August 8, 2011

VIA EMAIL TO: CCE-2010-BT-CE-0014@ee.doe.gov

Ms. Brenda Edwards US Department of Energy Buildings Technologies Program Mail Stop EE-2J 1000 Independence Ave, SW Washington, DC 20585-0121

Energy Conservation Program: Certification, Complia nce and Enforcement for Consumer Products and Commercial and Industrial Equipment

Docket Number: EERE 2010-BT-CE-0014

RIN Number 1904-AC23

NEMA continued request for extension to the DOE CCE Rule for Metal Halide Lamp Ballasts and

Fixtures

NEMA thanks the DOE for allowing us to review the d raft CCE extension and for allowing us to meet in p erson to further discuss out concerns. NEMA and its memb er companies are strong advocates for energy effici ency. We have met with DOE in the past regarding business concerns related to non-compliant products in the market place. We support the DOE efforts to improve produ ct compliance and enforcement for energy regulation s. We believe that this rule will provide long term benef its to our members’ businesses. However, NEMA and its members still have strong concerns that the propose d three month extension does not allow enough time for products to be tested and reported.

As noted in our recent face to face meeting with re presentatives of DOE, NEMA and its members overlook ed the March 9, 2010 final rule for Test Procedures fo r MH lamp ballasts that increased test sample size from 1 to not fewer than 4 units. Since they realized and u nderstood this change, the member companies have be gun the additional testing. NEMA feels all parties involve d contributed to the need for a delay and we need t o work together to set a workable time line.

DOE has requested additional information regarding the testing of MH lamp ballasts. The information b elow describes the testing process and coordination with luminaires that use those ballasts.

• The number of ballast models covered by the energy standard varies significantly based on the individu al

ballast manufacturer. Several ballast manufacturer s indicate that they have about 40-50 covered balla sts, but a few larger manufacturers may have well over 1 00 covered ballasts.

• One luminaire manufacturer has indicated they purch ase over 1000 covered ballast models from 15 differ ent
vendors.

1300 North 17th Street, Suite 1752

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• Ballast manufacturers have indicated that testing b allast efficiency typically requires about 2 hours; however the entire set up of calibration and stabilization can result in a total lab test time of 8 to 24 hour s per ballast. The variation depends on the type of ballast and st abilization requirements. Of comments received fro m ballast manufacturers, the most commonly sited time frame is 3 working days to complete the minimum sampling of four ballasts for a single ballast mode l.

• Ballast manufacturers have noted that the sample of 4 ballasts is very likely to meet the mean ballast efficiency, but a larger sample is required to achi eve the 99% LCL. Therefore additional samples and t est time is very likely to be required. A less stringe nt confidence level would help to ensure that addit ional testing is not necessary.

• Most ballast manufacturers have one lab bench dedic ated to ballast testing. Ballast manufacturers us e this bench to test ballasts that are not covered by the energy standard and it is unrealistic to assume the bench can be 100% dedicated to testing covered ballasts f or an extended period of time.

Based on the data above, in a best case scenario (4 0 models, 3 days to test three additional samples, test lab dedicated to only testing covered MH ballasts), the ballast testing will require 24 weeks with test da ta available to luminaire manufacturers around January 2012.

In a more realistic scenario (40 models, 5 days to test sufficient samples to achieve 99% LCL, lab 75% dedicated to testing covered MH ballasts), the ball ast testing will require 53 weeks with test data av ailable to luminaire manufacturers around August 2012.

NEMA has previously provided input regarding the lo gistics for luminaire manufacturers to correlate ea ch

ballast model for each vendor to each luminaire bas ic model. One luminaire manufacturer recently info rmed NEMA that their 2010 FTC report included over 260 b asic luminaire models of covered products. Each of these models covered multiple wattages and uses multiple ballast vendors and they may prefer to report each basic model for separate wattages and ballast vendors to minimize compliance risks. This would increase the number of basic models reported to DOE to several hundred basic models. The logistics of compiling, analyzin g and reporting the basic luminaire models is expected to require around 3 months.

NEMA ballast and luminaire manufacturers find that an extension to October 1, 2011 will not provide su fficient time to conduct the necessary ballast testing and c orrelation with luminaire basic models.

We again suggest that for MH luminaires, DOE delay the enforcement of compliance reporting for MH

luminaires until a date no earlier than September 1, 2012 to allow for a reasonable and accurate process to compile the tests and submit based the testing and reporting requirements. This date coincides with the annual reporting date, minimizing the burden of multiple r eports within the same year.

If you have any questions or comments, please do no t hesitate to contact Alex Boesenberg of NEMA Government Relations at (703) 841-3268 or alex.boes enberg@nema.org.



### Sincerely,