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, MDExecutive Court Reporters (301) 565-0064 2 **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 EnergyExecutive Court Reporters (301) 565-0064 3 **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 ConsultingExecutive Court Reporters (301) 565-0064 4 **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 169Executive Court Reporters (301) 565-0064 5

P R O C E E D I N G S 1 MR. BROOKMAN: Let’s start. Just take 2 your seats. Good morning everyone and welcome. 3 This is the U.S. Department of Energy’s public 4 meeting on Energy Conservation Standard Framework 5 Document for High-Intensity Discharge Lamps. Today 6 is Thursday, March 29, 2012 here in the Forrestal 7 Building in Washington, D.C. My name is Doug 8 Brookman from Public Solutions in Baltimore. So 9 happy to see you here this morning. 10 We’re going to start off with welcoming 11 remarks from Lucy deButts. 12 **Welcoming Remarks** 13 MS. deBUTTS: Hi everyone. I am Lucy 14 deButts, Project Manager for DOE’s lighting team. 15 Some of you may have already talked to me and some 16 not, but Tina Carlsburg, the previous manager is on 17 detail, so currently I am leading the team. Again, 18 welcome to our public meeting today. I’d like to 19 start by reminding everyone that the Notice of the 20 Public Meeting and the availability of framework 21 document was published in the Federal Register on 22 February 28 th . We also have it on DOE’s website for 23Executive Court Reporters (301) 565-0064 6 stakeholders to review, so feel free to go to the 1 website and read the documents. 2 We will provide an overview of the HID 3 approach today. We will talk about the history a 4 little bit of HID standards and scope of coverage 5 and analyses that DOE is planning on taking. So 6 looking forward to industry’s input and hoping for 7 your collaboration in this -- and cooperation in 8 this process. So at this time, I’d like to give it 9 back to Doug for further introductions. He is the 10 meeting facilitator and he will set some ground 11 rules and go over the meeting agenda. 12 MR. BROOKMAN: Thank you. Let’s start 13 over here. Give your name, and organizational 14 affiliation, and give you practice at turning these 15 microphones on and off. The little green button 16 needs to be illuminated. 17 **Introductions** 18 MR. HALLEY: Thanks, Doug. This is Joe 19 Halley, Manager of Industry Relations for GE 20 Lighting, and also chairman of the NEMA lamp 21 section. 22 MS. ANDERSON: Susan Anderson, Osram 23 Sylvania and I’m the Manager of Energy Relations. 24 MR. COOK: Keith Cook, Phillips 25Executive Court Reporters (301) 565-0064 7 Electronics. 1 MR. HARDING: Tom Harding, Venture 2 Lighting. 3 MR. GREEN: John Green, Cooper Lighting. 4 MS. MAUER: Joanna Mauer, Appliance 5 Standards Awareness Project. 6 MR. YOUNG: Daniel Young, California 7 Investor-Owned Utilities, Pacific Gas and Electric, 8 Southern California Edison and Semper Utilities 9 MR. MORRIS: Scott Morris, Pacific 10 Northwest National Laboratory. 11 MR. MYER: Mike Myer, Pacific Northwest 12 National Laboratory. 13 MR. BROOKMAN: You can just stand up, 14 that’ll be sufficient. 15 MR. WALKER: Matthew Walker, Navigant 16 Consulting. 17 MS. WALKER: Merry Walker, Navigant 18 Consulting. 19 MS. EDWARDS: Brenda Edwards, Department 20 of Energy. 21 MR. BROOKMAN: Please. 22 MS. TUCKER: Nancy Tucker, Navigant 23 Consulting. 24 MS. KOHL: Betsy Kohl, DOE, GC. 25Executive Court Reporters (301) 565-0064 8 MR. CHESTER: Matt Chester, Navigant 1 Consulting. 2 MR. BROOKMAN: Okay. Thanks to all of you 3 for being here. 4 **Agenda Review** 5 MR. BROOKMAN: All of you received a 6 packet of information as you came into the room. In 7 there was a copy of the agenda, and the PowerPoint 8 slides that will be the basis for both presentation 9 and discussion today. And also a copy of the 10 Federal Register Notice. 11 I’ll give you a very brief agenda review. 12 You can see that following this agenda review and a 13 few preparatory slides, there’s an opportunity for 14 anyone that wishes to do so, to make opening 15 remarks, brief summary statements about issues that 16 matter to you. 17 Following that we’ll dive straight into 18 the detail content, the regulatory history, 19 rulemaking overview, scope of coverage. 20 We’ll take a break mid-morning, round 21 about 10:15 or 10:30 or so. Following that, market 22 and technology assessment, screening analysis, 23 engineering analysis. We’ll break for lunch around 24 about noon. Energy use analysis, immediately 25Executive Court Reporters (301) 565-0064 9 following lunch. Markup analysis, life cycle cost 1 and payback period analysis. Moving on directly to 2 shipments analysis, national impacts analysis, life 3 cycle cost subgroup analysis. 4 We’ll break mid afternoon as required and 5 needed. Following the break, or whenever we get 6 there, manufacture impact analysis, utility impact 7 analysis, employment analysis, environmental 8 assessment, regulatory impact analysis. 9 You can see as listed in the agenda, yet 10 another opportunity for comment at the end of the 11 day, any issues you think have not been covered 12 sufficiently from your perspective. I see a few 13 things here at the outset, both Keith and Susan. 14 MR. COOK: Doug, I just want to ask, is 15 there anybody on the line? 16 MR. BROOKMAN: I’m certain there is. We - 17 - the Department anticipated that there would be 18 folks on the line. 19 MR. COOK: Should we ask for them to 20 introduce themselves? 21 MR. BROOKMAN: I’m not sure we have the 22 capacity to do that. We know who they are, because 23 they signed on, and their comments and questions 24 will be inserted in the record of the meeting. The 25Executive Court Reporters (301) 565-0064 1 0 Department’s trying to make that happen effectively. 1

Susan. 2 MS. ANDERSON: I’d just like to confirm if 3 Susan Callahan from Osram Sylvania is on the line. 4 MR. BROOKMAN: Okay. Let me look to see. 5 Do we -- yes. 6 MS. ANDERSON: Thank you. 7 MR. BROOKMAN: Yes, our web mistress says 8 yes. Okay. 9 MR. COOK: Can she read off the names? 10 MR. BROOKMAN: Can you read off the names? 11 Let’s get you so you can be heard. 12 MS. EDWARDS: We have Austin Gilder, Carl 13 Abramson, Dan Csorsky (ph), David Ellis, James Carl, 14 Larry Liepso (ph), Brenda Wilson, Rachel Dixon, Rich 15 Osanich (ph), Ronald Darbauch (ph), Susan Callahan. 16 MR. BROOKMAN: Okay. So the Department is 17 trying hard to make these meetings accessible via 18 the web. So, finally, I’d ask for your 19 consideration. Please during the course of this 20 meeting today, speak one at a time. Say your name 21 for the record each time you speak. You don’t need 22 to say your organizational affiliation unless that’s 23 what you would like to do. I’m going to be cuing 24 individuals by name to speak. I also wish to 25Executive Court Reporters (301) 565-0064 1 1 encourage follow on comments, particularly the back 1 and forth is useful to the Department as they 2 consider these issues. 3 If you can, keep the focus here. Please 4 turn your cell phones on silent mode, and limit 5 sidebar conversations. Make sure to turn the 6 microphone on, be concise, share the air time. 7 There’s a lot to be said and we want to be efficient 8 here today. So that’s all I have to say at the 9 outset, then back to Lucy. 10 **Introductory Remarks and Purpose** 11 MS. deBUTTS: So I just wanted to confirm 12 to everyone that we are broadcasting this over the 13 internet for those participants that cannot attend 14 in person. They can listen in, they can review the 15 slides. They can’t really talk to us at this point, 16 but they can provide their comments. Webinar 17 provides that feature, so we will try to address 18 their comments and questions as they come in. We 19 have over 30 participants registered for this 20 webinar so far, so we’ll try to answer them, time 21 permitting. They will be treated as a secondary 22 though, to the group that is here. So your 23 questions are going to be addressed first. However, 24 as I said, we will try to answer all questions and 25Executive Court Reporters (301) 565-0064 1 2 comments. 1 MS. ANDERSON: Are you saying they can’t 2

comment? 3 MS. deBUTTS: They can comment via the 4 comment feature within the webinar. 5 MS. ANDERSON: In the past, we’ve been 6 able to hear them, and quite frankly, our technical 7 people are the ones that are on the web, so really 8 need that feature of their being able to speak and 9 us being able to hear them as a group. 10

MR. BROOKMAN: I see. 11 MS. ANDERSON: Because they’ll be the 12 appropriate people to comment and answer some 13 questions. 14 MR. BROOKMAN: So, thank you Susan, for 15 that. Do we have the capacity for them to speak and 16 be heard here in the room? We do have that 17 capacity. 18 MS. deBUTTS: So we will try to do so, 19 then. 20 MR. BROOKMAN: So let’s see how that 21 works. Let’s try and make that work. 22 MS. ANDERSON: Because we did do that last 23 time. 24 MR. BROOKMAN: Yes, it’s been done several 25Executive Court Reporters (301) 565-0064 1 3 different ways during the course of these meetings. 1 MS. deBUTTS: But regardless, it’s like 2 Doug said, anything that they comment on via the 3 webinar feature, you know, typing in questions, will 4 be attached to the transcript and will be treated as 5 the normal written comments. 6 MR. BROOKMAN: And for those joining us 7 via the web, welcome. I’m glad to have you with us. 8 If you could try to either in written form, or 9 orally, if that succeeds, try and be brief, concise 10 in your comments. That would be helpful to all of 11

us. 12 MS. deBUTTS: All right. So and as a last 13 reminder, the transcript itself, including the 14 comments that were received today from the webinar 15 participants, and the presentation slides, are going 16 to be posted on DOE’s website shortly after this 17 meeting, so as soon as we get the transcript ready, 18 we’ll post it on the web. 19 As for the purpose of this public meeting, 20 it’s of course to review the HID framework document 21 that we issued. The PNNL and Navigant staff will 22 assist DOE in presenting the procedural and 23 analytical approaches to the evaluation of HID 24 standard. We will be discussing the rulemaking 25Executive Court Reporters (301) 565-0064 1 4 process itself, and the next steps that we’re 1 planning on taking, so once again, you are invited 2 to comment on those. 3 In addition, we would like to get any data 4 or information or summary comments you may wish to 5 add for us to consider while we are working on the 6 rulemaking. 7 So, comment boxes. You will see the 8 comment boxes like on this slide throughout the 9 presentation. These comment boxes highlight the 10 specific issues we are seeking comments on. The 11 item numbers in these comment boxes correspond to 12 the list of items that were listed in the framework 13 document. Obviously, we have more issues that could 14 be addressed, so please feel free to comment on any 15 aspects of the materials that we’re going to be 16 presenting today. 17 As far as for the comment period 18 submission, I just wanted to mention that the due 19 date is April 12 th , which is an extension from the 20 originally published date in the framework. The 21 extension -- comment period extension published this 22 morning, so we would like to get your remarks by 23 April 12 th if possible. 24 And last, but not least, we will discuss 25Executive Court Reporters (301) 565-0064 1 5 the avenues of submitting the comments at the end of 1 this presentation so everyone’s aware on how to 2 submit them, where to submit them via docket, e3 mail, or by mail. 4 So at this time, I think my part of 5 introductions is pretty much over, I will turn back 6 to Doug for opening remarks. 7 MR. BROOKMAN: Thank you. Now is the 8 opportunity for brief summary remarks, issues that 9 are important to you. Who’d like to start? Joe? 10 Alex? 11 MR. BOESENBERG: We are ready to comment 12 on the individual items. We have no opening 13

statement. 14 MR. BROOKMAN: Okay. Thank you. Other 15 comments here at the outset? No additional opening 16 remarks. Okay. So then let’s go right into the 17

content. 18 **Regulatory History, Rulemaking Overview** 19 **And Scope of Coverage** 20

MR. WALKER: Good morning. I’m with 21 Navigant and my name is Matthew Walker. Let’s get 22 started with the regulatory history for this 23 rulemaking. So the Energy Policy Act of 1992 added 24 HIV lamps to the covered equipment of the appliance 25Executive Court Reporters (301) 565-0064 1 6 standards program here at DOE. EPCA 1992 specified 1 three requirements that are relevant to these 2 products. The first was to conduct a determination 3 to decide whether standards would be technologically 4 feasible, economically justified, and have the 5 potential to save significant energy. And DOE has 6 completed this determination by publishing a 7 publication on July 1, 2010, and this document 8 concluded standards would be feasible. 9 The second requirement is that DOE must 10 complete a test procedure, final rule within 30 11 months of completing the determination document, and 12 DOE has initiated this process with a test procedure 13 Notice of Proposed Rulemaking that was published on 14 December 15, 2011. 15 And finally, the third requirement of EPCA 16 1992, which is the subject of today’s presentation, 17 is that DOE is directed to prescribe an energy 18 conservation standard within 18 months of completing 19 the test procedure final rule. So the time 20 intervals put forth by EPCA bring us to the 21 rulemaking schedule. 22 This slide presents the projected schedule 23 for the intermediate stages of this rulemaking. 24 Like we said before, the framework document was 25Executive Court Reporters (301) 565-0064 1 7 published in February of this year, and DOE is 1 anticipating an interim analysis being available 2 September this year, followed by a NOPR in June 3 2013, and a final rule by July 2014. The compliance 4 date for this rulemaking would be about three years 5 after -- or would be three years after the 6 publication of the final rule, so approximately July 7 2017. 8 I should also point out, there have been 9 comments in both the HID determination and the metal 10 halide lamp fixtures rulemakings that those two 11 rulemakings should be combined in some fashion. So 12 at this time, DOE intends to regulate each product 13 separately, both with separate metrics and with 14 separate rulemaking documents, but does intend to 15 share data and decisions between the two rulemakings 16 to coordinate the analysis and the adopted 17 standards. 18 So, at the bottom of this slide, in item 19 two, DOE is welcoming comments on any specific ways 20 it should coordinate the development of the final 21 rules for these two products. 22 MS. ANDERSON: We, NEMA, -- 23

MR. BROOKMAN: Susan. 24 MS. ANDERSON: Susan Anderson, Osram 25Executive Court Reporters (301) 565-0064 1 8 Sylvania. NEMA does agree that they should be kept 1 separately, handled separately, and what we’d like 2 to point out is that in the luminaire rulemaking 3 you’re only covering ballasts for new metal halide 4 luminaries, so you’re not covering anything there 5 relative to mercury vapor or high pressure sodium. 6 So in that respect, the rulemakings don’t coincide. 7 MR. BROOKMAN: Okay. Thank you. Joanna 8

Mauer. 9 MS. MAUER: Joanna Mauer. Just a question 10 about the schedule. Is the interim analysis that 11 DOE plans to publish is that different than what a 12 typical preliminary TSD would be? 13 MR. WALKER: It is. It’s very related. 14 It has some distinctions. There will be a more 15 substantial executive summary document, and a less 16 substantial Chapter 2, which is usually where 17 there’s a response to public comments and discussion 18 of decisions. And the way it’s been described in 19 the framework document is that the public comments 20 would be saved until the NOPR for an official 21 discussion, but of course the comments that come out 22 in the framework document, both from this meeting 23 and in written form, would be informing the interim 24 analysis that’s published later this year. 25Executive Court Reporters (301) 565-0064 1 9 MS. MAUER: Thank you. 1 MR. BROOKMAN: Other comments on the 2 schedule? Okay. 3 MR. WALKER: So between now and July 2014, 4 DOE will consider the following seven factors in its 5 analysis: 6

 It looks at individual impacts on consumers 7

 Individual economic impacts on consumers in the 8 life cycle cost analysis 9

 It then looks at energy savings and economic 10 impacts on consumers as a whole in the national 11 impact analysis 12

 It looks at economic impacts on manufacturers 13 in the manufacturer impact analysis 14

 And DOE also looks at impacts on utility or 15 performance, as well as any other factors the 16 Secretary considers relevant. 17 **Scope of Coverage** 18 So now we’ll discuss the scope of coverage 19 that’s under consideration in the framework 20 document. 21 HID lamps have not been previously been 22 regulated to this rulemaking establishes the first 23 scope of coverage for these products. EPCA’s 24Executive Court Reporters (301) 565-0064 2 0definition of HID lamp includes mercury vapor, high1 pressure sodium, and metal halide lamps. And while 2 low-pressure sodium lamps are often included in the 3 HID family, they’re not included in the EPCA 4 definition or this rulemaking. 5 There’s also another lamp technology 6 referred to as an electrodeless HID lamp or light7 emitting plasma. These lamps emit light through a 8 process that’s related to HID lamps and have a gas 9 composition that seems the most similar to metal 10 halide. So in item three on this slide, DOE is 11 welcoming comment on whether these electrodeless HID 12 lamps should be considered a subcategory of HID 13 lamps. 14

MR. BROOKMAN: Susan. 15 MS. ANDERSON: Susan Anderson, speaking 16 for NEMA. We do not consider them a subgroup. 17 They’re most similar to metal halide, but we 18 consider them to be their own unique technology, and 19 right now there are no standards at all for these 20 lamps, and there are none in development. So there 21 would be no reference standards for evaluating these 22 products. And our recommendation would be that you 23 not include them in this rulemaking. 24 MR. BROOKMAN: Is there a test procedure? 25Executive Court Reporters (301) 565-0064 2 1 No test procedure. 1 MS. ANDERSON: Not anything across the 2 industry. 3 MR. BROOKMAN: Interesting. 4 MS. ANDERSON: And very limited 5 manufacturing of these products. 6 MR. BROOKMAN: Okay. Thank you. That was 7 clear. Do you have any follow up questions from 8 that? 9 MR. WALKER: I would just maybe ask if 10 there was an agreed upon definition of those types 11 of lamps that would help us understand the 12 distinction between the two. 13 MS. ANDERSON: Tom, I’m going to defer to 14 you, but not that I know of. 15 MR. BROOKMAN: Tom. Tom, turn the mic on. 16 MR. HARDING: Tom Harding. No, they’re a 17 new technology. They’re electrodeless. The biggest 18 feature is they’re electrodeless, they’re driven by 19 radio frequency to heat up and then emit light. But 20 it’s done much differently than a ballast, for 21 example, running current through electrodes. So 22 it’s kind of an altogether different technology. 23 Been around and the analogy would be fluorescent has 24 systems where they have electrodeless lamps, so 25Executive Court Reporters (301) 565-0064 2 2 they’re similar to that, but there are no standards, 1 no technology work being done, simply a few 2 companies are doing these. 3 MR. BROOKMAN: One thing that would be of 4 interest to the Department is the trajectory of this 5 product, if you think it’s going to be -- there’s 6 going to be more of them, it’s going to go 7 mainstream, that sort of thing. 8 MR. HARDING: I wish I knew. I don’t 9 actually know, there’s so few of them right now. 10

MR. BROOKMAN: Joe. 11 MR. HALLEY: It appears to be a niche 12 product right now, very few manufacturers, very few 13 product sales. It’s going to be competing against 14 some other technologies. It doesn’t seem to be 15 widespread investment in this technology by the 16 major manufacturers. So it appears to be a niche 17 product right now that doesn’t offer a lot of 18 opportunity for either energy use or energy savings 19 at this point. 20 MR. BROOKMAN: Okay. Thank you. 21 PARTICIPANT: Can we have the microphone? 22 MR. BROOKMAN: The mic’s on. 23 PARTICIPANT: Maybe closer? 24 MR. BROOKMAN: Okay. I’ll speak up. I’ll 25Executive Court Reporters (301) 565-0064 2 3 do that. Alex, do you want to -- 1 MR. BOESENBERG: Just one last point. 2 These are operated on electronic ballasts and in our 3 scope discussions we were -- the DOE is planning to 4 exclude those products, so this wouldn’t fall under 5 the scope then. 6 MR. BROOKMAN: Okay. Other comments 7 related to the scope and these definitions? Okay, 8 we’re going to keep going. 9 MR. WALKER: So two of the more 10 significant parameters considered in the framework 11 document for the scope of coverage are lamp input 12 wattage and correlated color temperature, or CCT. 13 So, HID lamps span a wide range of input wattages 14 and CCTs, and these ranges vary according to the 15 lamp technology. So DOE is considering a subset of 16 the available input wattages and CCTs for its scope 17 in the framework, and those lamps that are outside 18 of the subset have a -- represent a very small 19 number of available products according to catalog 20 availability, and as a result, a limited potential 21 for energy savings. 22 So in summary, DOE is considering 23 including the lamps on the table on this slide: 24Executive Court Reporters (301) 565-0064 2 4

 metal halide lamps between 50 and 2000 watts 1 and between 2500 and 6999 Kelvin; 2

 mercury vapor lamps between 50 and 1000 watts 3 and between 3200 and 6800 Kelvin; 4

 and high pressure sodium lamps, 50 to 1000 5 watts and between 1900 and 2700 Kelvin. 6 Then from this table, DOE is considering 7 excluding certain types of lamps, and those include: 8

 HID lamps designed and labeled for use with 9 electronic ballast only; 10

 Directional HID lamps 11

 Self-ballast HID lamps 12

 Colored HID lamps, and 13

 Specialty application mercury vapor lamps. 14 And similar to what I just said a few 15 minutes ago, these lamp types represent a very small 16 portion of the available products according to 17 catalog availability, and therefore a limited 18 potential for energy savings. 19 So this brings us to two items for comment 20 on the scope of coverage. In item four, DOE is 21 welcoming comment on its decision to define the 22 scope of coverage using rated wattage instead of 23 lumen output, as well as the specific range of 24Executive Court Reporters (301) 565-0064 2 5 wattages included in coverage. I’ll go ahead -- 1 we’ll just leave it at that and pause for that one. 2 MR. BROOKMAN: Yes, Joe. 3 MR. HALLEY: In terms of the ranges of 4 products to be covered, we believe that the 50 to 5 1000 watt category in all three products represents 6 the high volume, general lighting use category, so 7 that would include metal halide as well. Although 8 there are metal halide products that are over 1000 9 watts, these tend to be niche products for specialty 10 applications, such as sports lighting, which are 11 operated for fairly low periods of time, and they 12 have relatively short lives as well because of the 13 high lumen output requirements. We don’t believe 14 that that particular specialty product category 15 should be regulated above 1000 watts. 16 Would you like me to comment on item five 17 as well? 18 MR. BROOKMAN: Why don’t you read it, 19 Matthew? 20 MR. WALKER: Sure I’ll read it. So in 21 item five, DOE is welcoming comments on the decision 22 to exclude certain types of lamps and specifically, 23 on unique characteristics of colored HID lamps that 24 can be used to characterize and define that 25Executive Court Reporters (301) 565-0064 2 6 exclusion. 1 MR. HALLEY: And we would agree that these 2 do represent niche product categories and they 3 should be exempted. The areas that you have listed 4 here, certainly would qualify. There may be some 5 additional categories as well, such as high CRI, low 6 color temperature lamps, such as the high CRI, high 7 pressure sodium lamps that are on the market. We’d 8 also recommend they be treated as a niche exempted 9 category. We may have further comments as well as 10 we review this a little more carefully. 11 MR. BROOKMAN: Okay. Thanks, Joe. Yes, 12

Susan. 13 MS. ANDERSON: Yes, we also had a comment 14 on the color temperature range covered for metal 15 halide. We would stop it at 6000 Kelvin, because 16 any lamps that are available that are at higher 17 color temperatures, are for very specialized 18 applications, like aquarium lighting. They’re not 19 used for general application lighting. 20 And then the other thing to note is that 21 there are specialty application metal halide lamps 22 that also need to be taken into consideration. 23 MR. BROOKMAN: They wouldn’t be included 24 in these? 25Executive Court Reporters (301) 565-0064 2 7 MS. ANDERSON: No. 1 MR. BROOKMAN: Oh. So what would the 2 definition of -- what would be their specifications? 3 MS. ANDERSON: We actually have comments 4 on that further on. We plan to provide some 5 definitions to help guide the DOE on what would 6 include specialty versus general lighting. 7 MR. BROOKMAN: Okay. Thank you. That’s 8 good. Other comments on these scope of coverage 9 issues? Yes, Daniel. 10 MR. YOUNG: Yes, Daniel Young. With 11 regards to electronic ballasts, our understanding is 12 that the trajectory of the market is trending 13 towards st... metal halide electronically ballasted 14 products, and within three or five years this may 15 represent a much larger share of the market. Does 16 DOE or other manufacturers have any other comments 17 on that? 18

MR. BROOKMAN: Susan. 19 MS. ANDERSON: Most of the electronic 20 ballasts are being developed right now are for the 21 metal halide family, and typically right now they 22 are very low wattage, though we have some higher 23 wattage ones on the market. How fast they become 24 adopted by the market may depend very much on the 25Executive Court Reporters (301) 565-0064 2 8 metal halide luminaire rulemaking, and what ballast 1 efficiency standards are set there. 2 MR. BROOKMAN: That means you don’t know. 3 Keith. 4 MR. COOK: Keith Cook. You have -- 5 basically the problem, I think, is the fact that we 6 have such a huge installed base already with 7 magnetic ballast, that even as this grows and the 8 growth has not been huge, it’s still going to be a 9 very, very small percentage of the installed base, 10 even going forward. 11 MR. BROOKMAN: Thank you. Those are all 12 very useful comments. Final comments before we move 13

on? 14 MR. WALKER: I was going to ask a follow 15

on. 16 MR. BROOKMAN: Please. 17 MR. WALKER: I was going to say one thing 18 if it was possible, if NEMA was able to provide 19 specific shipment percentages of some of these 20 excluded lamp types to support the niche application 21 and limited potential for energy savings. 22 MR. BROOKMAN: Alex. 23 MR. BOESENBERG: For this subject and a 24 few others on the list of items, NEMA is open to 25Executive Court Reporters (301) 565-0064 2 9 discussing if we can reach an arrangement to provide 1 data, yes. I can’t promise it. It depends what you 2 ask, how you ask it and what data we have and how we 3 can parse it up. But we’re open to that discussion. 4 MR. BROOKMAN: You’ll be the point of 5

contact -- 6

MR. BOESENBERG: Yes. 7 MR. BROOKMAN: -- for that discussion? 8 Yes. Joanna. Oh, you want to -- yes. 9 MS. deBUTTS: We received a question from 10 the webinar participant, and Larry Liepso (ph) -- I 11 apologize for not pronouncing the name correctly -- 12 he’s asking why self-ballast energy lamps are not 13 included, because they’re fairly efficient. 14 MR. BROOKMAN: What’s the category again? 15 MS. deBUTTS: The self-ballasted energy 16 lamps. 17 MR. WALKER: Self-ballasted HID lamps? 18

MR. BROOKMAN: Susan? 19 MS. ANDERSON: Susan Anderson. I mean the 20 two families where you have self-ballasted lamps, 21 the original ones are self-ballasted mercury vapor 22 lamps that were basically incandescent replacement, 23 and the volume is very, very low. It’s been dying 24 for years. The other, a couple of companies, my 25Executive Court Reporters (301) 565-0064 3 0 company being one, we have self-ballasted metal 1 halide that’s actually a replacement for halogen, 2 and the main market for that is retail. But it’s 3 long-lived and much more efficient than the halogen. 4 But once again, it’s a small market application. 5 Niche market. 6 MR. BROOKMAN: Okay. 7 MS. deBUTTS: Thank you. 8 MR. WALKER: I think that’s all. 9 MR. BROOKMAN: All with that. Yes, 10

Joanna. 11 MS. MAUER: Joanna Mauer. I think, Joe, 12 you were mentioning the high CRI HPS lamps. Do they 13 provide some different utility than metal halide 14 lamps, or what’s the application for these types of 15 lamps? 16 MR. HALLEY: It just gives architects or 17 landscape designers a different color palette to 18 paint with light, if you will, so it’s a very low 19 chromaticity, so it’s only 2200 degrees Kelvin. It 20 still has a very large yellow component, but it 21 provides a high color rendering index at a very low 22 chromaticity. It is -- there’s very few 23 applications for it. There’s a few applications for 24 it, but it would definitely qualify as a niche 25Executive Court Reporters (301) 565-0064 3 1 product category. It’s not growing. It’s used in a 1 few, mostly outdoor -- specialty outdoor kind of 2 applications for highlighting various finishes. 3 Provides a different effect. 4 MS. MAUER: Okay. 5 MR. BROOKMAN: Yes, Daniel. 6 MR. YOUNG: Daniel Young. Just a follow 7 on question to that. What’s, I guess, kind of the 8 efficiency penalty for going up to a higher CRI? Is 9 it a big difference? 10 MR. HALLEY: I’d have to look at the 11 catalog, but I -- they’re still very efficient. 12 It’s still high pressure sodium, so it still has a 13 very high efficiency relative to other light 14

sources. 15 MR. BROOKMAN: Additional comments before 16 we move on? Okay. 17 MR. WALKER: All right, so item six 18 continues with comments on exclusions and this one 19 is welcoming comments on whether lamps for special 20 applications have defining characteristics that 21 differentiate them from lamps used for general 22 illumination purposes, and in addition, whether the 23 specialty applications that are relevant to mercury 24 vapor technology can be served by high pressure 25Executive Court Reporters (301) 565-0064 3 2 sodium metal halide technology. 1 MS. ANDERSON: Susan Anderson, speaking 2 for NEMA. I want to start with the mercury vapor 3 versus metal halide and high pressure sodium first. 4 You cannot substitute metal halide or high pressure 5 sodium for mercury vapor in those applications, 6 because it is the UV output of the mercury vapor 7 that is essential in those applications. 8 MR. BROOKMAN: Pardon me, Susan. Are you 9 getting her? Just a little closer. You’re coming 10 across great here. 11 MS. ANDERSON: All right. So there really 12 isn’t an exchange possible there. You don’t get the 13 same output. And then in terms of other specialty 14 application lamps, both when you look at mercury 15 vapor and metal halide, they’re generally short arc 16 tube lamps, very short arcs, so you get very 17 precise, optical control and very high internal 18 pressures. In fact many of them can’t even be 19 shipped unless they’re within a protective container 20 and the way the equipment maintains them that 21 utilizes them, it has protective coverings around 22 them because they can experience non-passive 23 failures. So they are very specialized. 24 In other cases, they have very short 25Executive Court Reporters (301) 565-0064 3 3 usable life because they’re required to have very 1 high lumen output for the applications where they’re 2 used, so when you get into lumen maintenance, they 3 can’t be used in applications where the general 4 lighting lamps are. In many cases, in fact Alan 5 found one base in common for most of those lamps. 6 And others that you run into -- specialty 7 -- we’ve mentioned plant growth, we’ve mentioned 8 color-corrected high pressure sodium, we mentioned 9 aquarium lighting. So for like for plant growth, 10 they’re lamps that give you light output in the blue 11 spectrum and the red spectrum, because that’s all 12 that plants care about, so they’re not really 13 suitable for general lighting applications. 14 Aquarium is very high color temperature that’s not 15 acceptable in general lighting applications. So 16 there are specialized features about them, and NEMA 17 plans to provide you with definition guidance to 18 help you exclude those items and make it clear so 19 that it’s much -- so there’s no confusion as to 20 what’s general lighting versus what’s specialty. 21 MR. BROOKMAN: Okay. 22 MS. ANDERSON: The one family where there 23 may be some issue are the clear mercury vapor lamps 24 with medium screw bases and mogul (ph) screw bases 25Executive Court Reporters (301) 565-0064 3 4 and medium skirted screw bases. They are used, you 1 see them used, for outdoor illumination. They’re 2 the ones that turn green as they get older. But 3 they also have a utility as a UV curing, and for 4 inspection purposes. So that’s the one family that 5 there may be some -- we need to very closely define 6 or label the lamps in some way. 7 MR. BROOKMAN: Should they be included or 8 excluded? 9 MS. ANDERSON: In the sense that they can 10 be used for general lighting applications, which 11 would typically be outdoors, in less color-critical 12 applications, they should be covered. But I think 13 there needs to be some provision for the UV curing 14 and the inspection applications, because they are 15 widely used for that. 16 MR. BROOKMAN: And it would be a separate 17 definition? 18 MS. ANDERSON: We’ll try to work out 19 something, try to work with DOE and Navigant and 20

PNNL. 21 MR. BROOKMAN: Okay. Well, thank you, 22 that was very helpful. Daniel. 23 MR. YOUNG: Daniel Young. Just a follow 24 on question to that. Is there -- what about LEDs? 25Executive Court Reporters (301) 565-0064 3 5 Could those be used in the specialty applications? 1 MS. ANDERSON: You have some LEDs with UV 2 output, but really the UV output of LEDs is pretty 3 limited at this point, and not sufficient for those 4 applications. You have short arc to high pressure 5 mercury vapor lamps, for example, that are used to 6 etch the circuitry on silicon chips, and you would 7 never get the output from LEDs at this point in time 8 for that type of application. 9 MR. BROOKMAN: Okay. 10 MR. YOUNG: Thanks. 11

MR. BROOKMAN: Joanna. 12 MS. MAUER: Joanna Mauer. Just another 13 clarification question. Susan, all of these types 14 of mercury vapor lamps that you’re talking about, 15 these are ones that are used with ballasts that are 16 exempted from the -- 17 MS. ANDERSON: In the case of mercury 18 vapor, they are exempted based on, if we go back to 19 ESA 2007, but metal halide was never considered at 20 that point, because it was only mercury vapor 21 ballasts that had been eliminated. 22 MS. MAUER: Okay. So it’s mercury vapor 23 lamps that are using ballasts that are exempted from 24 the -- 25Executive Court Reporters (301) 565-0064 3 6 MS. ANDERSON: The ballasts are specially 1 labeled right now, for specialty application only, 2 so I’m thinking we could do something similar for 3 clear mercury vapor lamps that are used for the UV 4 curing and the inspection processes. 5 MR. BROOKMAN: Okay. There are several 6 distinct pieces of information that the Department 7 is asking about in item six and seven, particularly 8 I call your attention to item seven, “any additional 9 lamps that should be excluded from the scope of 10 coverage.” Yes, Keith. 11 MR. COOK: Keith Cook. Basically, the one 12 thing that was in the written text which is not 13 included so far in this is whether or not standby 14 mode should be included. And standby mode does not 15 apply, really, to lamps. It’s an electronic driver 16 which is excluded anyway. We also, though, agree 17 with the current coverage except as Joe pointed out 18 earlier, we think it should be stopped at 1000 watts 19 - above 1000 watts is -- should be also excluded, 20 because it’s not a general lighting. 21 MR. BROOKMAN: Okay. Additional comments 22 on these two. Look at them. Defining 23 characteristics and also specialty applications, and 24 then in seven, exclusions. Nothing additional. 25Executive Court Reporters (301) 565-0064 3 7 Okay. 1 MR. WALKER: All right, so we’ll move on 2 to metrics. DOE is considering several metrics for 3 assessing the performance of HID lamps. The first 4 will be initial lamp efficacy. Initial lamp 5 efficacy is the ratio of light output to input power 6 at the beginning of the life of the lamp. An 7 alternative metric could be a maximum input power, 8 or maximum input wattage. In this case, DOE would 9 establish a maximum input wattage for a given light 10 output or range of light outputs. 11 So these metrics cover omni-directional 12 lamps, which are lamps that cast light in all 13 directions. But if DOE were to include directional 14 lamps in the scope of coverage, it would plan to 15 pursue a different metric. 16 So this slide goes over possible metrics 17 that could be employed if directional lamps were 18 included. Center beam candle power and beam ... 19 lumens could be possibilities. Center beam candle 20 power or CBCP measures the intensity of light at the 21 center of the beam angle, and DOE could require a 22 minimum CBCP for a given lamp shape diameter or 23 input power. And alternatively, for beam lumens, 24 DOE could require a minimum beam lumens or zonal 25Executive Court Reporters (301) 565-0064 3 8 lumens per watt for a particular lumen output, or 1 input power range. 2 So this slide provides opportunities for 3 comment on the metrics. In item 13, DOE is asking 4 for comments on the use of efficacy as a metric for 5 omni-directional lamps, and then item 14, essential 6 metrics that could be used if directional lamps were 7 to be included. Though from the discussion that 8 we’ve had so far, the interest seems to be for them 9 to be excluded. 10 MR. BROOKMAN: Okay. We’d like to get 11 further confirmation, I believe. Susan. 12 MS. ANDERSON: Well, I notice that you 13 skipped over several items. 14 MR. BROOKMAN: Oh. 15 MR. WALKER: You mean in terms of the 16 numbering? 17

MS. ANDERSON: Yes. 18 MR. WALKER: The numbering doesn’t match 19 the framework document. The numbering matches the 20 comments that you would have seen in the framework 21 document, but are not necessarily in the same order. 22 MR. BROOKMAN: But everything in the 23 framework document you’ll cover rather 24 systematically? 25Executive Court Reporters (301) 565-0064 3 9 MR. WALKER: There may be one or two 1 exceptions where an item is left out, but there’s 2 still an opportunity for that to be done in a 3 written comment. 4 MR. BROOKMAN: So I don’t want to -- it 5 looks like you’re very well prepared. We don’t want 6 to mess you up. 7 MS. ANDERSON: We can -- so long as we 8 have the opportunity to comment there. 9 MR. BROOKMAN: Great. We’ll make sure 10 you’ve got that. Okay. Let’s try and -- I think 11 it’s useful to make the comments as they fit with 12 the order of the slides. It’s better for the 13 record, I think. 14 So you can see item 13 and 14, potential 15 metrics in HID lamp conservation standards and also, 16 let me see, differentiating between center beam -- 17 well, the center beam intensity metric. Susan. 18 MS. ANDERSON: Susan Anderson. We 19 absolutely agree that the lamps should be measured 20 based on initial lumen output. Our standards are, 21 Tom, I believe, you measure them at 100 hours, so 22 you have achieved lamp stability. We also had, in 23 our earlier comments when we did the test and 24 measurement procedures, we had recommended that you 25Executive Court Reporters (301) 565-0064 4 0 use the definition for lamp efficacy that’s in IES 1 RP16. On double checking it, we find that they 2 don’t define lamp efficacy. They define luminous 3 efficacy, which is the lumen output of the lamps 4 divided by the input wattage, which is what you’re 5 going after. So our recommendation would be that 6 you still use the definition in RP16, but perhaps 7 you should use the term lamp luminous efficacy as 8 the appropriate term. 9 Then in terms of other measurements, say 10 for directional lamps, the DOE has already suggested 11 discarding these and excluding them from this 12 particular rulemaking, and NEMA definitely agrees 13 with that. And if that’s the case, then you don’t 14 need to come up with metrics for those, specific to 15 those lamp types. 16

MR. BROOKMAN: Joe. 17 MR. HALLEY: Yes. We would agree with 18 that, that there is very limited use of directional 19 lamps in the HID area, and it certainly -- new 20 metrics based on zonal lumen, center beam candle 21 power, would be complex to develop. They have not 22 been developed yet and don’t think it would be 23 appropriate to develop them in the HID family. We 24 recognize there’s other rulemakings going on that 25Executive Court Reporters (301) 565-0064 4 1 deal more with directional lamps that might be more 1 appropriate to develop such metrics, but we wouldn’t 2 recommend developing them here. 3 MR. BROOKMAN: Susan, you were speaking on 4 behalf of NEMA, and Joe as chair of that section, 5 you’re reinforcing what she said. 6 MR. HALLEY: Yes, that’s correct. 7 MR. BROOKMAN: Thank you. Okay. So then 8 any additional questions you have about this? No? 9 No additional. Joanna. 10 MS. MAUER: Joanna Mauer. My 11 understanding is that lighting designers typically 12 use mean lumens when choosing lamps and fixtures, 13 and then if you have a lamp that has poor lumen 14 maintenance that you’d have to use lamps with higher 15 wattages or use more fixtures. And so that lumen 16 maintenance has a direct relationship to energy use 17 in the field. So I’m wondering if DOE is 18 considering including or incorporating lumen 19 maintenance somehow in the standards? 20 MR. WALKER: For now the plan per the 21 framework document is that when considering more 22 efficacious and lower energy-consuming replacements, 23 and when considering the effects of standards, that 24 those replacements would be -- make sure that those 25Executive Court Reporters (301) 565-0064 4 2 replacements could have the same lumen appreciation, 1 LLD, mean lumen output. I don’t know if that 2 answers your question exactly. Maybe a manufacturer 3 could speak to the relationship between initial 4 efficacy and mean efficacy. 5 MR. BROOKMAN: Let’s let Joe try. Joe, go 6 ahead. 7 MR. HALLEY: Yes, just want to make a 8 comment that lighting designers do consider that but 9 recognize that this standard is for all HID lamps in 10 all applications. New construction, new design 11 represents just a small percentage of sales in any 12 one year. So when you’re considering the 95 percent 13 or more of installed base that these lamps would go 14 into, it doesn’t really have any effect because the 15 user would have to use a lamp that’s appropriate for 16 that fixture. HID lamps are very difficult -- 17 systems are very difficult to use other sources. 18 You’re typically locked into to a certain HID system 19 once that’s designed and installed. 20 With regard to new installation, there is 21 a separate rulemaking going on with the ballast that 22 will more directly affect those new installations, 23 as opposed to this rulemaking, which is going to 24 have a much bigger effect on existing installed 25Executive Court Reporters (301) 565-0064 4 3 base, which is really how we should be looking at 1 this rulemaking. 2 MS. MAUER: This is Joanna Mauer again. 3 And in the existing installations, would lumen 4 maintenance affect the wattage of lamps that you 5 would install? 6 MR. HALLEY: No, it only affects how fast 7 you lose light output, but the wattage is the same, 8 so there’s no energy impact on that. 9 MS. MAUER: But if you’re moving towards a 10 lamp that’s much more efficacious, you might kind of 11 go a step down in wattage to account for the extra 12 lumens you’re getting at the same wattage? 13 MR. HALLEY: If that was possible, but it 14 often requires a different fixture, a different 15 ballast to do that, and in some cases -- there may 16 be a few opportunities where that’s possible, but 17 it’s limited right now, and most HID systems, the 18 user really doesn’t have a lot of options. 19 MR. BROOKMAN: Because of the installed 20 base. 21 MR. HALLEY: Well, yeah, they’re just 22 technically not a lot of options for the user to say 23 if they’re using a 250 watt metal halide, they 24 really don’t have the option of putting 175 watt 25Executive Court Reporters (301) 565-0064 4 4 metal halide lamp in there. It’s not like 1 incandescent. The ballast is driving that lamp at a 2 specific wattage. If you put 175 watt lamp in 3 there, the ballast will try to drive it at 250 4 watts, will overdrive it and give you very short 5 lamp life if they try to do that. And probably 6 violate UL ratings and other things if you tried to 7 do that. So it -- it’s much more difficult for 8 users of existing systems to lower the wattage of 9 those systems. 10 MR. BROOKMAN: Susan, you want to add on? 11 No. Okay. Alex. 12 MR. BOESENBERG: Alex Boesenberg, NEHI. I 13 just wanted to point out that we will include some 14 comments relative to this under item 38 and 39 where 15 questions are asked about group relamping and 16 relamping practices as well as maintenance and 17 repair of HID lamps, ballasts, and fixtures. And 18 it’s pretty much the same answer. No, we don’t 19 think anything’s going to change, and no, it’s not 20 economical often, to repair one of these devices, 21 you just replace them. 22 MR. BROOKMAN: Okay. Thank you. Final 23 comments here? 24 MR. WALKER: Okay. So we had a break on 25Executive Court Reporters (301) 565-0064 4 5 the agenda, but we’re doing pretty well. 1 MR. BROOKMAN: We’ve only been at this for 2 about 50 minutes. So keep going. 3 MR. WALKER: Okay. Keep on going. 4 **Market and Technology Assessment, Screening Analysis** 5 MR. WALKER: Let’s start with the 6 discussion of the Market and Technology Assessment, 7 followed by the Screening Analysis. You can see on 8 this flow chart that decisions and information 9 thought about in these two steps flow through to the 10 rest of the interim analysis. 11 So in the market technology assessment, it 12 serves two main functions. First would be to 13 determine equipment classes and the second to 14 identify technology options that can be used to 15 increase efficacy. And in the screening analysis, 16 DOE examines its list of technology options from the 17 technology assessment, and determines which ones 18 should and should not be considered in the 19 engineering analysis. 20 So we’ll move into the first output of the 21 market and technology assessment, which is equipment 22 classes. And equipment class establishes the 23 category of lamps that are subject to the same 24 standard, and so in considering potential groupings, 25Executive Court Reporters (301) 565-0064 4 6 DOE looks at criteria such as capacity of the 1 product, type of energy use, and other performance2 related features such as those that affect consumer 3 utility. 4 So in the framework document DOE outlined 5 equipment classes on the basis of CCT and initial 6 light output, and DOE did not consider separating 7 equipment classes based on lamp technology because 8 it determined CCT effectively segregated those 9 groups, or segregated high pressure sodium from 10 metal halide or mercury vapor. 11 If we look at CCT in a little more detail, 12 HID lamps are available with a variety of CCTs, but 13 equipment usage indicates that consumers specify 14 lamps of particular CCTs for certain applications. 15 For example, the higher CCT of metal halide lamp is 16 preferred to the lower CCT of a high pressure sodium 17 lamp in an indoor warehouse application where people 18 would be moving about. And so this indicates 19 consumer utility on the factor of CCT. And then 20 based on a review of catalog information, it does 21 indicate that initial efficacy varies with CCT. 22 So based on the difference in efficacy and 23 the presence of consumer utility, DOE is considering 24 establishing equipment class on the basis of CCT. 25Executive Court Reporters (301) 565-0064 4 7 So the table at the bottom of this slide 1 shows the three CCT ranges under consideration in 2 the framework document. The 1900 to 2500 range 3 would include high pressure sodium lamps, nd the 4 2501 to 5000, and 5001 to 6999 would include metal 5 halide and mercury vapor. 6 So I’ll go over the second class-setting 7 factor. 8 MR. BROOKMAN: You want to comment here, 9 Susan? You can do that. 10 MS. ANDERSON: Well, just a comment that 11 we made earlier, that the highest temperature range 12 should really be capped at 6000 because anything 13 above that is more that aquarium lighting. 14 MR. BROOKMAN: Okay. Thank you. 15 MR. WALKER: Okay. So if we look at the 16 second class setting factor, which was initial light 17 output, again, HID lamps are available with a 18 variety of light outputs, input powers, and while 19 light output and input power are highly correlated, 20 DOE decided to use light output as the class setting 21 factor because it’s the feature more directly valued 22 by the customer. And again, customer light output 23 preferences vary by application. For a high ceiling, 24 the customer would require a higher light output 25Executive Court Reporters (301) 565-0064 4 8 lamp than for a lower ceiling or a short pole. 1 So this indicates the presence of consumer 2 utility and again, a review of catalog data 3 indicated lamps of increased light output or 4 increased input power, were generally more 5 efficacious. So based on the difference in lumen 6 efficacy and consumer utility, DOE considered 7 establishing separate equipment classes based on 8 initial light output. 9 So this table outlines the equipment 10 classes for two of the three CCT ranges under 11 consideration, and again, moving forward, if 12 directionality and ballast location are not factors 13 for this rulemaking because directional lamps and 14 self-ballasted lamps have been excluded, they would 15 be removed from tables such as these. And I also 16 want to point out that the lumen ranges that you see 17 on the far right-hand side of the table, have the 18 potential to be collapsed into much fewer categories 19 as we’ll discuss in the engineering analysis, 20 because DOE is considering an equation-based 21 approach that could span more than one of these 22

ranges. 23 So this brings us to two items for comment 24 on equipment classes. In item 16, DOE is generally 25Executive Court Reporters (301) 565-0064 4 9 requesting comment on the equipment classes and 1 additional approaches that could be used that are in 2 accordance with this requirement, and specifically, 3 input on the proposal to establish equipment classes 4 based on light output, rather than rated wattage, as 5 well as on CCT, and the appropriateness of the 6 specific lumen output and CCT ranges selected. I 7 know we’ve heard on the 6999 range, but we could 8 also look for comment on the other ranges as well. 9

MR. BROOKMAN: Susan. 10 MS. ANDERSON: Okay. NEMA disagrees with 11 setting these standards based on lumen ranges. We 12 plan to provide an alternate proposal that will be 13 wattage-based, because of all of our tested 14 measurement is done at wattage, all the standards 15 are based on wattage, and quite frankly, lamps are 16 locked into fixtures based on lamp ballast 17 compatibility and wattage. 18 Also, besides color temperature impacting 19 lumen output, you also have coated versus clear 20 lamps. Generally, coated lamps have a lower lumen 21 output than coated lamps (sic), yet there’s a 22 specific utility for the coated lamps. You have 23 things like our standby lamps, which are double arc 24 tube lamps, that have two utilities specific to 25Executive Court Reporters (301) 565-0064 5 0 them. One is longer lamp life, and the other is a 1 safety issue. Those are generally lower lumen 2 output. You also have protect lamps, where you have 3 a shroud around the arc tube to provide special -- 4 additional containment properties, so it’s another 5 safety issue. In fact, in your opening slide, you 6 had two protect lamps, shrouded lamps, pictured 7 there. That generally impacts lumen output. 8 So, as I said, NEMA will be providing an 9 alternate proposal that will be wattage-based. 10 MR. BROOKMAN: Thank you. Additional 11 comments here? Do you want to talk -- do you want 12 to give them any initial thoughts about the many 13 different ranges listed here in this table? 14 MS. ANDERSON: Well, one thing we found 15 when looking at these ranges, for a given wattage 16 you could have a coated or a protect or a standby 17 lamp in a different category from where the clear 18 version would be. So that’s why we think you need 19 to take those things into consideration and do a 20 wattage-based system, rather than a lumen based 21 system. 22 MR. BROOKMAN: Joe, you want to add on 23 here? 24 MR. HALLEY: This was in line with what 25Executive Court Reporters (301) 565-0064 5 1 Susan was saying, that you could have a single 1 wattage lamp and have it be in two different 2 categories simultaneously, depending on some of the 3 physical construction of the lamp or even depending 4 on testing variability. There is a wide tolerance 5 range on these particular lamp types with regard to 6 lumen output, which could vary by testing facility 7 or other measurements and we believe this would 8 create a lot of issues and problems going forward in 9 trying to determine exactly where a lamp falls in 10 what lumen category. Which is why we’re going to 11 suggest that the proper way to differentiate this 12 product line is by wattage, not by the lumen output. 13 MR. BROOKMAN: Matthew, did we address 17? 14 I don’t think we did. 15 MR. WALKER: Well, Susan got into it a 16 little bit. I mean this 17 lists some of the other 17 factors that DOE might consider for equipment 18 classes, including operating position, open versus 19 enclosed fixture rating, CRI-based type, the bulb 20 finish. 21 MR. BROOKMAN: If NEMA’s going to come 22 back with a different proposal based on wattage, 23 this is still relevant, right? Shouldn’t you 24 comment on 17 as well? Susan. 25Executive Court Reporters (301) 565-0064 5 2 MS. ANDERSON: Seventeen does include some 1 of the things that we’ve talked about, for instance, 2 the enclosed versus open -- that would be the 3 protect lamp is suitable for an open fixture, where 4 an unprotected lamp would typically be used in an 5 enclosed fixture. We’ve addressed -- well, we 6 talked about color temperature, not necessarily CRI, 7 but in some cases, in some technologies, when you 8 improve CRI, you’re doing it by adding a coating and 9 that lowers the lumen output, the fact that you’ve 10 added the coating. 11 And if you look at metal halide 12 technology, we changed the chemistry so a lot of 13 times the 4000, 4200 Kelvin lamps are higher lumen 14 output than the 3000 Kelvin, yet they both have 15 utilities, you know, depending on the application. 16 And coated versus clear, we’ve already talked about 17 that. 18 When you talk about base type, lamp 19 oriented specific, for instance, most of us have 20 higher performing probe-start metal halide lamps and 21 they are position-specific, so there’s a specific 22 lamp for a horizontal, specific lamp for base up, 23 and specific lamp for base down. And we change the 24 arc tube configuration based on where -- the 25Executive Court Reporters (301) 565-0064 5 3 position the lamp’s going to be operated in. So 1 that doesn’t necessarily affect lumen output, so 2 long as they’re used in the correct position. But 3 then again, if you do have a universal lamp, say, 4 and that would be most typically in standard probe5 start technology, that’s a lamp that has a higher 6 performance in a vertical position, base up or base 7 down, than it does in horizontal, but yet there’s a 8 utility for those lamps in the fact that if you have 9 an aiming application, you can’t use a restrictive 10 position lamp in those applications. 11 You also have an issue that we use 12 position-oriented mobile bases on those position13 specific lamps, and they won’t fit in a standard 14 socket, which would be in many fixtures, and you 15 also have issues with end users misapplying lamps. 16 And one of the great things about the universal 17 burning lamp is that you cannot misapply it. It can 18 be used in any position. 19 MR. BROOKMAN: Alex. 20 MR. BOESENBERG: Alex Boesenberg. One, I 21 guess, housekeeping comment, relative for that, is 22 that table 3.1, the initial proposed classes based 23 on lumen range, as we’ve stated clearly, we are 24 developing a NEMA proposal for a wattage-based 25Executive Court Reporters (301) 565-0064 5 4 approach, but just one housekeeping note relative to 1 that table is it includes direction, self-ballasted 2 and things like that, and as has already been 3 discussed, those are outside of the scope per the 4 DOE’s initial determination. So, if that table is 5 kept, and we recommend you don’t keep it, you should 6 at least pull those things out of it. 7 MR. BROOKMAN: Okay. Thank you. And I 8 just wanted to -- so you need to be submitting that 9 rather quickly, right, since the comment period ends 10 April 19 th

. 11 MR. WALKER: Twelfth. 12 MR. BROOKMAN: Twelfth. I tried to give 13 you an extra week. 14 MR. BOESENBERG: Yes. It will be as 15 quickly as possible. 16 MR. BROOKMAN: Thank you. Trying to slip 17 that in there. 18 MR. BOESENBERG: Yes, we understand the 19 deadline and I’ve got what we think is the final 20 draft of that table, we’re just not ready to show it 21 to you today until everyone’s had a chance to see 22 it. 23 MR. BROOKMAN: Good. I’m sure the 24 Department appreciates your getting that done. 25Executive Court Reporters (301) 565-0064 5 5 Additional comments? Yes, Daniel. 1 MR. YOUNG: Yes, Daniel Young. I had a 2 question for NEMA about the change to a wattage3 based system. My understanding is that the efficacy 4 is a component of the wattage and the lumen output, 5 and efficacy being the thing that we’re trying to 6 regulate, I’m just a little confused about since one 7 kind of leads to the other, what the difference is. 8

MR. BROOKMAN: Susan. 9 MS. ANDERSON: Well, in HID, if a ballast 10 is designed to operate a 400 watt lamp, it’s 11 designed to operate a 400 watt lamp. So if you’ve 12 got a 400 watt lamp, it doesn’t matter whether it’s 13 35, 36,000 lumens initially, or 42,000 lumens 14 initially. Remember, most of these are sold into 15 existing installations, the fixture installation is 16 the fixture installation. The ballast is the 17 ballast. If that system uses 450 watts, it’s not 18 going to matter whether it’s a 36,000 lumen lamp or 19 a 42,000 lumen lamp. There’s no energy savings to 20 be realized. 21 MR. BROOKMAN: Daniel. 22 MR. YOUNG: Right. I understand that. I 23 guess my question is, doesn’t that just make one 24 lamp perhaps not meet the standard and one that does 25Executive Court Reporters (301) 565-0064 5 6 meet the standard? 1 MS. ANDERSON: But the whole purpose of 2 this rulemaking is to realize energy savings. 3 MR. YOUNG: Sure, right. 4 MS. ANDERSON: There’s no energy savings. 5 MR. YOUNG: So I think maybe -- 6 MS. ANDERSON: The rulemaking that’s 7 covering the ballast and the new metal halide 8 luminaries, that can result in energy savings, and 9 that can determine then, the lamp that’s used in 10 that luminaire. Like what’s already in place, 11 because of ESA 2007, if it’s between 150 and 500 12 watts, it has to be pulse-start. And pulse-start, 13 in general, has better performance than probe start. 14 So that is providing for additional energy 15 efficiency. This would not. 16 MR. HALLEY: I think in this particular 17 case, just a follow-on. For instance, let’s 18 consider the case with HID lamps, there’s a 400 watt 19 mercury vapor lamp and a 400 watt metal halide lamp 20 and they both use the same amount of wattage. If, 21 for instance, the standard was set such that the 400 22 watt mercury vapor lamp couldn’t meet it, the user 23 of that system would have to replace their entire 24 system, would have to replace their fixture, and the 25Executive Court Reporters (301) 565-0064 5 7 theory then is once they have to replace that 1 fixture, they would replace it with either high 2 pressure sodium or metal halide at a much lower 3 wattage for the same light output. And that would 4 drive energy savings. 5 This is one case where often it’s a whole 6 system change that’s required as these older 7 inefficient systems go away. It does put a much 8 greater burden, though, on trying to show cost9 effectiveness, since the users in the HID world 10 typically are going to have to invest somewhat 11 significantly once these -- if lamp types are 12 eliminated. But it would then ultimately produce 13 energy savings as they switch to a different 14 technology. They may even switch to an LED 15 technology if it’s an outdoor fixture, but it would 16 force their hand to do something. 17 MR. BROOKMAN: Okay. That was good. 18 Thank you. Yes. 19 MR. WALKER: So that’s all for equipment 20 classes. So we’ll move to the second main function 21 of the market and technology assessment, which is 22 development of the list of technology options that 23 can be used to increase lamp efficacy. These 24 technology options are based on those used in 25Executive Court Reporters (301) 565-0064 5 8 commercially available lamps as well as working 1 prototypes. 2 So this slide and the next goes over 3 options identified for each lamp technology. So 4 starting with mercury vapor lamps. These lamps have 5 been heavily replaced with metal halide and high 6 pressure sodium, and DOE is not aware of options for 7 the mercury vapor lamp itself, but rather use the 8 transition to other lamp technologies as the pathway 9 to increased efficacy and reduced energy savings -- 10 I mean, reduce energy use. 11 So then moving to high pressure sodium 12 lamps, catalogs indicate a range of high pressure 13 sodium efficacy exists, but DOE is not aware in the 14 framework document of specific options used to 15 achieve these different efficacies. DOE is also not 16 considering other lamp technologies to be 17 substitutes for high pressure sodium, just 18 contrasted with the mercury vapor situation. 19 And then finally, we have metal halide 20 lamps, and the table on this slide describes some of 21 the options available for increasing the efficacy of 22 these types of lamps. 23

 First the use of pulse starting rather than 24Executive Court Reporters (301) 565-0064 5 9 probe start; 1

 The use of ceramic material in the arc tube as 2 opposed to quartz; 3

 The use of formed or offset electrode arc tube 4 design; 5

 The use of novel gases or different gas 6 compositions within the arc tube; and finally, 7

 New electrode designs or fluoro... materials 8 could reduce losses in the electrodes, and just 9 in general, all of these methods could increase 10 the efficacy of metal halide lamp. 11 So item 18 welcomes comment on the 12 technology options identified in this section for 13 all three lamp technologies, as well as any 14 additional options that should be taken into 15

account. 16

MR. BROOKMAN: Joe. 17 MR. HALLEY: Just a few comments, perhaps 18 one on the pulse start versus probe start 19 technologies. The pulse start lamps aren’t 20 necessarily more efficient than the probe start 21 lamps if you’re looking at initial efficiency. Also 22 an existing user of a probe start system, which are 23 the older metal halide systems, can’t just switch to 24Executive Court Reporters (301) 565-0064 6 0 a pulse start lamp. They would have to put new 1 ballasting system in that fixture for that to 2 operate. 3 MR. WALKER: Right. 4 MR. HALLEY: So there are limitations to 5 some of these technology options. 6 MR. WALKER: I mean that sort of 7 transition would be accounted for in the engineering 8 analysis, transition from probe to a pulse start 9 lamp would also require a purchase of a new pulse 10 start ballast. 11 MR. HALLEY: Right, and it’s already 12 occurring as well, and I know you’re to consider 13 other rulemakings, but there’s another rulemaking on 14 fixtures that is basically also already forcing this 15 transition in new fixture design where it’s the most 16 cost effective. We do not believe this would be 17 cost effective for existing users, but the way to do 18 it is to transition it through the new fixture 19 design, the fixture rulemaking. But I’m sure in the 20 analysis you’ll take that into account. 21

MR. BROOKMAN: Susan. 22 MS. ANDERSON: Well, I was just going to 23 say it’s not just the ballast that also has to be 24 changed. If you were to try to retrofit a fixture, 25Executive Court Reporters (301) 565-0064 6 1 you also have to change the socket. You have to 1 change the wiring in the fixture, because what’s 2 there for a probe start system is not rated to take 3 the high voltages required for the pulse start 4 system. So that’s why, in general, if they could 5 not buy replacement lamp, they would have to go to 6 an entirely new luminaire. 7 MR. BROOKMAN: Okay. 8 MS. ANDERSON: So for some end users, that 9 could be a huge financial impact on them. And, you 10 know, further on in here you talk about incentive 11 programs. Well, the incentive programs for HID are 12 generally for outdoor applications, and it’s usually 13 for eliminating HID and going to LED. It’s not for 14 installing HID. And, in fact, the fluorescent 15 programs, incentive programs, are taken, when you 16 look at a tear out applications, are actually 17 incentivizing people to go from HID to fluorescent. 18 So there’s a declining market for HID lamps. 19 They’re being hit from multiple sides. 20 MR. BROOKMAN: Okay. John. 21 MR. GREEN: Yes, John Green. As a fixture 22 manufacturer, I totally agree with what Susan said 23 about rewiring and what’s necessary to change over a 24 fixture. There’s also another item. We have to add 25Executive Court Reporters (301) 565-0064 6 2 a starter into this new electrical circuit for a 1 pulse start lamp, and many fixtures may not be able 2 to handle the additional components. 3 MR. BROOKMAN: They won’t fit? 4 MR. GREEN: They won’t fit. There’s just 5 no place to put it, correct. 6 MR. BROOKMAN: Okay. Daniel. 7 MR. YOUNG: Daniel Young. So I understand 8 there are some products that are built to work as a 9 pulse start lamp on a probe start ballast. So just 10 a note for DOE to make sure to take those into 11

account. 12 MR. BROOKMAN: Okay. Keith. 13 MR. COOK: I think you’re referring to 14 some of the new ceramic metal halide type lamps, 15 like the all-start, and yeah, they can be 16 replacement, but they very -- also very efficacious 17

too. 18

MR. BROOKMAN: Joanna. 19 MS. MAUER: Joanna Mauer. Just on the 20 ceramic metal halide, I think DOE said in the 21 framework document that it’s considering ceramic 22 metal halide as a technology option for lamps up to 23 400 watts, because that’s maybe what’s on the market 24 currently. But I think we just encourage DOE to 25Executive Court Reporters (301) 565-0064 6 3 consider not just where the technology is being 1 applied today but where it is kind of evolving, and 2 where it may be or could be applied, and if it could 3 be applied to higher wattage lamps if we’re talking 4 about a standard that won’t go into effect until 5 2017 or so. 6 MR. BROOKMAN: Thank you. You can see 7 several different technology options there. I don’t 8 think we’ve covered all of these yet. I’m quite 9 sure we haven’t. So additional comments on -- 10 additional thoughts on technology options. Daniel. 11 MR. YOUNG: Daniel Young. Just a quick 12 comment. Someone noted that a lot of the incentive 13 programs are pushing people away from HID, but I 14 just wanted to make the comment that we have rebate 15 programs that are focused on pulse start metal 16 halide and ceramic metal halide technologies. 17 MR. BROOKMAN: Those are the companies you 18 represent in California? 19 MR. YOUNG: Yes, California Investor-owned 20 Utilities. 21 MR. BROOKMAN: What about the rest of the 22 country? Do you know about that? 23 MR. YOUNG: I don’t. 24 MR. BROOKMAN: Okay. Susan. No? Nothing 25Executive Court Reporters (301) 565-0064 6 4 additional? Additional -- yes, Daniel. 1 MR. YOUNG: One more thing. Daniel Young. 2 So again, on the previous slide there’s a sentence 3 that says DOE does not consider other lamp 4 technologies to be substitutes for HPS. Does that 5 mean that DOE doesn’t include LEDs as substitutes 6 for HPS, or is that not something that’s relevant to 7 this right now? 8 MR. WALKER: I think the intention of that 9 statement was looking at the HID world. 10 MR. YOUNG: Sure. Thank you. 11 MR. BROOKMAN: Okay. 12 MR. WALKER: Can I ask a follow-on to 13 John, on fixtures? So, I was wondering if you could 14 comment on the extent to which a customer would have 15 to purchase a new fixture if they’re converting a 16 mercury vapor installation to high pressure sodium 17 or metal halide? 18 MR. GREEN: John Green. I’m not sure I 19 understand the question. 20 MR. WALKER: I guess I’m asking if a new 21 ballast, igniter, lamp could be installed in the 22 existing enclosure -- 23 MR. GREEN: For mercury -- 24 MR. HALLEY: For mercury vapor fixture and 25Executive Court Reporters (301) 565-0064 6 5 simply retrofit the guts into a metal halide -- 1 MR. GREEN: That’s probably even less 2 likely than if you had a probe start metal halide 3 current fixture and tried to fit a pulse start into 4 it. Mercury vapor fixtures would be even less 5 likely to accommodate pulse start. 6 MR. BROOKMAN: You’re better off pulling 7 it all out and putting in something entirely new? 8 MR. GREEN: Well, the fixture is something 9 -- you mean the entire fixture, yes, that’s true. 10 You’d have to probably just consider replacing the 11 entire fixture. 12

MR. BROOKMAN: Susan. 13 MS. ANDERSON: This is going back to my 14 days when I was a ... fixture rep. But there’s also 15 something called redirected energy, and you have to 16 make sure that the arc tube is correctly positioned 17 within the optical system of the fixture, and if 18 it’s not then the reflector can redirect energy back 19 into the arc tube and cause the arc tube to self20 destruct. So if you try to retrofit, there’s a lot 21 of things you have to take into consideration beyond 22 just whether you have the right operating system or 23

not. 24 MR. BROOKMAN: Okay. You okay? Get to 25Executive Court Reporters (301) 565-0064 6 6 the microphone, please, Merry. Say your name for 1 the record. 2 MS. WALKER: Merry Walker. As a follow-up 3 to John’s comment about replacing mercury vapor 4 lamps with -- 5 MR. BROOKMAN: Merry, get close. 6 MS. WALKER: -- pulse start metal halide, 7 were there any issues with replacing mercury vapor 8 with a probe start metal halide, or just with the 9 pulse start? 10 MR. BROOKMAN: John. 11 MR. GREEN: Yeah, the probe start metal 12 halide would probably be a more likely fit. It’s so 13 dependent on how the fixture was originally 14 constructed. But there are differences in light 15 center lengths and things that make the optics work 16 correctly, so it’s not just an electrical issue, 17 it’s a matter of are you distributing light 18 correctly as well. And will the optical system work 19 with the other source. So there’s a lot of 20 variables and that’s why I hesitate to give you a 21 pat answer. But the probe start would be a more 22 likely fit, at least from the electrical component 23 viewpoint. I don’t think I can say any more than 24 that at this point. 25Executive Court Reporters (301) 565-0064 6 7 MR. HALLEY: And maybe just -- industry 1 experience hasn’t been that people retrofit mercury 2 vapor fixtures to the other technologies. We just 3 don’t see it done. What we see done is brand new 4 fixture. They might use the same pole, but they put 5 a brand new fixture on that pole, that’s either 6 designed specifically for metal halide or high 7 pressure sodium. 8 MR. BROOKMAN: John, follow on. Just for 9 the record, thank you, Joe, and now back to John. 10 MR. GREEN: John Green again. I think 11 that’s a good point Joe made, because most of the 12 mercury vapor fixtures that are out there are 13 probably very old. Mercury vapor lasts a long time, 14 so if someone’s going to the expense of trying to 15 retrofit an electrical system, they’re probably 16 going to just go ahead and do the entire fixture 17 change out. 18 MR. BROOKMAN: I see. Okay. 19 MS. WALKER: Thank you. 20

MR. BROOKMAN: Susan. 21 MS. ANDERSON: I hope everyone remembers 22 that because of prior legislation, you can’t buy 23 replacement mercury vapor ballasts, so we already 24 have things in place to get rid of mercury. 25Executive Court Reporters (301) 565-0064 6 8 MR. BROOKMAN: Okay. Great. Thank you. 1 Yes, one more slide. 2 MR. WALKER: So, last slide for me, 3 screening analysis. DOE reviews its technology 4 option list and decides which of those options 5 should become design options for consideration in 6 the engineering. So DOE uses criteria like 7 technological feasibility, the practicability to 8 manufacture, install and service that particular 9 design, as well as any adverse effects on product 10 utility or availability, or health and safety. 11 So in item 19, DOE is welcoming comment on 12 how these four criteria could be applied to the 13 technology options that we discussed in the previous 14 slides. 15

MR. BROOKMAN: Joe. 16 MR. HALLEY: NEMA agrees that DOE should 17 focus on the maximum practical design. But in the 18 HID world, especially, there’s a lot of limitations 19 on what represents a practical retrofit. As you 20 work through what’s practical, we agree on assessing 21 it this way. 22 MR. BROOKMAN: You wish to change the 23 wording here and emphasize practical. 24 MR. HALLEY: Number two does say practical 25Executive Court Reporters (301) 565-0064 6 9 to manufacturing, so -- 1 MR. WALKER: I’m with you. 2 MR. BROOKMAN: I think we’ve got that. 3 Okay. Additional comments? Yes, Susan. 4 MS. ANDERSON: Well, our fear is, because 5 this had happened in prior rulemakings, is looking 6 at prototype lamps that have never been made on 7 regular production equipment or ever installed in 8 the field to get any kind of service data on them, 9 you know, let’s stick to something we know works. 10 MR. BROOKMAN: That’s a useful comment, 11 thank you. Other comments related to 19 and these 12 criteria, these aspects of screening? Nothing 13 additional. 14 Let’s take a break. We really covered a 15 lot of ground very efficiently, very effectively, so 16 my thanks to everyone in the room. It’s now 10:20, 17 we’re going to take a break for 15 minutes, which 18 means we’ll resume at 10:35. Thanks to those 19 joining us via the web, we want you to continue to 20 stay with us. If you’re going to -- please -- 21 (Whereupon, at 10:20 a.m., the meeting was 22 recessed for a 15 minute period.) 23 MR. BROOKMAN: For those of you joining us 24 via the web, I understand that here in the room that 25Executive Court Reporters (301) 565-0064 7 0 we don’t have the capacity, at this point, to unmute 1 the lines that are incoming, although we’re working 2 on it, trying to reverse that. So those of you that 3 are joining us via the web, if you have questions or 4 comments, please type them in and we’ll try to 5 insert them in the conversation. In the meantime, 6 we’ve got the tech guys coming up here to see if we 7 can solve that issue. 8 MS. deBUTTS: I mean that was not an issue 9 so far in our conversation, people were able to 10 submit the comments, but we just want to make sure 11 that we can unmute the participants. 12 MR. BROOKMAN: Doing our best to work on 13 that. So we really made good progress already 14 today, and now we’re going to hear from Merry 15 Walker, engineering analysis. 16 Engineering Analysis 17 MS. WALKER: My name’s Merry Walker, and 18 I’m also from Navigant. I’ll be discussing the 19 engineering and the product price determination 20 analysis. So as you can see, the outputs of the 21 engineering and the product price determination 22 analyses uses inputs for the life cycle cost and 23 national impact analyses. 24 This slide depicts the engineering 25 analysis methodology. So first DOE chooses 26 representative equipment classes from the full 27Executive Court Reporters (301) 565-0064 7 1 equipment classes that were discussed earlier. Then 1 DOE selects the baseline models from the 2 representative equipment classes and we’ll use the 3 base line models to assess changes due to 4 establishing energy conservation standards. 5 Then DOE will identify higher efficacy 6 substitutes from a database of commercially 7 available lamps and develop efficacy levels that 8 range from the baseline model baselines to the 9 maximum technologically feasible level. 10 Finally, DOE will scale the results from 11 the representative equipment classes to those that 12 are not directly analyzed. 13 The representative equipment classes are 14 those that have high volumes or unique performance 15 characteristics. DOE concentrates its analytical 16 effort on these specific equipment classes. Within 17 each representative equipment class, DOE then 18 selects the lamp models that are the most common and 19 least efficacious to be the baseline models. When 20 there’s a large portion of the market that has 21 already adopted a more efficacious lamp, then DOE 22 will consider analyzing two baseline models. 23 This table here shows the nine 24 representative equipment classes and their 25Executive Court Reporters (301) 565-0064 7 2 associated 13 baseline models that DOE has 1 preliminarily chosen its analysis. DOE chose these 2 lamps by analyzing commercially available lamps and 3 found that the listed models are the least 4 efficacious and most common. For the representative 5 equipment classes below, you see that there are two 6 baseline models selected. The mercury vapor lamps 7 are the least efficacious -- are typically the least 8 efficacious within their respective representative 9 equipment class, but a large portion of the market 10 has already adopted metal halide lamps. DOE is 11 analyzing both as baseline models because it is 12 important for DOE to be able to correctly assess the 13 life cycle impacts and efficacy level against what 14 is currently used in the market today. 15 So with that, I’d like to open the floor 16 for comments on the representative equipment classes 17 as well as the baseline models selected. 18 MR. BROOKMAN: Let’s go back to the 19 previous table. Susan. 20 MS. ANDERSON: One kind of a general 21 comment that we had is that the scaling doesn’t 22 typically work with HID lamps. They’re non-linear. 23 Whereas scaling worked for halogen car lamps. We 24 don’t see it working for HID lamps. 25Executive Court Reporters (301) 565-0064 7 3 And the other thing, we are going to 1 present an alternate proposal that will be wattage 2 based and in that we will establish proposed 3 baseline lamps as well. And then one other thing -- 4 and one of the lumen ranges here, this is in the 5 metal halide/mercury grouping, in the 8001 to 12000 6 lumen range, one of your proposed baseline lamps is 7 a 150 watt probe start metal halide. As far as I 8 know, all 150 watt metal halide lamps are pulse 9 start. Is there an exception -- 10

MR. BROOKMAN: Tom. 11 MR. HARDING: Tom Harding. There is one. 12 There’s a 150 watt probe start that’s actually works 13 on the 175 watt ballast as a replacement lamp -- and 14

saves -- 15 MS. ANDERSON: It’s a retrofit? 16 MR. HARDING: It’s a retrofit lamp for a 17 175 watt probe start ballast system. 18 MR. BROOKMAN: So what does -- I didn’t 19 understand what that does to the categories that are 20 here. 21 MS. ANDERSON: I was just pointing out 22 that except for this one exception, then, there’s no 23 150 watt probe start metal halide which was chosen 24 as a baseline lamp. 25Executive Court Reporters (301) 565-0064 7 4 MR. BROOKMAN: Okay. 1 MS. ANDERSON: All the medium screw-base 2 lamps, when those were developed, those were pulse 3

start. 4 MR. BROOKMAN: NEMA’s going to come 5 forward with an alternate proposal, based on 6 wattage. Okay. Additional comments on these -- 7 this table? None. Okay. 8 MS. WALKER: Okay. After establishing ht 9 baseline models, DOE selects higher efficacy 10 substitutes by collecting and analyzing commercially 11 available lamps. DOE recognizes the lamps lumen 12 package and other performance characteristics, such 13 as CRI and CCT are important design criteria for 14 customers and chooses more efficacious lamp 15 substitutes with performances similar to that of the 16 baseline lamp. In order to maintain lumen output, 17 DOE may select a reduced wattage, high efficacy lamp 18 replacement or respace and reduce the number of 19 fixtures to equalize lumen output. 20 Because lamps and ballasts operate 21 together in practice, DOE is basing its energy 22 consumption analysis on a lamp and ballast system. 23 When the ballast is also taken into consideration, 24 it will more accurately characterize the cost 25Executive Court Reporters (301) 565-0064 7 5 effectiveness of an efficacy level. 1 We’d like to open the floor for comments 2 on high efficacy lamp substitutes as well as the 3 availability of reduced wattage lamps, and the 4 practicality of respacing and reducing fixtures as 5 well as whether barriers exist in developing new 6 lamps that would provide reduced wattage 7 alternatives in today’s lamps. 8

MR. BROOKMAN: Susan. 9 MS. ANDERSON: Yes. A lot -- we’ve 10 already made a lot of comments that really apply to 11 this and do please remember that when you’re looking 12 at a retrofit like if someone were to go from probe 13 start to pulse start, remember the issues with that, 14 and as John said, you have to have add a starter 15 into the fixture and there really isn’t -- he 16 doesn’t expect there to be room for that, so it’s 17 really not practical. You’re talking about going to 18 a whole new fixture. So you should take in to when 19 you do your cost analysis, it should be based on a 20 new luminaire. Not a retrofit situation. 21 The other thing, I think John is going to 22

comment. 23 MR. BROOKMAN: John. 24 MR. GREEN: Yes, John Green. As far as 25Executive Court Reporters (301) 565-0064 7 6 the idea of changing the spacing of fixtures, maybe 1 bringing them closer together or further apart, 2 based on a new lamp, is really impractical. There 3 are a few wiring systems out there that allow 4 fixtures to be moved around. They’re called 5 flexible wiring systems or modular wiring systems, 6 that are specifically put in to make a space 7 flexible in the way it’s utilized. However, the 8 vast majority of installations are done with a fixed 9 conduit system, with fixed terminations where the 10 luminaries are located, and to move luminaries would 11 be a very expensive and time consuming proposition, 12 because conduits would have to be moved, hanging 13 systems redone, and in a lot of cases, a building 14 layout drives the way the fixtures are located 15 anyway. The aisle-ways in warehouses, or grocery 16 stores or wherever this fixture is being used, the 17 location of the fixture is important because of the 18 layout of the application. So the fixture cost may 19 pale in comparison to trying to move electrical 20 systems and repositioning fixtures. So it’s a very 21 impractical assumption to make. 22 MR. BROOKMAN: Okay. Susan. 23 MS. ANDERSON: Kind of an additional 24 comment along that line. A lot of times, it’s the 25Executive Court Reporters (301) 565-0064 7 7 location of other systems -- duct work, sprinkler 1 heads and that sort of thing that really have the 2 final determination of where the lighting fixture 3 can be located. And in the case of sprinkler heads 4 for safety and insurance reasons, that takes 5 precedence over the ideal location for the 6 luminaire. So it’s -- chances are you’re not going 7 to see any gain from assuming something like that. 8 And it seemed to me as I read this, that the DOE had 9 come to the same conclusion there. 10 MR. BROOKMAN: Okay. Tom, you want to 11 comment? No. Okay. Susan, please. 12 MS. ANDERSON: One other thing. We did 13 want to note that when you look at mercury vapor 14 being replaced by metal halide or high pressure 15 sodium, it’s really application driven. So indoors 16 you tend to see mercury vapor replaced with metal 17 halide or fluorescent, and outdoors, you tend to see 18 mercury vapor replaced with high pressure sodium. 19 That’s been the traditional replacement, but in more 20 recent years, because of a lot of the incentive 21 programs that are out there, it’s been going to LED, 22 particularly in the last three years, with the 23 stimulus funding that many states and communities 24 have received. 25Executive Court Reporters (301) 565-0064 7 8 MR. BROOKMAN: Okay. Thank you. Yes, 1 Mimi. 2 MS. GUPTA: Mimi Gupta, Navigant. So 3 earlier we talked about a lot of the limitations 4 associated with using reduced wattage lamps and how 5 that might necessitate a ballast change. And then 6 we talked about how changing technology would 7 necessitate a ballast change also. Does the 8 industry see any opportunities for energy savings 9 that would not necessitate ballast change? 10 MS. ANDERSON: We do have some lamps, in 11 our case we call them super cybrus, that’s our 12 traditional name, where we have a 360 watt metal 13 halide that replaces a 400 watt metal halide. But 14 it operates on the same ballast, and your savings is 15 that 40 watts difference in the lamp. Those are 16 already in the market place. 17 MS. GUPTA: Right. And so I think we’ve 18 seen those on the market, but there aren’t reduced 19 wattage options for every wattage out there. Is 20 there that capability of designing those? 21 MR. BROOKMAN: Keith. 22 MR. COOK: Keith Cook. In all honesty, 23 it’s highly unlikely, and the reason is there’s such 24 an emphasis on LED systems now as a replacement for 25Executive Court Reporters (301) 565-0064 7 9 a large part of this whole market, that the 1 resources are being spent in that area, as opposed 2 to developing new technologies and new replacement 3 lamps in the HID market. The long term bet is 4 really on the LEDs, and so as far as developing new 5 models, highly unlikely. 6

MR. BROOKMAN: Joe. 7 MR. HALLEY: I would agree with that. 8 Pretty much what is on the market today, you have to 9 assume that that is what you have to work with. 10 MS. WALKER: Is there a certain tolerance 11 in terms of wattage that a ballast can tolerate, 12 like, you know, you talked about going from 400 to 13 360 as you can operate that on the same ballast. 14 But maybe going from 250 to 175 is out of that 15 capability, it’s too big of a difference. Is there 16 a percentage change that -- 17

MR. BROOKMAN: Susan. 18 MS. ANDERSON: Well, yeah, that’s not 19 within the ballast tolerance range. And there you’d 20 have such a difference in light level, would not be 21 -- you wouldn’t be providing equivalent light. 22 MR. BROOKMAN: Keith. 23 MR. COOK: Yeah, essentially what we have 24 to do when we design a new lamp is to actually make 25Executive Court Reporters (301) 565-0064 8 0 sure that there are ballasts available that will 1 drive it. So it’s almost an impedance match, and so 2 we have to look at that and to make sure that the 3 replacement that we’re putting in will work in that 4 application. 5 MR. BROOKMAN: John. 6 MR. GREEN: Susan noted about the -- I 7 think we’ve all noted about the technology and where 8 resources are being spent. They were commenting on 9 the lamp manufacturers’ viewpoint, but the same 10 thing applies to fixture manufacturers. Very little 11 is being placed now on sources other than LED, so 12 we’d rather place our development funding and 13 resources into a technology we feel is going to be 14 more appropriate in the next five years. So just 15 wanted to reinforce that. 16 MR. BROOKMAN: Thank you. Okay. 17 MS. WALKER: Okay. After identifying more 18 efficacious lamp substitutes, DOE develops a set of 19 candidate standard levels, also known as CSLs, that 20 are considered in the interim analysis. The CSLs 21 span the range of lamp efficacies from the baseline 22 to the maximum technologically feasible level, and 23 considers other factors such as design options. 24 The equipment class structure that was 25Executive Court Reporters (301) 565-0064 8 1 previously discussed reflects a bin efficacy level 1 approach in which DOE would establish one lamp 2 efficacy for each lumen range. Although this may 3 simplify standards, it would subject all the lamps 4 within a lumen range to the same level. Because 5 high efficacy lamps typically have higher lumen 6 output, it could potentially shift the market 7 towards high lumen output lamps that also have 8 higher input power within each bin, thereby negating 9 energy savings. Because of this, DOE is considering 10 an equation-based approach in which lamp efficacy 11 would be defined as a function of lumen output, thus 12 eliminating the need for equipment classes to be set 13 on lumen output. 14 So we had some comments earlier about 15 using wattage instead of lumen output, but we would 16 also like to receive comment on the use of an 17 equation-based approach rather than a bin approach, 18 and also whether highly efficacious lighting systems 19 could be eliminated given a particular lamp efficacy 20 requirement. 21

MR. BROOKMAN: Yes. 22 MR. HALLEY: This is Joe. We, for this 23 particular product area, we don’t believe an 24 equation-based approach is practical -- is a 25Executive Court Reporters (301) 565-0064 8 2 practical way to apply an analysis. We believe, in 1 this case, you have to look at, since this is mostly 2 going to affect new -- mostly going to affect 3 existing systems, you have to look at the existing 4 system installed, for instance, a 200 watt -- or 250 5 watt, say, metal halide system -- and determine is 6 there any practical replacement for that system. 7 They’re going to have very limited ability to just 8 change a lamp, which means they’d have to change a 9 lamp and a ballast. And if they have to change a 10 lamp and a ballast, the question is, will the 11 starter, for instance, if you’re going to pulse 12 start, the pulse start system fit. In most cases it 13 wouldn’t, and so you would have to assume you have a 14 fixture change. If you’re going to a fixture 15 change, you have to determine whether or not it’s 16 cost-effective to change out an entire system that’s 17 already fairly efficient to one that’s perhaps 18 slightly more efficient. And given that each system 19 represents its own discrete problems, and there 20 might be different options, whether you’re talking 21 175 or 250 or 400, we believe you have to look at 22 each of these in a binned approach. You have to 23 look at each wattage bin, which is what we’ll be 24 suggesting, creating wattage bins. And you have to 25Executive Court Reporters (301) 565-0064 8 3 analyze each wattage bin to look at what options 1 there are for the existing system, because this is 2 going to have the biggest impact on existing 3 systems. 4 We believe new systems are already being 5 converted by two other rulemakings, one that 6 essentially eliminated mercury vapor ballasts, and 7 the other one that’s forcing fixtures to go to -- 8 brand new fixtures to go to pulse start systems. 9 That has taken care of the new systems going forward 10 which represent the future systems. But in terms of 11 the existing system, this rulemaking is going to 12 have the biggest impact on existing systems, 13 existing users, and you have to really look at what 14 they have and what their real options are, and 15 whether or not it’s cost-effective to force them, in 16 most cases, to go into an entire new fixture, 17 including electrical labor rates associated with 18 putting in a new fixture. 19 So, again, we don’t think -- an equation 20 only works in theory. It’s a good theoretical 21 concept if we’re in college, maybe that’s a good 22 approach. But in the real world, we have to look at 23 specific systems and what these specific equipment 24 options are for that application. 25Executive Court Reporters (301) 565-0064 8 4 MR. BROOKMAN: Keith. 1 MR. COOK: Keith Cook. For item 25, we’re 2 not against evaluating highly efficacious light 3 systems, but we do want to proceed very, very 4 cautiously here. And the reason we’re saying that 5 is, we know for a fact right now that an unprotected 6 lamp is going to be more efficacious than one that 7 is protected or one that’s coated. And yet there 8 are many applications where we absolutely have no 9 choice but to put in a protected lamp. Like 10 gymnasiums or grocery stores or those kind of 11 environments. And so if we jump to the conclusion 12 that we have to go to this because it’s the most 13 efficacious light system, we end up with no solution 14 to the market, I’ll tell you right now. So, you 15 know, we agree, let’s look at it, but we can’t rule 16 out that a lot of these lamps that we know for a 17 fact are less efficacious. 18 MR. BROOKMAN: Okay. Susan. 19 MS. ANDERSON: Well, there’s another thing 20 to think about in terms of the protect versus the 21 non-protected lamp too, and that the protect lamp 22 can go in an open luminaire, and in many cases those 23 are more efficient systems and they stay -- the 24 whole system stays cleaner longer, it has better 25Executive Court Reporters (301) 565-0064 8 5 lumen maintenance over its life because of the 1 design of the luminaire not having that lens in 2 place. There’s one manufacturer where it’s always 3 open around the top of the optical system, so 4 there’s literally a chimney effect so that dirt 5 rising up into the fixture, the air movement, the 6 hot air rising from the heat generated by the lamp, 7 lifts it up and out of the fixture, so the inside of 8 the luminaire stays cleaner. So there are definite 9 advantages to these open fixtures as opposed to 10 enclosed. 11 MR. BROOKMAN: Daniel. 12 MR. YOUNG: Daniel Young. I have a 13 question for NEMA. Is your proposal then looking at 14 specific rated wattages, or are there still going to 15 be multiple rated wattages per bin? So instead of 16 DOE’s approach, which is to look at bins that might 17 include multiple rated wattages, -- 18 MR. BROOKMAN: Daniel, get close to that 19 microphone, please. 20 MR. YOUNG: Sorry. As opposed to DOE’s 21 proposal which could potentially include multiple 22 rated wattages within a single bin, is NEMA’s 23 approach to split completely by rated wattage and to 24 look at -- so for this rated wattage, this energy 25Executive Court Reporters (301) 565-0064 8 6 would be set here, and so forth? 1 MS. ANDERSON: Our technical folks are 2 actually in discussion on that now. We started out 3 with a proposal that came from our company, and it 4 was strictly wattage based. I’m sure there’ll be 5 some binning, but not in terms of today’s existing 6 wattages. So like a -- it’s possible, I don’t know 7 what they’re going to come up with -- like the 360 8 watt energy saving lamp would end up in the same bin 9 as the 400. Because they operate on the same 10 ballast. 11 MR. BROOKMAN: Did we cover it? Mimi. 12 MS. GUPTA: I just want to ask one 13 question, following on a comment that Joe made 14 earlier on -- in the meeting, relating to the 15 variability of lumen output for a given wattage 16 lamp. This is an issue that’s kind of come up in a 17 lot of the previous lighting rulemakings, having to 18 do with, you know, say we find a commercially 19 available lamp on the market that saves energy, and 20 DOE wants to target as an energy saving option. 21 What is the efficacy standard that represents that 22 lamp? And how does variability fit into that? So I 23 would just request industry to submit whatever data 24 they can as early as possible, regarding the 25Executive Court Reporters (301) 565-0064 8 7 variability in terms of efficacy of a given model 1 and how that should be incorporated into the 2 analysis. 3 MR. BROOKMAN: Okay. 4 MS. WALKER: Okay. Well, actually I have 5 a question, and this is related to the bin versus 6 the equation-based approach. So the same concern 7 that when there’s one efficacy level set for a 8 particular bin, it might shift the market towards 9 one end of the bin because it’s easier to meet a 10 standard because the lamps are more efficacious at 11 one level. Would you anticipate the same thing 12 happening with the wattage bin approach, shifting it 13 towards higher wattage lamps, perhaps? 14

MR. BROOKMAN: Joe. 15 MR. HALLEY: No. We wouldn’t expect that 16 to happen because the ballasts are rated to drive a 17 specific lamp design, a specific lamp wattage, so 18 you just can’t put in a 400 watt lamp in a 250 watt, 19 say, system, because it’s more efficient. In fact, 20 the reg grouped 250s and 400s together in the same 21 bin, and you set the reg based on the 400, it would 22 eliminate a 250 watt lamp, and there would literally 23 be no product that could go into that system if you 24 did that for that user, because he couldn’t use it. 25Executive Court Reporters (301) 565-0064 8 8 He’d have to go to a brand new fixture in that case. 1 So, bin hopping in this particular case, that might 2 be more of an argument for perhaps a source where 3 you can go up and down quite easily with wattages, 4 perhaps more of an incandescent type of source, 5 where you can move it anywhere. Where, with metal 6 halide, they’re discretely designed. The wattages 7 are discrete. The ballasts are discrete. There 8 really isn’t any opportunity for the user to bin hop 9 up or down. So we wouldn’t expect that to be a 10 concern with this particular product line. 11

MR. BROOKMAN: Joanna. 12 MS. MAUER: Joanna Mauer. I think we’d 13 encourage DOE to consider an equation-based approach 14 if DOE can develop an equation that represents the 15 relationship between lumen output and efficacy, I 16 think it would just better represent that 17 relationship between efficacy and lumen output. 18 MS. WALKER: Okay. The final step to the 19 engineering analysis is to scale the efficacy levels 20 that are established for the representative 21 equipment classes to those that are not directly 22 analyzed. DOE intends on using scaling factors that 23 are observed in catalog data or by extrapolating 24 lumen output using regression equations. 25Executive Court Reporters (301) 565-0064 8 9 We’d like to open the floor for comments 1 on the scaling approach. 2

MR. BROOKMAN: Susan? 3 MS. ANDERSON: Well, as we’ve already 4 mentioned, HID lamps are non-linear in response, so 5 we really don’t see how you can go down that path. 6 You also have the issue, once again, of coated 7 versus clear, protect versus unprotect, standby 8 versus not standby, CCT, CRI -- 9 MR. HALLEY: Orientation. 10 MS. ANDERSON: -- orientation. 11 MR. HALLEY: Orientation is a big one. 12 MS. ANDERSON: We have all those issues. 13 MR. BROOKMAN: Mimi. 14 MS. GUPTA: So, I guess I think the 15 question here, this is Mimi Gupta, is for those 16 other issues that you’re talking about, can none of 17 them be characterized by a percentage reduction in 18 efficacy if we’re talking about coated versus 19 uncoated or maybe can orientation be represented in 20 that way? 21 MS. ANDERSON: Well, orientation is 22 already pretty clearly represented, because if you 23 look in our catalogues, for -- say, for instance, if 24 it’s the universal operating lamp, we give you 25Executive Court Reporters (301) 565-0064 9 0 vertical lumens versus horizontal lumens. And in 1 lamps where we have position-specific oriented 2 lamps, you can compare those ratings base up, to 3 base down, to horizontal. That’s all published 4 information. And as is coated versus clear. And 5 when you get into the metal halide family, in 6 particular, you can see the different chemistries 7 and the impact on the lumens, 3000 Kelvin versus 8 4000 Kelvin. 9 MS. GUPTA: So when you say, you know, you 10 don’t think scaling is appropriate for HID lamps, 11 you’re more talking about scaling across wattages? 12

MS. ANDERSON: Yes. 13 MS. GUPTA: Okay. 14 MR. BROOKMAN: Okay. 15 MS. WALKER: In considering standards, DOE 16 will not set a level -- oh. 17 MR. YOUNG: Sorry, Daniel Young. A 18 question about the scaling. So you’ve mentioned 19 that it’s not a linear relationship. Is there no 20 relationship, or can you isolate certain factors 21 like CCT or coating and develop some kind of 22 relationship. 23

MR. BROOKMAN: Tom. 24 MR. HARDING: Tom Harding. There are 25Executive Court Reporters (301) 565-0064 9 1 relationships. There was a general statement made 1 that as you go up in wattage, you generally get more 2 efficacious. The problem is trying to do one size 3 fits all. There are so many jumps: clear/coated, 4 universal, ... co... temperatures. There are different 5 chemical technologies. I mean from a standpoint of 6 materials, metal halide is one of the most 7 complicated ones. Most light sources have one or 8 two elements. Metal halide can have ten. So 9 they’re very complex, and they all do different 10 things. And so it’s very hard to find an equation 11 that covers everything. But within very narrow 12 parameters you can make short jumps in equations. 13 But then you can’t jump, as Susan said, if you want 14 to make a more efficacious fixture, you might take a 15 lens off and use a less efficacious lamp, say a 16 protected lamp, makes a better system, doesn’t make 17 it that more efficacious lamp. So just so many 18 jumps. But in general there are rules that -- not 19 rules, there are observations as you go up in 20 wattage you generally get more efficacious. 21 But I can sit here and give you all kinds 22 of exceptions. I can tell you now a 400 watt lamp 23 that has higher efficacy than 1000 watt lamp. 24 Changing chemistry and materials. There’s just so 25Executive Court Reporters (301) 565-0064 9 2 much of that in these metal halide systems. 1 MS. WALKER: Okay. So, again, in 2 considering standards, DOE will not set a level that 3 can only be met by a single proprietary design. 4 Because of this, DOE is seeking feedback on the 5 existence of proprietary designs. We’d like to open 6 the floor for comment on this issue, as well as any 7 other issue related to the engineering analysis. 8 MR. BROOKMAN: Alex. 9 MR. BOESENBERG: Given the individual 10 nature of the comment, NEMA will not be able to 11 provide comment on this subject. So my comment is I 12 have no comment. 13

MR. BROOKMAN: Joe. 14 MR. HALLEY: There may be individual 15 manufacturer designs, but as you’re going through 16 the manufacturer interview process, you may ask them 17 about unique designs that companies may have. 18 MR. BROOKMAN: So you would just -- 19 MR. HALLEY: They do exist. 20 MR. BROOKMAN: That’s what I wondered. 21 You anticipate that there could be proprietary 22 designs that the Department of Energy might need to 23 consider. 24 MS. ANDERSON: Yes, patent protected. 25Executive Court Reporters (301) 565-0064 9 3 MR. BROOKMAN: And so they will need to 1 seek that out. 2

MR. HALLEY: Yes. 3 MR. BROOKMAN: In a protected sort of a 4 way. Okay. 5 MS. WALKER: Thank you. For this 6 rulemaking, DOE plans on estimating end user price 7 directly, rather than using a bill of materials and 8 marking that up to generate the manufacturer’s 9 selling prices, also known as MSPs. This is because 10 it’s not practical to reverse engineer an HID lamp 11 to derive the manufacturer production cost of the 12 lamp. They are not easily disassembled and full gas 13 composition and partial pressures are difficult to 14 assess. Therefore, DOE is considering collecting 15 manufacturers’ suggested price lists, also known as 16 blue book values, and applying discounts based on 17 distribution channels through which the lamp is 18 purchased. DOE will gather price information from 19 state procurement contracts, large distributors, and 20 other publicly available end user prices to 21 determine discounts. 22 We would like to open the floor for 23 comment on end user price approach for calculating 24 the cost of this efficacy relationship for HID 25Executive Court Reporters (301) 565-0064 9 4 lamps. In particular, DOE seeks comment on typical 1 distribution channels for HID lamps, as well as the 2 allocation of market share between these channels. 3 MR. BROOKMAN: Alex. 4 MR. BOESENBERG: Alex Boesenberg. That’s 5 another topic we refer to the individual 6 manufacturer interviews, given the individual nature 7 of such arrangements and cost structures. 8 MR. BROOKMAN: You can’t characterize 9 typical distribution channels as we have in previous 10 rulemakings? 11 MS. ANDERSON: Distribution channels, yes. 12 Pricing, though, we’re not allowed to discuss, due 13 to antitrust rules. 14 MR. BROOKMAN: Okay. 15 MS. ANDERSON: And we do -- in our written 16 comments we will have some modifications to the 17 distribution channel. 18 MR. BROOKMAN: Okay. 19 MS. WALKER: Okay. Thank you. Should we 20 continue? 21

MR. BROOKMAN: Yes. 22 MS. WALKER: I’ll pass on to Mike Myer. 23 MR. BROOKMAN: Now, energy use analysis, 24 Michael Myer. How are we doing with the folks on 25Executive Court Reporters (301) 565-0064 9 5 line, Emily. 1 EMILY: We’re going to patch them through 2 so they can comment. 3 MR. BROOKMAN: Okay. 4 **Energy Use and Markup Analysis** 5 MR. MYER: Thank you. My name is Michael 6 Myer. 7 MR. BROOKMAN: I guess we then need to 8 remind everyone who’s joining us on line to mute 9 their telephones if they’re not going to speak and 10 unmute them if you want to speak, and we’ll be 11 recognizing you as best we can when our webmaster 12 over here sees that you want to contribute to the 13 conversation. Okay, Michael. 14 MR. MYER: That was just -- 15 (Problems with sound.) 16 MR. BROOKMAN: So we’re having technical 17 difficulty and we’re going to try and resolve this 18 very quickly, so hang in there those here via the 19 web. 20 MR. MYER: I’m going to try it again. I 21 think they’ve corrected it in the room while we’re 22 waiting, so I’ll wait one more second. This works, 23 I don’t hear any echo, so I will continue on. Do 24 we need to wait for the court reporter? Okay. 25Executive Court Reporters (301) 565-0064 9 6

Thank you. 1 My name is Michael Myer, and I’ll be 2 discussing both Energy Use and Markup Analysis. 3 These are both inputs that are factored into the 4 life cycle cost and payback analysis, which then 5 also get factored into other analysis later on. 6 Energy analysis is pretty straightforward. 7 We’re trying to determine the energy use data for 8 HID systems. Obviously, as we discussed, ballasts 9 are important role here, mainly for the power 10 input, so they’ll be used. We’ll take the power 11 data from the engineering analysis, just a median - 12 - a typical wattage input that’ll be generated in 13 the engineering analysis. Ultimately, we want to 14 get a sense of where lamps are used, in what type 15 of spaces, and roughly how long they’re operated in 16 those spaces. We will look at the most recent 2010 17 US lighting market characterization, the commercial 18 building energy consumption survey, also known as 19 CBECS, and also the manufacturing energy 20 consumption survey. 21 We’ll take all that data and aggregate it 22 and get a sense of what the typical operating hours 23 are, and then we’ll take the typical input power 24 and multiply them together and you get an operating 25Executive Court Reporters (301) 565-0064 9 7

hours per year. 1 Brings us to items 31 and 32. On the 31, 2 we’re requesting comment on ballast efficiency and 3 ballast input power. This is separate from -- this 4 is really more historic numbers, because the idea 5 with the energy analysis is we’re trying to get a 6 sense of what the energy savings potential could be 7 from standards, and so we’re interested in ballasts 8 that were previously installed, what their input 9 powers are that are now probably covered by 10 standards such as metal halide or the mercury vapor 11 standard and what those ballast efficiencies should 12 be. It’s a slightly different scenario than usual. 13 I’ll pause for comment for a second. 14

MR. BROOKMAN: Susan. 15 MS. ANDERSON: Well, when taking into 16 consideration the installed base, I mean the 17 installed base is basically magnetic, so where 18 magnetic ballast, you’re going to have to make sure 19 that you look across multiple manufacturers’ 20 catalogs, and look at those system input powers. 21 And you might also look at luminaries because you 22 also -- it’s not as much so as in fluorescent, but 23 you can have a fixture effect that can impact the 24 system input power. 25Executive Court Reporters (301) 565-0064 9 8

MR. BROOKMAN: What is that? A system 1 effect? 2 MS. ANDERSON: Once the ballast is 3 installed in a fixture and it’s in a confined area, 4 it can change the input power of the system. 5 MR. BROOKMAN: Okay. 6 MR. MYER: I guess I’d like to elaborate 7 on that. So using current catalog data for -- can 8 we use stand-in for mercury vapor specialty 9 ballasts, since they can still be currently sold 10 and they’re in catalogs, as a representative 11 mercury ballast -- mercury vapor ballast input 12 power for something, let’s say, that was installed 13 in 2006? That’s -- ultimately that’s the historic 14 aspect we’re trying to get at. And the same 15 question would be for probe start metal halide 16 fixtures, now that the ballasts are covered by a 17 standard, can we use the current magnetic data that 18 we’re seeing out there and should we assume a 19 different efficiency and thus a different input 20 power for magnetic probe start systems that were 21 installed in, again, let’s say 2008, that were 22 precovered? 23 MS. ANDERSON: For metal halide, you’re 24 going to be able to get at least the ballast, for 25Executive Court Reporters (301) 565-0064 9 9

the ballast manufacturers, you’ll be able to get 1 those numbers because there’s no restriction on 2 selling replacement metal halide ballasts. 3 MR. MYER: Okay. 4 MS. ANDERSON: In the case of mercury 5 vapor, for most applications, those ballasts that 6 drive the specialty lamps are not the same ballasts 7 that drive the general lighting lamps. But I would 8 think that ballast manufacturers would have -- 9 could help with older editions of their catalogs, 10 or even luminaire manufacturers, older editions of 11 their catalogs to help you get to that information. 12 MR. BROOKMAN: Thank you. John. 13 MR. GREEN: Yes, in a previous employment 14 I actually did a lot of ballast design, and it may 15 not be as simple as pegging one input wattage to a 16 ballast. When I was designing ballasts, we 17 actually manufactured two, one was a low loss 18 version, which had lower input power than the 19 standard. It had a premium cost associated with 20 it, but it was a choice customers could make. So 21 it may be a little more involved than just picking 22 one number. May have to look at a number of 23 different types of ballasts. 24 MR. BROOKMAN: Okay. Thank you. Joe. 25Executive Court Reporters (301) 565-0064 1 00

MR. HALLEY: On item 32, I just was going 1 to agree that your proposed methodology and the 2 sources that you have selected to look at seem 3 appropriate. Trying to get at hours of use and 4 various applications. We’ve seen those studies in 5 reports and they seem like they represent a 6 reasonable survey of actual operating conditions. 7 MR. BROOKMAN: So are you speaking on 8 behalf of NEMA? 9 MR. HALLEY: On behalf of NEMA, yes. 10 MR. BROOKMAN: Thank you. Susan. 11 MS. ANDERSON: I would say in one previous 12 rulemaking, we saw when they took commercial 13 offices different from retail, so just keep that in 14 mind, because when we saw that previous rulemaking, 15 the number for commercial did not reflect retail 16 operating hours. 17 MR. HALLEY: I suppose that’s true. We 18 reserve the right to actually see what numbers 19 you’re selecting. And further comment, if we think 20 that they were accurately selected. 21 MR. MYER: Sure. Of course. In terms of 22 follow on what you’re saying, Susan, in terms of 23 HID and typical applications, you’re going to see 24 them much more common in retail than you are in 25Executive Court Reporters (301) 565-0064 1 01

commercial -- in commercial office -- and that’s 1 why you’re pointing that out. 2 MS. ANDERSON: Right. Like you’re going 3 to see them in a big box retailer, that’s our 4 grocery store, that sort of thing. You’re not 5 going to see them -- so commercial generally 6 reflects more office space as opposed to retail 7

space. 8 MR. MYER: Thank you. Continuing on. So 9 then the other analysis would be the markup 10 analysis, and that was briefly touched on 11 previously by Merry Walker. The purpose -- this is 12 slightly different than previous passes -- Merry 13 said, you can’t really take apart an HID lamp and 14 get a sense of the cost, so we’re going to use the 15 existing cost for -- not the existing cost, but the 16 blue book or the price list where we can. But at 17 the same time, we still look for markups that’s 18 been discussed many times in this meeting already, 19 that in some cases you may have to replace a 20 ballast, or in some cases you may have to replace 21 an entire fixture, and those do have markups 22 associated with them, as well we’re interested in 23 any costs associated that we can figure in as well. 24 So what we’re going to do is we’re going 25Executive Court Reporters (301) 565-0064 1 02

to identify distribution channels which we’ll show 1 in a second, and then we’re also going to want to 2 estimate markups from each step in the 3 manufacturing process. 4 So we identified two initial HID lamp 5 distribution channels. They’re shown here as one 6 and two. They’re very similar. The first one 7 would be from the manufacturer to wholesaler or 8 electrical distributor, to a contractor, to an end 9 user. The second one there’s no contractor, it 10 would be just the manufacturer to the electrical 11 wholesaler to the end user. 12 As we’ve discussed also, in some cases you 13 will possibly need to replace a ballast outright. 14 We then identified a replacement HID ballast 15 distribution channel. Again in this case, it would 16 be the ballast manufacturer, to an electrical 17 distributor, to a contractor to an end user. 18 And then the third option that we 19 discussed rather in depth, is that the potential to 20 have to change to a wholesale fixture. In this 21 case, we identified in this case, it would be a 22 fixture manufacturer to an electrical distributor, 23 to a contractor, to an end user. 24 And that brings us to items 33 and 34. We 25Executive Court Reporters (301) 565-0064 1 03

welcome comments and suggestions concerning pricing 1 and approach for existing consumer prices for 2 lamps, but also for ballasts and fixtures, because 3 they will have to get factored in there. And item 4 34, comments on typical manufacturer, wholesaler, 5 and contractor markups. 6 MR. BROOKMAN: Susan. Alex first. 7 MR. BOESENBERG: I can do the first one on 8 pricing. We can’t do that here, sorry. Individual 9 manufacturers, during their interviews, will have 10 an opportunity to assist the DOE in that. 11 MR. BROOKMAN: Thank you. Susan. 12 MS. ANDERSON: My comment is on 13 distribution channels. When you’re looking at the 14 HID ballast and also the luminaire distribution, 15 remember that you have, particularly like with 16 industrial businesses, they have people that can do 17 the work. They don’t need a contractor. So it may 18 go from the manufacturer to the wholesaler, to the 19 end user. 20 And then also, when you get to the fixture 21 distribution channels, there are some fixture 22 manufacturers that sell directly to the end user. 23 And they totally skip the wholesaler and the 24

contractor. 25Executive Court Reporters (301) 565-0064 1 04

MR. MYER: Would those be utilities or 1 what type of industry would you expect those to be? 2 MR. COOK: Could be utilities, could be 3 municipalities, typically project work. 4 MR. MYER: I’m sorry, I’m not familiar 5 with the term “project work.” 6 MR. COOK: It’s when we’re selling 7 specific -- like we will bid on a job at a specific 8 city, and so we will deliver straight to that city, 9 and they will arrange installation and things like 10 that. 11 MR. MYER: Would you characterize that as 12 outdoor more you can’t define it as whether it’s 13 outdoor or indoor? 14 MR. COOK: It doesn’t have to be 15 necessarily outdoor, although that is a good 16 example of it. 17 MR. MYER: Okay. 18 PARTICIPANT: Sometimes they’re sold that 19

way. 20 MR. COOK: Depends on who the customer is. 21 MR. MYER: Thank you. At this time I’m 22 going to turn the presentation over -- 23 MR. BROOKMAN: Wait. Yes, John, please. 24 MR. GREEN: Back up. The HIV lamp 25Executive Court Reporters (301) 565-0064 1 05

distribution channel. There’s also probably a 1 number three there, where a lot of -- I’ll say some 2 fixture manufacturers package lamps with fixtures, 3 so it’s actually a light manufacturer to the 4 fixture manufacturer, and then that would be a 5 third method of distribution of HID lamps. 6 MR. MYER: Okay. And that would be in a 7 new construction scenario and not in a replacement 8 scenario. 9 MR. GREEN: That’s correct, yes. 10 MR. MYER: Okay. And they would be paying 11 a markup -- so I guess I need to figure that out. 12 So it would be fixture manufacturer with lamp, but 13 it would be -- and then it would be the same 14 channel, the fixture channel, but with a lamp. 15 MR. GREEN: Yes, just so you take number 16 two and insert fixture manufacturer after lamp 17 manufacturer, and then still go to the wholesaler 18 and end user. 19 MR. MYER: Okay. 20 MS. ANDERSON: That’s typically the most 21 common scenario with new installations. Because it 22 saves the contractor the labor of installing the 23 lamp. 24 MR. MYER: Great, and appreciate any rough 25Executive Court Reporters (301) 565-0064 1 06

estimates of percentage of distribution channels as 1 well. 2 At this time I will turn the presentation 3 over to Scott Morris, who will introduce life cycle 4 cost analysis and payback period analysis. 5 **Life Cycle Cost Analysis and** 6 **Payback Period Analysis**  7 MR. MORRIS: Thank you, Michael. Good 8 morning. I’m Scott Morris, and as Michael 9 mentioned, I’ll be talking first about the life 10 cycle cost and payback period analysis. 11 So the life cycle cost and payback period 12 analysis build upon previous analyses to determine, 13 as the name implies, the total life cycle cost and 14 payback period of the equipment considered in this 15 rulemaking. The life cycle cost and payback period 16 analysis considers the effects of a standard on 17 individual customers, specifically life cycle cost 18 is the total cost of HID lamps, including the price 19 of the lamp, installation costs, and operating 20 expenses through the end of the lamp’s lifetime, 21 expressed in today’s dollar figures. 22 The payback period of a lamp, more 23 efficacious than a baseline lamp, is the average 24 number of years it takes a customer to recover the 25Executive Court Reporters (301) 565-0064 1 07

potentially higher first cost through decreases in 1 operating expenses, as shown in the diagram in the 2 bottom here. To account for the range of possible 3 life cycle costs and payback periods, DOE will 4 incorporate Monte Carlo simulations which uses 5 inputs originating from probability distributions, 6 as opposed to average values. 7 Of course, reduced energy use yields 8 reduced energy costs. DOE will use the most recent 9 annual energy outlook produced by the Energy 10 Information Administration to project future 11 electricity price trends. At the same time, DOE 12 uses EAA form A26 data to establish current 13 electricity prices, and then uses the annual energy 14 outlook to project those prices into the future. 15 This brings us to item 35. DOE welcomes 16 any comments on the proposed methodology for 17 estimating electricity prices. 18 MR. BROOKMAN: Alex. 19 MR. BOESENBERG: Alex Boesenberg. I 20 believe as we have in the past, we highly recommend 21 that DOE consult the Edison Electric Institute -- 22 MR. MORRIS: Pardon me? 23 MR. BOESENBERG: Edison Electric 24 Institute, Mr. Steve Rosenstock, due to their 25Executive Court Reporters (301) 565-0064 1 08

excellent information regarding price by region and 1

users. 2 MR. BROOKMAN: Okay. Thank you. 3 Additional comments on electricity prices and the 4 methodology also? Okay. 5 MR. MORRIS: Thank you. Discount rates 6 are used to establish the present day value of 7 future expenses. DOE uses the weighted average of 8 ... set to equity ratios to develop a distribution of 9 discount rates for use in the life cycle cost 10 analysis. And as item 36 says, of course, the 11 Department welcomes any comments regarding the 12 approach for determining discount rates for the 13 life cycle cost analysis. 14 MR. BROOKMAN: No comments? Okay. 15 MR. MORRIS: So there are two primary 16 costs associated with the lifetime of HID lamps, 17 installation costs and operating costs. DOE will 18 consider the expenses involved with installing HID 19 lamps, ballasts, and fixtures. The Department 20 assumes HID lamps require no maintenance during 21 their lifetimes, but are replaced upon failure or 22 early retirement. For example, cleaning costs are 23 typically, we believe cleaning costs are typically 24 part of a fixture operating cost. Any comments in 25Executive Court Reporters (301) 565-0064 1 09

that regard? 1

MR. BROOKMAN: Joe. 2 MR. HALLEY: Yeah, we would agree that 3 with HID, they’re generally replaced as they fail, 4 especially high wattage HID lamps cover a large 5 area, and unlike fluorescent where if one 6 fluorescent lamp goes out in, for instance, the 7 fixtures in this room, it could be left out for 8 quite a while and doesn’t really impact the light 9 level of this room. But if a, say a 400 watt metal 10 halide goes out in a store, they’re going to 11 replace that lamp fairly quickly and not leave a 12 whole section of their store dark. And generally, 13 when they replace it, they may clean the fixture 14 when it’s being replaced. They usually don’t do 15 cleaning in between. 16 In terms of electrical rates, RS means is 17 one source of electrical labor rates. I will note, 18 however, that electrical labor rates can vary 19 greatly in this country, depending on what city 20 you’re working in -- from past experience. So, 21 somehow, I’m not sure how that’s factored in, but 22 this has to be cost-effective in the high labor 23 rate areas as well as the low labor rate areas. 24 MR. MORRIS: Part of the purpose of the 25Executive Court Reporters (301) 565-0064 1 10

Monte Carlo analysis is to incorporate higher and 1 variable electricity costs, but we’ll definitely 2 keep that in consideration. 3 MR. HALLEY: So that’s electricity cost, 4 but I was referring to the electrical contractor 5 labor rates. 6 MR. MORRIS: Sorry. 7 MR. HALLEY: They both have similar issues 8 of quite a bit of variability throughout the 9 country. 10 MR. BROOKMAN: So you can see the comment 11 box. 12 MR. MORRIS: Yes, I forwarded to the two 13 comments here, the two comment boxes. 14 MR. BROOKMAN: Leave that up. 15 MR. MORRIS: Okay. So each lamp’s life 16 cycle cost is of course affected -- 17 MR. BROOKMAN: Pardon me, I wasn’t clear. 18 Would you go back to items 37 and 39? 19 MR. MORRIS: I’m sorry. 20 MR. BROOKMAN: I wasn’t sure that we 21 covered this and I lost track, so I just want to 22 make sure that we did before we move on. 23 Installation and maintenance and repair. Okay. I 24 think we covered it. 25Executive Court Reporters (301) 565-0064 1 11

MR. MORRIS: We did. I mean the idea that 1 you cannot repair or maintain an HID lamp is 2 correct. Nobody removes an HID lamp and repairs 3 it. It is definitely replaced. 4 MR. BROOKMAN: Thank you. Now you may 5

move on. 6 MR. MORRIS: Sorry for the confusion, 7 Doug. So each lamp’s life cycle cost is affected 8 by its lifetime. DOE will use manufacturer 9 literature, other literature sources and inputs 10 from other interested parties in determining lamp 11 lifetimes. Lifetimes can be adjusted to account 12 for group relamping practices, which decreases the 13 cost per lamp because labor is less costly when 14 many lamps are replaced at once. 15 On the next slide we have a couple comment 16 boxes. Item number 40, the Department welcomes 17 comments on lamp lifetimes and how group relamping 18 practices may affect lamp lifetimes. And 38, 19 comments regarding how relamping practices would 20 change if HID lamp life is affected by new 21 standards. 22

MR. BROOKMAN: Susan. 23 MS. ANDERSON: Well, basically, for HID 24 lamps, it’s much more common to see spot versus 25Executive Court Reporters (301) 565-0064 1 12

group, even though we do specifically recommend 1 group relamping, particularly with metal halide. 2 The reality is spot relamping is what is done. And 3 the other thing that I would say, if you do 4 evaluate group relamping, if you go to the IES 5 recommendations for indoor applications, it’s RP36- 6 03, and they recommend group relamping at 60 to 70 7 percent of rated life. And then it’s DG-4-03 for 8 roadway. So those would be good sources for that. 9 You might also want to check with lighting service 10 companies. Like, we have a division that’s a 11 lighting service company and find out if they do 12 group relampings, what they actually do in 13 practice. But they don’t -- it’s not a reduction 14 of 91 to 94 percent or whatever is over there. 15 It’s much greater than that. 16 MR. BROOKMAN: Okay. Thank you. That’s 17 helpful. Michael. 18 MR. MYER: Michael Myer. Pacific 19 Northwest National laboratory. Susan, you said 20 kind of in general that HID lamps are not group 21 relamped. Is there any other, within the three 22 lamp types, or in applications -- I understand 23 street lighting probably is last group relamped 24 because of the magnitude of street lighting, but 25Executive Court Reporters (301) 565-0064 1 13

parking lots or interior, any -- either of those or 1 metal halide -- any specific -- any -- 2 MS. ANDERSON: They all tend to be much 3 more spot relamped than group relamped. Because as 4 Joe was mentioning earlier, a given fixture covers 5 -- it’s the only thing providing light in a given 6 area, so when it goes out, it needs to be replaced. 7 MR. HALLEY: You might be able to get a 8 little better information from having conversations 9 with these lighting service companies who generally 10 are group relamping fluorescent systems, but you 11 could ask them what their experience is with group 12 relamping HID systems. I think it would be 13 relatively minor, but they may be able to give you 14 a better sense of how often these are group 15 relamped. 16 MR. BROOKMAN: Okay? 17 MR. MORRIS: Okay. Thank you. I’ll turn 18 the mic back over to Michael Myer to discuss 19 shipments. 20 MR. BROOKMAN: How are we doing here? 21 We’re ahead of schedule, and are we okay? Keep 22 pressing ahead here? Yes? We’ll just see where we 23 are as we approach noon. Okay. 24 **Shipments Analysis** 25Executive Court Reporters (301) 565-0064 1 14

MR. MYER: Thank you, Doug. The shipment 1 analysis works in tandem with the life cycle cost 2 and payback period analysis to provide information 3 into the national impact analysis. The shipment 4 analysis is to look at -- we create two scenarios. 5 One’s called the base case scenario and the other 6 one is called the standards case scenario. And we 7 want to get a sense of how they affect national 8 energy savings and net present value. 9 How we develop shipment scenarios or 10 shipment projections, we look at a lot of data if 11 we can get it. We look at manufacturer and 12 industry organizations, any reports talking about 13 shifts in technology, or continuation of 14 technology, trends in technology, national energy 15 and lamp surveys, and also historic HID lamp 16 shipment data from NEMA. I know NEMA publishes a 17 newsletter that often shows quarterly what some of 18 the HID shipments are, and we use that as a source 19 as well. 20 We’ll discuss each of the different 21 shipments and the methodology in a second. But I 22 want to first start with items 15 and 41. On 15, 23 DOE welcomes input on disaggregated market share 24 based on input wattage for each of the HID lamp 25Executive Court Reporters (301) 565-0064 1 15

technologies. And I’ll pause for a second. 1 MR. BOESENBERG: Alex Boesenberg, NEMA. 2 To item 15, first of all, we’re a little confused 3 about what was being asked for in terms of what the 4 data is intended to drive. What’s the goal from 5 that data? Then to continue on, as you noted, we 6 do collect data on these products, however, one 7 challenge we have to providing the government with 8 data is that we don’t necessarily gather it in the 9 way that you were asking. We don’t tend to report, 10 have our members report, based on wattages, but 11 rather based on technology and base type. Since 12 it’s sales data, we want to know where -- who is 13 buying it, where it’s going, which means we care 14 more about the application. As we’ve already 15 stated, I think the discussions have borne that 16 out. The fixture type and where it is, strongly 17 dictates what goes in it. So we track it by 18 application. 19 In our public comments, we’re going to 20 give you an excerpt of what one of our quarterly 21 reports looks like, and we welcome discussions as 22 to whether or not there’s a way for us to either 23 analyze the existing data, or if necessary, I can 24 ask my members to consider a special survey. But 25Executive Court Reporters (301) 565-0064 1 16

we welcome the opportunity to see if we can work 1 something out, save the government time in 2 gathering this information. And I’ll pause if you 3 have any questions on my comments on item 15, 4 particularly what’s the end goal, so we know what 5 you’re looking for. 6 MR. MYER: Ultimately, I mean, the end 7 goal is to get a sense of if, rather than just say 8 that metal halide was X million units or X percent, 9 to get a sense of where the trends are in -- better 10 than just low, medium or high wattage -- in the 175 11 watt versus the 250 watt, where are you seeing 12 shipments? Whatever finer, granular resolution we 13 can get related to shipments, related to -- again, 14 at a global level, HID lamps up or down, limits 15 some of the analysis we can do. 16 MR. BROOKMAN: Alex. 17 MR. BOESENBERG: Alex Boesenberg. Based 18 on your shipments, do you -- it’s your impression 19 that the fact that our data is gathered then by 20 application and base type, will that still be 21 useful to you? It sounds to me like it will. 22

MR. MYER: In some cases. 23 MS. ANDERSON: It’s technology. 24 MR. BOESNEBERG: Technology, sorry. What 25Executive Court Reporters (301) 565-0064 1 17

did I say? 1 MS. ANDERSON: Application. 2 MR. BOESNEBERG: Oh, yeah. 3 MR. MYER: Now that Susan’s elaborated 4 that it’s technology, not application, that is 5 different. In terms of technology, I assume you’re 6 separating out by mercury vapor, high pressure 7 sodium and then the three typical types of metal 8 halide. And then for base type, pretty much 150 is 9 medium base and 150 and above is mogul base, but 10 anything we can get beyond that would be helpful as 11 well. I know some special surveys in the past have 12 done, at least the wattage bins -- low, medium and 13 high wattage bins. But again, anything -- so 14 beyond just the base type would be helpful. Yes. 15 MR. BOESENBERG: Anything else, Susan? 16

MR. BROOKMAN: Susan? 17 MS. ANDERSON: The only metal halide 18 family we separate out is ceramic. So we don’t 19 separate by pulse start versus probe start. 20 MR. HALLEY: We would need a special 21

survey. 22 MS. ANDERSON: Right. 23 MR. HALLEY: To get what you’re asking 24 for. We can consider a special survey. 25Executive Court Reporters (301) 565-0064 1 18

MR. BROOKMAN: So I think it’s worth 1 having that on the record, Joe. You could consider 2 a special survey to gather that data? 3 MR. HALLEY: Right. We’d want to discuss, 4 you know, exactly what would be most useful before 5 we would go through that exercise. Perhaps we 6 could have that further discussion. 7 MR. BROOKMAN: Thank you. 8 MR. MYER: Continue on to item 41. DOE 9 welcomes recommendations on other sources of HID 10 shipment by proposed equipment class. We also 11 welcome comments on future long term trends in HID 12 lamp efficacy. 13 MR. BROOKMAN: Probe start, quartz, metal 14 halide versus pulse start, quartz or pulse start 15 ceramic. Sounds pretty complicated. 16 MR. HALLEY: We understand it. 17

MR. BROOKMAN: Susan. 18 MS. ANDERSON: Well, I mean, the new 19 products we’re seeing an expansion in lower 20 wattages, and we’re seeing an expansion in pulse 21 start ceramic. That’s where the new technology is 22 going. It’s not going in probe start. 23 MR. BROOKMAN: That’s the industry at 24 large? 25Executive Court Reporters (301) 565-0064 1 19

MS. ANDERSON: Industry at large. 1 MR. BROOKMAN: Okay. 2 MR. MYER: I’m sorry, can we separate 3 those two out, so I understand it better. You’re 4 seeing an increase in ceramic pulse, and then low 5 wattage -- is that also in ceramic pulse or all. 6

MS. ANDERSON: Yes. 7 MR. MYER: So it’s really con -- the same. 8 Thank you. 9 MS. ANDERSON: But the new wattages that 10 are coming out tend to be in the low wattage range, 11 to replace halogen. 12 MR. MYER: So if you’re saying replacing 13 halogen, is that omnidirectional or non14 omnidirectional? 15 MS. ANDERSON: Both. 16 MR. MYER: Thank you. 17 MR. BROOKMAN: Okay. That’s helpful. 18 Thank you. Additional comments on item 15 and 41? 19 MR. MYER: Continuing on to the 20 methodology. So the shipments model will look at 21 three different essentially accounting 22 methodologies for -- one is new installations. 23 These are fixtures that are being brought to market 24 with a -- a new fixture, essentially, for new 25Executive Court Reporters (301) 565-0064 1 20

construction with an HID lamp. Replacements. 1 These are lamps that have failed or retired from 2 service and they’re being sold. And then 3 retrofits. These are early replacements, such as 4 an entire grocery store is being relighted and the 5 equipment is still in good service condition but 6 they’re just going with a new design. So those are 7 the three different scenarios there. And we would 8 like to -- we’ll ultimately estimate proportions of 9 shipments based on those types of scenarios. 10 We welcome comments based on our 11 accounting methodology here described. 12 MR. BOESENBERG: Alex Rosenberg, NEMA. We 13 have no further edits or clarifications to that. 14 Those definitions seem acceptable. 15 MR. BROOKMAN: Okay. Thank you. Joe. 16 MR. HALLEY: The only thing I’ll add is 17 the overwhelming bulk of what this rulemaking would 18 accomplish is going to affect the replacement 19 options. The new installation is more affected by 20 the existing ban on mercury vapor ballasts and the 21 requirement to put a pulse start ballast in new 22 metal halide fixtures, most of the new metal halide 23 fixtures. And there’s not a lot of retrofits that 24 occur because of the previous discussion, of how 25Executive Court Reporters (301) 565-0064 1 21

difficult it is to retrofit an HID fixture. So 1 really the focus should be overwhelmingly on how 2 this affects replacements. 3 MR. BROOKMAN: Additional comments. 4 Keith. 5 MR. COOK: Well, just a real quick 6 comment. Even on the new installations, this whole 7 market is driven by efficiency and so to think 8 we’re going to have a huge impact, I think is 9 misleading, because our marked on HID is already 10 being attacked by linear fluorescent, T5s, T8s, 11 because of the efficaciousness of those 12 applications, and that’s typically in warehouses 13 and industrial applications and things like that. 14 And in the outdoor market, the LED is by far 15 becoming dominant, again attacking what had 16 predominantly been this market in the past. And so 17 just a word of caution. We don’t see where we’re 18 going to be able to impact this particular market 19 very much going forward with new rulemaking. 20 MR. MYER: Thank you. Continuing on. So, 21 as I mentioned earlier, there are two types of 22 scenarios. One is called the base case, the other 23 one is called the standards case. The base case 24 essentially assumes what would the shipments be 25Executive Court Reporters (301) 565-0064 1 22

projected into the future, in the absence of any 1 amended -- or I’m sorry, new, in this case -- new 2 standards. That being said, it will actually look 3 at what the effects of lamp shipments are from 4 other standards such as we’ve discussed many times, 5 mercury vapor and metal halide having the effect. 6 While those are separate standards, they do have an 7 effect on future shipments of those two 8 technologies, so they will be included here in the 9 base case. ... to wrap your mind around. And it’ll 10 be a mixture of the different efficacies sold and 11 the absence again, of new regulation. We typically 12 look at historical shipments and try to get a 13 lifetime distribution and how they’re installed and 14 replaced, and that type of thing. 15 Then there’s the standards case -- I think 16 I’m having problems with the computer -- Thank you. 17 That contrasts with the other type of analysis I 18 mentioned, the standards case. This is what 19 ultimately would be in -- what would the shipments 20 look like into the future, assuming the proposed 21 standards. We will -- it helps us to look at the 22 difference between the two programs and you look at 23 the differential, and you get a sense of the 24 savings and -- energy savings and the net present 25Executive Court Reporters (301) 565-0064 1 23

value. 1 We will also consider the effects from 2 market pull programs which have been discussed 3 previously in this presentation as well. 4 Brings us to item 43, DOE welcomes 5 comments on proposed conservation standards might 6 affect shipments of HIV lamps, and also any 7 information on market pull programs. 8

MR. BROOKMAN: Susan. 9 MS. ANDERSON: Well, as we’ve already 10 talked about, the -- we already have regulations in 11 place that are impacting what’s happening in new 12 fixtures, and those were both laws that were 13 passed, EPAC 2005 and then ESA 2007. The other 14 thing, I think somewhere in here I think it 15 mentioned maybe the impact of state programs, but 16 most state programs, except for California’s Title 17 20, were negated by the federal regulations that 18 passed there. So basically the federal regulations 19 copied what had already been passed in existing 20 state legislation. 21 And then on the pull through, I know the 22 gentleman from Energy Solutions said that they do 23 have incentive programs for going from probe start 24 to pulse start. But what we’re really seeing 25Executive Court Reporters (301) 565-0064 1 24

happening in the market place is that people aren’t 1 going from probe start to pulse start, they’re 2 going from probe start to fluorescent. And you can 3 get a lower wattage package, you have greater 4 energy savings, you have longer lamp life, and the 5 energy savings is compounded by the fact that you 6 get better lumen maintenance out of those 7 fluorescent lamps, so that means you can go with an 8 even lower wattage system. So that accentuates the 9 energy savings. 10 Where we are seeing incentive programs, 11 it’s impacting more outdoors, and people are going 12 to solid state as opposed to going to another HID 13 technology. In some cases they’re going to 14 induction, because induction is kind of a long15 lived, lower cost option, compared to solid state. 16 But most of it is going to solid state. I mean, 17 the HID market, the market place is taking HID out 18 of installations. 19

MR. BROOKMAN: Joe. 20 MR. HALLEY: I just wanted to reiterate 21 that the effect of the market pool programs might 22 be different than you’re projecting, but it’s 23 actually -- the effect has been to shrink this 24 market and to eliminate the lower efficiency 25Executive Court Reporters (301) 565-0064 1 25

sources, and we expect that will continue. So your 1 projection on market pool should take that into 2 consideration. 3 MR. BROOKMAN: Thank you. Okay. Okay. 4 MR. MYER: At this time I’m going to 5 return the presentation to Scott Morris who will 6 discuss national impact analysis. 7 **National Impact Analysis** 8 MR. MORRIS: The national impact analysis 9 effectively combines the results of the life cycle 10 cost analysis and shipments analysis to determine 11 the energy savings potential and monetary effect of 12 a standard on the nation as a whole 13 So to state it differently, the NIA is 14 designed to assess the monetary impact and energy 15 savings of a standard on the entire country. So to 16 put it simply, each year in a 30-year analysis 17 period, which is DOE looks at a 30-year analysis 18 period, which begins in the year when the standard 19 takes effect, most likely, 2017. Each year has 20 equipment purchase and installation costs and 21 operating expenditures. In any given year, if 22 operating cost savings are greater than the 23 increased equipment costs, the result is a net 24 savings. If the equipment costs outweigh operating 25Executive Court Reporters (301) 565-0064 1 26

cost savings, the result is a net cost to the 1 nation. The national impact analysis sums across 2 all years of the analysis period to determine the 3 economic effect on the nation, and the national 4 energy savings resulting from a standard. 5 National energy use is calculated for the 6 base case, shown on the left side in the base case 7 scenario and for the standards case scenario shown 8 on the right, for every year of the analysis 9 period, all 30 years. The site energy use in both 10 cases is converted into primary or source energy 11 use, using a site to source conversion factor. The 12 difference in energy savings between the base case 13 and the standards case projections yields national 14 energy savings. 15 Is there any comments or confusion on the 16 diagram or anything I’ve said? Okay. Methodology 17 is somewhat clear. Good. 18 The net present value calculations are 19 done in similar fashion as the net national energy 20 savings calculations. Monetary costs for both base 21 case and standards case scenarios are calculated. 22 The difference between operating cost savings which 23 in both base case and standards case scenarios is 24 the sum of the energy cost and repair and 25Executive Court Reporters (301) 565-0064 1 27

maintenance cost boxes, the difference between 1 operating cost savings and installed cost 2 increases, discounted appropriately, yields the 3 national net present value of savings. 4 So this brings us to a couple items for 5 discussion. First of all, DOE welcomes comments on 6 any data sources that should be used in the 7 national impact analysis. In number 44 and 45, the 8 Department welcomes comments on whether more 9 efficacious lamps would be operated more as a 10 result of their increased efficacy. 11

MR. BROOKMAN: Joe. 12 MR. HALLEY: Well, in this particular 13 case, the HID market is under tremendous change 14 right now, given what was just talked about, the 15 market pool programs, the existing regulations, 16 making it -- perhaps a ten year analysis possible 17 in terms of analyzing what we expect to see happen 18 over the next ten years. But we think this is 19 impossible to try to figure out what might happen 20 over the next 30 years, given the dynamic changes 21 happening over the next ten years. We don’t know 22 what this market’s going to look like ten years 23 from now, and what you would project over the last 24 20 years, it would be a wild card in terms of what 25Executive Court Reporters (301) 565-0064 1 28

may exist, what technologies -- I mean a lot of 1 these technologies may not even exist in the market 2 place at that time. Obviously, if they wouldn’t 3 exist, there wouldn’t be any national energy 4 savings to pull forward. 5 So we’re not sure -- perhaps there’s a 6 reason why a 30 year analysis is required, but from 7 a practical standpoint, it doesn’t seem to make 8 much sense. Perhaps we could even ask why -- why 9 30 years with such a radically changing market? 10 In terms of the -- 11 MS. ANDERSON: (Comment off mic) 12 MR. MORRIS: So let’s stop and see if 13 there’s a response -- 14 MR. BROOKMAN: Do we have an answer for 15 the 30 year? 16 MR. MORRIS: Historical precedence -- 17 Michael, do you have a comment? 18

MR. MYER: No. 19 MS. ANDERSON: Is there a regulation? 20 Something that requires you to use 30 years? 21 MR. BROOKMAN: Betsy. 22 MS. KOHL: This is Betsy Kohl from the 23 DOE-GC. There may be something in our process rule 24 that we publish that sorts of sets the standards 25Executive Court Reporters (301) 565-0064 1 29

for our analyses, and that’s actually available on 1 our website, but I mean if you guys have comments 2 on a different or better analysis period, and why 3 that might be useful, we’d certainly consider them. 4 MS. ANDERSON: I mean the comments that 5 Joe just made, I mean technology is changing so 6 fast. I mean, I don’t -- as efficient as -- and 7 I’m an old fluorescent person -- as efficient as 8 fluorescent is, in 30 years, I don’t know if it’ll 9 be here. And I think fluorescent will outlast HID, 10 except in a very few limited applications. I mean 11 the world is going solid state. 12 MR. HALLEY: Basically, if this regulation 13 doesn’t make sense in ten years, it’s certainly not 14 going to make sense in 30 years, because of all the 15 change happening in HID market place. And so maybe 16 we would recommend that you look at a ten year 17 analysis, might be more robust than a 30 year. If 18 you still want to do your 30 year, I’m not sure 19 what you’re putting in your last 20 years. You may 20 not have much product to play with at that point. 21 MR. BROOKMAN: Okay. Thank you. Susan, 22

yes. 23 MS. ANDERSON: The other comment that I 24 would make -- and this will be in our written 25Executive Court Reporters (301) 565-0064 1 30

comments -- when we work with end users, three 1 years is about the longest payback time any of them 2 will tolerate. If it goes beyond that, they won’t 3 do the change-out. 4 The other thing that I want to say to you, 5 and I’m speaking from my own experience within my 6 own company, is we are an HID lamp manufacturer, 7 but we took out HID in a brand new distribution 8 center and replaced it with T5 fluorescent. 9 MR. BROOKMAN: In your facility? 10 MS. ANDERSON: In our own facility, 11 economics were there to justify it. So -- and when 12 we do all the evaluations, because we’ve 13 retrofitted all of our facilities, when we do the 14 evaluations, we don’t do payback, we do ROI. 15 MR. BROOKMAN: Daniel, I’m looking at you, 16 noting that California frequently leads the charge 17 on these things with market pull programs, so I’m 18 wondering if they have a -- if what’s going on 19 there tracks the manufacturers experience. 20 MR. YOUNG: Sure, absolutely. We’re 21 definitely trying to incentivize LEDs as much as 22 possible, and I think -- I personally would love to 23 see LEDs wipe out HIDs in the next two years. But 24 obviously that’s not going to happen. But joking 25Executive Court Reporters (301) 565-0064 1 31

aside, I do think that in existing fixtures, that 1 could last anywhere from ten to 20 years, there may 2 still be a market for the lamps that go into those 3 fixtures, so that’s something that could help to 4 justify a longer analysis period, even if it’s 5 difficult to project. 6 MR. BROOKMAN: Michael Myer. 7 MR. MYER: Thank you, Doug. The fact that 8 mercury vapor is roughly 80-plus years old this 9 year, and probe start is roughly 50 years old at 10 this point, and they’re still installed in the 11 market place, and if users want a low payback or 12 low ROI, there are probably legacy products out 13 there that are still going to continue to just 14 replace the lamps until they can’t replace the 15 lamps well into the future. I think mercury vapor 16 is a great example. The ballast can no longer be 17 sold, but we’re still selling -- well, not we, but 18 the industry is still selling lamps, at least over 19 a couple million is the last NEMA estimate I’ve 20 seen. I know it’s a decline, but it’s still 21 existing. So I think even though we are projecting 22 out 30 years and it’s hard to know where we will be 23 in 30 years. Thirty years ago if I could have 24 bought some Apple stock, I probably would have at 25Executive Court Reporters (301) 565-0064 1 32

this point. You know, projecting into the future 1 with -- do we know that certain technologies live 2 on, and so I think there’s still -- we may not be 3 able to project forward with great accuracy, but we 4 still -- there’s definitely precedent that mercury 5 vapor and probe start which are very old, still 6 exist in the marketplace and there’s an abundance 7 of installed stock. 8 MS. ANDERSON: But the other thing to keep 9 in mind is that the innovation rate has accelerated 10 dramatically from what it was in the past. And 11 it’s -- that’s changing the world, and so are LEDs. 12 MR. BROOKMAN: Yeah, the lighting industry 13 is being transformed as we speak, right. Keith, go 14 ahead. 15 MR. COOK: And believe it or not, I have 16 seen replacement LED devices to replace the quartz 17 metal halides in street lighting fixtures. And so 18 the replacement market is not stationary either. 19 It’s also changing. And so the thought that what’s 20 already installed base is going to continue there 21 may not be true in this technology. 22 MR. HALLEY: I think the point is that you 23 should consider these shrinking as you project out 24 five, ten, 15, 20 years. You should be projecting 25Executive Court Reporters (301) 565-0064 1 33

out shrinking market segments for mercury vapor, 1 for probe start lamps, I mean these should be 2 projecting down to zero at some point, because they 3 probably -- I can’t imagine mercury vapor systems 4 lasting 30 more years. 5 MR. BROOKMAN: Joe, thank you, and Keith, 6 thank you. Michael. 7 MR. MYER: I think those are -- I 8 appreciate those comments. Those will be 9 definitely factored into the shipments analysis in 10 the base case already, based on what you’re telling 11 us. And just while I have you, do you project 12 either pulse start or high pressure sodium, which 13 way that line’s going in roughly, you know, you 14 were nice enough to prognosticate a year, rough 15 time window for other technologies? Do you see 16 high pressure sodium 30 years out, declining, or to 17 a point? I know it’s a guess, but -- 18

MR. BROOKMAN: Joe. 19 MR. HALLEY: That’s harder to project. We 20 don’t expect, certainly, growth in that area. 21 Whether utilities will stay with high pressure 22 sodium. High pressure sodium still is very 23 efficient from a lumens per watt standpoint, so 24 that may be the hardest to dislodge with the other 25Executive Court Reporters (301) 565-0064 1 34

technologies. That may still have a life, but 1 that’s a very efficient source right now. Probably 2 the most efficient HID source we make. 3

MR. BROOKMAN: Susan. 4 MS. ANDERSON: I was just going to say one 5 of the things that’s happening is utility rate 6 structures, the way they’re set up, they -- in some 7 cases they can’t accommodate the LED retrofit, so 8 there’s a huge change going over there and how the 9 LEDs -- how the utilities have their rates 10 structure set up. 11 And something else that’s going on, and 12 it’s happening at the University -- not the 13 University of Virginia, but Virginia Tech -- and 14 we’re participating in it, and I know some of my 15 other fellow NEMA member companies are -- there are 16 studies that are being done, as to white light 17 versus the more golden white light of high pressure 18 sodium as we like to diplomatically refer to it, 19 that -- to determine whether seeing in outdoor 20 applications is better under white light sources 21 than it is under the more golden white light. And 22 if that would, in fact, allow people to go to lower 23 wattage systems than as opposed to using the high 24 pressure sodium. 25Executive Court Reporters (301) 565-0064 1 35

So there’s a lot of research going on in 1 that area in the white light and color temperature 2 arena that may have a big impact down the road too. 3 MR. MYER: I just have one other question. 4 I appreciate this candid feedback. As regards to 5 shipments and changes in technology, is it fair to 6 say that low wattage or low lumen sources are going 7 to be the first on the bubble to be possibly 8 replaced by other technologies? And essentially, 9 you know, as you increase in lumen package or 10 wattage, it’s going to be harder, not harder, it’s 11 going to be a more delayed effect before other 12 suitable other option, since you’re talking about 13 other technologies outside the HID realm. 14

MR. BROOKMAN: Susan. 15

MS. ANDERSON: Yes. 16 MR. MYER: Thank you. 17 MR. BROOKMAN: Okay. That was helpful. 18 MR. MORRIS: Thank you. It sounds like 19 all the fun is in the shipments part of this. But 20 jumping back to the national impact analysis, the 21 Department of Energy will use the DOE national 22 energy savings and NIA spreadsheet which calculates 23 energy consumption beginning in the first year of 24 the analysis period through the end of the analysis 25Executive Court Reporters (301) 565-0064 1 36

period. And basically, this slide is especially 1 important for the item 46, the Department welcomes 2 any comments on features it would like to see in 3 the NIA model, as well as any other inputs on the 4 national impact analysis model. 5 MR. BOESENBERG: Alex Boesenberg. We sort 6 of glazed past item 45. I’d like to return to that 7 for one brief comment, if I may. 8 MR. BROOKMAN: Yes, please do. 9 MR. BOESENBERG: The question is, will 10 these more efficacious, more efficient HID lamps be 11 operated longer, more, that is, on a given basis 12 because they’re more efficient? The rebound effect 13 of, oh, don’t worry, those CFLs are efficient, we 14 don’t have to turn off the lights in the living 15 room any more. Because these products are not 16 residential and don’t have a lot of human 17 intervention, but rather they are operated on 18 astronomical clocks or as dictated by sunrise and 19 sunset, we do not believe that there will be much, 20 if any, change in operating hours just because 21 they’re more efficient. Perhaps more popularity, 22 but not -- they’re just not going to leave street 23 lights on all day. 24 MR. BROOKMAN: Gotcha. Okay. Thank you. 25Executive Court Reporters (301) 565-0064 1 37

(comment off mic) 1 MR. BOESENBERG: Yeah, but the alternative 2 is control systems are getting better, right. 3 (comments off mic) 4 MR. MORRIS: So then -- 5 MR. BROOKMAN: Forty-six, thank you. 6 MR. BOESENBERG: NEMA has no comment on 7 item 46. 8 MR. BROOKMAN: So we’re at a point where 9 we should decide what to do. It’s noon. It’s five 10 after noon. The -- typically, the manufacturer 11 impact analysis takes, I don’t know how long, but 12 the next -- the utility impact, employment, 13 environmental, and regulatory impact analysis, 14 those are downstream analyses, they don’t take very 15 long to breeze through those. So, do you want to 16 just keep going? 17 PARTICIPANTS: Yeah. 18 MR. BROOKMAN: Strong preference to keep 19 going. 20 MS. ANDERSON: We’ve got consensus, yes. 21 MR. BROOKMAN: I’m with you. Okay. 22 MR. MORRIS: You hear nods from everybody. 23 MR. BROOKMAN: I think we can hang in here 24 for 20 minutes or so. 25Executive Court Reporters (301) 565-0064 1 3 8

MR. MORRIS: Very good. So we’ll jump 1 into the NOPR analyses. 2 **NOPR Analyses** 3 MR. MORRIS: I will be talking about this 4 first one. So on the NOPR phase of this 5 rulemaking, DOE will conduct several additional 6 analyses to determine how this energy conservation 7 standard affects things such as customer subgroups, 8 manufacturers, utilities, and emissions. And I 9 will briefly discuss the life cycle cost subgroup 10 analysis. 11 The LCC subgroup analysis quantifies the 12 impact of a standard on subgroups of customers 13 within the general population. Chiefly, DOE will 14 study the effects of this energy conservation 15 standard on customer subgroups who may be adversely 16 affected by the rulemaking. 17 In the comment box, DOE welcomes any 18 comments -- I should mention too a couple examples 19 of possible customer subgroups -- include 20 utilities, municipalities, and transportation 21 facilities. The Department would be very 22 interested in any other subgroups of the population 23 who might be -- who should be considered in the 24 rulemaking. 25Executive Court Reporters (301) 565-0064 1 39

MR. BROOKMAN: Joe. 1 MR. HALLEY: I think that subgroups here 2 to consider as we do these analyses are people who 3 are using existing mercury vapor systems, or -- if 4 -- as you’re projecting different levels of 5 standards, I imagine one of the levels will get to 6 the point where people using probe start metal 7 halide lamps are affected at some point, and those 8 subgroups, the users, are going to be forced to 9 replace the entire fixture when you get up to that 10 point. I suppose you could say the smaller users 11 of those systems, say, school districts that might 12 just use these in a gymnasium, or something of that 13 nature, or a smaller retailer accounts, would be 14 significantly affected if all of a sudden they 15 could not get the lamp and they have to replace 16 their entire lighting system with a brand new HID 17 lighting system. That would have a significant 18 impact and maybe not -- it would possibly be hard 19 to cost justify, but certainly you should look at 20 whether or not that kind of forced behavior could 21 be cost justified on those smaller user groups. 22 MR. MORRIS: Thank you, Joe. You 23 mentioned the school districts, specifically. Can 24 you mention other entities? 25Executive Court Reporters (301) 565-0064 1 40

MR. BROOKMAN: Susan’s going to follow on. 1 MS. ANDERSON: I was going to say like 2 community centers. You see a lot of community 3 centers with HID lighting and like a general 4 purpose gymnasium facility, or swimming pools and 5 that sort of thing. Yeah, those are typically 6 people on a limited budget, where it’s going to 7 have a much greater impact on them. 8 MR. BROOKMAN: Okay. Keith. 9 MR. COOK: Yes, similarly, roadway 10 lighting ends up being a major issue, and the 11 problem we’ve got is if you are requiring a 12 situation where you can’t get a replacement any 13 longer, the utilities or municipalities or 14 whatever, then has this significant problem, 15 because unfortunately roadway lighting pools have a 16 tendency to get hit by cars, and they don’t want to 17 have to go through and replace all of them, and 18 they don’t want one that’s mismatched. And so 19 you’ll end up with significant push back from those 20 areas if they have to change out their poles. 21 MR. BROOKMAN: Susan, keep going. 22 MS. ANDERSON: Something else I was going 23 to mention. I worked in the Kansas City market 24 area for a number of years, both with Holophote 25Executive Court Reporters (301) 565-0064 1 41 (ph) and with Sylvania. We sold roadway lighting 1 systems, high mass lighting systems. And they -- 2 the state of Kansas had an interesting philosophy 3 when they did roadway lighting. They did the 4 interchanges with metal halide, and then they did 5 the roadways leading up to the interchanges with 6 high pressures sodium. And had a couple good 7 reasons for that. The color change signaled a 8 change to the drivers, and then where the accidents 9 were most likely to happen were in the congested 10 areas of the interchanges, so they had better color 11 rendering for all the investigative purposes, and 12 for eyewitness accounts and that sort of thing. So 13 they had a very distinctive purpose in wanting to 14 have two distinctive colors. And the high pressure 15 sodium was the more efficient, so it was used 16 covering the greater area, but then in the more 17 critical area they used the metal halide. So 18 there’s value in different technologies. 19 MR. BROOKMAN: Alex, did you have -- 20 nothing there. So additional comments on subgroups 21 as requested, and also 49. 22 MR. MORRIS: Okay. Thank you. I’ll turn 23 the time over to Merry Walker. 24 **Manufacturer Impact Analysis** 25Executive Court Reporters (301) 565-0064 1 42

MS. WALKER: The purpose of the 1 Manufacturer Impact Analysis or also known as the 2 MIA, is to identify the impacts of energy 3 conservation standards on manufacturers, 4 manufacturers subgroups, and the cumulative 5 regulatory burden on the industry as a whole. DOE 6 does this by analyzing the industry cash flow and 7 net present value through the GRIM, or the 8 Government Regulatory Impact Model, and 9 interviewing manufacturers to assess the impact of 10 standards, both qualitative and quantitative. 11 The analysis methodology is broken into 12 three main phases. The first is in which DOE 13 creates an industry profile to characterize the 14 industry and to identify the key uses in 15 manufacturing. The second phase, DOE prepares an 16 industry cash flow model with the GRIM that takes 17 into account any investment and revenue changes 18 that the industry might experience, and an 19 interview questionnaire to guide interviews with 20 manufacturers. In phase three, DOE interviews 21 manufacturers, assesses the impacts of standards, 22 both quantitative and qualitative, looking at the 23 impacts on competition, manufacturing capacity, 24 employment, and regulatory burden. 25Executive Court Reporters (301) 565-0064 1 43

With that, DOE seeks comment on the HID 1 lamp manufacturer subgroups and regulations that 2 DOE should consider in examining cumulative 3 regulatory burden. 4 MR. BROOKMAN: Keith. 5 MR. COOK: One concern that we’ve got is 6 the fact that along with the new potential 7 rulemaking comes significant testing and reporting 8 requirements. And as we’ve discussed in previous 9 Meetings, this can be significant due to the number 10 of subgroups we may end up with, within the HID 11 family. And, you know, we’ve estimated per 12 manufacturer, the testing could easily exceed a 13 million dollars per year on a market that’s flat, 14 as we’ve already discussed, flat at best, and 15 probably even diminishing. 16 That amount of testing ends up being a 17 significant burden to the smaller manufacturers who 18 aren’t even really represented here today, to the 19 point where it could lead to them getting out of 20 the market entirely if we’re not careful. So this 21 has a significant impact in, like I said, a market 22 that’s not growing, and we’re very concerned with 23 it. 24 MR. BROOKMAN: Okay. Thank you. Susan. 25Executive Court Reporters (301) 565-0064 1 44

MS. ANDERSON: To add to that, there was a 1 suggestion made that instead of looking at initial, 2 to look at mean lumens and maintained lumens. 3 These are very long-lived products, so by the time 4 we get to 40 or 50 percent of rated life, which the 5 metal halide, mean lumens are measured at 40 6 percent, for mercury vapor and HPS it’s at 50 7 percent of rated life. That’s thousands of hours 8 of operation, and you’re talking about huge 9 electricity bills, and not just from operating the 10 systems, but then the necessary cooling for those 11 facilities where we use those. There’s a huge 12 expense, an investment in the equipment, and then 13 the operating expense will be huge. 14 MR. BROOKMAN: Okay. You can see the 15 request for comment there, 48 and 49. Additional 16 comments, and particularly -- have we heard about 17 cumulative regulatory burden yet? Yes, Joanna. 18 MS. MAUER: Joanna Mauer. If I can just 19 ask a follow up question to Susan. We’re talking 20 about measuring mean lumens, would that be 21 something different than what you’re -- because you 22 often report mean lumens in catalogs. Would this 23 be additional testing? 24 MS. ANDERSON: But we don’t do it on the 25Executive Court Reporters (301) 565-0064 1 45

number of lamps that we’re anticipating the DOE 1 might require us to do. So you’re talking about a 2 significant additional investment. 3 MR. BROOKMAN: Alex. 4 MR. BOESENBERG: Alex Boesenberg. So to 5 follow up on Susan’s statement. We did provide 6 our best estimates in the test procedures NOPR over 7 potential costs and comments on the, not only cost 8 of performing the testing, but the cost of test 9 rigs and things like that. Everything that adds 10 costs increases the burden. We will mention in our 11 written comments several additional considerations 12 for cumulative regulatory burden, and I am 13 personally open to being involved in the 14 discussions of that, both to better understand it 15 myself, and better represent the interests of the 16 members. 17 But the reason NEMA created a manager of 18 regulatory affairs is our existing legislative 19 regulative guy couldn’t handle the workload, and 20 we’ve even had to add another position for state 21 regulation. I consider it job security, but I’ve 22 always enjoyed putting myself out of a job by 23 getting a system streamlined or properly set up. 24 I’m never worried about finding work. Personally, 25Executive Court Reporters (301) 565-0064 1 46

as I said, I would like to see open discussions to 1 better understand the models being used to quantify 2 and estimate regulatory burden, because industry -- 3 we are trying to figure it out ourselves. 4 But so many companies make multiple 5 products, and almost every one’s got a regulation 6 or is slotted for one. These are the same people 7 you saw at the last rulemaking, and these are the 8 same people you saw at the one before that. We can 9 only do so much. 10 MR. BROOKMAN: Okay. I’m with you. Do 11 you have something here, Matthew? 12 MR. WALKER: Yes, I had a question back on 13 the small business impacts. I was curious if you 14 had kind of estimates of number of lamps that those 15 types of companies would sell, or what the size of 16 those businesses would be. Is that something you 17 can talk about? 18 MR. BROOKMAN: Keith. 19 MR. COOK: I would say you really need to 20 try and approach them to try and get that 21 information. 22 MR. WALKER: We will include that, I was 23 just ready for a sneak peek. 24 MR. BOESENBERG: That’s something, when 25Executive Court Reporters (301) 565-0064 1 47

you come to me, to NEMA, to discuss how to obtain 1 the lamp shipment and technology shipment sales 2 data, that’s a good question to ask at that time 3 when I have a NEMA business office there, they will 4 be able to answer it, whether or not that’s 5 something we’re able to parse out -- I mean, we 6 know who we get the information from, but we have 7 very strict laws, internal bylaws, regarding the -- 8 what’s the right word -- the disclosure, thank you 9 -- you knew what I was saying -- the disclosure of 10 sales per company. So we usually aggregate the 11 data and anonymize it. But relative to your 12 question, we may be able to provide, I can’t 13 promise, but it comes to my mind that we do have 14 small manufacturers, so for a given product type, 15 we may be able to give you the aggregate small 16 business sales or something. I don’t know. That’s 17 a question we have to put not only to the NEMA 18 business office, but probably to the NEMA lawyers. 19 MR. BROOKMAN: Okay. 20 MS. WALKER: I have just one follow up 21 question to NEMA. I was wondering if we could also 22 receive some feedback on the percentage of all lamp 23 manufacturers, specifically HID lamp manufacturers, 24 that are part of NEMA. I know that the percentage 25Executive Court Reporters (301) 565-0064 1 48

is very high, but it would be nice just to 1 understand approximately what percentage of the 2 lamp manufacturers are part of NEMA. 3 MR. BOESENBERG: I’ll see what we can do. 4 MS. WALKER: Okay. Thank you. I will 5 pass it on to Michael Myer. 6 **Downstream Analyses** 7 MR. MYER: Thanks, Merry. As Doug said, I 8 will be doing the remainder analyses which happen 9 downstream, which means they happen not in the 10 interim analysis, but in the NOPR analysis itself. 11 The first one that happens is the utility 12 impact analysis. The focus of the utility impact 13 analysis is to examine the effects of potential 14 standards on electricity generation. We use a 15 model called the National Energy Modeling System, 16 NEMS. It’s been modified for the DOE buildings 17 technology program, so it’s designated as NEMS-BT. 18 We use some AEO data regarding generation. We 19 model what the energy savings effects could be from 20 standards compared to non-standards, and get a 21 differential, and the output is what the deferred 22 generating capacity could be. 23 Brings us to item 50. We seek comment on 24 input or plans to use NEMS-BT and conduct the 25Executive Court Reporters (301) 565-0064 1 49

utility impact analysis. 1 MR. BROOKMAN: Alex. 2 MR. BOESENBERG: Alex Boesenberg. We 3 suggest the government follow up with that at the 4 individual manufacturer interviews. 5 MR. MYER: The follow on question. 6 There’s something in there specific to each 7 manufacturer regarding utility generation? 8 MR. BOESENBERG: This is a topic we 9 historically do not have a lot of comments on, is 10 the best way to answer your question. I wish I 11 understood NEMS, but I haven’t had the time. 12 MR. BROOKMAN: Thank you. 13 MR. MYER: Moving on. The next one is 14 employment analysis. This -- the manufacturers 15 impact analysis just looks at direct employment on 16 the manufacturers. The employment analysis looks 17 at indirect employment effects. It does look at 18 both, direct and indirect, but the ultimate output 19 is about indirect. It also uses a model, and this 20 one is the Impact Sector Energy Technologies Model 21 to look at the indirect employment analysis. 22 Again, it looks at what the potential effect on -- 23 indirect employment could be as a result of 24 standards. 25Executive Court Reporters (301) 565-0064 1 50

Item 51, DOE requests feedback on its 1 approach to assessing employment impacts for the 2 equipment covered. 3 MR. BROOKMAN: Alex. 4 MR. BOESENBERG: Alex Boesenberg. This is 5 another topic that varies greatly, I would venture 6 to say, by individual company and their policies, 7 and their individual geographic and regional 8 considerations. So we have to defer to the 9 manufacturer interviews for that. 10 MR. BROOKMAN: Thank you. John. 11 MR. GREEN: Yes, I understand you’ll 12 probably be interviewing lamp manufacturers, but 13 will interviews be done for other companies that 14 may be impacted by this, such as ballast and 15 luminaire manufacturers? It was just a question. 16 MR. MYER: At this time, yes, lamp 17 manufacturers are the only ones being interviewed, 18 but it is something we will take into 19 consideration, interviewing -- besides the ballast 20 and fixture manufacturers, are there other 21 manufacturers that could be potentially affected? 22 MR. GREEN: Those are the two that come to 23 mind, but they could have some input on the impact 24 on employment, so that’s why I brought it up here. 25Executive Court Reporters (301) 565-0064 1 51

MR. MYER: We appreciate it, thank you. 1 MR. BROOKMAN: Additional comments? None. 2 MR. MYER: The next one is the emissions 3 analysis. Those who are familiar with the process 4 might know this better as the environmental 5 assessment. Same type of idea, just a new name. 6 The whole point of the emissions analysis is to 7 look at the environmental effects resulting again 8 from energy standards, and changes in power plant 9 emissions. There’s four emissions that we look at: 10

 Carbon dioxide 11

 Sulfur dioxide 12

 Nitrous oxides, and 13

 Mercury. 14 Carbon dioxide is the main emission that 15 is reported and reviewed. Because of existing 16 legislation on sulfur dioxide, not major changes 17 are expected, near zero is usually the way we 18 describe it. With nitrous oxide, it’s kind of a 19 mixture. There are caps in 28 states, and so we 20 look at the effects of nitrous oxides in the non21 covered 22 states. And then also we will report 22 possible mercury emissions being affected because 23 of all the standards. 24Executive Court Reporters (301) 565-0064 1 52

Item 52, DOE seeks input on its plans 1 again to use the NEMS-BT model to modify slightly 2 to look at the different effects on emissions for 3 this standard. 4 MR. BROOKMAN: Alex. 5 MR. BOESENBERG: NEMA has no specific 6 comments to this. 7 MR. HALLEY: I just have one thought is 8 that I believe that the EPA has passed requirements 9 for utilities to limit mercury emissions as well in 10 the next few years, so if that has not been 11 incorporated in this analysis before, you may want 12 to look into that rulemaking, and see if that 13 requires -- I believe it affects coal fired power 14 plants primarily. 15 MR. MYER: I don’t know the exact extent 16 of it, but yes, there was some recent work done 17 related to mercury. It was added into the 18 framework because it happened really recently as 19 well, and since this is a downstream analysis, we 20 will look at whatever the new guidance is, the new 21 requirements are. But thank you for the direction. 22 MR. BROOKMAN: Alex. 23 MR. BOESENBERG: Since we’re pretty much 24 at the end and we’re ahead of schedule, I hope 25Executive Court Reporters (301) 565-0064 1 53

you’ll entertain a couple questions about NEMS. 1 You talk about using it for an environmental 2 analysis. Does that mean that if it will greatly 3 reduce carbon dioxide emissions, then it’s a good 4 idea? How does NEMS weight this? If you got rid 5 of all street and area lighting, boy would we save 6 a lot of electricity and reduce carbon dioxide 7 consumption. Accidents and deaths might go up. So 8 I’m just curious, what’s the tool to balance all 9 that? 10 MR. MYER: That’s actually a fair 11 question. This slide, monetization, helps with 12 some of that. So yes, there is some monetization 13 related to that. If you read the NOPR analysis, it 14 does provide a breakdown of many things that are 15 important. So when something goes from a NOPR 16 which is a Notice of Proposed Rule, to the Final 17 Rule stage, there’s a whole -- the NOPR includes a 18 whole list of things such as what this standard 19 would potentially have the effect on employment; 20 what it would have on costs; what it would have on 21 emissions. I would say that there’s no one guiding 22 rule, no bright line test that says if emissions 23 went to this value then it’s a go, because 24 conversely, as you said, there’s some other 25Executive Court Reporters (301) 565-0064 1 54

possible effects resulting from turning off all 1 street lighting, something like that. So it’s a -- 2 there’s no one guiding principle that says if you 3 meet this bar, then it goes forward. It looks at a 4 lot of potential effects. Again, employment, 5 direct and indirect; net present value, both the 6 industry net present value as well as the energy 7 savings and generating capacity. 8 MR. BOESENBERG: Thank you. That’s a very 9 good explanation and I appreciate it. So that 10 leads to the follow on concern that is far too 11 complex for us to really be able to comment on. I 12 have some discomfort with it, I hope you’ll 13 understand, I don’t know. 14 MR. BROOKMAN: I’m sure that there are 15 many resources here in the room and elsewhere in 16 the Department that would, perhaps when they come 17 to see you, they could give you more of a fuller 18 explanation on NEMS. 19 MR. BOESENBERG: I welcome that, thank 20

you. 21 MR. BROOKMAN: Okay. Thank you. 22 MR. MYER: So I briefly made mention of 23 the monetization of emissions. We’re going to use 24 the social cost of carbon. The second bullet here 25Executive Court Reporters (301) 565-0064 1 55

kind of provides -- there’s different intra-agency 1 reviews of the social cost of carbon. They range 2 from 4.9 to 67.6 dollars per metric ton -- those 3 are in 2010 dollars. I’m sorry? 4 MR. HALLEY: It’s a big range. 5 MR. MYER: Yes, Joe, it is a wide range, 6 and there’s many things that factor that. There 7 are different discount rates and it’s actually 8 there’s a lot of different caveats of why it’s a 9 different range in different analyses. They’re all 10 reported in different tables within the NOPRs. And 11 then we also estimate the potential monetary 12 benefit of reduced nitrous oxide emissions 13 resulting from considered ... 14 The final analysis that is done in the 15 NOPR analysis is the regulatory impact analysis. I 16 always personally find the regulatory impact 17 analysis somewhat contradicting in title, because 18 it actually says what could be done in -- separate 19 from a standard, such as a non-regulatory action. 20 Non-regulatory alternatives can be customer 21 rebates, customer tax credits, manufacturer tax 22 credits, voluntary targets, early replacement and 23 bulk government procurement. Again, we use -- in 24 this case we use the national energy spreadsheet. 25Executive Court Reporters (301) 565-0064 1 56

It’s modified to say well, what if we did this, 1 what if we did this, to estimate the effects of 2 non-regulatory scenarios, based on experience with 3 considered policies. 4 And the outputs are again, national energy 5 savings, and net present value for the described 6 non-regulatory alternatives. 7

MR. BROOKMAN: Susan. 8 MS. ANDERSON: It’s interesting that you 9 mention the other alternatives. Right now there is 10 legislation, it’s Senate Bill 398, that would, in 11 the case of outdoor lighting, one of the provision 12 in it would be to eliminate mercury vapor for 13 general lighting applications, the lamps -- the 14 ballasts are already gone. 15 But something else, right now there’s -- 16 are you familiar with the Commercial Building Tax 17 Deduction Program? 18

MR. MYER: Yes. 19 MS. ANDERSON: It’s a federal program. 20 Right now it only includes indoor lighting. It 21 doesn’t cover outdoor lighting. You know, a lot of 22 HID is used outdoors. And that’s -- 23 MR. HALLEY: (comment off mic) 24 MR. MYER: Just some clarification for 25Executive Court Reporters (301) 565-0064 1 57

those in the room and those who may not be familiar 1 with it. It’s -- the deduction that Susan and Joe 2 are referring to was part of EPACT. It gives a 3 proportional income tax deduction, not a credit, 4 related to reduction in installed power density 5 against standard 90.1 2001. From my understanding, 6 I think -- and it does not cover outdoor. The only 7 quasi outdoor activity it does cover is parking 8 garages, which the IRS ruled under an interim rule 9 that they are a non-conditioned indoor space. So I 10 know that there is some review of that ongoing by 11 other agencies as well, that legislation, but I 12 just wanted to clarify that it is a deduction, not 13 a credit. But thank you for the suggestion or to 14 possibly look at the effect of it. 15 MS. ANDERSON: Yeah, I mean there were a 16 couple reasons why they didn’t cover it to begin 17 with, because 90.1 only covers systems that are 18 managed by the power system of the building, and a 19 lot of outdoor lighting is not. But still, there’s 20 a huge opportunity for energy savings if there were 21 some sort of incentive there to get people to 22 convert outdoor lighting to something more energy 23 efficient. 24 MS. deBUTTS: We will definitely consider 25Executive Court Reporters (301) 565-0064 1 58

that and since the folks that work on that program, 1 you know, are close by as well, so we thank you for 2 the remarks and we’ll see if we can include that. 3 MR. MYER: Yes, I had one question for the 4 manufacturers who are reviewing it. One of my 5 concerns about it is that ... it’s not always used in 6 interior applications, especially related to HID is 7 the bilevel provision. Do you have any thoughts on 8 how the bilevel provision related to HID lighting 9 could be addressed related to -- there’s a 10 requirement that the lighting has to have a bilevel 11 aspect to it. 12 MS. ANDERSON: We’re actually working on 13 that in order to accommodate new standards that 14 will be coming out in California. 15 MR. MYER: Thank you. 16 MS. ANDERSON: So, with metal halide you 17 can’t -- you don’t have this infinite dimming range 18 or anything like that, like you can with 19 fluorescent, but you can step it down, so there -- 20 and there also already have been some studies done 21 by California Lighting Technology Center on 22 implementing that type of system. 23

MR. BROOKMAN: I see. Joe. 24 MR. HALLEY: To that point, the tax 25Executive Court Reporters (301) 565-0064 1 59

incentives so far has been to promote people taking 1 out a HID systems out of warehouses and putting in 2 fluorescent systems that can be more easily 3 bileveled, controlled. And so it’s -- that’s 4 another -- other regulatory activity that’s going 5 on that we hadn’t mentioned to date, that you 6 should consider in your analysis. That of course, 7 just continues through 2013, unless Congress 8 decides to extend it. The last time, they decided 9 to extend it five years. All bets are off with 10 what this Congress may do. But that’s a 2013 11 Congress that hasn’t been elected yet either, so 12 I’m not sure what they might do next year. But 13 that should be taken into account as well, perhaps, 14 as another factor that is impacting the HID 15 marketplace. Not in a positive way, in a negative 16

way. 17 MR. MYER: Thank you. 18 MR. BROOKMAN: Alex. 19 MR. BOESENBERG: Alex Boesenberg. I have 20 one clarifying question for this slide, non21 regulatory alternatives for the regulatory impact 22 analysis. So am I correct when I say that your 23 analysis is in that how non-regulatorial 24 alternatives such as those listed might reduce the 25Executive Court Reporters (301) 565-0064 1 60

opportunity for energy savings from the rule and 1 somehow they impact -- encourage energy savings any 2 way or already, but you’re not considering new 3 ones, is that right? Because I don’t know how the 4 Department would extend the Commercial Building Tax 5 Deduction, even if they agree with it. 6 MR. MYER: Well, there’s definitely a 7 mixture of things here. Certain -- the six items 8 listed there, some are not actually promoted by -- 9 customer rebates, obviously, would not come from 10 the government, would come from -- 11 MR. BOESENBERG: We’re open to that 12 option. 13 (Laughter.) 14 MR. MYER: So the way I tend to think of 15 this in my head is that we look at what the 16 national energy savings are, which is reported in 17 quads of energy savings, and the net present value, 18 which is dollar amount from the standards case. 19 And then what could it be from these potential 20 other alternatives. As Joe was saying that you’re 21 seeing other incentives push away from HID. Is 22 there greater savings from not doing a standard but 23 encouraging manufacturers to retool or to upgrade 24 through a tax credit, rather than a regulatory 25Executive Court Reporters (301) 565-0064 1 61

compulsory action, but financially - the carrot, I 1 guess is the best example -- rather than requiring 2 them, you must be this efficient, or rather saying, 3 you know, you can write of much faster deduction of 4 upgrading to a new machine that develops this type 5 of lamp. So that’s what it is, it’s a comparison 6 of could they do other things that are not standard 7 driven. 8 MR. BROOKMAN: Okay. So comments on -- 9 additional comments on the regulatory impact 10 analysis? 11 MR. MYER: At this time -- 12 MR. BROOKMAN: Then now we have an 13 opportunity to have additional comments, anything 14 that we haven’t covered already today that perhaps 15 some of you even have notes on, being as well 16 prepared as you are. 17 MR. BROOKMAN: Susan, microphone. 18 MS. ANDERSON: We wanted to go back to 19 eight, nine, ten, and eleven, and actually Tom 20 Harding has the expertise to comment on those. 21 Those were things impacting the -- where we were 22 allowed to make additional comments related to the 23 test procedure. 24 **Final Comments** 25Executive Court Reporters (301) 565-0064 1 62

MR. HARDING: Yes, being the 12:30 time, 1 just because you wanted to hear from me. Quickly, 2 I’ll make it in five minutes, I think, unless you 3 have a lot of questions. 4 Item eight, which is welcoming comments on 5 test procedures, and particularly for photometry, 6 and it was an open-ended question on integrating 7 spheres specificity, and LM78, and the answer is 8 that’s fine. We accept LM 78, the information 9 needed to photometer these HID lamps is all in 10 there. It related to source size versus sphere 11 measurement size. It’s all in there. We accept 12 that. It’s also related to the CIE recommendations 13 on that. 14 MR. BROOKMAN: Michael. 15 MR. MYER: Michael Myer, Pacific Northwest 16 National Laboratory. I’m supporting the test 17 procedures. I just have one question. During the 18 test procedure meeting, there was comment about LM 19 51 being updated. We were forwarded a draft copy 20 of LM 51 and it appears that a fair amount of the 21 new stuff in LM 51 is also related to sphere 22 specificity, and do you feel that LM 78 covers 23 enough of that, or do you still will you direct us 24 back to the new -- currently revised version of LM 25Executive Court Reporters (301) 565-0064 1 63

51? 1 MR. HARDING: Well, I haven’t seen the 2 revised version of LM 51. I am familiar with the 3 document, but I haven’t seen any revision of it 4 yet, so I don’t know what they’ve changed in it. I 5 don’t think it’s a big issue. I think we’re all 6 fine that there’s historically a ten to one ratio 7 from lamp arc size or source size to sphere 8 diameter, and I don’t see that that’s changing. 9 Item nine was the document -- NEMA 10 standard, SD 26, which was on tolerancing, it’s not 11 been a published document, and because of all this 12 regulatory work, we’re revising it very regularly, 13 a couple times a month, and we started with 14 incandescents, added fluorescent, it’s now adding 15 HID. It’s including not just lamps, it’s including 16 ballasts. And it deals with the standard 17 deviations of all these measurements. And inherent 18 in the source, as well as from lab to lab kind of 19 things. So we’re trying to put that all in, and 20 it’s a very active group, mid-year is kind of our 21 target date to have this all out. But once you 22 know the statistics, you may be able to do better 23 plans for measuring these things. 24 MR. MYER: Michael Myer, Pacific Northwest 25Executive Court Reporters (301) 565-0064 1 64

National Laboratory. I’m sorry, so mid-year, so 1 would that be summer of 2012? 2 MR. HARDING: I’m guessing. I don’t have 3 a firm date. It’s winding down, I know that, 4 because we’ve submitted all our data. I just don’t 5 know what NEMA’s looking at a target date, but we 6 said mid-year and I believe -- there’s discussions 7 and I believe that’s about right. 8 Item ten was the use of NAVLAB accredited 9 testing facilities. Data normally submitted to 10 these things come from NAVLAB facilities, but the 11 way the lighting companies work, they typically 12 have one setup, on sphere system for light sources 13 that’s NAVLAB accredited. But the data is often 14 taken at the factories where they produce the 15 product, they pull samples out, put them on test 16 and do the data. So the data bases we all have are 17 not on NAVLAB systems. And they’re expensive to 18 maintain, that’s why basically each company has 19 one. So if we’re going to require a lot more data 20 like this light testing data in particular, which 21 is normally done at the plants, we have a NAVLAB 22 situation. We’ve either got to overload the 23 central unit, if we’re not careful, or we’ve got to 24 diversity out to some of the plants to make them 25Executive Court Reporters (301) 565-0064 1 65

NAVLAB approved. 1 MR. BROOKMAN: Those labs in the plant, 2 are they somehow NAVLAB certified or something? 3 MR. HARDING: No, I don’t think they’re 4 anything, they’re just their own place. Now they 5 often try to correlate the data to the central 6 NAVLAB-approved system, but it’s not directly 7 NAVLAB measured. 8 MR. BROOKMAN: Michael. 9 MR. HARDING: It’s used as a correlation 10 headquarters, if you like, to make sure the plants 11 stick there. 12 MR. MYER: Michael Myer, Pacific Northwest 13 National Laboratory. I guess -- I read the written 14 comments related to NAVLAB, and I was a little 15 confused. So it appeared that in NEMA’s written 16 comments related to NAVLAB, they were supportive of 17 NAVLAB for color measurements, and you just said 18 now but NAVLAB is hard for -- 19 MR. HARDING: Well, efficacy and color. 20 MR. MYER: So you were going to be okay 21 with that -- I guess that’s the clarification. So 22 NAVLAB for efficacy and color is fine, but when 23 something that’s a long term, such as lumen 24 maintenance, there’s a burden -- not burden, but a 25Executive Court Reporters (301) 565-0064 1 66

potential, as you said, of overloading the center - 1 - not enough ... space. 2 MR. HARDING: There is that, yes. 3 Efficacy of course is what you’re measuring 4 anyway. There was an issue when it came to 5 incandescent, general service incandescent 6 lighting, you know where there was a life 7 requirement of 1000 hours and we’re saying, how do 8 you do 1000 hour light verification in a NAVLAB 9 facility? That was an issue. 10 But everybody will agree that lumens and 11 color can easily be done there, in any NAVLAB 12 facility. The issue is how much money has to be 13 spent to bring all this life testing into 14 compliance with NAVLAB. In other words, do we have 15 to now NAVLAB approved factories where the data is 16 taken? Do we have to expand the central NAVLAB 17 facility? All of that costs money, manpower, and 18 equipment, as well as the certification cost, which 19 is not maybe so bad for huge corporations, but for 20 some of the smaller companies, it’s significant, 21 let me tell you. I’ve been having trouble getting 22 the money allocated. 23 Those are the items that we had skipped 24 over. I think that was all of them. Oh, the 25Executive Court Reporters (301) 565-0064 1 67

sample size one, yeah. Sorry. We did look at 1 sample sizes where 21’s one of the going numbers 2 that’s thrown around. We’re kind of reserving our 3 own judgment until we get done with this LSD 26 4 paper and know some of the statistics. Knowing 5 some of the statistics will help us perhaps make a 6 better recommendation as to how to do it. 7 One of the things is, if we have to do 8 long life testing, how do you choose, for example, 9 the infamous three lamps a month over seven months 10 in a 12 month period, and then put them all up for 11 life testing. Or do you put them up three a month? 12 And then you’ve got staggered outputs or one 13 thought is maybe we do a chunk at the beginning if 14 we have to do this kind of testing. But we wanted 15 to see what the statistics showed up, and this LSD 16 26 working group is looking at this one as well. 17 MR. BROOKMAN: Okay. Thank you. Alex. 18 MR. BOESENBERG: Alex Boesenberg, NEMA. 19 And as a reminder, we did submit comments on a 12 20 lamp sample size in our test procedures NOPR 21 response and we continue to stand by that. It’s a 22 very challenging number at that size for the 23 equipment, manpower, and cost of performing those 24

tests. 25Executive Court Reporters (301) 565-0064 1 68

MR. BROOKMAN: Okay. Thank you. 1 MR. BOESENBERG: A thousand watt lamps, 2 boy does that burn a lot of juice. 3 MR. BROOKMAN: Thank you. So you seem 4 quite systematic. Michael, go ahead. 5 MR. MYER: Michael Myer. Reading the NEMA 6 comments and going back to what Tom was saying 7 about three lamp samples per month, is it fair to 8 say that unlike other lamp technologies that 9 production runs are not continuous for certain HID 10 lamps, or that if they’re continuous they happen on 11 maybe a more staggered cycle and there’s not 12 monthly? It would be, you know, six or eight 13 weeks, some longer -- some more intermediate period 14 than a monthly lamp run? 15

MR. BROOKMAN: Tom. 16 MR. HARDING: Tom Harding. Depends on the 17 type. There’s some very specialized products, 18 well, I shouldn’t say specialized, lower volume 19 products, and you’re not going to run those all the 20 time. You’re going to do it at intervals. The 21 more higher production, higher sales items, you’re 22 going to run more often. So it does vary. I don’t 23 know, I can’t speak for the other companies, so I 24 don’t know how often they run the various types. 25Executive Court Reporters (301) 565-0064 1 69

We do them, of course, in significant enough runs 1 to justify the equipment setup. 2 MR. BROOKMAN: Now is an opportunity to 3 make any additional comments, raise additional 4 issues that haven’t been covered fully and seems as 5 though you all had quite a lot of preparation that 6 went into this. I’m certain the Department really 7 appreciates that. Anything else that you’d like to 8 raise at this point? Because we’re nearing the 9 close of this meeting. Nothing additional at this 10 time? So back to then, Lucy deButts for closing 11 remarks. 12 **Closing Remarks** 13 MS. deBUTTS: Sure. Well, again I would 14 like to thank everyone for providing us with your 15 input. I think it was a very interesting 16 discussion, and we got a lot of good information 17 from you guys, so thanks. In case you want to 18 submit written comments which we expect from you 19 and appreciate, there are several avenues for you 20 to do that. As usual, when you submit written 21 comments please address the rulemaking, provide the 22 docket number, and refer to the ... for that 23 rulemaking when you’re providing written comments. 24 We encourage you to submit them through 25Executive Court Reporters (301) 565-0064 1 70

the regulations.gov, you know, or through the e1 mail address shown here on this slide. However, if 2 there are difficulties to doing it electronically, 3 there’s always an option to send it in the postal 4 office or courier, as shown here. And Brenda 5 Edwards, who we met earlier and in all the previous 6 meetings, will be taking care of the comment 7 collection. 8 So again, comment period is closing on 9 April 12 th , and we extended it to accommodate 10 everybody as much as we can. We have to consider 11 the test procedures so we’d like to get your 12 comments by April 12 th if possible. 13 And again, if you’d like to give 14 additional information or you need to access the 15 framework document, or agenda, and the transcript 16 of this meeting, these are the links that will be 17 useful for you to consider. So the website and 18 each product pages. 19 Any questions on that? 20 MR. BROOKMAN: There’s one more thing. 21 The Department frequently provides a Xerox copy of 22 the business cards of the individuals that have 23 checked in, and I see Brenda is going to be handing 24 out a copy of that right now for your reference. 25Executive Court Reporters (301) 565-0064 1 71

MS. deBUTTS: So at this time, any 1 questions, and if -- before we conclude? Well, 2 Doug, it’s back to you. 3 MR. BROOKMAN: Thanks to all of you. 4 Appreciate it, and safe travels. 5 (Whereupon, at 12:46 p.m., the meeting in 6 the above captioned matter was adjourned.) 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 REPORTER'S CERTIFICATE

This is to certify that the attached proceedings before:Executive Court Reporters (301) 565-0064 1 72 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 appe ars and that this is the original transcript ther eof for the file of the Department, Commiss ion, Board, Admi nistrative Law Judge or the Agency. Further, I am neither co unsel for or related to any party to the ab ove proceedings.



### Wendy Greene Official Reporter Dated: April 3, 2012