at the bottom of this slide 

2 shows the three CCT ranges under consideration in 

3 the framework document. The 1900 to 2500 range 

4 would include high pressure sodium lamps, nd the 

5 2501 to 5000, and 5001 to 6999 would include metal 

6 halide and mercury vapor. 

7 So I’ll go over the second class-setting 

8 factor. 

9 MR. BROOKMAN: You want to comment here, 

10 Susan? You can do that. 

11 MS. ANDERSON: Well, just a comment that 

12 we made earlier, that the highest temperature range 

13 should really be capped at 6000 because anything 

14 above that is more that aquarium lighting. 

15 MR. BROOKMAN: Okay. Thank you. 

16 MR. WALKER: Okay. So if we look at the 

17 second class setting factor, which was initial light 

18 output, again, HID lamps are available with a 

19 variety of light outputs, input powers, and while 

20 light output and input power are highly correlated, 

21 DOE decided to use light output as the class setting 

22 factor because it’s the feature more directly valued 

23 by the customer. And again, customer light output 

24 preferences vary by application. For a high ceiling, 

25 the customer would require a higher light output 
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1 lamp than for a lower ceiling or a short pole. 

2 So this indicates the presence of consumer 

3 utility and again, a review of catalog data 

4 indicated lamps of increased light output or 

5 increased input power, were generally more 

6 efficacious. So based on the difference in lumen 

7 efficacy and consumer utility, DOE considered 

8 establishing separate equipment classes based on 

9 initial light output. 

10 So this table outlines the equipment 

11 classes for two of the three CCT ranges under 

12 consideration, and again, moving forward, if 

13 directionality and ballast location are not factors 

14 for this rulemaking because directional lamps and 

15 self-ballasted lamps have been excluded, they would 

16 be removed from tables such as these. And I also 

17 want to point out that the lumen ranges that you see 

18 on the far right-hand side of the table, have the 

19 potential to be collapsed into much fewer categories 

20 as we’ll discuss in the engineering analysis, 

21 because DOE is considering an equation-based 

22 approach that could span more than one of these 

23 ranges. 

24 So this brings us to two items for comment 

25 on equipment classes. In item 16, DOE is generally 
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1 requesting comment on the equipment classes and 

2 additional approaches that could be used that are in 

3 accordance with this requirement, and specifically, 

4 input on the proposal to establish equipment classes 

5 based on light output, rather than rated wattage, as 

6 well as on CCT, and the appropriateness of the 

7 specific lumen output and CCT ranges selected. I 

8 know we’ve heard on the 6999 range, but we could 

9 also look for comment on the other ranges as well. 

10 MR. BROOKMAN: Susan. 

11 MS. ANDERSON: Okay. NEMA disagrees with 

12 setting these standards based on lumen ranges. We 

13 plan to provide an alternate proposal that will be 

14 wattage-based, because of all of our tested 

15 measurement is done at wattage, all the standards 

16 are based on wattage, and quite frankly, lamps are 

17 locked into fixtures based on lamp ballast 

18 compatibility and wattage. 

19 Also, besides color temperature impacting 

20 lumen output, you also have coated versus clear 

21 lamps. Generally, coated lamps have a lower lumen 

22 output than coated lamps (sic), yet there’s a 

23 specific utility for the coated lamps. You have 

24 things like our standby lamps, which are double arc 

25 tube lamps, that have two utilities specific to 
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1 them. One is longer lamp life, and the other is a 

2 safety issue. Those are generally lower lumen 

3 output. You also have protect lamps, where you have 

4 a shroud around the arc tube to provide special -- 

5 additional containment properties, so it’s another 

6 safety issue. In fact, in your opening slide, you 

7 had two protect lamps, shrouded lamps, pictured 

8 there. That generally impacts lumen output. 

9 So, as I said, NEMA will be providing an 

10 alternate proposal that will be wattage-based. 

11 MR. BROOKMAN: Thank you. Additional 

12 comments here? Do you want to talk -- do you want 

13 to give them any initial thoughts about the many 

14 different ranges listed here in this table? 

15 MS. ANDERSON: Well, one thing we found 

16 when looking at these ranges, for a given wattage 

17 you could have a coated or a protect or a standby 

18 lamp in a different category from where the clear 

19 version would be. So that’s why we think you need 

20 to take those things into consideration and do a 

21 wattage-based system, rather than a lumen based 

22 system. 

23 MR. BROOKMAN: Joe, you want to add on 

24 here? 

25 MR. HALLEY: This was in line with what 
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1 Susan was saying, that you could have a single 

2 wattage lamp and have it be in two different 

3 categories simultaneously, depending on some of the 

4 physical construction of the lamp or even depending 

5 on testing variability. There is a wide tolerance 

6 range on these particular lamp types with regard to 

7 lumen output, which could vary by testing facility 

8 or other measurements and we believe this would 

9 create a lot of issues and problems going forward in 

10 trying to determine exactly where a lamp falls in 

11 what lumen category. Which is why we’re going to 

12 suggest that the proper way to differentiate this 

13 product line is by wattage, not by the lumen output. 

14 MR. BROOKMAN: Matthew, did we address 17? 

15 I don’t think we did. 

16 MR. WALKER: Well, Susan got into it a 

17 little bit. I mean this 17 lists some of the other 

18 factors that DOE might consider for equipment 

19 classes, including operating position, open versus 

20 enclosed fixture rating, CRI-based type, the bulb 

21 finish. 

22 MR. BROOKMAN: If NEMA’s going to come 

23 back with a different proposal based on wattage, 

24 this is still relevant, right? Shouldn’t you 

25 comment on 17 as well? Susan. 
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1 MS. ANDERSON: Seventeen does include some 

2 of the things that we’ve talked about, for instance, 

3 the enclosed versus open -- that would be the 

4 protect lamp is suitable for an open fixture, where 

5 an unprotected lamp would typically be used in an 

6 enclosed fixture. We’ve addressed -- well, we 

7 talked about color temperature, not necessarily CRI, 

8 but in some cases, in some technologies, when you 

9 improve CRI, you’re doing it by adding a coating and 

10 that lowers the lumen output, the fact that you’ve 

11 added the coating. 

12 And if you look at metal halide 

13 technology, we changed the chemistry so a lot of 

14 times the 4000, 4200 Kelvin lamps are higher lumen 

15 output than the 3000 Kelvin, yet they both have 

16 utilities, you know, depending on the application. 

17 And coated versus clear, we’ve already talked about 

18 that. 

19 When you talk about base type, lamp 

20 oriented specific, for instance, most of us have 

21 higher performing probe-start metal halide lamps and 

22 they are position-specific, so there’s a specific 

23 lamp for a horizontal, specific lamp for base up, 

24 and specific lamp for base down. And we change the 

25 arc tube configuration based on where -- the 
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1 position the lamp’s going to be operated in. So 

2 that doesn’t necessarily affect lumen output, so 

3 long as they’re used in the correct position. But 

4 then again, if you do have a universal lamp, say, 

5 and that would be most typically in standard probe6 start technology, that’s a lamp that has a higher 

7 performance in a vertical position, base up or base 

8 down, than it does in horizontal, but yet there’s a 

9 utility for those lamps in the fact that if you have 

10 an aiming application, you can’t use a restrictive 

11 position lamp in those applications. 

12 You also have an issue that we use 

13 position-oriented mobile bases on those position14 specific lamps, and they won’t fit in a standard 

15 socket, which would be in many fixtures, and you 

16 also have issues with end users misapplying lamps. 

17 And one of the great things about the universal 

18 burning lamp is that you cannot misapply it. It can 

19 be used in any position. 

20 MR. BROOKMAN: Alex. 

21 MR. BOESENBERG: Alex Boesenberg. One, I 

22 guess, housekeeping comment, relative for that, is 

23 that table 3.1, the initial proposed classes based 

24 on lumen range, as we’ve stated clearly, we are 

25 developing a NEMA proposal for a wattage-based 
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1 approach, but just one housekeeping note relative to 

2 that table is it includes direction, self-ballasted 

3 and things like that, and as has already been 

4 discussed, those are outside of the scope per the 

5 DOE’s initial determination. So, if that table is 

6 kept, and we recommend you don’t keep it, you should 

7 at least pull those things out of it. 

8 MR. BROOKMAN: Okay. Thank you. And I 

9 just wanted to -- so you need to be submitting that 

10 rather quickly, right, since the comment period ends 

April 19th 11 . 

12 MR. WALKER: Twelfth. 

13 MR. BROOKMAN: Twelfth. I tried to give 

14 you an extra week. 

15 MR. BOESENBERG: Yes. It will be as 

16 quickly as possible. 

17 MR. BROOKMAN: Thank you. Trying to slip 

18 that in there. 

19 MR. BOESENBERG: Yes, we understand the 

20 deadline and I’ve got what we think is the final 

21 draft of that table, we’re just not ready to show it 

22 to you today until everyone’s had a chance to see 

23 it. 

24 MR. BROOKMAN: Good. I’m sure the 

25 Department appreciates your getting that done. 
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1 Additional comments? Yes, Daniel. 

2 MR. YOUNG: Yes, Daniel Young. I had a 

3 question for NEMA about the change to a wattage4 based system. My understanding is that the efficacy 

5 is a component of the wattage and the lumen output, 

6 and efficacy being the thing that we’re trying to 

7 regulate, I’m just a little confused about since one 

8 kind of leads to the other, what the difference is. 

9 MR. BROOKMAN: Susan. 

10 MS. ANDERSON: Well, in HID, if a ballast 

11 is designed to operate a 400 watt lamp, it’s 

12 designed to operate a 400 watt lamp. So if you’ve 

13 got a 400 watt lamp, it doesn’t matter whether it’s 

14 35, 36,000 lumens initially, or 42,000 lumens 

15 initially. Remember, most of these are sold into 

16 existing installations, the fixture installation is 

17 the fixture installation. The ballast is the 

18 ballast. If that system uses 450 watts, it’s not 

19 going to matter whether it’s a 36,000 lumen lamp or 

20 a 42,000 lumen lamp. There’s no energy savings to 

21 be realized. 

22 MR. BROOKMAN: Daniel. 

23 MR. YOUNG: Right. I understand that. I 

24 guess my question is, doesn’t that just make one 

25 lamp perhaps not meet the standard and one that does 
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1 meet the standard? 

2 MS. ANDERSON: But the whole purpose of 

3 this rulemaking is to realize energy savings. 

4 MR. YOUNG: Sure, right. 

5 MS. ANDERSON: There’s no energy savings. 

6 MR. YOUNG: So I think maybe -- 

7 MS. ANDERSON: The rulemaking that’s 

8 covering the ballast and the new metal halide 

9 luminaries, that can result in energy savings, and 

10 that can determine then, the lamp that’s used in 

11 that luminaire. Like what’s already in place, 

12 because of ESA 2007, if it’s between 150 and 500 

13 watts, it has to be pulse-start. And pulse-start, 

14 in general, has better performance than probe start. 

15 So that is providing for additional energy 

16 efficiency. This would not. 

17 MR. HALLEY: I think in this particular 

18 case, just a follow-on. For instance, let’s 

19 consider the case with HID lamps, there’s a 400 watt 

20 mercury vapor lamp and a 400 watt metal halide lamp 

21 and they both use the same amount of wattage. If, 

22 for instance, the standard was set such that the 400 

23 watt mercury vapor lamp couldn’t meet it, the user 

24 of that system would have to replace their entire 

25 system, would have to replace their fixture, and the 
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1 theory then is once they have to replace that 

2 fixture, they would replace it with either high 

3 pressure sodium or metal halide at a much lower 

4 wattage for the same light output. And that would 

5 drive energy savings. 

6 This is one case where often it’s a whole 

7 system change that’s required as these older 

8 inefficient systems go away. It does put a much 

9 greater burden, though, on trying to show cost10 effectiveness, since the users in the HID world 

11 typically are going to have to invest somewhat 

12 significantly once these -- if lamp types are 

13 eliminated. But it would then ultimately produce 

14 energy savings as they switch to a different 

15 technology. They may even switch to an LED 

16 technology if it’s an outdoor fixture, but it would 

17 force their hand to do something. 

18 MR. BROOKMAN: Okay. That was good. 

19 Thank you. Yes. 

20 MR. WALKER: So that’s all for equipment 

21 classes. So we’ll move to the second main function 

22 of the market and technology assessment, which is 

23 development of the list of technology options that 

24 can be used to increase lamp efficacy. These 

25 technology options are based on those used in 
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1 commercially available lamps as well as working 

2 prototypes. 

3 So this slide and the next goes over 

4 options identified for each lamp technology. So 

5 starting with mercury vapor lamps. These lamps have 

6 been heavily replaced with metal halide and high 

7 pressure sodium, and DOE is not aware of options for 

8 the mercury vapor lamp itself, but rather use the 

9 transition to other lamp technologies as the pathway 

10 to increased efficacy and reduced energy savings -- 

11 I mean, reduce energy use. 

12 So then moving to high pressure sodium 

13 lamps, catalogs indicate a range of high pressure 

14 sodium efficacy exists, but DOE is not aware in the 

15 framework document of specific options used to 

16 achieve these different efficacies. DOE is also not 

17 considering other lamp technologies to be 

18 substitutes for high pressure sodium, just 

19 contrasted with the mercury vapor situation. 

20 And then finally, we have metal halide 

21 lamps, and the table on this slide describes some of 

22 the options available for increasing the efficacy of 

23 these types of lamps. 

24  First the use of pulse starting rather than 
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1 probe start; 

2  The use of ceramic material in the arc tube as 

3 opposed to quartz; 

4  The use of formed or offset electrode arc tube 

5 design; 

6  The use of novel gases or different gas 

7 compositions within the arc tube; and finally, 

8  New electrode designs or fluoro... materials 

9 could reduce losses in the electrodes, and just 

10 in general, all of these methods could increase 

11 the efficacy of metal halide lamp. 

12 So item 18 welcomes comment on the 

13 technology options identified in this section for 

14 all three lamp technologies, as well as any 

15 additional options that should be taken into 

16 account. 

17 MR. BROOKMAN: Joe. 

18 MR. HALLEY: Just a few comments, perhaps 

19 one on the pulse start versus probe start 

20 technologies. The pulse start lamps aren’t 

21 necessarily more efficient than the probe start 

22 lamps if you’re looking at initial efficiency. Also 

23 an existing user of a probe start system, which are 

24 the older metal halide systems, can’t just switch to 
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1 a pulse start lamp. They would have to put new 

2 ballasting system in that fixture for that to 

3 operate. 

4 MR. WALKER: Right. 

5 MR. HALLEY: So there are limitations to 

6 some of these technology options. 

7 MR. WALKER: I mean that sort of 

8 transition would be accounted for in the engineering 

9 analysis, transition from probe to a pulse start 

10 lamp would also require a purchase of a new pulse 

11 start ballast. 

12 MR. HALLEY: Right, and it’s already 

13 occurring as well, and I know you’re to consider 

14 other rulemakings, but there’s another rulemaking on 

15 fixtures that is basically also already forcing this 

16 transition in new fixture design where it’s the most 

17 cost effective. We do not believe this would be 

18 cost effective for existing users, but the way to do 

19 it is to transition it through the new fixture 

20 design, the fixture rulemaking. But I’m sure in the 

21 analysis you’ll take that into account. 

22 MR. BROOKMAN: Susan. 

23 MS. ANDERSON: Well, I was just going to 

24 say it’s not just the ballast that also has to be 

25 changed. If you were to try to retrofit a fixture, 
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1 you also have to change the socket. You have to 

2 change the wiring in the fixture, because what’s 

3 there for a probe start system is not rated to take 

4 the high voltages required for the pulse start 

5 system. So that’s why, in general, if they could 

6 not buy replacement lamp, they would have to go to 

7 an entirely new luminaire. 

8 MR. BROOKMAN: Okay. 

9 MS. ANDERSON: So for some end users, that 

10 could be a huge financial impact on them. And, you 

11 know, further on in here you talk about incentive 

12 programs. Well, the incentive programs for HID are 

13 generally for outdoor applications, and it’s usually 

14 for eliminating HID and going to LED. It’s not for 

15 installing HID. And, in fact, the fluorescent 

16 programs, incentive programs, are taken, when you 

17 look at a tear out applications, are actually 

18 incentivizing people to go from HID to fluorescent. 

19 So there’s a declining market for HID lamps. 

20 They’re being hit from multiple sides. 

21 MR. BROOKMAN: Okay. John. 

22 MR. GREEN: Yes, John Green. As a fixture 

23 manufacturer, I totally agree with what Susan said 

24 about rewiring and what’s necessary to change over a 

25 fixture. There’s also another item. We have to add 
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1 a starter into this new electrical circuit for a 

2 pulse start lamp, and many fixtures may not be able 

3 to handle the additional components. 

4 MR. BROOKMAN: They won’t fit? 

5 MR. GREEN: They won’t fit. There’s just 

6 no place to put it, correct. 

7 MR. BROOKMAN: Okay. Daniel. 

8 MR. YOUNG: Daniel Young. So I understand 

9 there are some products that are built to work as a 

10 pulse start lamp on a probe start ballast. So just 

11 a note for DOE to make sure to take those into 

12 account. 

13 MR. BROOKMAN: Okay. Keith. 

14 MR. COOK: I think you’re referring to 

15 some of the new ceramic metal halide type lamps, 

16 like the all-start, and yeah, they can be 

17 replacement, but they very -- also very efficacious 

18 too. 

19 MR. BROOKMAN: Joanna. 

20 MS. MAUER: Joanna Mauer. Just on the 

21 ceramic metal halide, I think DOE said in the 

22 framework document that it’s considering ceramic 

23 metal halide as a technology option for lamps up to 

24 400 watts, because that’s maybe what’s on the market 

25 currently. But I think we just encourage DOE to 
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1 consider not just where the technology is being 

2 applied today but where it is kind of evolving, and 

3 where it may be or could be applied, and if it could 

4 be applied to higher wattage lamps if we’re talking 

5 about a standard that won’t go into effect until 

6 2017 or so. 

7 MR. BROOKMAN: Thank you. You can see 

8 several different technology options there. I don’t 

9 think we’ve covered all of these yet. I’m quite 

10 sure we haven’t. So additional comments on -- 

11 additional thoughts on technology options. Daniel. 

12 MR. YOUNG: Daniel Young. Just a quick 

13 comment. Someone noted that a lot of the incentive 

14 programs are pushing people away from HID, but I 

15 just wanted to make the comment that we have rebate 

16 programs that are focused on pulse start metal 

17 halide and ceramic metal halide technologies. 

18 MR. BROOKMAN: Those are the companies you 

19 represent in California? 

20 MR. YOUNG: Yes, California Investor-owned 

21 Utilities. 

22 MR. BROOKMAN: What about the rest of the 

23 country? Do you know about that? 

24 MR. YOUNG: I don’t. 

25 MR. BROOKMAN: Okay. Susan. No? Nothing 
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1 additional? Additional -- yes, Daniel. 

2 MR. YOUNG: One more thing. Daniel Young. 

3 So again, on the previous slide there’s a sentence 

4 that says DOE does not consider other lamp 

5 technologies to be substitutes for HPS. Does that 

6 mean that DOE doesn’t include LEDs as substitutes 

7 for HPS, or is that not something that’s relevant to 

8 this right now? 

9 MR. WALKER: I think the intention of that 

10 statement was looking at the HID world. 

11 MR. YOUNG: Sure. Thank you. 

12 MR. BROOKMAN: Okay. 

13 MR. WALKER: Can I ask a follow-on to 

14 John, on fixtures? So, I was wondering if you could 

15 comment on the extent to which a customer would have 

16 to purchase a new fixture if they’re converting a 

17 mercury vapor installation to high pressure sodium 

18 or metal halide? 

19 MR. GREEN: John Green. I’m not sure I 

20 understand the question. 

21 MR. WALKER: I guess I’m asking if a new 

22 ballast, igniter, lamp could be installed in the 

23 existing enclosure -- 

24 MR. GREEN: For mercury -- 

25 MR. HALLEY: For mercury vapor fixture and 
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1 simply retrofit the guts into a metal halide -- 

2 MR. GREEN: That’s probably even less 

3 likely than if you had a probe start metal halide 

4 current fixture and tried to fit a pulse start into 

5 it. Mercury vapor fixtures would be even less 

6 likely to accommodate pulse start. 

7 MR. BROOKMAN: You’re better off pulling 

8 it all out and putting in something entirely new? 

9 MR. GREEN: Well, the fixture is something 

10 -- you mean the entire fixture, yes, that’s true. 

11 You’d have to probably just consider replacing the 

12 entire fixture. 

13 MR. BROOKMAN: Susan. 

14 MS. ANDERSON: This is going back to my 

15 days when I was a ... fixture rep. But there’s also 

16 something called redirected energy, and you have to 

17 make sure that the arc tube is correctly positioned 

18 within the optical system of the fixture, and if 

19 it’s not then the reflector can redirect energy back 

20 into the arc tube and cause the arc tube to self21 destruct. So if you try to retrofit, there’s a lot 

22 of things you have to take into consideration beyond 

23 just whether you have the right operating system or 

24 not. 

25 MR. BROOKMAN: Okay. You okay? Get to 
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1 the microphone, please, Merry. Say your name for 

2 the record. 

3 MS. WALKER: Merry Walker. As a follow-up 

4 to John’s comment about replacing mercury vapor 

5 lamps with -- 

6 MR. BROOKMAN: Merry, get close. 

7 MS. WALKER: -- pulse start metal halide, 

8 were there any issues with replacing mercury vapor 

9 with a probe start metal halide, or just with the 

10 pulse start? 

11 MR. BROOKMAN: John. 

12 MR. GREEN: Yeah, the probe start metal 

13 halide would probably be a more likely fit. It’s so 

14 dependent on how the fixture was originally 

15 constructed. But there are differences in light 

16 center lengths and things that make the optics work 

17 correctly, so it’s not just an electrical issue, 

18 it’s a matter of are you distributing light 

19 correctly as well. And will the optical system work 

20 with the other source. So there’s a lot of 

21 variables and that’s why I hesitate to give you a 

22 pat answer. But the probe start would be a more 

23 likely fit, at least from the electrical component 

24 viewpoint. I don’t think I can say any more than 

25 that at this point. 
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1 MR. HALLEY: And maybe just -- industry 

2 experience hasn’t been that people retrofit mercury 

3 vapor fixtures to the other technologies. We just 

4 don’t see it done. What we see done is brand new 

5 fixture. They might use the same pole, but they put 

6 a brand new fixture on that pole, that’s either 

7 designed specifically for metal halide or high 

8 pressure sodium. 

9 MR. BROOKMAN: John, follow on. Just for 

10 the record, thank you, Joe, and now back to John. 

11 MR. GREEN: John Green again. I think 

12 that’s a good point Joe made, because most of the 

13 mercury vapor fixtures that are out there are 

14 probably very old. Mercury vapor lasts a long time, 

15 so if someone’s going to the expense of trying to 

16 retrofit an electrical system, they’re probably 

17 going to just go ahead and do the entire fixture 

18 change out. 

19 MR. BROOKMAN: I see. Okay. 

20 MS. WALKER: Thank you. 

21 MR. BROOKMAN: Susan. 

22 MS. ANDERSON: I hope everyone remembers 

23 that because of prior legislation, you can’t buy 

24 replacement mercury vapor ballasts, so we already 

25 have things in place to get rid of mercury. 
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1 MR. BROOKMAN: Okay. Great. Thank you. 

2 Yes, one more slide. 

3 MR. WALKER: So, last slide for me, 

4 screening analysis. DOE reviews its technology 

5 option list and decides which of those options 

6 should become design options for consideration in 

7 the engineering. So DOE uses criteria like 

8 technological feasibility, the practicability to 

9 manufacture, install and service that particular 

10 design, as well as any adverse effects on product 

11 utility or availability, or health and safety. 

12 So in item 19, DOE is welcoming comment on 

13 how these four criteria could be applied to the 

14 technology options that we discussed in the previous 

15 slides. 

16 MR. BROOKMAN: Joe. 

17 MR. HALLEY: NEMA agrees that DOE should 

18 focus on the maximum practical design. But in the 

19 HID world, especially, there’s a lot of limitations 

20 on what represents a practical retrofit. As you 

21 work through what’s practical, we agree on assessing 

22 it this way. 

23 MR. BROOKMAN: You wish to change the 

24 wording here and emphasize practical. 

25 MR. HALLEY: Number two does say practical 
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1 to manufacturing, so -- 

2 MR. WALKER: I’m with you. 

3 MR. BROOKMAN: I think we’ve got that. 

4 Okay. Additional comments? Yes, Susan. 

5 MS. ANDERSON: Well, our fear is, because 

6 this had happened in prior rulemakings, is looking 

7 at prototype lamps that have never been made on 

8 regular production equipment or ever installed in 

9 the field to get any kind of service data on them, 

10 you know, let’s stick to something we know works. 

11 MR. BROOKMAN: That’s a useful comment, 

12 thank you. Other comments related to 19 and these 

13 criteria, these aspects of screening? Nothing 

14 additional. 

15 Let’s take a break. We really covered a 

16 lot of ground very efficiently, very effectively, so 

17 my thanks to everyone in the room. It’s now 10:20, 

18 we’re going to take a break for 15 minutes, which 

19 means we’ll resume at 10:35. Thanks to those 

20 joining us via the web, we want you to continue to 

21 stay with us. If you’re going to -- please -- 

22 (Whereupon, at 10:20 a.m., the meeting was 

23 recessed for a 15 minute period.) 

24 MR. BROOKMAN: For those of you joining us 

25 via the web, I understand that here in the room that 
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1 we don’t have the capacity, at this point, to unmute 

2 the lines that are incoming, although we’re working 

3 on it, trying to reverse that. So those of you that 

4 are joining us via the web, if you have questions or 

5 comments, please type them in and we’ll try to 

6 insert them in the conversation. In the meantime, 

7 we’ve got the tech guys coming up here to see if we 

8 can solve that issue. 

9 MS. deBUTTS: I mean that was not an issue 

10 so far in our conversation, people were able to 

11 submit the comments, but we just want to make sure 

12 that we can unmute the participants. 

13 MR. BROOKMAN: Doing our best to work on 

14 that. So we really made good progress already 

15 today, and now we’re going to hear from Merry 

16 Walker, engineering analysis. 

17 Engineering Analysis 

18 MS. WALKER: My name’s Merry Walker, and 

19 I’m also from Navigant. I’ll be discussing the 

20 engineering and the product price determination 

21 analysis. So as you can see, the outputs of the 

22 engineering and the product price determination 

23 analyses uses inputs for the life cycle cost and 

24 national impact analyses. 

25 This slide depicts the engineering 

26 analysis methodology. So first DOE chooses 

27 representative equipment classes from the full 
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1 equipment classes that were discussed earlier. Then 

2 DOE selects the baseline models from the 

3 representative equipment classes and we’ll use the 

4 base line models to assess changes due to 

5 establishing energy conservation standards. 

6 Then DOE will identify higher efficacy 

7 substitutes from a database of commercially 

8 available lamps and develop efficacy levels that 

9 range from the baseline model baselines to the 

10 maximum technologically feasible level. 

11 Finally, DOE will scale the results from 

12 the representative equipment classes to those that 

13 are not directly analyzed. 

14 The representative equipment classes are 

15 those that have high volumes or unique performance 

16 characteristics. DOE concentrates its analytical 

17 effort on these specific equipment classes. Within 

18 each representative equipment class, DOE then 

19 selects the lamp models that are the most common and 

20 least efficacious to be the baseline models. When 

21 there’s a large portion of the market that has 

22 already adopted a more efficacious lamp, then DOE 

23 will consider analyzing two baseline models. 

24 This table here shows the nine 

25 representative equipment classes and their 
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1 associated 13 baseline models that DOE has 

2 preliminarily chosen its analysis. DOE chose these 

3 lamps by analyzing commercially available lamps and 

4 found that the listed models are the least 

5 efficacious and most common. For the representative 

6 equipment classes below, you see that there are two 

7 baseline models selected. The mercury vapor lamps 

8 are the least efficacious -- are typically the least 

9 efficacious within their respective representative 

10 equipment class, but a large portion of the market 

11 has already adopted metal halide lamps. DOE is 

12 analyzing both as baseline models because it is 

13 important for DOE to be able to correctly assess the 

14 life cycle impacts and efficacy level against what 

15 is currently used in the market today. 

16 So with that, I’d like to open the floor 

17 for comments on the representative equipment classes 

18 as well as the baseline models selected. 

19 MR. BROOKMAN: Let’s go back to the 

20 previous table. Susan. 

21 MS. ANDERSON: One kind of a general 

22 comment that we had is that the scaling doesn’t 

23 typically work with HID lamps. They’re non-linear. 

24 Whereas scaling worked for halogen car lamps. We 

25 don’t see it working for HID lamps. 
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1 And the other thing, we are going to 

2 present an alternate proposal that will be wattage 

3 based and in that we will establish proposed 

4 baseline lamps as well. And then one other thing -- 

5 and one of the lumen ranges here, this is in the 

6 metal halide/mercury grouping, in the 8001 to 12000 

7 lumen range, one of your proposed baseline lamps is 

8 a 150 watt probe start metal halide. As far as I 

9 know, all 150 watt metal halide lamps are pulse 

10 start. Is there an exception -- 

11 MR. BROOKMAN: Tom. 

12 MR. HARDING: Tom Harding. There is one. 

13 There’s a 150 watt probe start that’s actually works 

14 on the 175 watt ballast as a replacement lamp -- and 

15 saves -- 

16 MS. ANDERSON: It’s a retrofit? 

17 MR. HARDING: It’s a retrofit lamp for a 

18 175 watt probe start ballast system. 

19 MR. BROOKMAN: So what does -- I didn’t 

20 understand what that does to the categories that are 

21 here. 

22 MS. ANDERSON: I was just pointing out 

23 that except for this one exception, then, there’s no 

24 150 watt probe start metal halide which was chosen 

25 as a baseline lamp. 
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1 MR. BROOKMAN: Okay. 

2 MS. ANDERSON: All the medium screw-base 

3 lamps, when those were developed, those were pulse 

4 start. 

5 MR. BROOKMAN: NEMA’s going to come 

6 forward with an alternate proposal, based on 

7 wattage. Okay. Additional comments on these -- 

8 this table? None. Okay. 

9 MS. WALKER: Okay. After establishing ht 

10 baseline models, DOE selects higher efficacy 

11 substitutes by collecting and analyzing commercially 

12 available lamps. DOE recognizes the lamps lumen 

13 package and other performance characteristics, such 

14 as CRI and CCT are important design criteria for 

15 customers and chooses more efficacious lamp 

16 substitutes with performances similar to that of the 

17 baseline lamp. In order to maintain lumen output, 

18 DOE may select a reduced wattage, high efficacy lamp 

19 replacement or respace and reduce the number of 

20 fixtures to equalize lumen output. 

21 Because lamps and ballasts operate 

22 together in practice, DOE is basing its energy 

23 consumption analysis on a lamp and ballast system. 

24 When the ballast is also taken into consideration, 

25 it will more accurately characterize the cost 
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1 effectiveness of an efficacy level. 

2 We’d like to open the floor for comments 

3 on high efficacy lamp substitutes as well as the 

4 availability of reduced wattage lamps, and the 

5 practicality of respacing and reducing fixtures as 

6 well as whether barriers exist in developing new 

7 lamps that would provide reduced wattage 

8 alternatives in today’s lamps. 

9 MR. BROOKMAN: Susan. 

10 MS. ANDERSON: Yes. A lot -- we’ve 

11 already made a lot of comments that really apply to 

12 this and do please remember that when you’re looking 

13 at a retrofit like if someone were to go from probe 

14 start to pulse start, remember the issues with that, 

15 and as John said, you have to have add a starter 

16 into the fixture and there really isn’t -- he 

17 doesn’t expect there to be room for that, so it’s 

18 really not practical. You’re talking about going to 

19 a whole new fixture. So you should take in to when 

20 you do your cost analysis, it should be based on a 

21 new luminaire. Not a retrofit situation. 

22 The other thing, I think John is going to 

23 comment. 

24 MR. BROOKMAN: John. 

25 MR. GREEN: Yes, John Green. As far as 
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1 the idea of changing the spacing of fixtures, maybe 

2 bringing them closer together or further apart, 

3 based on a new lamp, is really impractical. There 

4 are a few wiring systems out there that allow 

5 fixtures to be moved around. They’re called 

6 flexible wiring systems or modular wiring systems, 

7 that are specifically put in to make a space 

8 flexible in the way it’s utilized. However, the 

9 vast majority of installations are done with a fixed 

10 conduit system, with fixed terminations where the 

11 luminaries are located, and to move luminaries would 

12 be a very expensive and time consuming proposition, 

13 because conduits would have to be moved, hanging 

14 systems redone, and in a lot of cases, a building 

15 layout drives the way the fixtures are located 

16 anyway. The aisle-ways in warehouses, or grocery 

17 stores or wherever this fixture is being used, the 

18 location of the fixture is important because of the 

19 layout of the application. So the fixture cost may 

20 pale in comparison to trying to move electrical 

21 systems and repositioning fixtures. So it’s a very 

22 impractical assumption to make. 

23 MR. BROOKMAN: Okay. Susan. 

24 MS. ANDERSON: Kind of an additional 

25 comment along that line. A lot of times, it’s the 
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1 location of other systems -- duct work, sprinkler 

2 heads and that sort of thing that really have the 

3 final determination of where the lighting fixture 

4 can be located. And in the case of sprinkler heads 

5 for safety and insurance reasons, that takes 

6 precedence over the ideal location for the 

7 luminaire. So it’s -- chances are you’re not going 

8 to see any gain from assuming something like that. 

9 And it seemed to me as I read this, that the DOE had 

10 come to the same conclusion there. 

11 MR. BROOKMAN: Okay. Tom, you want to 

12 comment? No. Okay. Susan, please. 

13 MS. ANDERSON: One other thing. We did 

14 want to note that when you look at mercury vapor 

15 being replaced by metal halide or high pressure 

16 sodium, it’s really application driven. So indoors 

17 you tend to see mercury vapor replaced with metal 

18 halide or fluorescent, and outdoors, you tend to see 

19 mercury vapor replaced with high pressure sodium. 

20 That’s been the traditional replacement, but in more 

21 recent years, because of a lot of the incentive 

22 programs that are out there, it’s been going to LED, 

23 particularly in the last three years, with the 

24 stimulus funding that many states and communities 

25 have received. 
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1 MR. BROOKMAN: Okay. Thank you. Yes, 

2 Mimi. 

3 MS. GUPTA: Mimi Gupta, Navigant. So 

4 earlier we talked about a lot of the limitations 

5 associated with using reduced wattage lamps and how 

6 that might necessitate a ballast change. And then 

7 we talked about how changing technology would 

8 necessitate a ballast change also. Does the 

9 industry see any opportunities for energy savings 

10 that would not necessitate ballast change? 

11 MS. ANDERSON: We do have some lamps, in 

12 our case we call them super cybrus, that’s our 

13 traditional name, where we have a 360 watt metal 

14 halide that replaces a 400 watt metal halide. But 

15 it operates on the same ballast, and your savings is 

16 that 40 watts difference in the lamp. Those are 

17 already in the market place. 

18 MS. GUPTA: Right. And so I think we’ve 

19 seen those on the market, but there aren’t reduced 

20 wattage options for every wattage out there. Is 

21 there that capability of designing those? 

22 MR. BROOKMAN: Keith. 

23 MR. COOK: Keith Cook. In all honesty, 

24 it’s highly unlikely, and the reason is there’s such 

25 an emphasis on LED systems now as a replacement for 
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1 a large part of this whole market, that the 

2 resources are being spent in that area, as opposed 

3 to developing new technologies and new replacement 

4 lamps in the HID market. The long term bet is 

5 really on the LEDs, and so as far as developing new 

6 models, highly unlikely. 

7 MR. BROOKMAN: Joe. 

8 MR. HALLEY: I would agree with that. 

9 Pretty much what is on the market today, you have to 

10 assume that that is what you have to work with. 

11 MS. WALKER: Is there a certain tolerance 

12 in terms of wattage that a ballast can tolerate, 

13 like, you know, you talked about going from 400 to 

14 360 as you can operate that on the same ballast. 

15 But maybe going from 250 to 175 is out of that 

16 capability, it’s too big of a difference. Is there 

17 a percentage change that -- 

18 MR. BROOKMAN: Susan. 

19 MS. ANDERSON: Well, yeah, that’s not 

20 within the ballast tolerance range. And there you’d 

21 have such a difference in light level, would not be 

22 -- you wouldn’t be providing equivalent light. 

23 MR. BROOKMAN: Keith. 

24 MR. COOK: Yeah, essentially what we have 

25 to do when we design a new lamp is to actually make 
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1 sure that there are ballasts available that will 

2 drive it. So it’s almost an impedance match, and so 

3 we have to look at that and to make sure that the 

4 replacement that we’re putting in will work in that 

5 application. 

6 MR. BROOKMAN: John. 

7 MR. GREEN: Susan noted about the -- I 

8 think we’ve all noted about the technology and where 

9 resources are being spent. They were commenting on 

10 the lamp manufacturers’ viewpoint, but the same 

11 thing applies to fixture manufacturers. Very little 

12 is being placed now on sources other than LED, so 

13 we’d rather place our development funding and 

14 resources into a technology we feel is going to be 

15 more appropriate in the next five years. So just 

16 wanted to reinforce that. 

17 MR. BROOKMAN: Thank you. Okay. 

18 MS. WALKER: Okay. After identifying more 

19 efficacious lamp substitutes, DOE develops a set of 

20 candidate standard levels, also known as CSLs, that 

21 are considered in the interim analysis. The CSLs 

22 span the range of lamp efficacies from the baseline 

23 to the maximum technologically feasible level, and 

24 considers other factors such as design options. 

25 The equipment class structure that was 
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1 previously discussed reflects a bin efficacy level 

2 approach in which DOE would establish one lamp 

3 efficacy for each lumen range. Although this may 

4 simplify standards, it would subject all the lamps 

5 within a lumen range to the same level. Because 

6 high efficacy lamps typically have higher lumen 

7 output, it could potentially shift the market 

8 towards high lumen output lamps that also have 

9 higher input power within each bin, thereby negating 

10 energy savings. Because of this, DOE is considering 

11 an equation-based approach in which lamp efficacy 

12 would be defined as a function of lumen output, thus 

13 eliminating the need for equipment classes to be set 

14 on lumen output. 

15 So we had some comments earlier about 

16 using wattage instead of lumen output, but we would 

17 also like to receive comment on the use of an 

18 equation-based approach rather than a bin approach, 

19 and also whether highly efficacious lighting systems 

20 could be eliminated given a particular lamp efficacy 

21 requirement. 

22 MR. BROOKMAN: Yes. 

23 MR. HALLEY: This is Joe. We, for this 

24 particular product area, we don’t believe an 

25 equation-based approach is practical -- is a 
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1 practical way to apply an analysis. We believe, in 

2 this case, you have to look at, since this is mostly 

3 going to affect new -- mostly going to affect 

4 existing systems, you have to look at the existing 

5 system installed, for instance, a 200 watt -- or 250 

6 watt, say, metal halide system -- and determine is 

7 there any practical replacement for that system. 

8 They’re going to have very limited ability to just 

9 change a lamp, which means they’d have to change a 

10 lamp and a ballast. And if they have to change a 

11 lamp and a ballast, the question is, will the 

12 starter, for instance, if you’re going to pulse 

13 start, the pulse start system fit. In most cases it 

14 wouldn’t, and so you would have to assume you have a 

15 fixture change. If you’re going to a fixture 

16 change, you have to determine whether or not it’s 

17 cost-effective to change out an entire system that’s 

18 already fairly efficient to one that’s perhaps 

19 slightly more efficient. And given that each system 

20 represents its own discrete problems, and there 

21 might be different options, whether you’re talking 

22 175 or 250 or 400, we believe you have to look at 

23 each of these in a binned approach. You have to 

24 look at each wattage bin, which is what we’ll be 

25 suggesting, creating wattage bins. And you have to 
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1 analyze each wattage bin to look at what options 

2 there are for the existing system, because this is 

3 going to have the biggest impact on existing 

4 systems. 

5 We believe new systems are already being 

6 converted by two other rulemakings, one that 

7 essentially eliminated mercury vapor ballasts, and 

8 the other one that’s forcing fixtures to go to -- 

9 brand new fixtures to go to pulse start systems. 

10 That has taken care of the new systems going forward 

11 which represent the future systems. But in terms of 

12 the existing system, this rulemaking is going to 

13 have the biggest impact on existing systems, 

14 existing users, and you have to really look at what 

15 they have and what their real options are, and 

16 whether or not it’s cost-effective to force them, in 

17 most cases, to go into an entire new fixture, 

18 including electrical labor rates associated with 

19 putting in a new fixture. 

20 So, again, we don’t think -- an equation 

21 only works in theory. It’s a good theoretical 

22 concept if we’re in college, maybe that’s a good 

23 approach. But in the real world, we have to look at 

24 specific systems and what these specific equipment 

25 options are for that application. 
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1 MR. BROOKMAN: Keith. 

2 MR. COOK: Keith Cook. For item 25, we’re 

3 not against evaluating highly efficacious light 

4 systems, but we do want to proceed very, very 

5 cautiously here. And the reason we’re saying that 

6 is, we know for a fact right now that an unprotected 

7 lamp is going to be more efficacious than one that 

8 is protected or one that’s coated. And yet there 

9 are many applications where we absolutely have no 

10 choice but to put in a protected lamp. Like 

11 gymnasiums or grocery stores or those kind of 

12 environments. And so if we jump to the conclusion 

13 that we have to go to this because it’s the most 

14 efficacious light system, we end up with no solution 

15 to the market, I’ll tell you right now. So, you 

16 know, we agree, let’s look at it, but we can’t rule 

17 out that a lot of these lamps that we know for a 

18 fact are less efficacious. 

19 MR. BROOKMAN: Okay. Susan. 

20 MS. ANDERSON: Well, there’s another thing 

21 to think about in terms of the protect versus the 

22 non-protected lamp too, and that the protect lamp 

23 can go in an open luminaire, and in many cases those 

24 are more efficient systems and they stay -- the 

25 whole system stays cleaner longer, it has better 
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1 lumen maintenance over its life because of the 

2 design of the luminaire not having that lens in 

3 place. There’s one manufacturer where it’s always 

4 open around the top of the optical system, so 

5 there’s literally a chimney effect so that dirt 

6 rising up into the fixture, the air movement, the 

7 hot air rising from the heat generated by the lamp, 

8 lifts it up and out of the fixture, so the inside of 

9 the luminaire stays cleaner. So there are definite 

10 advantages to these open fixtures as opposed to 

11 enclosed. 

12 MR. BROOKMAN: Daniel. 

13 MR. YOUNG: Daniel Young. I have a 

14 question for NEMA. Is your proposal then looking at 

15 specific rated wattages, or are there still going to 

16 be multiple rated wattages per bin? So instead of 

17 DOE’s approach, which is to look at bins that might 

18 include multiple rated wattages, -- 

19 MR. BROOKMAN: Daniel, get close to that 

20 microphone, please. 

21 MR. YOUNG: Sorry. As opposed to DOE’s 

22 proposal which could potentially include multiple 

23 rated wattages within a single bin, is NEMA’s 

24 approach to split completely by rated wattage and to 

25 look at -- so for this rated wattage, this energy 
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1 would be set here, and so forth? 

2 MS. ANDERSON: Our technical folks are 

3 actually in discussion on that now. We started out 

4 with a proposal that came from our company, and it 

5 was strictly wattage based. I’m sure there’ll be 

6 some binning, but not in terms of today’s existing 

7 wattages. So like a -- it’s possible, I don’t know 

8 what they’re going to come up with -- like the 360 

9 watt energy saving lamp would end up in the same bin 

10 as the 400. Because they operate on the same 

11 ballast. 

12 MR. BROOKMAN: Did we cover it? Mimi. 

13 MS. GUPTA: I just want to ask one 

14 question, following on a comment that Joe made 

15 earlier on -- in the meeting, relating to the 

16 variability of lumen output for a given wattage 

17 lamp. This is an issue that’s kind of come up in a 

18 lot of the previous lighting rulemakings, having to 

19 do with, you know, say we find a commercially 

20 available lamp on the market that saves energy, and 

21 DOE wants to target as an energy saving option. 

22 What is the efficacy standard that represents that 

23 lamp? And how does variability fit into that? So I 

24 would just request industry to submit whatever data 

25 they can as early as possible, regarding the 
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1 variability in terms of efficacy of a given model 

2 and how that should be incorporated into the 

3 analysis. 

4 MR. BROOKMAN: Okay. 

5 MS. WALKER: Okay. Well, actually I have 

6 a question, and this is related to the bin versus 

7 the equation-based approach. So the same concern 

8 that when there’s one efficacy level set for a 

9 particular bin, it might shift the market towards 

10 one end of the bin because it’s easier to meet a 

11 standard because the lamps are more efficacious at 

12 one level. Would you anticipate the same thing 

13 happening with the wattage bin approach, shifting it 

14 towards higher wattage lamps, perhaps? 

15 MR. BROOKMAN: Joe. 

16 MR. HALLEY: No. We wouldn’t expect that 

17 to happen because the ballasts are rated to drive a 

18 specific lamp design, a specific lamp wattage, so 

19 you just can’t put in a 400 watt lamp in a 250 watt, 

20 say, system, because it’s more efficient. In fact, 

21 the reg grouped 250s and 400s together in the same 

22 bin, and you set the reg based on the 400, it would 

23 eliminate a 250 watt lamp, and there would literally 

24 be no product that could go into that system if you 

25 did that for that user, because he couldn’t use it. 
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1 He’d have to go to a brand new fixture in that case. 

2 So, bin hopping in this particular case, that might 

3 be more of an argument for perhaps a source where 

4 you can go up and down quite easily with wattages, 

5 perhaps more of an incandescent type of source, 

6 where you can move it anywhere. Where, with metal 

7 halide, they’re discretely designed. The wattages 

8 are discrete. The ballasts are discrete. There 

9 really isn’t any opportunity for the user to bin hop 

10 up or down. So we wouldn’t expect that to be a 

11 concern with this particular product line. 

12 MR. BROOKMAN: Joanna. 

13 MS. MAUER: Joanna Mauer. I think we’d 

14 encourage DOE to consider an equation-based approach 

15 if DOE can develop an equation that represents the 

16 relationship between lumen output and efficacy, I 

17 think it would just better represent that 

18 relationship between efficacy and lumen output. 

19 MS. WALKER: Okay. The final step to the 

20 engineering analysis is to scale the efficacy levels 

21 that are established for the representative 

22 equipment classes to those that are not directly 

23 analyzed. DOE intends on using scaling factors that 

24 are observed in catalog data or by extrapolating 

25 lumen output using regression equations. 
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1 We’d like to open the floor for comments 

2 on the scaling approach. 

3 MR. BROOKMAN: Susan? 

4 MS. ANDERSON: Well, as we’ve already 

5 mentioned, HID lamps are non-linear in response, so 

6 we really don’t see how you can go down that path. 

7 You also have the issue, once again, of coated 

8 versus clear, protect versus unprotect, standby 

9 versus not standby, CCT, CRI -- 

10 MR. HALLEY: Orientation. 

11 MS. ANDERSON: -- orientation. 

12 MR. HALLEY: Orientation is a big one. 

13 MS. ANDERSON: We have all those issues. 

14 MR. BROOKMAN: Mimi. 

15 MS. GUPTA: So, I guess I think the 

16 question here, this is Mimi Gupta, is for those 

17 other issues that you’re talking about, can none of 

18 them be characterized by a percentage reduction in 

19 efficacy if we’re talking about coated versus 

20 uncoated or maybe can orientation be represented in 

21 that way? 

22 MS. ANDERSON: Well, orientation is 

23 already pretty clearly represented, because if you 

24 look in our catalogues, for -- say, for instance, if 

25 it’s the universal operating lamp, we give you 
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1 vertical lumens versus horizontal lumens. And in 

2 lamps where we have position-specific oriented 

3 lamps, you can compare those ratings base up, to 

4 base down, to horizontal. That’s all published 

5 information. And as is coated versus clear. And 

6 when you get into the metal halide family, in 

7 particular, you can see the different chemistries 

8 and the impact on the lumens, 3000 Kelvin versus 

9 4000 Kelvin. 

10 MS. GUPTA: So when you say, you know, you 

11 don’t think scaling is appropriate for HID lamps, 

12 you’re more talking about scaling across wattages? 

13 MS. ANDERSON: Yes. 

14 MS. GUPTA: Okay. 

15 MR. BROOKMAN: Okay. 

16 MS. WALKER: In considering standards, DOE 

17 will not set a level -- oh. 

18 MR. YOUNG: Sorry, Daniel Young. A 

19 question about the scaling. So you’ve mentioned 

20 that it’s not a linear relationship. Is there no 

21 relationship, or can you isolate certain factors 

22 like CCT or coating and develop some kind of 

23 relationship. 

24 MR. BROOKMAN: Tom. 

25 MR. HARDING: Tom Harding. There are 
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1 relationships. There was a general statement made 

2 that as you go up in wattage, you generally get more 

3 efficacious. The problem is trying to do one size 

4 fits all. There are so many jumps: clear/coated, 

5 universal, ... co... temperatures. There are different 

6 chemical technologies. I mean from a standpoint of 

7 materials, metal halide is one of the most 

8 complicated ones. Most light sources have one or 

9 two elements. Metal halide can have ten. So 

10 they’re very complex, and they all do different 

11 things. And so it’s very hard to find an equation 

12 that covers everything. But within very narrow 

13 parameters you can make short jumps in equations. 

14 But then you can’t jump, as Susan said, if you want 

15 to make a more efficacious fixture, you might take a 

16 lens off and use a less efficacious lamp, say a 

17 protected lamp, makes a better system, doesn’t make 

18 it that more efficacious lamp. So just so many 

19 jumps. But in general there are rules that -- not 

20 rules, there are observations as you go up in 

21 wattage you generally get more efficacious. 

22 But I can sit here and give you all kinds 

23 of exceptions. I can tell you now a 400 watt lamp 

24 that has higher efficacy than 1000 watt lamp. 

25 Changing chemistry and materials. There’s just so 
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1 much of that in these metal halide systems. 

2 MS. WALKER: Okay. So, again, in 

3 considering standards, DOE will not set a level that 

4 can only be met by a single proprietary design. 

5 Because of this, DOE is seeking feedback on the 

6 existence of proprietary designs. We’d like to open 

7 the floor for comment on this issue, as well as any 

8 other issue related to the engineering analysis. 

9 MR. BROOKMAN: Alex. 

10 MR. BOESENBERG: Given the individual 

11 nature of the comment, NEMA will not be able to 

12 provide comment on this subject. So my comment is I 

13 have no comment. 

14 MR. BROOKMAN: Joe. 

15 MR. HALLEY: There may be individual 

16 manufacturer designs, but as you’re going through 

17 the manufacturer interview process, you may ask them 

18 about unique designs that companies may have. 

19 MR. BROOKMAN: So you would just -- 

20 MR. HALLEY: They do exist. 

21 MR. BROOKMAN: That’s what I wondered. 

22 You anticipate that there could be proprietary 

23 designs that the Department of Energy might need to 

24 consider. 

25 MS. ANDERSON: Yes, patent protected. 
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1 MR. BROOKMAN: And so they will need to 

2 seek that out. 

3 MR. HALLEY: Yes. 

4 MR. BROOKMAN: In a protected sort of a 

5 way. Okay. 

6 MS. WALKER: Thank you. For this 

7 rulemaking, DOE plans on estimating end user price 

8 directly, rather than using a bill of materials and 

9 marking that up to generate the manufacturer’s 

10 selling prices, also known as MSPs. This is because 

11 it’s not practical to reverse engineer an HID lamp 

12 to derive the manufacturer production cost of the 

13 lamp. They are not easily disassembled and full gas 

14 composition and partial pressures are difficult to 

15 assess. Therefore, DOE is considering collecting 

16 manufacturers’ suggested price lists, also known as 

17 blue book values, and applying discounts based on 

18 distribution channels through which the lamp is 

19 purchased. DOE will gather price information from 

20 state procurement contracts, large distributors, and 

21 other publicly available end user prices to 

22 determine discounts. 

23 We would like to open the floor for 

24 comment on end user price approach for calculating 

25 the cost of this efficacy relationship for HID 
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1 lamps. In particular, DOE seeks comment on typical 

2 distribution channels for HID lamps, as well as the 

3 allocation of market share between these channels. 

4 MR. BROOKMAN: Alex. 

5 MR. BOESENBERG: Alex Boesenberg. That’s 

6 another topic we refer to the individual 

7 manufacturer interviews, given the individual nature 

8 of such arrangements and cost structures. 

9 MR. BROOKMAN: You can’t characterize 

10 typical distribution channels as we have in previous 

11 rulemakings? 

12 MS. ANDERSON: Distribution channels, yes. 

13 Pricing, though, we’re not allowed to discuss, due 

14 to antitrust rules. 

15 MR. BROOKMAN: Okay. 

16 MS. ANDERSON: And we do -- in our written 

17 comments we will have some modifications to the 

18 distribution channel. 

19 MR. BROOKMAN: Okay. 

20 MS. WALKER: Okay. Thank you. Should we 

21 continue? 

22 MR. BROOKMAN: Yes. 

23 MS. WALKER: I’ll pass on to Mike Myer. 

24 MR. BROOKMAN: Now, energy use analysis, 

25 Michael Myer. How are we doing with the folks on 
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1 line, Emily. 

2 EMILY: We’re going to patch them through 

3 so they can comment. 

4 MR. BROOKMAN: Okay. 

5 Energy Use and Markup Analysis 

6 MR. MYER: Thank you. My name is Michael 

7 Myer. 

8 MR. BROOKMAN: I guess we then need to 

9 remind everyone who’s joining us on line to mute 

10 their telephones if they’re not going to speak and 

11 unmute them if you want to speak, and we’ll be 

12 recognizing you as best we can when our webmaster 

13 over here sees that you want to contribute to the 

14 conversation. Okay, Michael. 

15 MR. MYER: That was just -- 

16 (Problems with sound.) 

17 MR. BROOKMAN: So we’re having technical 

18 difficulty and we’re going to try and resolve this 

19 very quickly, so hang in there those here via the 

20 web. 

21 MR. MYER: I’m going to try it again. I 

22 think they’ve corrected it in the room while we’re 

23 waiting, so I’ll wait one more second. This works, 

24 I don’t hear any echo, so I will continue on. Do 

25 we need to wait for the court reporter? Okay. 
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1 Thank you. 

2 My name is Michael Myer, and I’ll be 

3 discussing both Energy Use and Markup Analysis. 

4 These are both inputs that are factored into the 

5 life cycle cost and payback analysis, which then 

6 also get factored into other analysis later on. 

7 Energy analysis is pretty straightforward. 

8 We’re trying to determine the energy use data for 

9 HID systems. Obviously, as we discussed, ballasts 

10 are important role here, mainly for the power 

11 input, so they’ll be used. We’ll take the power 

12 data from the engineering analysis, just a median -

13 - a typical wattage input that’ll be generated in 

14 the engineering analysis. Ultimately, we want to 

15 get a sense of where lamps are used, in what type 

16 of spaces, and roughly how long they’re operated in 

17 those spaces. We will look at the most recent 2010 

18 US lighting market characterization, the commercial 

19 building energy consumption survey, also known as 

20 CBECS, and also the manufacturing energy 

21 consumption survey. 

22 We’ll take all that data and aggregate it 

23 and get a sense of what the typical operating hours 

24 are, and then we’ll take the typical input power 

25 and multiply them together and you get an operating 
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1 hours per year. 

2 Brings us to items 31 and 32. On the 31, 

3 we’re requesting comment on ballast efficiency and 

4 ballast input power. This is separate from -- this 

5 is really more historic numbers, because the idea 

6 with the energy analysis is we’re trying to get a 

7 sense of what the energy savings potential could be 

8 from standards, and so we’re interested in ballasts 

9 that were previously installed, what their input 

10 powers are that are now probably covered by 

11 standards such as metal halide or the mercury vapor 

12 standard and what those ballast efficiencies should 

13 be. It’s a slightly different scenario than usual. 

14 I’ll pause for comment for a second. 

15 MR. BROOKMAN: Susan. 

16 MS. ANDERSON: Well, when taking into 

17 consideration the installed base, I mean the 

18 installed base is basically magnetic, so where 

19 magnetic ballast, you’re going to have to make sure 

20 that you look across multiple manufacturers’ 

21 catalogs, and look at those system input powers. 

22 And you might also look at luminaries because you 

23 also -- it’s not as much so as in fluorescent, but 

24 you can have a fixture effect that can impact the 

25 system input power. 
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1 MR. BROOKMAN: What is that? A system 

2 effect? 

3 MS. ANDERSON: Once the ballast is 

4 installed in a fixture and it’s in a confined area, 

5 it can change the input power of the system. 

6 MR. BROOKMAN: Okay. 

7 MR. MYER: I guess I’d like to elaborate 

8 on that. So using current catalog data for -- can 

9 we use stand-in for mercury vapor specialty 

10 ballasts, since they can still be currently sold 

11 and they’re in catalogs, as a representative 

12 mercury ballast -- mercury vapor ballast input 

13 power for something, let’s say, that was installed 

14 in 2006? That’s -- ultimately that’s the historic 

15 aspect we’re trying to get at. And the same 

16 question would be for probe start metal halide 

17 fixtures, now that the ballasts are covered by a 

18 standard, can we use the current magnetic data that 

19 we’re seeing out there and should we assume a 

20 different efficiency and thus a different input 

21 power for magnetic probe start systems that were 

22 installed in, again, let’s say 2008, that were 

23 precovered? 

24 MS. ANDERSON: For metal halide, you’re 

25 going to be able to get at least the ballast, for 
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1 the ballast manufacturers, you’ll be able to get 

2 those numbers because there’s no restriction on 

3 selling replacement metal halide ballasts. 

4 MR. MYER: Okay. 

5 MS. ANDERSON: In the case of mercury 

6 vapor, for most applications, those ballasts that 

7 drive the specialty lamps are not the same ballasts 

8 that drive the general lighting lamps. But I would 

9 think that ballast manufacturers would have -- 

10 could help with older editions of their catalogs, 

11 or even luminaire manufacturers, older editions of 

12 their catalogs to help you get to that information. 

13 MR. BROOKMAN: Thank you. John. 

14 MR. GREEN: Yes, in a previous employment 

15 I actually did a lot of ballast design, and it may 

16 not be as simple as pegging one input wattage to a 

17 ballast. When I was designing ballasts, we 

18 actually manufactured two, one was a low loss 

19 version, which had lower input power than the 

20 standard. It had a premium cost associated with 

21 it, but it was a choice customers could make. So 

22 it may be a little more involved than just picking 

23 one number. May have to look at a number of 

24 different types of ballasts. 

25 MR. BROOKMAN: Okay. Thank you. Joe. 
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1 MR. HALLEY: On item 32, I just was going 

2 to agree that your proposed methodology and the 

3 sources that you have selected to look at seem 

4 appropriate. Trying to get at hours of use and 

5 various applications. We’ve seen those studies in 

6 reports and they seem like they represent a 

7 reasonable survey of actual operating conditions. 

8 MR. BROOKMAN: So are you speaking on 

9 behalf of NEMA? 

10 MR. HALLEY: On behalf of NEMA, yes. 

11 MR. BROOKMAN: Thank you. Susan. 

12 MS. ANDERSON: I would say in one previous 

13 rulemaking, we saw when they took commercial 

14 offices different from retail, so just keep that in 

15 mind, because when we saw that previous rulemaking, 

16 the number for commercial did not reflect retail 

17 operating hours. 

18 MR. HALLEY: I suppose that’s true. We 

19 reserve the right to actually see what numbers 

20 you’re selecting. And further comment, if we think 

21 that they were accurately selected. 

22 MR. MYER: Sure. Of course. In terms of 

23 follow on what you’re saying, Susan, in terms of 

24 HID and typical applications, you’re going to see 

25 them much more common in retail than you are in 
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1 commercial -- in commercial office -- and that’s 

2 why you’re pointing that out. 

3 MS. ANDERSON: Right. Like you’re going 

4 to see them in a big box retailer, that’s our 

5 grocery store, that sort of thing. You’re not 

6 going to see them -- so commercial generally 

7 reflects more office space as opposed to retail 

8 space. 

9 MR. MYER: Thank you. Continuing on. So 

10 then the other analysis would be the markup 

11 analysis, and that was briefly touched on 

12 previously by Merry Walker. The purpose -- this is 

13 slightly different than previous passes -- Merry 

14 said, you can’t really take apart an HID lamp and 

15 get a sense of the cost, so we’re going to use the 

16 existing cost for -- not the existing cost, but the 

17 blue book or the price list where we can. But at 

18 the same time, we still look for markups that’s 

19 been discussed many times in this meeting already, 

20 that in some cases you may have to replace a 

21 ballast, or in some cases you may have to replace 

22 an entire fixture, and those do have markups 

23 associated with them, as well we’re interested in 

24 any costs associated that we can figure in as well. 

25 So what we’re going to do is we’re going 
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1 to identify distribution channels which we’ll show 

2 in a second, and then we’re also going to want to 

3 estimate markups from each step in the 

4 manufacturing process. 

5 So we identified two initial HID lamp 

6 distribution channels. They’re shown here as one 

7 and two. They’re very similar. The first one 

8 would be from the manufacturer to wholesaler or 

9 electrical distributor, to a contractor, to an end 

10 user. The second one there’s no contractor, it 

11 would be just the manufacturer to the electrical 

12 wholesaler to the end user. 

13 As we’ve discussed also, in some cases you 

14 will possibly need to replace a ballast outright. 

15 We then identified a replacement HID ballast 

16 distribution channel. Again in this case, it would 

17 be the ballast manufacturer, to an electrical 

18 distributor, to a contractor to an end user. 

19 And then the third option that we 

20 discussed rather in depth, is that the potential to 

21 have to change to a wholesale fixture. In this 

22 case, we identified in this case, it would be a 

23 fixture manufacturer to an electrical distributor, 

24 to a contractor, to an end user. 

25 And that brings us to items 33 and 34. We 
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1 welcome comments and suggestions concerning pricing 

2 and approach for existing consumer prices for 

3 lamps, but also for ballasts and fixtures, because 

4 they will have to get factored in there. And item 

5 34, comments on typical manufacturer, wholesaler, 

6 and contractor markups. 

7 MR. BROOKMAN: Susan. Alex first. 

8 MR. BOESENBERG: I can do the first one on 

9 pricing. We can’t do that here, sorry. Individual 

10 manufacturers, during their interviews, will have 

11 an opportunity to assist the DOE in that. 

12 MR. BROOKMAN: Thank you. Susan. 

13 MS. ANDERSON: My comment is on 

14 distribution channels. When you’re looking at the 

15 HID ballast and also the luminaire distribution, 

16 remember that you have, particularly like with 

17 industrial businesses, they have people that can do 

18 the work. They don’t need a contractor. So it may 

19 go from the manufacturer to the wholesaler, to the 

20 end user. 

21 And then also, when you get to the fixture 

22 distribution channels, there are some fixture 

23 manufacturers that sell directly to the end user. 

24 And they totally skip the wholesaler and the 

25 contractor. 
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1 MR. MYER: Would those be utilities or 

2 what type of industry would you expect those to be? 

3 MR. COOK: Could be utilities, could be 

4 municipalities, typically project work. 

5 MR. MYER: I’m sorry, I’m not familiar 

6 with the term “project work.” 

7 MR. COOK: It’s when we’re selling 

8 specific -- like we will bid on a job at a specific 

9 city, and so we will deliver straight to that city, 

10 and they will arrange installation and things like 

11 that. 

12 MR. MYER: Would you characterize that as 

13 outdoor more you can’t define it as whether it’s 

14 outdoor or indoor? 

15 MR. COOK: It doesn’t have to be 

16 necessarily outdoor, although that is a good 

17 example of it. 

18 MR. MYER: Okay. 

19 PARTICIPANT: Sometimes they’re sold that 

20 way. 

21 MR. COOK: Depends on who the customer is. 

22 MR. MYER: Thank you. At this time I’m 

23 going to turn the presentation over -- 

24 MR. BROOKMAN: Wait. Yes, John, please. 

25 MR. GREEN: Back up. The HIV lamp 
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1 distribution channel. There’s also probably a 

2 number three there, where a lot of -- I’ll say some 

3 fixture manufacturers package lamps with fixtures, 

4 so it’s actually a light manufacturer to the 

5 fixture manufacturer, and then that would be a 

6 third method of distribution of HID lamps. 

7 MR. MYER: Okay. And that would be in a 

8 new construction scenario and not in a replacement 

9 scenario. 

10 MR. GREEN: That’s correct, yes. 

11 MR. MYER: Okay. And they would be paying 

12 a markup -- so I guess I need to figure that out. 

13 So it would be fixture manufacturer with lamp, but 

14 it would be -- and then it would be the same 

15 channel, the fixture channel, but with a lamp. 

16 MR. GREEN: Yes, just so you take number 

17 two and insert fixture manufacturer after lamp 

18 manufacturer, and then still go to the wholesaler 

19 and end user. 

20 MR. MYER: Okay. 

21 MS. ANDERSON: That’s typically the most 

22 common scenario with new installations. Because it 

23 saves the contractor the labor of installing the 

24 lamp. 

25 MR. MYER: Great, and appreciate any rough 
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1 estimates of percentage of distribution channels as 

2 well. 

3 At this time I will turn the presentation 

4 over to Scott Morris, who will introduce life cycle 

5 cost analysis and payback period analysis. 

6 Life Cycle Cost Analysis and 

7 Payback Period Analysis

8 MR. MORRIS: Thank you, Michael. Good 

9 morning. I’m Scott Morris, and as Michael 

10 mentioned, I’ll be talking first about the life 

11 cycle cost and payback period analysis. 

12 So the life cycle cost and payback period 

13 analysis build upon previous analyses to determine, 

14 as the name implies, the total life cycle cost and 

15 payback period of the equipment considered in this 

16 rulemaking. The life cycle cost and payback period 

17 analysis considers the effects of a standard on 

18 individual customers, specifically life cycle cost 

19 is the total cost of HID lamps, including the price 

20 of the lamp, installation costs, and operating 

21 expenses through the end of the lamp’s lifetime, 

22 expressed in today’s dollar figures. 

23 The payback period of a lamp, more 

24 efficacious than a baseline lamp, is the average 

25 number of years it takes a customer to recover the 
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1 potentially higher first cost through decreases in 

2 operating expenses, as shown in the diagram in the 

3 bottom here. To account for the range of possible 

4 life cycle costs and payback periods, DOE will 

5 incorporate Monte Carlo simulations which uses 

6 inputs originating from probability distributions, 

7 as opposed to average values. 

8 Of course, reduced energy use yields 

9 reduced energy costs. DOE will use the most recent 

10 annual energy outlook produced by the Energy 

11 Information Administration to project future 

12 electricity price trends. At the same time, DOE 

13 uses EAA form A26 data to establish current 

14 electricity prices, and then uses the annual energy 

15 outlook to project those prices into the future. 

16 This brings us to item 35. DOE welcomes 

17 any comments on the proposed methodology for 

18 estimating electricity prices. 

19 MR. BROOKMAN: Alex. 

20 MR. BOESENBERG: Alex Boesenberg. I 

21 believe as we have in the past, we highly recommend 

22 that DOE consult the Edison Electric Institute -- 

23 MR. MORRIS: Pardon me? 

24 MR. BOESENBERG: Edison Electric 

25 Institute, Mr. Steve Rosenstock, due to their 
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1 excellent information regarding price by region and 

2 users. 

3 MR. BROOKMAN: Okay. Thank you. 

4 Additional comments on electricity prices and the 

5 methodology also? Okay. 

6 MR. MORRIS: Thank you. Discount rates 

7 are used to establish the present day value of 

8 future expenses. DOE uses the weighted average of 

9 ... set to equity ratios to develop a distribution of 

10 discount rates for use in the life cycle cost 

11 analysis. And as item 36 says, of course, the 

12 Department welcomes any comments regarding the 

13 approach for determining discount rates for the 

14 life cycle cost analysis. 

15 MR. BROOKMAN: No comments? Okay. 

16 MR. MORRIS: So there are two primary 

17 costs associated with the lifetime of HID lamps, 

18 installation costs and operating costs. DOE will 

19 consider the expenses involved with installing HID 

20 lamps, ballasts, and fixtures. The Department 

21 assumes HID lamps require no maintenance during 

22 their lifetimes, but are replaced upon failure or 

23 early retirement. For example, cleaning costs are 

24 typically, we believe cleaning costs are typically 

25 part of a fixture operating cost. Any comments in 
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1 that regard? 

2 MR. BROOKMAN: Joe. 

3 MR. HALLEY: Yeah, we would agree that 

4 with HID, they’re generally replaced as they fail, 

5 especially high wattage HID lamps cover a large 

6 area, and unlike fluorescent where if one 

7 fluorescent lamp goes out in, for instance, the 

8 fixtures in this room, it could be left out for 

9 quite a while and doesn’t really impact the light 

10 level of this room. But if a, say a 400 watt metal 

11 halide goes out in a store, they’re going to 

12 replace that lamp fairly quickly and not leave a 

13 whole section of their store dark. And generally, 

14 when they replace it, they may clean the fixture 

15 when it’s being replaced. They usually don’t do 

16 cleaning in between. 

17 In terms of electrical rates, RS means is 

18 one source of electrical labor rates. I will note, 

19 however, that electrical labor rates can vary 

20 greatly in this country, depending on what city 

21 you’re working in -- from past experience. So, 

22 somehow, I’m not sure how that’s factored in, but 

23 this has to be cost-effective in the high labor 

24 rate areas as well as the low labor rate areas. 

25 MR. MORRIS: Part of the purpose of the 
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1 Monte Carlo analysis is to incorporate higher and 

2 variable electricity costs, but we’ll definitely 

3 keep that in consideration. 

4 MR. HALLEY: So that’s electricity cost, 

5 but I was referring to the electrical contractor 

6 labor rates. 

7 MR. MORRIS: Sorry. 

8 MR. HALLEY: They both have similar issues 

9 of quite a bit of variability throughout the 

10 country. 

11 MR. BROOKMAN: So you can see the comment 

12 box. 

13 MR. MORRIS: Yes, I forwarded to the two 

14 comments here, the two comment boxes. 

15 MR. BROOKMAN: Leave that up. 

16 MR. MORRIS: Okay. So each lamp’s life 

17 cycle cost is of course affected -- 

18 MR. BROOKMAN: Pardon me, I wasn’t clear. 

19 Would you go back to items 37 and 39? 

20 MR. MORRIS: I’m sorry. 

21 MR. BROOKMAN: I wasn’t sure that we 

22 covered this and I lost track, so I just want to 

23 make sure that we did before we move on. 

24 Installation and maintenance and repair. Okay. I 

25 think we covered it. 
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1 MR. MORRIS: We did. I mean the idea that 

2 you cannot repair or maintain an HID lamp is 

3 correct. Nobody removes an HID lamp and repairs 

4 it. It is definitely replaced. 

5 MR. BROOKMAN: Thank you. Now you may 

6 move on. 

7 MR. MORRIS: Sorry for the confusion, 

8 Doug. So each lamp’s life cycle cost is affected 

9 by its lifetime. DOE will use manufacturer 

10 literature, other literature sources and inputs 

11 from other interested parties in determining lamp 

12 lifetimes. Lifetimes can be adjusted to account 

13 for group relamping practices, which decreases the 

14 cost per lamp because labor is less costly when 

15 many lamps are replaced at once. 

16 On the next slide we have a couple comment 

17 boxes. Item number 40, the Department welcomes 

18 comments on lamp lifetimes and how group relamping 

19 practices may affect lamp lifetimes. And 38, 

20 comments regarding how relamping practices would 

21 change if HID lamp life is affected by new 

22 standards. 

23 MR. BROOKMAN: Susan. 

24 MS. ANDERSON: Well, basically, for HID 

25 lamps, it’s much more common to see spot versus 
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1 group, even though we do specifically recommend 

2 group relamping, particularly with metal halide. 

3 The reality is spot relamping is what is done. And 

4 the other thing that I would say, if you do 

5 evaluate group relamping, if you go to the IES 

6 recommendations for indoor applications, it’s RP36-

7 03, and they recommend group relamping at 60 to 70 

8 percent of rated life. And then it’s DG-4-03 for 

9 roadway. So those would be good sources for that. 

10 You might also want to check with lighting service 

11 companies. Like, we have a division that’s a 

12 lighting service company and find out if they do 

13 group relampings, what they actually do in 

14 practice. But they don’t -- it’s not a reduction 

15 of 91 to 94 percent or whatever is over there. 

16 It’s much greater than that. 

17 MR. BROOKMAN: Okay. Thank you. That’s 

18 helpful. Michael. 

19 MR. MYER: Michael Myer. Pacific 

20 Northwest National laboratory. Susan, you said 

21 kind of in general that HID lamps are not group 

22 relamped. Is there any other, within the three 

23 lamp types, or in applications -- I understand 

24 street lighting probably is last group relamped 

25 because of the magnitude of street lighting, but 
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1 parking lots or interior, any -- either of those or 

2 metal halide -- any specific -- any -- 

3 MS. ANDERSON: They all tend to be much 

4 more spot relamped than group relamped. Because as 

5 Joe was mentioning earlier, a given fixture covers 

6 -- it’s the only thing providing light in a given 

7 area, so when it goes out, it needs to be replaced. 

8 MR. HALLEY: You might be able to get a 

9 little better information from having conversations 

10 with these lighting service companies who generally 

11 are group relamping fluorescent systems, but you 

12 could ask them what their experience is with group 

13 relamping HID systems. I think it would be 

14 relatively minor, but they may be able to give you 

15 a better sense of how often these are group 

16 relamped. 

17 MR. BROOKMAN: Okay? 

18 MR. MORRIS: Okay. Thank you. I’ll turn 

19 the mic back over to Michael Myer to discuss 

20 shipments. 

21 MR. BROOKMAN: How are we doing here? 

22 We’re ahead of schedule, and are we okay? Keep 

23 pressing ahead here? Yes? We’ll just see where we 

24 are as we approach noon. Okay. 

25 Shipments Analysis 
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1 MR. MYER: Thank you, Doug. The shipment 

2 analysis works in tandem with the life cycle cost 

3 and payback period analysis to provide information 

4 into the national impact analysis. The shipment 

5 analysis is to look at -- we create two scenarios. 

6 One’s called the base case scenario and the other 

7 one is called the standards case scenario. And we 

8 want to get a sense of how they affect national 

9 energy savings and net present value. 

10 How we develop shipment scenarios or 

11 shipment projections, we look at a lot of data if 

12 we can get it. We look at manufacturer and 

13 industry organizations, any reports talking about 

14 shifts in technology, or continuation of 

15 technology, trends in technology, national energy 

16 and lamp surveys, and also historic HID lamp 

17 shipment data from NEMA. I know NEMA publishes a 

18 newsletter that often shows quarterly what some of 

19 the HID shipments are, and we use that as a source 

20 as well. 

21 We’ll discuss each of the different 

22 shipments and the methodology in a second. But I 

23 want to first start with items 15 and 41. On 15, 

24 DOE welcomes input on disaggregated market share 

25 based on input wattage for each of the HID lamp 
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1 technologies. And I’ll pause for a second. 

2 MR. BOESENBERG: Alex Boesenberg, NEMA. 

3 To item 15, first of all, we’re a little confused 

4 about what was being asked for in terms of what the 

5 data is intended to drive. What’s the goal from 

6 that data? Then to continue on, as you noted, we 

7 do collect data on these products, however, one 

8 challenge we have to providing the government with 

9 data is that we don’t necessarily gather it in the 

10 way that you were asking. We don’t tend to report, 

11 have our members report, based on wattages, but 

12 rather based on technology and base type. Since 

13 it’s sales data, we want to know where -- who is 

14 buying it, where it’s going, which means we care 

15 more about the application. As we’ve already 

16 stated, I think the discussions have borne that 

17 out. The fixture type and where it is, strongly 

18 dictates what goes in it. So we track it by 

19 application. 

20 In our public comments, we’re going to 

21 give you an excerpt of what one of our quarterly 

22 reports looks like, and we welcome discussions as 

23 to whether or not there’s a way for us to either 

24 analyze the existing data, or if necessary, I can 

25 ask my members to consider a special survey. But 
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1 we welcome the opportunity to see if we can work 

2 something out, save the government time in 

3 gathering this information. And I’ll pause if you 

4 have any questions on my comments on item 15, 

5 particularly what’s the end goal, so we know what 

6 you’re looking for. 

7 MR. MYER: Ultimately, I mean, the end 

8 goal is to get a sense of if, rather than just say 

9 that metal halide was X million units or X percent, 

10 to get a sense of where the trends are in -- better 

11 than just low, medium or high wattage -- in the 175 

12 watt versus the 250 watt, where are you seeing 

13 shipments? Whatever finer, granular resolution we 

14 can get related to shipments, related to -- again, 

15 at a global level, HID lamps up or down, limits 

16 some of the analysis we can do. 

17 MR. BROOKMAN: Alex. 

18 MR. BOESENBERG: Alex Boesenberg. Based 

19 on your shipments, do you -- it’s your impression 

20 that the fact that our data is gathered then by 

21 application and base type, will that still be 

22 useful to you? It sounds to me like it will. 

23 MR. MYER: In some cases. 

24 MS. ANDERSON: It’s technology. 

25 MR. BOESNEBERG: Technology, sorry. What 
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1 did I say? 

2 MS. ANDERSON: Application. 

3 MR. BOESNEBERG: Oh, yeah. 

4 MR. MYER: Now that Susan’s elaborated 

5 that it’s technology, not application, that is 

6 different. In terms of technology, I assume you’re 

7 separating out by mercury vapor, high pressure 

8 sodium and then the three typical types of metal 

9 halide. And then for base type, pretty much 150 is 

10 medium base and 150 and above is mogul base, but 

11 anything we can get beyond that would be helpful as 

12 well. I know some special surveys in the past have 

13 done, at least the wattage bins -- low, medium and 

14 high wattage bins. But again, anything -- so 

15 beyond just the base type would be helpful. Yes. 

16 MR. BOESENBERG: Anything else, Susan? 

17 MR. BROOKMAN: Susan? 

18 MS. ANDERSON: The only metal halide 

19 family we separate out is ceramic. So we don’t 

20 separate by pulse start versus probe start. 

21 MR. HALLEY: We would need a special 

22 survey. 

23 MS. ANDERSON: Right. 

24 MR. HALLEY: To get what you’re asking 

25 for. We can consider a special survey. 
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1 MR. BROOKMAN: So I think it’s worth 

2 having that on the record, Joe. You could consider 

3 a special survey to gather that data? 

4 MR. HALLEY: Right. We’d want to discuss, 

5 you know, exactly what would be most useful before 

6 we would go through that exercise. Perhaps we 

7 could have that further discussion. 

8 MR. BROOKMAN: Thank you. 

9 MR. MYER: Continue on to item 41. DOE 

10 welcomes recommendations on other sources of HID 

11 shipment by proposed equipment class. We also 

12 welcome comments on future long term trends in HID 

13 lamp efficacy. 

14 MR. BROOKMAN: Probe start, quartz, metal 

15 halide versus pulse start, quartz or pulse start 

16 ceramic. Sounds pretty complicated. 

17 MR. HALLEY: We understand it. 

18 MR. BROOKMAN: Susan. 

19 MS. ANDERSON: Well, I mean, the new 

20 products we’re seeing an expansion in lower 

21 wattages, and we’re seeing an expansion in pulse 

22 start ceramic. That’s where the new technology is 

23 going. It’s not going in probe start. 

24 MR. BROOKMAN: That’s the industry at 

25 large? 
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1 MS. ANDERSON: Industry at large. 

2 MR. BROOKMAN: Okay. 

3 MR. MYER: I’m sorry, can we separate 

4 those two out, so I understand it better. You’re 

5 seeing an increase in ceramic pulse, and then low 

6 wattage -- is that also in ceramic pulse or all. 

7 MS. ANDERSON: Yes. 

8 MR. MYER: So it’s really con -- the same. 

9 Thank you. 

10 MS. ANDERSON: But the new wattages that 

11 are coming out tend to be in the low wattage range, 

12 to replace halogen. 

13 MR. MYER: So if you’re saying replacing 

14 halogen, is that omnidirectional or non15 omnidirectional? 

16 MS. ANDERSON: Both. 

17 MR. MYER: Thank you. 

18 MR. BROOKMAN: Okay. That’s helpful. 

19 Thank you. Additional comments on item 15 and 41? 

20 MR. MYER: Continuing on to the 

21 methodology. So the shipments model will look at 

22 three different essentially accounting 

23 methodologies for -- one is new installations. 

24 These are fixtures that are being brought to market 

25 with a -- a new fixture, essentially, for new 
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1 construction with an HID lamp. Replacements. 

2 These are lamps that have failed or retired from 

3 service and they’re being sold. And then 

4 retrofits. These are early replacements, such as 

5 an entire grocery store is being relighted and the 

6 equipment is still in good service condition but 

7 they’re just going with a new design. So those are 

8 the three different scenarios there. And we would 

9 like to -- we’ll ultimately estimate proportions of 

10 shipments based on those types of scenarios. 

11 We welcome comments based on our 

12 accounting methodology here described. 

13 MR. BOESENBERG: Alex Rosenberg, NEMA. We 

14 have no further edits or clarifications to that. 

15 Those definitions seem acceptable. 

16 MR. BROOKMAN: Okay. Thank you. Joe. 

17 MR. HALLEY: The only thing I’ll add is 

18 the overwhelming bulk of what this rulemaking would 

19 accomplish is going to affect the replacement 

20 options. The new installation is more affected by 

21 the existing ban on mercury vapor ballasts and the 

22 requirement to put a pulse start ballast in new 

23 metal halide fixtures, most of the new metal halide 

24 fixtures. And there’s not a lot of retrofits that 

25 occur because of the previous discussion, of how 
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1 difficult it is to retrofit an HID fixture. So 

2 really the focus should be overwhelmingly on how 

3 this affects replacements. 

4 MR. BROOKMAN: Additional comments. 

5 Keith. 

6 MR. COOK: Well, just a real quick 

7 comment. Even on the new installations, this whole 

8 market is driven by efficiency and so to think 

9 we’re going to have a huge impact, I think is 

10 misleading, because our marked on HID is already 

11 being attacked by linear fluorescent, T5s, T8s, 

12 because of the efficaciousness of those 

13 applications, and that’s typically in warehouses 

14 and industrial applications and things like that. 

15 And in the outdoor market, the LED is by far 

16 becoming dominant, again attacking what had 

17 predominantly been this market in the past. And so 

18 just a word of caution. We don’t see where we’re 

19 going to be able to impact this particular market 

20 very much going forward with new rulemaking. 

21 MR. MYER: Thank you. Continuing on. So, 

22 as I mentioned earlier, there are two types of 

23 scenarios. One is called the base case, the other 

24 one is called the standards case. The base case 

25 essentially assumes what would the shipments be 
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1 projected into the future, in the absence of any 

2 amended -- or I’m sorry, new, in this case -- new 

3 standards. That being said, it will actually look 

4 at what the effects of lamp shipments are from 

5 other standards such as we’ve discussed many times, 

6 mercury vapor and metal halide having the effect. 

7 While those are separate standards, they do have an 

8 effect on future shipments of those two 

9 technologies, so they will be included here in the 

10 base case. ... to wrap your mind around. And it’ll 

11 be a mixture of the different efficacies sold and 

12 the absence again, of new regulation. We typically 

13 look at historical shipments and try to get a 

14 lifetime distribution and how they’re installed and 

15 replaced, and that type of thing. 

16 Then there’s the standards case -- I think 

17 I’m having problems with the computer -- Thank you. 

18 That contrasts with the other type of analysis I 

19 mentioned, the standards case. This is what 

20 ultimately would be in -- what would the shipments 

21 look like into the future, assuming the proposed 

22 standards. We will -- it helps us to look at the 

23 difference between the two programs and you look at 

24 the differential, and you get a sense of the 

25 savings and -- energy savings and the net present 
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1 value. 

2 We will also consider the effects from 

3 market pull programs which have been discussed 

4 previously in this presentation as well. 

5 Brings us to item 43, DOE welcomes 

6 comments on proposed conservation standards might 

7 affect shipments of HIV lamps, and also any 

8 information on market pull programs. 

9 MR. BROOKMAN: Susan. 

10 MS. ANDERSON: Well, as we’ve already 

11 talked about, the -- we already have regulations in 

12 place that are impacting what’s happening in new 

13 fixtures, and those were both laws that were 

14 passed, EPAC 2005 and then ESA 2007. The other 

15 thing, I think somewhere in here I think it 

16 mentioned maybe the impact of state programs, but 

17 most state programs, except for California’s Title 

18 20, were negated by the federal regulations that 

19 passed there. So basically the federal regulations 

20 copied what had already been passed in existing 

21 state legislation. 

22 And then on the pull through, I know the 

23 gentleman from Energy Solutions said that they do 

24 have incentive programs for going from probe start 

25 to pulse start. But what we’re really seeing 
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1 happening in the market place is that people aren’t 

2 going from probe start to pulse start, they’re 

3 going from probe start to fluorescent. And you can 

4 get a lower wattage package, you have greater 

5 energy savings, you have longer lamp life, and the 

6 energy savings is compounded by the fact that you 

7 get better lumen maintenance out of those 

8 fluorescent lamps, so that means you can go with an 

9 even lower wattage system. So that accentuates the 

10 energy savings. 

11 Where we are seeing incentive programs, 

12 it’s impacting more outdoors, and people are going 

13 to solid state as opposed to going to another HID 

14 technology. In some cases they’re going to 

15 induction, because induction is kind of a long16 lived, lower cost option, compared to solid state. 

17 But most of it is going to solid state. I mean, 

18 the HID market, the market place is taking HID out 

19 of installations. 

20 MR. BROOKMAN: Joe. 

21 MR. HALLEY: I just wanted to reiterate 

22 that the effect of the market pool programs might 

23 be different than you’re projecting, but it’s 

24 actually -- the effect has been to shrink this 

25 market and to eliminate the lower efficiency 
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1 sources, and we expect that will continue. So your 

2 projection on market pool should take that into 

3 consideration. 

4 MR. BROOKMAN: Thank you. Okay. Okay. 

5 MR. MYER: At this time I’m going to 

6 return the presentation to Scott Morris who will 

7 discuss national impact analysis. 

8 National Impact Analysis 

9 MR. MORRIS: The national impact analysis 

10 effectively combines the results of the life cycle 

11 cost analysis and shipments analysis to determine 

12 the energy savings potential and monetary effect of 

13 a standard on the nation as a whole 

14 So to state it differently, the NIA is 

15 designed to assess the monetary impact and energy 

16 savings of a standard on the entire country. So to 

17 put it simply, each year in a 30-year analysis 

18 period, which is DOE looks at a 30-year analysis 

19 period, which begins in the year when the standard 

20 takes effect, most likely, 2017. Each year has 

21 equipment purchase and installation costs and 

22 operating expenditures. In any given year, if 

23 operating cost savings are greater than the 

24 increased equipment costs, the result is a net 

25 savings. If the equipment costs outweigh operating 
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1 cost savings, the result is a net cost to the 

2 nation. The national impact analysis sums across 

3 all years of the analysis period to determine the 

4 economic effect on the nation, and the national 

5 energy savings resulting from a standard. 

6 National energy use is calculated for the 

7 base case, shown on the left side in the base case 

8 scenario and for the standards case scenario shown 

9 on the right, for every year of the analysis 

10 period, all 30 years. The site energy use in both 

11 cases is converted into primary or source energy 

12 use, using a site to source conversion factor. The 

13 difference in energy savings between the base case 

14 and the standards case projections yields national 

15 energy savings. 

16 Is there any comments or confusion on the 

17 diagram or anything I’ve said? Okay. Methodology 

18 is somewhat clear. Good. 

19 The net present value calculations are 

20 done in similar fashion as the net national energy 

21 savings calculations. Monetary costs for both base 

22 case and standards case scenarios are calculated. 

23 The difference between operating cost savings which 

24 in both base case and standards case scenarios is 

25 the sum of the energy cost and repair and 
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1 maintenance cost boxes, the difference between 

2 operating cost savings and installed cost 

3 increases, discounted appropriately, yields the 

4 national net present value of savings. 

5 So this brings us to a couple items for 

6 discussion. First of all, DOE welcomes comments on 

7 any data sources that should be used in the 

8 national impact analysis. In number 44 and 45, the 

9 Department welcomes comments on whether more 

10 efficacious lamps would be operated more as a 

11 result of their increased efficacy. 

12 MR. BROOKMAN: Joe. 

13 MR. HALLEY: Well, in this particular 

14 case, the HID market is under tremendous change 

15 right now, given what was just talked about, the 

16 market pool programs, the existing regulations, 

17 making it -- perhaps a ten year analysis possible 

18 in terms of analyzing what we expect to see happen 

19 over the next ten years. But we think this is 

20 impossible to try to figure out what might happen 

21 over the next 30 years, given the dynamic changes 

22 happening over the next ten years. We don’t know 

23 what this market’s going to look like ten years 

24 from now, and what you would project over the last 

25 20 years, it would be a wild card in terms of what 
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1 may exist, what technologies -- I mean a lot of 

2 these technologies may not even exist in the market 

3 place at that time. Obviously, if they wouldn’t 

4 exist, there wouldn’t be any national energy 

5 savings to pull forward. 

6 So we’re not sure -- perhaps there’s a 

7 reason why a 30 year analysis is required, but from 

8 a practical standpoint, it doesn’t seem to make 

9 much sense. Perhaps we could even ask why -- why 

10 30 years with such a radically changing market? 

11 In terms of the -- 

12 MS. ANDERSON: (Comment off mic) 

13 MR. MORRIS: So let’s stop and see if 

14 there’s a response -- 

15 MR. BROOKMAN: Do we have an answer for 

16 the 30 year? 

17 MR. MORRIS: Historical precedence -- 

18 Michael, do you have a comment? 

19 MR. MYER: No. 

20 MS. ANDERSON: Is there a regulation? 

21 Something that requires you to use 30 years? 

22 MR. BROOKMAN: Betsy. 

23 MS. KOHL: This is Betsy Kohl from the 

24 DOE-GC. There may be something in our process rule 

25 that we publish that sorts of sets the standards 
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1 for our analyses, and that’s actually available on 

2 our website, but I mean if you guys have comments 

3 on a different or better analysis period, and why 

4 that might be useful, we’d certainly consider them. 

5 MS. ANDERSON: I mean the comments that 

6 Joe just made, I mean technology is changing so 

7 fast. I mean, I don’t -- as efficient as -- and 

8 I’m an old fluorescent person -- as efficient as 

9 fluorescent is, in 30 years, I don’t know if it’ll 

10 be here. And I think fluorescent will outlast HID, 

11 except in a very few limited applications. I mean 

12 the world is going solid state. 

13 MR. HALLEY: Basically, if this regulation 

14 doesn’t make sense in ten years, it’s certainly not 

15 going to make sense in 30 years, because of all the 

16 change happening in HID market place. And so maybe 

17 we would recommend that you look at a ten year 

18 analysis, might be more robust than a 30 year. If 

19 you still want to do your 30 year, I’m not sure 

20 what you’re putting in your last 20 years. You may 

21 not have much product to play with at that point. 

22 MR. BROOKMAN: Okay. Thank you. Susan, 

23 yes. 

24 MS. ANDERSON: The other comment that I 

25 would make -- and this will be in our written 
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1 comments -- when we work with end users, three 

2 years is about the longest payback time any of them 

3 will tolerate. If it goes beyond that, they won’t 

4 do the change-out. 

5 The other thing that I want to say to you, 

6 and I’m speaking from my own experience within my 

7 own company, is we are an HID lamp manufacturer, 

8 but we took out HID in a brand new distribution 

9 center and replaced it with T5 fluorescent. 

10 MR. BROOKMAN: In your facility? 

11 MS. ANDERSON: In our own facility, 

12 economics were there to justify it. So -- and when 

13 we do all the evaluations, because we’ve 

14 retrofitted all of our facilities, when we do the 

15 evaluations, we don’t do payback, we do ROI. 

16 MR. BROOKMAN: Daniel, I’m looking at you, 

17 noting that California frequently leads the charge 

18 on these things with market pull programs, so I’m 

19 wondering if they have a -- if what’s going on 

20 there tracks the manufacturers experience. 

21 MR. YOUNG: Sure, absolutely. We’re 

22 definitely trying to incentivize LEDs as much as 

23 possible, and I think -- I personally would love to 

24 see LEDs wipe out HIDs in the next two years. But 

25 obviously that’s not going to happen. But joking 
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1 aside, I do think that in existing fixtures, that 

2 could last anywhere from ten to 20 years, there may 

3 still be a market for the lamps that go into those 

4 fixtures, so that’s something that could help to 

5 justify a longer analysis period, even if it’s 

6 difficult to project. 

7 MR. BROOKMAN: Michael Myer. 

8 MR. MYER: Thank you, Doug. The fact that 

9 mercury vapor is roughly 80-plus years old this 

10 year, and probe start is roughly 50 years old at 

11 this point, and they’re still installed in the 

12 market place, and if users want a low payback or 

13 low ROI, there are probably legacy products out 

14 there that are still going to continue to just 

15 replace the lamps until they can’t replace the 

16 lamps well into the future. I think mercury vapor 

17 is a great example. The ballast can no longer be 

18 sold, but we’re still selling -- well, not we, but 

19 the industry is still selling lamps, at least over 

20 a couple million is the last NEMA estimate I’ve 

21 seen. I know it’s a decline, but it’s still 

22 existing. So I think even though we are projecting 

23 out 30 years and it’s hard to know where we will be 

24 in 30 years. Thirty years ago if I could have 

25 bought some Apple stock, I probably would have at 
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1 this point. You know, projecting into the future 

2 with -- do we know that certain technologies live 

3 on, and so I think there’s still -- we may not be 

4 able to project forward with great accuracy, but we 

5 still -- there’s definitely precedent that mercury 

6 vapor and probe start which are very old, still 

7 exist in the marketplace and there’s an abundance 

8 of installed stock. 

9 MS. ANDERSON: But the other thing to keep 

10 in mind is that the innovation rate has accelerated 

11 dramatically from what it was in the past. And 

12 it’s -- that’s changing the world, and so are LEDs. 

13 MR. BROOKMAN: Yeah, the lighting industry 

14 is being transformed as we speak, right. Keith, go 

15 ahead. 

16 MR. COOK: And believe it or not, I have 

17 seen replacement LED devices to replace the quartz 

18 metal halides in street lighting fixtures. And so 

19 the replacement market is not stationary either. 

20 It’s also changing. And so the thought that what’s 

21 already installed base is going to continue there 

22 may not be true in this technology. 

23 MR. HALLEY: I think the point is that you 

24 should consider these shrinking as you project out 

25 five, ten, 15, 20 years. You should be projecting 
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1 out shrinking market segments for mercury vapor, 

2 for probe start lamps, I mean these should be 

3 projecting down to zero at some point, because they 

4 probably -- I can’t imagine mercury vapor systems 

5 lasting 30 more years. 

6 MR. BROOKMAN: Joe, thank you, and Keith, 

7 thank you. Michael. 

8 MR. MYER: I think those are -- I 

9 appreciate those comments. Those will be 

10 definitely factored into the shipments analysis in 

11 the base case already, based on what you’re telling 

12 us. And just while I have you, do you project 

13 either pulse start or high pressure sodium, which 

14 way that line’s going in roughly, you know, you 

15 were nice enough to prognosticate a year, rough 

16 time window for other technologies? Do you see 

17 high pressure sodium 30 years out, declining, or to 

18 a point? I know it’s a guess, but -- 

19 MR. BROOKMAN: Joe. 

20 MR. HALLEY: That’s harder to project. We 

21 don’t expect, certainly, growth in that area. 

22 Whether utilities will stay with high pressure 

23 sodium. High pressure sodium still is very 

24 efficient from a lumens per watt standpoint, so 

25 that may be the hardest to dislodge with the other 
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1 technologies. That may still have a life, but 

2 that’s a very efficient source right now. Probably 

3 the most efficient HID source we make. 

4 MR. BROOKMAN: Susan. 

5 MS. ANDERSON: I was just going to say one 

6 of the things that’s happening is utility rate 

7 structures, the way they’re set up, they -- in some 

8 cases they can’t accommodate the LED retrofit, so 

9 there’s a huge change going over there and how the 

10 LEDs -- how the utilities have their rates 

11 structure set up. 

12 And something else that’s going on, and 

13 it’s happening at the University -- not the 

14 University of Virginia, but Virginia Tech -- and 

15 we’re participating in it, and I know some of my 

16 other fellow NEMA member companies are -- there are 

17 studies that are being done, as to white light 

18 versus the more golden white light of high pressure 

19 sodium as we like to diplomatically refer to it, 

20 that -- to determine whether seeing in outdoor 

21 applications is better under white light sources 

22 than it is under the more golden white light. And 

23 if that would, in fact, allow people to go to lower 

24 wattage systems than as opposed to using the high 

25 pressure sodium. 
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1 So there’s a lot of research going on in 

2 that area in the white light and color temperature 

3 arena that may have a big impact down the road too. 

4 MR. MYER: I just have one other question. 

5 I appreciate this candid feedback. As regards to 

6 shipments and changes in technology, is it fair to 

7 say that low wattage or low lumen sources are going 

8 to be the first on the bubble to be possibly 

9 replaced by other technologies? And essentially, 

10 you know, as you increase in lumen package or 

11 wattage, it’s going to be harder, not harder, it’s 

12 going to be a more delayed effect before other 

13 suitable other option, since you’re talking about 

14 other technologies outside the HID realm. 

15 MR. BROOKMAN: Susan. 

16 MS. ANDERSON: Yes. 

17 MR. MYER: Thank you. 

18 MR. BROOKMAN: Okay. That was helpful. 

19 MR. MORRIS: Thank you. It sounds like 

20 all the fun is in the shipments part of this. But 

21 jumping back to the national impact analysis, the 

22 Department of Energy will use the DOE national 

23 energy savings and NIA spreadsheet which calculates 

24 energy consumption beginning in the first year of 

25 the analysis period through the end of the analysis 
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1 period. And basically, this slide is especially 

2 important for the item 46, the Department welcomes 

3 any comments on features it would like to see in 

4 the NIA model, as well as any other inputs on the 

5 national impact analysis model. 

6 MR. BOESENBERG: Alex Boesenberg. We sort 

7 of glazed past item 45. I’d like to return to that 

8 for one brief comment, if I may. 

9 MR. BROOKMAN: Yes, please do. 

10 MR. BOESENBERG: The question is, will 

11 these more efficacious, more efficient HID lamps be 

12 operated longer, more, that is, on a given basis 

13 because they’re more efficient? The rebound effect 

14 of, oh, don’t worry, those CFLs are efficient, we 

15 don’t have to turn off the lights in the living 

16 room any more. Because these products are not 

17 residential and don’t have a lot of human 

18 intervention, but rather they are operated on 

19 astronomical clocks or as dictated by sunrise and 

20 sunset, we do not believe that there will be much, 

21 if any, change in operating hours just because 

22 they’re more efficient. Perhaps more popularity, 

23 but not -- they’re just not going to leave street 

24 lights on all day. 

25 MR. BROOKMAN: Gotcha. Okay. Thank you. 
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1 (comment off mic) 

2 MR. BOESENBERG: Yeah, but the alternative 

3 is control systems are getting better, right. 

4 (comments off mic) 

5 MR. MORRIS: So then -- 

6 MR. BROOKMAN: Forty-six, thank you. 

7 MR. BOESENBERG: NEMA has no comment on 

8 item 46. 

9 MR. BROOKMAN: So we’re at a point where 

10 we should decide what to do. It’s noon. It’s five 

11 after noon. The -- typically, the manufacturer 

12 impact analysis takes, I don’t know how long, but 

13 the next -- the utility impact, employment, 

14 environmental, and regulatory impact analysis, 

15 those are downstream analyses, they don’t take very 

16 long to breeze through those. So, do you want to 

17 just keep going? 

18 PARTICIPANTS: Yeah. 

19 MR. BROOKMAN: Strong preference to keep 

20 going. 

21 MS. ANDERSON: We’ve got consensus, yes. 

22 MR. BROOKMAN: I’m with you. Okay. 

23 MR. MORRIS: You hear nods from everybody. 

24 MR. BROOKMAN: I think we can hang in here 

25 for 20 minutes or so. 
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1 MR. MORRIS: Very good. So we’ll jump 

2 into the NOPR analyses. 

3 NOPR Analyses 

4 MR. MORRIS: I will be talking about this 

5 first one. So on the NOPR phase of this 

6 rulemaking, DOE will conduct several additional 

7 analyses to determine how this energy conservation 

8 standard affects things such as customer subgroups, 

9 manufacturers, utilities, and emissions. And I 

10 will briefly discuss the life cycle cost subgroup 

11 analysis. 

12 The LCC subgroup analysis quantifies the 

13 impact of a standard on subgroups of customers 

14 within the general population. Chiefly, DOE will 

15 study the effects of this energy conservation 

16 standard on customer subgroups who may be adversely 

17 affected by the rulemaking. 

18 In the comment box, DOE welcomes any 

19 comments -- I should mention too a couple examples 

20 of possible customer subgroups -- include 

21 utilities, municipalities, and transportation 

22 facilities. The Department would be very 

23 interested in any other subgroups of the population 

24 who might be -- who should be considered in the 

25 rulemaking. 
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1 MR. BROOKMAN: Joe. 

2 MR. HALLEY: I think that subgroups here 

3 to consider as we do these analyses are people who 

4 are using existing mercury vapor systems, or -- if 

5 -- as you’re projecting different levels of 

6 standards, I imagine one of the levels will get to 

7 the point where people using probe start metal 

8 halide lamps are affected at some point, and those 

9 subgroups, the users, are going to be forced to 

10 replace the entire fixture when you get up to that 

11 point. I suppose you could say the smaller users 

12 of those systems, say, school districts that might 

13 just use these in a gymnasium, or something of that 

14 nature, or a smaller retailer accounts, would be 

15 significantly affected if all of a sudden they 

16 could not get the lamp and they have to replace 

17 their entire lighting system with a brand new HID 

18 lighting system. That would have a significant 

19 impact and maybe not -- it would possibly be hard 

20 to cost justify, but certainly you should look at 

21 whether or not that kind of forced behavior could 

22 be cost justified on those smaller user groups. 

23 MR. MORRIS: Thank you, Joe. You 

24 mentioned the school districts, specifically. Can 

25 you mention other entities? 
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1 MR. BROOKMAN: Susan’s going to follow on. 

2 MS. ANDERSON: I was going to say like 

3 community centers. You see a lot of community 

4 centers with HID lighting and like a general 

5 purpose gymnasium facility, or swimming pools and 

6 that sort of thing. Yeah, those are typically 

7 people on a limited budget, where it’s going to 

8 have a much greater impact on them. 

9 MR. BROOKMAN: Okay. Keith. 

10 MR. COOK: Yes, similarly, roadway 

11 lighting ends up being a major issue, and the 

12 problem we’ve got is if you are requiring a 

13 situation where you can’t get a replacement any 

14 longer, the utilities or municipalities or 

15 whatever, then has this significant problem, 

16 because unfortunately roadway lighting pools have a 

17 tendency to get hit by cars, and they don’t want to 

18 have to go through and replace all of them, and 

19 they don’t want one that’s mismatched. And so 

20 you’ll end up with significant push back from those 

21 areas if they have to change out their poles. 

22 MR. BROOKMAN: Susan, keep going. 

23 MS. ANDERSON: Something else I was going 

24 to mention. I worked in the Kansas City market 

25 area for a number of years, both with Holophote 
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1 (ph) and with Sylvania. We sold roadway lighting 

2 systems, high mass lighting systems. And they -- 

3 the state of Kansas had an interesting philosophy 

4 when they did roadway lighting. They did the 

5 interchanges with metal halide, and then they did 

6 the roadways leading up to the interchanges with 

7 high pressures sodium. And had a couple good 

8 reasons for that. The color change signaled a 

9 change to the drivers, and then where the accidents 

10 were most likely to happen were in the congested 

11 areas of the interchanges, so they had better color 

12 rendering for all the investigative purposes, and 

13 for eyewitness accounts and that sort of thing. So 

14 they had a very distinctive purpose in wanting to 

15 have two distinctive colors. And the high pressure 

16 sodium was the more efficient, so it was used 

17 covering the greater area, but then in the more 

18 critical area they used the metal halide. So 

19 there’s value in different technologies. 

20 MR. BROOKMAN: Alex, did you have -- 

21 nothing there. So additional comments on subgroups 

22 as requested, and also 49. 

23 MR. MORRIS: Okay. Thank you. I’ll turn 

24 the time over to Merry Walker. 

25 Manufacturer Impact Analysis 
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1 MS. WALKER: The purpose of the 

2 Manufacturer Impact Analysis or also known as the 

3 MIA, is to identify the impacts of energy 

4 conservation standards on manufacturers, 

5 manufacturers subgroups, and the cumulative 

6 regulatory burden on the industry as a whole. DOE 

7 does this by analyzing the industry cash flow and 

8 net present value through the GRIM, or the 

9 Government Regulatory Impact Model, and 

10 interviewing manufacturers to assess the impact of 

11 standards, both qualitative and quantitative. 

12 The analysis methodology is broken into 

13 three main phases. The first is in which DOE 

14 creates an industry profile to characterize the 

15 industry and to identify the key uses in 

16 manufacturing. The second phase, DOE prepares an 

17 industry cash flow model with the GRIM that takes 

18 into account any investment and revenue changes 

19 that the industry might experience, and an 

20 interview questionnaire to guide interviews with 

21 manufacturers. In phase three, DOE interviews 

22 manufacturers, assesses the impacts of standards, 

23 both quantitative and qualitative, looking at the 

24 impacts on competition, manufacturing capacity, 

25 employment, and regulatory burden. 
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1 With that, DOE seeks comment on the HID 

2 lamp manufacturer subgroups and regulations that 

3 DOE should consider in examining cumulative 

4 regulatory burden. 

5 MR. BROOKMAN: Keith. 

6 MR. COOK: One concern that we’ve got is 

7 the fact that along with the new potential 

8 rulemaking comes significant testing and reporting 

9 requirements. And as we’ve discussed in previous 

10 Meetings, this can be significant due to the number 

11 of subgroups we may end up with, within the HID 

12 family. And, you know, we’ve estimated per 

13 manufacturer, the testing could easily exceed a 

14 million dollars per year on a market that’s flat, 

15 as we’ve already discussed, flat at best, and 

16 probably even diminishing. 

17 That amount of testing ends up being a 

18 significant burden to the smaller manufacturers who 

19 aren’t even really represented here today, to the 

20 point where it could lead to them getting out of 

21 the market entirely if we’re not careful. So this 

22 has a significant impact in, like I said, a market 

23 that’s not growing, and we’re very concerned with 

24 it. 

25 MR. BROOKMAN: Okay. Thank you. Susan. 
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1 MS. ANDERSON: To add to that, there was a 

2 suggestion made that instead of looking at initial, 

3 to look at mean lumens and maintained lumens. 

4 These are very long-lived products, so by the time 

5 we get to 40 or 50 percent of rated life, which the 

6 metal halide, mean lumens are measured at 40 

7 percent, for mercury vapor and HPS it’s at 50 

8 percent of rated life. That’s thousands of hours 

9 of operation, and you’re talking about huge 

10 electricity bills, and not just from operating the 

11 systems, but then the necessary cooling for those 

12 facilities where we use those. There’s a huge 

13 expense, an investment in the equipment, and then 

14 the operating expense will be huge. 

15 MR. BROOKMAN: Okay. You can see the 

16 request for comment there, 48 and 49. Additional 

17 comments, and particularly -- have we heard about 

18 cumulative regulatory burden yet? Yes, Joanna. 

19 MS. MAUER: Joanna Mauer. If I can just 

20 ask a follow up question to Susan. We’re talking 

21 about measuring mean lumens, would that be 

22 something different than what you’re -- because you 

23 often report mean lumens in catalogs. Would this 

24 be additional testing? 

25 MS. ANDERSON: But we don’t do it on the 
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1 number of lamps that we’re anticipating the DOE 

2 might require us to do. So you’re talking about a 

3 significant additional investment. 

4 MR. BROOKMAN: Alex. 

5 MR. BOESENBERG: Alex Boesenberg. So to 

6 follow up on Susan’s statement. We did provide 

7 our best estimates in the test procedures NOPR over 

8 potential costs and comments on the, not only cost 

9 of performing the testing, but the cost of test 

10 rigs and things like that. Everything that adds 

11 costs increases the burden. We will mention in our 

12 written comments several additional considerations 

13 for cumulative regulatory burden, and I am 

14 personally open to being involved in the 

15 discussions of that, both to better understand it 

16 myself, and better represent the interests of the 

17 members. 

18 But the reason NEMA created a manager of 

19 regulatory affairs is our existing legislative 

20 regulative guy couldn’t handle the workload, and 

21 we’ve even had to add another position for state 

22 regulation. I consider it job security, but I’ve 

23 always enjoyed putting myself out of a job by 

24 getting a system streamlined or properly set up. 

25 I’m never worried about finding work. Personally, 
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1 as I said, I would like to see open discussions to 

2 better understand the models being used to quantify 

3 and estimate regulatory burden, because industry -- 

4 we are trying to figure it out ourselves. 

5 But so many companies make multiple 

6 products, and almost every one’s got a regulation 

7 or is slotted for one. These are the same people 

8 you saw at the last rulemaking, and these are the 

9 same people you saw at the one before that. We can 

10 only do so much. 

11 MR. BROOKMAN: Okay. I’m with you. Do 

12 you have something here, Matthew? 

13 MR. WALKER: Yes, I had a question back on 

14 the small business impacts. I was curious if you 

15 had kind of estimates of number of lamps that those 

16 types of companies would sell, or what the size of 

17 those businesses would be. Is that something you 

18 can talk about? 

19 MR. BROOKMAN: Keith. 

20 MR. COOK: I would say you really need to 

21 try and approach them to try and get that 

22 information. 

23 MR. WALKER: We will include that, I was 

24 just ready for a sneak peek. 

25 MR. BOESENBERG: That’s something, when 
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1 you come to me, to NEMA, to discuss how to obtain 

2 the lamp shipment and technology shipment sales 

3 data, that’s a good question to ask at that time 

4 when I have a NEMA business office there, they will 

5 be able to answer it, whether or not that’s 

6 something we’re able to parse out -- I mean, we 

7 know who we get the information from, but we have 

8 very strict laws, internal bylaws, regarding the -- 

9 what’s the right word -- the disclosure, thank you 

10 -- you knew what I was saying -- the disclosure of 

11 sales per company. So we usually aggregate the 

12 data and anonymize it. But relative to your 

13 question, we may be able to provide, I can’t 

14 promise, but it comes to my mind that we do have 

15 small manufacturers, so for a given product type, 

16 we may be able to give you the aggregate small 

17 business sales or something. I don’t know. That’s 

18 a question we have to put not only to the NEMA 

19 business office, but probably to the NEMA lawyers. 

20 MR. BROOKMAN: Okay. 

21 MS. WALKER: I have just one follow up 

22 question to NEMA. I was wondering if we could also 

23 receive some feedback on the percentage of all lamp 

24 manufacturers, specifically HID lamp manufacturers, 

25 that are part of NEMA. I know that the percentage 
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1 is very high, but it would be nice just to 

2 understand approximately what percentage of the 

3 lamp manufacturers are part of NEMA. 

4 MR. BOESENBERG: I’ll see what we can do. 

5 MS. WALKER: Okay. Thank you. I will 

6 pass it on to Michael Myer. 

7 Downstream Analyses 

8 MR. MYER: Thanks, Merry. As Doug said, I 

9 will be doing the remainder analyses which happen 

10 downstream, which means they happen not in the 

11 interim analysis, but in the NOPR analysis itself. 

12 The first one that happens is the utility 

13 impact analysis. The focus of the utility impact 

14 analysis is to examine the effects of potential 

15 standards on electricity generation. We use a 

16 model called the National Energy Modeling System, 

17 NEMS. It’s been modified for the DOE buildings 

18 technology program, so it’s designated as NEMS-BT. 

19 We use some AEO data regarding generation. We 

20 model what the energy savings effects could be from 

21 standards compared to non-standards, and get a 

22 differential, and the output is what the deferred 

23 generating capacity could be. 

24 Brings us to item 50. We seek comment on 

25 input or plans to use NEMS-BT and conduct the 
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1 utility impact analysis. 

2 MR. BROOKMAN: Alex. 

3 MR. BOESENBERG: Alex Boesenberg. We 

4 suggest the government follow up with that at the 

5 individual manufacturer interviews. 

6 MR. MYER: The follow on question. 

7 There’s something in there specific to each 

8 manufacturer regarding utility generation? 

9 MR. BOESENBERG: This is a topic we 

10 historically do not have a lot of comments on, is 

11 the best way to answer your question. I wish I 

12 understood NEMS, but I haven’t had the time. 

13 MR. BROOKMAN: Thank you. 

14 MR. MYER: Moving on. The next one is 

15 employment analysis. This -- the manufacturers 

16 impact analysis just looks at direct employment on 

17 the manufacturers. The employment analysis looks 

18 at indirect employment effects. It does look at 

19 both, direct and indirect, but the ultimate output 

20 is about indirect. It also uses a model, and this 

21 one is the Impact Sector Energy Technologies Model 

22 to look at the indirect employment analysis. 

23 Again, it looks at what the potential effect on -- 

24 indirect employment could be as a result of 

25 standards. 
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1 Item 51, DOE requests feedback on its 

2 approach to assessing employment impacts for the 

3 equipment covered. 

4 MR. BROOKMAN: Alex. 

5 MR. BOESENBERG: Alex Boesenberg. This is 

6 another topic that varies greatly, I would venture 

7 to say, by individual company and their policies, 

8 and their individual geographic and regional 

9 considerations. So we have to defer to the 

10 manufacturer interviews for that. 

11 MR. BROOKMAN: Thank you. John. 

12 MR. GREEN: Yes, I understand you’ll 

13 probably be interviewing lamp manufacturers, but 

14 will interviews be done for other companies that 

15 may be impacted by this, such as ballast and 

16 luminaire manufacturers? It was just a question. 

17 MR. MYER: At this time, yes, lamp 

18 manufacturers are the only ones being interviewed, 

19 but it is something we will take into 

20 consideration, interviewing -- besides the ballast 

21 and fixture manufacturers, are there other 

22 manufacturers that could be potentially affected? 

23 MR. GREEN: Those are the two that come to 

24 mind, but they could have some input on the impact 

25 on employment, so that’s why I brought it up here. 
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1 MR. MYER: We appreciate it, thank you. 

2 MR. BROOKMAN: Additional comments? None. 

3 MR. MYER: The next one is the emissions 

4 analysis. Those who are familiar with the process 

5 might know this better as the environmental 

6 assessment. Same type of idea, just a new name. 

7 The whole point of the emissions analysis is to 

8 look at the environmental effects resulting again 

9 from energy standards, and changes in power plant 

10 emissions. There’s four emissions that we look at: 

11  Carbon dioxide 

12  Sulfur dioxide 

13  Nitrous oxides, and 

14  Mercury. 

15 Carbon dioxide is the main emission that 

16 is reported and reviewed. Because of existing 

17 legislation on sulfur dioxide, not major changes 

18 are expected, near zero is usually the way we 

19 describe it. With nitrous oxide, it’s kind of a 

20 mixture. There are caps in 28 states, and so we 

21 look at the effects of nitrous oxides in the non22 covered 22 states. And then also we will report 

23 possible mercury emissions being affected because 

24 of all the standards. 
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1 Item 52, DOE seeks input on its plans 

2 again to use the NEMS-BT model to modify slightly 

3 to look at the different effects on emissions for 

4 this standard. 

5 MR. BROOKMAN: Alex. 

6 MR. BOESENBERG: NEMA has no specific 

7 comments to this. 

8 MR. HALLEY: I just have one thought is 

9 that I believe that the EPA has passed requirements 

10 for utilities to limit mercury emissions as well in 

11 the next few years, so if that has not been 

12 incorporated in this analysis before, you may want 

13 to look into that rulemaking, and see if that 

14 requires -- I believe it affects coal fired power 

15 plants primarily. 

16 MR. MYER: I don’t know the exact extent 

17 of it, but yes, there was some recent work done 

18 related to mercury. It was added into the 

19 framework because it happened really recently as 

20 well, and since this is a downstream analysis, we 

21 will look at whatever the new guidance is, the new 

22 requirements are. But thank you for the direction. 

23 MR. BROOKMAN: Alex. 

24 MR. BOESENBERG: Since we’re pretty much 

25 at the end and we’re ahead of schedule, I hope 
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1 you’ll entertain a couple questions about NEMS. 

2 You talk about using it for an environmental 

3 analysis. Does that mean that if it will greatly 

4 reduce carbon dioxide emissions, then it’s a good 

5 idea? How does NEMS weight this? If you got rid 

6 of all street and area lighting, boy would we save 

7 a lot of electricity and reduce carbon dioxide 

8 consumption. Accidents and deaths might go up. So 

9 I’m just curious, what’s the tool to balance all 

10 that? 

11 MR. MYER: That’s actually a fair 

12 question. This slide, monetization, helps with 

13 some of that. So yes, there is some monetization 

14 related to that. If you read the NOPR analysis, it 

15 does provide a breakdown of many things that are 

16 important. So when something goes from a NOPR 

17 which is a Notice of Proposed Rule, to the Final 

18 Rule stage, there’s a whole -- the NOPR includes a 

19 whole list of things such as what this standard 

20 would potentially have the effect on employment; 

21 what it would have on costs; what it would have on 

22 emissions. I would say that there’s no one guiding 

23 rule, no bright line test that says if emissions 

24 went to this value then it’s a go, because 

25 conversely, as you said, there’s some other 
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1 possible effects resulting from turning off all 

2 street lighting, something like that. So it’s a -- 

3 there’s no one guiding principle that says if you 

4 meet this bar, then it goes forward. It looks at a 

5 lot of potential effects. Again, employment, 

6 direct and indirect; net present value, both the 

7 industry net present value as well as the energy 

8 savings and generating capacity. 

9 MR. BOESENBERG: Thank you. That’s a very 

10 good explanation and I appreciate it. So that 

11 leads to the follow on concern that is far too 

12 complex for us to really be able to comment on. I 

13 have some discomfort with it, I hope you’ll 

14 understand, I don’t know. 

15 MR. BROOKMAN: I’m sure that there are 

16 many resources here in the room and elsewhere in 

17 the Department that would, perhaps when they come 

18 to see you, they could give you more of a fuller 

19 explanation on NEMS. 

20 MR. BOESENBERG: I welcome that, thank 

21 you. 

22 MR. BROOKMAN: Okay. Thank you. 

23 MR. MYER: So I briefly made mention of 

24 the monetization of emissions. We’re going to use 

25 the social cost of carbon. The second bullet here 
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1 kind of provides -- there’s different intra-agency 

2 reviews of the social cost of carbon. They range 

3 from 4.9 to 67.6 dollars per metric ton -- those 

4 are in 2010 dollars. I’m sorry? 

5 MR. HALLEY: It’s a big range. 

6 MR. MYER: Yes, Joe, it is a wide range, 

7 and there’s many things that factor that. There 

8 are different discount rates and it’s actually 

9 there’s a lot of different caveats of why it’s a 

10 different range in different analyses. They’re all 

11 reported in different tables within the NOPRs. And 

12 then we also estimate the potential monetary 

13 benefit of reduced nitrous oxide emissions 

14 resulting from considered ... 

15 The final analysis that is done in the 

16 NOPR analysis is the regulatory impact analysis. I 

17 always personally find the regulatory impact 

18 analysis somewhat contradicting in title, because 

19 it actually says what could be done in -- separate 

20 from a standard, such as a non-regulatory action. 

21 Non-regulatory alternatives can be customer 

22 rebates, customer tax credits, manufacturer tax 

23 credits, voluntary targets, early replacement and 

24 bulk government procurement. Again, we use -- in 

25 this case we use the national energy spreadsheet. 
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1 It’s modified to say well, what if we did this, 

2 what if we did this, to estimate the effects of 

3 non-regulatory scenarios, based on experience with 

4 considered policies. 

5 And the outputs are again, national energy 

6 savings, and net present value for the described 

7 non-regulatory alternatives. 

8 MR. BROOKMAN: Susan. 

9 MS. ANDERSON: It’s interesting that you 

10 mention the other alternatives. Right now there is 

11 legislation, it’s Senate Bill 398, that would, in 

12 the case of outdoor lighting, one of the provision 

13 in it would be to eliminate mercury vapor for 

14 general lighting applications, the lamps -- the 

15 ballasts are already gone. 

16 But something else, right now there’s -- 

17 are you familiar with the Commercial Building Tax 

18 Deduction Program? 

19 MR. MYER: Yes. 

20 MS. ANDERSON: It’s a federal program. 

21 Right now it only includes indoor lighting. It 

22 doesn’t cover outdoor lighting. You know, a lot of 

23 HID is used outdoors. And that’s -- 

24 MR. HALLEY: (comment off mic) 

25 MR. MYER: Just some clarification for 
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1 those in the room and those who may not be familiar 

2 with it. It’s -- the deduction that Susan and Joe 

3 are referring to was part of EPACT. It gives a 

4 proportional income tax deduction, not a credit, 

5 related to reduction in installed power density 

6 against standard 90.1 2001. From my understanding, 

7 I think -- and it does not cover outdoor. The only 

8 quasi outdoor activity it does cover is parking 

9 garages, which the IRS ruled under an interim rule 

10 that they are a non-conditioned indoor space. So I 

11 know that there is some review of that ongoing by 

12 other agencies as well, that legislation, but I 

13 just wanted to clarify that it is a deduction, not 

14 a credit. But thank you for the suggestion or to 

15 possibly look at the effect of it. 

16 MS. ANDERSON: Yeah, I mean there were a 

17 couple reasons why they didn’t cover it to begin 

18 with, because 90.1 only covers systems that are 

19 managed by the power system of the building, and a 

20 lot of outdoor lighting is not. But still, there’s 

21 a huge opportunity for energy savings if there were 

22 some sort of incentive there to get people to 

23 convert outdoor lighting to something more energy 

24 efficient. 

25 MS. deBUTTS: We will definitely consider 
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1 that and since the folks that work on that program, 

2 you know, are close by as well, so we thank you for 

3 the remarks and we’ll see if we can include that. 

4 MR. MYER: Yes, I had one question for the 

5 manufacturers who are reviewing it. One of my 

6 concerns about it is that ... it’s not always used in 

7 interior applications, especially related to HID is 

8 the bilevel provision. Do you have any thoughts on 

9 how the bilevel provision related to HID lighting 

10 could be addressed related to -- there’s a 

11 requirement that the lighting has to have a bilevel 

12 aspect to it. 

13 MS. ANDERSON: We’re actually working on 

14 that in order to accommodate new standards that 

15 will be coming out in California. 

16 MR. MYER: Thank you. 

17 MS. ANDERSON: So, with metal halide you 

18 can’t -- you don’t have this infinite dimming range 

19 or anything like that, like you can with 

20 fluorescent, but you can step it down, so there -- 

21 and there also already have been some studies done 

22 by California Lighting Technology Center on 

23 implementing that type of system. 

24 MR. BROOKMAN: I see. Joe. 

25 MR. HALLEY: To that point, the tax 
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1 incentives so far has been to promote people taking 

2 out a HID systems out of warehouses and putting in 

3 fluorescent systems that can be more easily 

4 bileveled, controlled. And so it’s -- that’s 

5 another -- other regulatory activity that’s going 

6 on that we hadn’t mentioned to date, that you 

7 should consider in your analysis. That of course, 

8 just continues through 2013, unless Congress 

9 decides to extend it. The last time, they decided 

10 to extend it five years. All bets are off with 

11 what this Congress may do. But that’s a 2013 

12 Congress that hasn’t been elected yet either, so 

13 I’m not sure what they might do next year. But 

14 that should be taken into account as well, perhaps, 

15 as another factor that is impacting the HID 

16 marketplace. Not in a positive way, in a negative 

17 way. 

18 MR. MYER: Thank you. 

19 MR. BROOKMAN: Alex. 

20 MR. BOESENBERG: Alex Boesenberg. I have 

21 one clarifying question for this slide, non22 regulatory alternatives for the regulatory impact 

23 analysis. So am I correct when I say that your 

24 analysis is in that how non-regulatorial 

25 alternatives such as those listed might reduce the 
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1 opportunity for energy savings from the rule and 

2 somehow they impact -- encourage energy savings any 

3 way or already, but you’re not considering new 

4 ones, is that right? Because I don’t know how the 

5 Department would extend the Commercial Building Tax 

6 Deduction, even if they agree with it. 

7 MR. MYER: Well, there’s definitely a 

8 mixture of things here. Certain -- the six items 

9 listed there, some are not actually promoted by -- 

10 customer rebates, obviously, would not come from 

11 the government, would come from -- 

12 MR. BOESENBERG: We’re open to that 

13 option. 

14 (Laughter.) 

15 MR. MYER: So the way I tend to think of 

16 this in my head is that we look at what the 

17 national energy savings are, which is reported in 

18 quads of energy savings, and the net present value, 

19 which is dollar amount from the standards case. 

20 And then what could it be from these potential 

21 other alternatives. As Joe was saying that you’re 

22 seeing other incentives push away from HID. Is 

23 there greater savings from not doing a standard but 

24 encouraging manufacturers to retool or to upgrade 

25 through a tax credit, rather than a regulatory 
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1 compulsory action, but financially - the carrot, I 

2 guess is the best example -- rather than requiring 

3 them, you must be this efficient, or rather saying, 

4 you know, you can write of much faster deduction of 

5 upgrading to a new machine that develops this type 

6 of lamp. So that’s what it is, it’s a comparison 

7 of could they do other things that are not standard 

8 driven. 

9 MR. BROOKMAN: Okay. So comments on -- 

10 additional comments on the regulatory impact 

11 analysis? 

12 MR. MYER: At this time -- 

13 MR. BROOKMAN: Then now we have an 

14 opportunity to have additional comments, anything 

15 that we haven’t covered already today that perhaps 

16 some of you even have notes on, being as well 

17 prepared as you are. 

18 MR. BROOKMAN: Susan, microphone. 

19 MS. ANDERSON: We wanted to go back to 

20 eight, nine, ten, and eleven, and actually Tom 

21 Harding has the expertise to comment on those. 

22 Those were things impacting the -- where we were 

23 allowed to make additional comments related to the 

24 test procedure. 

25 Final Comments 
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1 MR. HARDING: Yes, being the 12:30 time, 

2 just because you wanted to hear from me. Quickly, 

3 I’ll make it in five minutes, I think, unless you 

4 have a lot of questions. 

5 Item eight, which is welcoming comments on 

6 test procedures, and particularly for photometry, 

7 and it was an open-ended question on integrating 

8 spheres specificity, and LM78, and the answer is 

9 that’s fine. We accept LM 78, the information 

10 needed to photometer these HID lamps is all in 

11 there. It related to source size versus sphere 

12 measurement size. It’s all in there. We accept 

13 that. It’s also related to the CIE recommendations 

14 on that. 

15 MR. BROOKMAN: Michael. 

16 MR. MYER: Michael Myer, Pacific Northwest 

17 National Laboratory. I’m supporting the test 

18 procedures. I just have one question. During the 

19 test procedure meeting, there was comment about LM 

20 51 being updated. We were forwarded a draft copy 

21 of LM 51 and it appears that a fair amount of the 

22 new stuff in LM 51 is also related to sphere 

23 specificity, and do you feel that LM 78 covers 

24 enough of that, or do you still will you direct us 

25 back to the new -- currently revised version of LM 
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1 51? 

2 MR. HARDING: Well, I haven’t seen the 

3 revised version of LM 51. I am familiar with the 

4 document, but I haven’t seen any revision of it 

5 yet, so I don’t know what they’ve changed in it. I 

6 don’t think it’s a big issue. I think we’re all 

7 fine that there’s historically a ten to one ratio 

8 from lamp arc size or source size to sphere 

9 diameter, and I don’t see that that’s changing. 

10 Item nine was the document -- NEMA 

11 standard, SD 26, which was on tolerancing, it’s not 

12 been a published document, and because of all this 

13 regulatory work, we’re revising it very regularly, 

14 a couple times a month, and we started with 

15 incandescents, added fluorescent, it’s now adding 

16 HID. It’s including not just lamps, it’s including 

17 ballasts. And it deals with the standard 

18 deviations of all these measurements. And inherent 

19 in the source, as well as from lab to lab kind of 

20 things. So we’re trying to put that all in, and 

21 it’s a very active group, mid-year is kind of our 

22 target date to have this all out. But once you 

23 know the statistics, you may be able to do better 

24 plans for measuring these things. 

25 MR. MYER: Michael Myer, Pacific Northwest 
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1 National Laboratory. I’m sorry, so mid-year, so 

2 would that be summer of 2012? 

3 MR. HARDING: I’m guessing. I don’t have 

4 a firm date. It’s winding down, I know that, 

5 because we’ve submitted all our data. I just don’t 

6 know what NEMA’s looking at a target date, but we 

7 said mid-year and I believe -- there’s discussions 

8 and I believe that’s about right. 

9 Item ten was the use of NAVLAB accredited 

10 testing facilities. Data normally submitted to 

11 these things come from NAVLAB facilities, but the 

12 way the lighting companies work, they typically 

13 have one setup, on sphere system for light sources 

14 that’s NAVLAB accredited. But the data is often 

15 taken at the factories where they produce the 

16 product, they pull samples out, put them on test 

17 and do the data. So the data bases we all have are 

18 not on NAVLAB systems. And they’re expensive to 

19 maintain, that’s why basically each company has 

20 one. So if we’re going to require a lot more data 

21 like this light testing data in particular, which 

22 is normally done at the plants, we have a NAVLAB 

23 situation. We’ve either got to overload the 

24 central unit, if we’re not careful, or we’ve got to 

25 diversity out to some of the plants to make them 
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1 NAVLAB approved. 

2 MR. BROOKMAN: Those labs in the plant, 

3 are they somehow NAVLAB certified or something? 

4 MR. HARDING: No, I don’t think they’re 

5 anything, they’re just their own place. Now they 

6 often try to correlate the data to the central 

7 NAVLAB-approved system, but it’s not directly 

8 NAVLAB measured. 

9 MR. BROOKMAN: Michael. 

10 MR. HARDING: It’s used as a correlation 

11 headquarters, if you like, to make sure the plants 

12 stick there. 

13 MR. MYER: Michael Myer, Pacific Northwest 

14 National Laboratory. I guess -- I read the written 

15 comments related to NAVLAB, and I was a little 

16 confused. So it appeared that in NEMA’s written 

17 comments related to NAVLAB, they were supportive of 

18 NAVLAB for color measurements, and you just said 

19 now but NAVLAB is hard for -- 

20 MR. HARDING: Well, efficacy and color. 

21 MR. MYER: So you were going to be okay 

22 with that -- I guess that’s the clarification. So 

23 NAVLAB for efficacy and color is fine, but when 

24 something that’s a long term, such as lumen 

25 maintenance, there’s a burden -- not burden, but a 
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1 potential, as you said, of overloading the center -

2 - not enough ... space. 

3 MR. HARDING: There is that, yes. 

4 Efficacy of course is what you’re measuring 

5 anyway. There was an issue when it came to 

6 incandescent, general service incandescent 

7 lighting, you know where there was a life 

8 requirement of 1000 hours and we’re saying, how do 

9 you do 1000 hour light verification in a NAVLAB 

10 facility? That was an issue. 

11 But everybody will agree that lumens and 

12 color can easily be done there, in any NAVLAB 

13 facility. The issue is how much money has to be 

14 spent to bring all this life testing into 

15 compliance with NAVLAB. In other words, do we have 

16 to now NAVLAB approved factories where the data is 

17 taken? Do we have to expand the central NAVLAB 

18 facility? All of that costs money, manpower, and 

19 equipment, as well as the certification cost, which 

20 is not maybe so bad for huge corporations, but for 

21 some of the smaller companies, it’s significant, 

22 let me tell you. I’ve been having trouble getting 

23 the money allocated. 

24 Those are the items that we had skipped 

25 over. I think that was all of them. Oh, the 
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1 sample size one, yeah. Sorry. We did look at 

2 sample sizes where 21’s one of the going numbers 

3 that’s thrown around. We’re kind of reserving our 

4 own judgment until we get done with this LSD 26 

5 paper and know some of the statistics. Knowing 

6 some of the statistics will help us perhaps make a 

7 better recommendation as to how to do it. 

8 One of the things is, if we have to do 

9 long life testing, how do you choose, for example, 

10 the infamous three lamps a month over seven months 

11 in a 12 month period, and then put them all up for 

12 life testing. Or do you put them up three a month? 

13 And then you’ve got staggered outputs or one 

14 thought is maybe we do a chunk at the beginning if 

15 we have to do this kind of testing. But we wanted 

16 to see what the statistics showed up, and this LSD 

17 26 working group is looking at this one as well. 

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

19 MR. BOESENBERG: Alex Boesenberg, NEMA. 

20 And as a reminder, we did submit comments on a 12 

21 lamp sample size in our test procedures NOPR 

22 response and we continue to stand by that. It’s a 

23 very challenging number at that size for the 

24 equipment, manpower, and cost of performing those 

25 tests. 
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1 MR. BROOKMAN: Okay. Thank you. 

2 MR. BOESENBERG: A thousand watt lamps, 

3 boy does that burn a lot of juice. 

4 MR. BROOKMAN: Thank you. So you seem 

5 quite systematic. Michael, go ahead. 

6 MR. MYER: Michael Myer. Reading the NEMA 

7 comments and going back to what Tom was saying 

8 about three lamp samples per month, is it fair to 

9 say that unlike other lamp technologies that 

10 production runs are not continuous for certain HID 

11 lamps, or that if they’re continuous they happen on 

12 maybe a more staggered cycle and there’s not 

13 monthly? It would be, you know, six or eight 

14 weeks, some longer -- some more intermediate period 

15 than a monthly lamp run? 

16 MR. BROOKMAN: Tom. 

17 MR. HARDING: Tom Harding. Depends on the 

18 type. There’s some very specialized products, 

19 well, I shouldn’t say specialized, lower volume 

20 products, and you’re not going to run those all the 

21 time. You’re going to do it at intervals. The 

22 more higher production, higher sales items, you’re 

23 going to run more often. So it does vary. I don’t 

24 know, I can’t speak for the other companies, so I 

25 don’t know how often they run the various types. 
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1 We do them, of course, in significant enough runs 

2 to justify the equipment setup. 

3 MR. BROOKMAN: Now is an opportunity to 

4 make any additional comments, raise additional 

5 issues that haven’t been covered fully and seems as 

6 though you all had quite a lot of preparation that 

7 went into this. I’m certain the Department really 

8 appreciates that. Anything else that you’d like to 

9 raise at this point? Because we’re nearing the 

10 close of this meeting. Nothing additional at this 

11 time? So back to then, Lucy deButts for closing 

12 remarks. 

13 Closing Remarks 

14 MS. deBUTTS: Sure. Well, again I would 

15 like to thank everyone for providing us with your 

16 input. I think it was a very interesting 

17 discussion, and we got a lot of good information 

18 from you guys, so thanks. In case you want to 

19 submit written comments which we expect from you 

20 and appreciate, there are several avenues for you 

21 to do that. As usual, when you submit written 

22 comments please address the rulemaking, provide the 

23 docket number, and refer to the ... for that 

24 rulemaking when you’re providing written comments. 

25 We encourage you to submit them through 
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1 the regulations.gov, you know, or through the e2 mail address shown here on this slide. However, if 

3 there are difficulties to doing it electronically, 

4 there’s always an option to send it in the postal 

5 office or courier, as shown here. And Brenda 

6 Edwards, who we met earlier and in all the previous 

7 meetings, will be taking care of the comment 

8 collection. 

9 So again, comment period is closing on 

April 12th 10 , and we extended it to accommodate 

11 everybody as much as we can. We have to consider 

12 the test procedures so we’d like to get your 

comments by April 12th 13 if possible. 

14 And again, if you’d like to give 

15 additional information or you need to access the 

16 framework document, or agenda, and the transcript 

17 of this meeting, these are the links that will be 

18 useful for you to consider. So the website and 

19 each product pages. 

20 Any questions on that? 

21 MR. BROOKMAN: There’s one more thing. 

22 The Department frequently provides a Xerox copy of 

23 the business cards of the individuals that have 

24 checked in, and I see Brenda is going to be handing 

25 out a copy of that right now for your reference. 
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1 MS. deBUTTS: So at this time, any 

2 questions, and if -- before we conclude? Well, 

3 Doug, it’s back to you. 

4 MR. BROOKMAN: Thanks to all of you. 

5 Appreciate it, and safe travels. 

6 (Whereupon, at 12:46 p.m., the meeting in 

7 the above captioned matter was adjourned.) 

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 REPORTER'S CERTIFICATE

 This is to certify that the attached proceedings 

before: 
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U.S. DEPARTMENT OF ENERGY 

In the Matter of: 

 

PUBLIC MEETING ON THE ENERGY CONSERVATION STANDARD 

FRAMEWORK DOCUMENT FOR 

HIGH-INTENSITY DISCHARGE LAMPS 

 Were held as herein appears and that this is the 

original transcript thereof for the file of the 

Department, Commission, Board, Administrative Law 

Judge or the Agency. 

 Further, I am neither counsel for or related to 

any party to the above proceedings. 

 

 

Wendy Greene 

 Official Reporter 

Dated: April 3, 2012