1 

UNITED STATES OF AMERICA 

DEPARTMENT OF ENERGY 

PUBLIC MEETING 

ENERGY CONSERVATION STANDARD 

 PRELIMINARY ANALYSIS AND ACTIVE MODE TEST PROCEDURE 

NOPR FOR FLUORESCENT LAMP BALLASTS 

U.S. Department of Energy 

1000 Independence Avenue, SW 

Washington, DC 20585 

Room 8E-089 

Monday 

April 26, 2010 

 

Chair: 

Linda Graves 

Department of Energy 

Facilitator 

Jim Raba 

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Participants Identified: 

Tim Ballo 

Earth Justice 

Ed Thomas 

GE Lighting 

John Green 

Cooper Lighting 

Joe Parisella 

Osram Sylvania 

Justin Newmann 

NEMA 

Mike McGaraghan 

Energy Solutions 

Joanna Mauer 

Appliance Standards Awareness Project 

Charlie Stephens 

Northwest Energy Efficiency Alliance 

Evan Haynes 

ICF International 

John Cymbalsky 

Department of Energy, Appliance Standards 

Linda Graves 

Department of Energy, Appliance Standards 

Graham Parker 

Pacific Northwest National Laboratory 

Natasha Collins 

Pacific Northwest National Laboratory 

Amanda Lowenberger 

American Council for an Energy-Efficient Economy 

Eric Andersen 

Pacific Northwest National Laboratory 

Ian Swink 

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U.S. Department of Justice, Antitrust Division 

Mark Duffy 

GE Lighting 

Keith Cook 

Philips Lighting 

Susan Anderson 

Osram Sylvania 

Jeff Plaskon 

GE Lighting 

Tom Eckman 

Northwest Power and Conservation Council 

Kyle Pitsor 

NEMA 

 

Bob Lingard 

Pacific Northwest National Laboratory 

Gavin McCormick 

Pacific Northwest National Laboratory 

Mimi Gupta 

Navigant Consulting 

Ali Lehr 

Navigant Consulting 

Matthew Walker 

Navigant Consulting 

Pekka Hakkarainen 

Lutron Electronics 

Bob Erhardt 

Philips Lighting Electronics 

Betsy Kohl 

Department of Energy, General Counsel’s Office 

Andrew deLaski 

Appliance Standards Awareness Project 

Alvin Razon 

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National Rural Electric Cooperative Association 

I N D E X

AGENDA ITEMS PAGE

Welcome, Ms. Graves 5 

Introductions 7 

Agenda Review, Mr. Raba 10 

Opening statements 12 

Test procedures: Overview and Existing Method 26 

 Mr. Walker 

Test procedures: Alternative Methods 54 

 Mr. Walker 

Test procedures: Proposed Method 76 

 Mr. Walker 

Energy Conservation Standard Introduction, 110 

Statute, and Context 

 Ms. Lehr 

Market and Technology Assessment; Screening 128 

Analysis 

 Ms. Lehr 

Engineering Analysis 145 

 Ms. Lehr 

Energy Use and Markup Analysis 193 

 Mr. Lingard 

Life-Cycle Cost and Payback Period Analysis 208 

 Mr. McCormick 

National Impact Analysis 235 

 Mr. McCormick 

Preliminary Manufacturer Impact Analysis 270 

 Mr. Carmichael 

NOPR Analyses 275 

 Mr. Lingard 

Final Questions/Discussions and closing 278 

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 Ms. Graves 

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

2 9:00 a.m. 

3 MR. RABA: Introducing Linda Graves, Project 

4 Manager. 

5 MS. GRAVES: Good morning and welcome to the 

6 U.S. Department of Energy. I’m Linda Graves. I’m the 

7 project leader for lighting standards, and we are 

8 doing something that we’ve done only a couple times in 

9 the past, we are presenting two rule makings in a 

10 single day. And the purpose of today’s meeting is to 

11 discuss the energy conservation standard preliminary 

12 analysis for fluorescent lamp ballasts, as well the 

13 draft proposed test procedures. 

14 We are particularly interested in your 

15 reaction to this format, because it’s our intention to 

16 follow this approach from now on, of compressing what 

17 used to be maybe a full day public meeting per rule 

18 making into half days, so we really would appreciate 

19 your response on the surveys at the end of the 

20 meeting. If this worked for you, we are still very 

21 intent upon getting your full participation and 

22 contribution. We’ve learned a lot from the back and 

23 forth with you, both at public meetings and through 

24 your written comments. So we certainly want to 

25 preserve that. 

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1 I’m here with my new boss, John Cymbalsky, 

2 but he’s not new to the U.S. Department of Energy. He 

3 was formerly with the Energy Information 

4 Administration for 20 years, and he is an expert on 

5 forecasting, and you can certainly see how that 

6 applies to our rulemaking. 

7 I’m also here with my, frankly, brilliant 

8 lighting teams from Pacific Northwest National 

9 Laboratory, and Navigant Consulting. They will be 

10 presenting the basic information to you. 

11 And I’m also here with Jim Raba, who is also 

12 from the Appliance Standards Group, but he has 

13 graciously agreed to facilitate for us. He has 

14 facilitated many times in the past, and I can always 

15 count on Jim’s calm demeanor to keep things friendly 

16 and civil and so everyone hears everyone. 

17 So with that, I’m turning the meeting over 

18 to Jim. 

19 MR. RABA: Linda, you’re too nice. Yes, we 

20 know that. Well, good morning. I’m Jim Raba, I’ll be 

21 facilitating your public meeting today. And as a 

22 facilitator, I try to keep you on track and focused. 

23 You’ve come a long way to accomplish a lot, so to make 

24 the best use of your time and your comments back to 

25 the Department of Energy’s rule making and preliminary 

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1 analyses. So everybody will have an opportunity to 

2 speak, so when you, be concise. 

3 Some things to go around the room first, 

4 like to have everybody introduce themselves, and when 

5 you do, notice the green lights on the microphones at 

6 the table. The green light should be on. If you want 

7 to push the mute, just push the button and it’ll be a 

8 mute as well. Let’s go around the room and introduce 

9 ourselves, starting with this side, please. Your 

10 name, the organization affiliation. 

11 INTRODUCTIONS 

12 MR. THOMAS: Hello, I’m Ed Thomas. I’m with 

13 GE Lighting. 

14 MR. RABA: You hear okay, court reporter? 

15 Okay. Just speak closer. Thank you very much. 

16 Proceed. 

17 MR. GREEN: John Green, with Cooper 

18 Lighting. 

19 MR. PARISELLA: Joe Parisella with Osram 

20 Sylvania. 

21 MR. NEUMANN: Justin Neumann with NEMA. 

22 MR. MCGARAGHAN: Mike McGaraghan with Energy 

23 Solutions, here on behalf of Pacific Gas and Electric 

24 Company, and Southern California Edison Company, and 

25 San Diego Gas and Electric. Three large investor-run 

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1 utilities in California. 

2 MS. MAUER: Joanna Mauer, Appliance 

3 Standards Awareness Project. 

4 MR. STEPHENS: Charlie Stephens. I 

5 represent the Northwest Energy Efficiency Alliance. 

6 MR. HAYNES: Evan Haynes, ICF International. 

7 MR. CYMBALSKY: John Cymbalsky, Department 

8 of Energy, Appliance Standards. 

9 MS. GRAVES: Linda Graves, Appliance 

10 Standards. 

11 MR. RABA: In the back, the microphones that 

12 are standing are live. You can use them to introduce, 

13 please. 

14 MR. PARKER: Graham Parker, Pacific 

15 Northwest National Laboratory. 

16 MS. COLLINS: Natasha Collins. I’m from 

17 Pacific Northwest National Labs. 

18 MS. LOWENBERGER: Amanda Lowenberger, 

19 American Council for an Energy-Efficient Economy. 

20 MR. ANDERSEN: Eric Andersen, Pacific 

21 Northwest National Laboratory. 

22 MR. SWINK: Ian Swink, U.S. Department of 

23 Justice, Antitrust Division. 

24 MR. DUFFY: Mark Duffy, GE Lighting. 

25 MR. COOK: Keith Cook, Philips Lighting. 

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1 MS. ANDERSON: Susan Anderson, Osram 

2 Sylvania. 

3 MR. PLASKON: Jeff Plaskon, GE Lighting. 

4 MR. ECKMAN: Tom Eckman, Northwest Power and 

5 Conservation Council. 

6 MR. PITSOR: Kyle Pitsor, NEMA. 

7 MR. RABA: Over here, please. 

8 MR. LINGARD: Bob Lingard, Pacific Northwest 

9 National Laboratory. 

10 MR. McCORMICK: Gavin McCormick, also 

11 Pacific Northwest National Lab. 

12 MS. GUPTA: Mimi Gupta, Navigant Consulting. 

13 MS. LEHR: Ali Lehr, Navigant Consulting. 

14 MR. RABA: Now we had a few come in -- and 

15 one more -- I’m sorry, I didn’t see you over there. 

16 MR. WALKER: My name’s Matthew Walker, also 

17 from Navigant Consulting. Thanks. 

18 MR. RABA: Go ahead, please. 

19 MR. HAKKAHANEN: Pekka Hakahanen, Lutron 

20 Electronics. 

21 MR. ERHARDT: I’m Bob Erhardt, Philips 

22 Lighting Electronics and chairman of the NEMA ballast 

23 section. 

24 MS. KOHL: Betsy Kohl, Department of Energy, 

25 General Counsel’s Office. 

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1 MR. RABA: Thank you very much. 

 2 

 3 

4 OPENING REMARKS, AGENDA ITEMS 

5 MR. RABA: Some things we’ve come to think 

6 of as norms at our public meetings to help get through 

7 and have everybody speak and be heard are some things 

8 we have established over many years and we’re 

9 comfortable with. Ask everybody to listen as an ally, 

10 we’re here to accomplish a purpose for your benefit. 

11 Be concise when you speak please. Speak one at a 

12 time. Raise your hand, I’ll recognize you and queue 

13 you one at a time for both introductory comments, 

14 statements, and final on discussions as well. 

15 Please put your cell phones on silent or 

16 vibrate or stun. No sidebar conversations -- take 

17 them out in the back or the hallway, perhaps, too. 

18 And keep the focus up here on the 

19 presentations, on the topics as well, so keep moving 

20 along. We have a lot to cover today, want to make the 

21 best use of your time. 

22 Some housekeeping items. Let’s see, very 

23 quickly, restrooms are at the far end of the hallway, 

24 either one. Coffee shop downstairs on the ground 

25 floor, about this position on the ground floor. We’ll 

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1 take breaks later on in the morning, and throughout 

2 the day. Yes, please. 

3 Has everybody signed in at the reception 

4 desk and checked in with a packet of information? All 

5 set there? Okay. Good. 

6 Agenda, I’ll deal with very quickly. You 

7 can see that the morning will be focused on the test 

8 procedures, an overview of them. We’ll look for a 

9 time to take a break. We have a schedule here, but we 

10 can see how the meeting flows through the day. Breaks 

11 are scheduled, we’ll take a look at that as they come 

12 along. Take a break for lunch when’s appropriate. We 

13 may get ahead of schedule, which is good, may not. 

14 We’ll take a look and see at that, and then later on 

15 this afternoon test procedures. 

16 Any question on today’s agenda? 

17 So as we say, the Department of Energy wants 

18 to hear from you. It’s a good time to speak. Make 

19 oral and written statements, which will be very 

20 helpful in lighting, when the comment period 

21 continues. And again, when you speak, please be 

22 recognized, state your name for the record, and your 

23 organization, affiliation. We have a court reporter 

24 here who will be transcribing today’s proceedings. 

25 There’ll be a copy of the transcript available after 

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1 the public meeting, and there’ll also be an attendance 

2 sheet, a list of attendees provided to you as the 

3 meeting’s over. So you’ll have that for your records 

4 as well. 

5 I understand the PowerPoint slides we’ll be 

6 using today, there’s a lot of content in them. 

7 They’re using comment boxes focus for the key point 

8 and issues, so we’ll look at them also, and each of 

9 the presenters will give their introductions and 

10 proceed with that and key you up on those comments and 

11 questions too. 

12 I think we’ve covered that so far. So 

13 essentially right here, right now, we’re inviting 

14 anyone to make opening statements or remarks for the 

15 records, and if you’d like to do that, you’re welcome 

16 to. Keep them short, concise, limit your time, 

17 please. About three minutes, the most, if you would. 

18 OPENING STATEMENTS 

19 MR. RABA: Are there any persons who would 

20 like to speak at this time? Opening statements, 

21 perhaps? State your name for the record. 

22 MS. GUPTA: I was just saying, this is Mimi 

23 Gupta, Navigant Consulting. I think we have a couple 

24 of presentations some stakeholders submitted, so this 

25 is probably the best time for it. 

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1 MR. RABA: It’s a good time. All right. 

2 MR. ERHARDT: They’re more than three 

3 minutes long, probably, but we an leave it to three 

4 minutes. 

5 MR. RABA: Okay, go ahead, but start -- 

6 would you like to start? Who would like to start? 

7 MR. WALKER: Yeah, we’ve got a PowerPoint 

8 presentation we submitted, I think. 

9 MR. RABA: Okay, cuing it up now? 

10 MR. WALKER: He’s cuing it up. 

11 MR. RABA: That’s fine. Okay, the 

12 highlights, mostly. Thank you. And state your name 

13 please, for the record. 

14 MR. ERHARDT: Bob Erhardt, Philips Lighting 

15 and Electronics. Chairman of the NEMA ballast 

16 section. 

17 (Discussion regarding use of computer.) 

18 Hello. Bob Erhardt, Philips Lighting and 

19 Electronics. Chairman of the NEMA ballast section. 

20 NEMA would like to thank the Department of Energy for 

21 allowing us to participate again. We participated two 

22 years ago, and again at the HID meeting, and we feel 

23 it’s been very fruitful. We also would like to 

24 congratulate Navigant. We feel they’ve done a good 

25 job on their report of investigation, was quite a bit 

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1 to go through. We’ve been very active the last 

2 several weeks. We have a few areas we’d like to 

3 comment on, but we were very impressed with how in 

4 depth they were able to go, and we appreciate how 

5 diligent they were in accepting our input. We feel 

6 they represented our input quite well. 

7 Some further areas of discussion. We have a 

8 few areas of discussion. We’ve been in parallel, 

9 working on method of measurement, trying to improve 

10 accuracy and Ed Thomas will give a more detailed 

11 presentation on that, and we’ll have detailed comments 

12 during the morning’s activities. 

13 We have a couple comments on using common BF 

14 filaments for different lamp types, a little bit on 

15 sales projections, cost analysis, scaling technique 

16 and considerations for emerging technologies. Again, 

17 as I said, Ed Thomas will be giving a more detailed 

18 presentation on method of measurement. 

19 We feel that we appreciate that DOE and 

20 Navigant, with Navigant’s recommendation, is looking 

21 at ballast efficiency. We have some further comments 

22 on that. We’ve been doing some further work. We’d 

23 like to talk about our work with you, seeing lamp 

24 loads with ballast efficiency measurements. 

25 We’d also like to remind you that even 

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1 though ballast efficiency measurements are more 

2 precise and more reproducible than lighting -- than 

3 light output measurements, please take into 

4 consideration there will still be some tolerances to 

5 be taken into account. I think we’ve been talking 

6 about two and a half percent one should assume per 

7 measurement BY accuracy in ballast efficiency and five 

8 percent for BEF measurements. 

9 Short comment on BEF limits for different 

10 lamp types. By definition, BEF refers to a light 

11 output from a given lamp. We feel that when you’ve 

12 used the same BEF measurement for you medium bi-pin, 

13 we feel that since the lamps were of the same light 

14 output that we agree with using one common set of BEF 

15 standards for T12 and T8. The medium bi-pin, we’d 

16 like you to take into consideration when you go to the 

17 T8 HO, the T12 HO, there is a 13 percent light output 

18 difference when you’re looking at the rated lumens and 

19 then so therefore the T12s would have a 12 percent -- 

20 a 13 percent disadvantage when you use a common BEF. 

21 Sales projections, we have a couple comments 

22 from NEMA biz on sales projections. There were some 

23 hills and valleys in the sales projections that we 

24 just historically haven’t seen, and we question that 

25 and we’ll have some comment on that. 

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1 Cost analysis. Very difficult to do, we 

2 recognize. We’re still trying to see if we can do it. 

3 We’re trying to pull together some cost numbers. I’ll 

4 make one comment here. There was an assumption that 

5 the most efficient ballast was cheaper than the lesser 

6 efficient ballast. We wish that were true, but we 

7 haven’t been able to find that fountain of youth or 

8 oxymoron, if you will. 

9 Scaling techniques. I think the scaling 

10 techniques are valid -- well, scaling techniques are 

11 valid. We have a couple comments on maybe where we 

12 could give some tweaks to them. I went to the 

13 California Energy Commission has a data base of over 

14 400 ballast models, and they are submittals that 

15 manufacturers must make to sell to California. They 

16 must come from a certified laboratory. So as far as I 

17 know, that’s the best data base I’ve found for public 

18 domain information on certified ballast parameters. 

19 And I used that, and I found your scaling techniques 

20 were pretty good. There might be some area with the 

21 one lamp, we had a lot of fall-out on the one lamp 

22 side. The data from the California Energy Commission 

23 website, when I did some averaging, it appears that 

24 maybe we would like some allowance on the one lamp. 

25 Some small differences in the -- going from 

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1 lamp power -- I’m sorry -- on the low, medium, and 

2 high output. In general, the LWs have lower 

3 efficiency. The high outputs actually have a little 

4 higher efficiency, you gave them lower. We’re not 

5 going to complain. But we may talk about that a 

6 little bit. 

7 We’ve going to have some comments on T5. If 

8 you look at the CSL-3 limits, a lot of us, even our 

9 premium products, our high-line products are on the 

10 edge or a half a point below what you propose. We’d 

11 like to talk about that a little bit. T5s, there’s 

12 some considerations -- first of all, because it’s a 

13 smaller lamp, it has the opportunity for more 

14 efficacious luminaires -- because you get better 

15 optical control out of them, and we’d like you to take 

16 that into consideration. 

17 And T5 lamps, at their operating 

18 temperature, they’re lumen output goes up slightly, 

19 and the T8s go down slightly, so that’s another area 

20 we’d like you to take into account when considering 

21 the BEF requirements for T5. 

22 And then, we’d like you to consider, when 

23 you’re looking at both the -- when you’re looking at 

24 future sales of fluorescent ballast, consider the 

25 emergence of solid state lighting. It is -- two years 

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1 ago, nobody knew exactly how it was taking off. Well, 

2 then I think the indication now is maybe it’s coming 

3 to be time, and you might want to consider if ten and 

4 15 years from now, what exactly the fluorescent market 

5 will be because there are some projections that solid 

6 state could be taking over as much as 50 percent of 

7 the lighting market in the ten year time frame. 

8 General comments. I mentioned we looked at 

9 the California Energy Commission. We’re going to 

10 comment on the CSL 2 and 3 data. 

11 The other thing we’d like you to consider is 

12 manufacturers are, you know, I think all of us here 

13 were very involved in improving energy efficiency. 

14 We’re doing it -- the newest areas of energy 

15 efficiency -- lighter controls and working with new 

16 light sources have the potential to generate 

17 significantly more energy savings than picking up one 

18 or two percent on an efficiency standard for a 

19 fluorescent ballast. So we hope that you’ll 

20 appreciate that when you’re talking about what it 

21 would take to dedicate engineering resources to 

22 redesigning fixed output ballast, please realize 

23 that’s probably energy resources you could be talking 

24 away from a much more beneficial technology, and 

25 please take that into consideration. 

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1 And those are my beginning comments. I hope 

2 I didn’t go over three minutes. 

3 MR. RABA: You did fine. That is very 

4 helpful. Very helpful indeed. 

5 MR. WALKER: We also have a second 

6 presentation? 

7 MR. THOMAS: Yes. 

8 MR. WALKER: All set. 

9 MR. THOMAS: Good morning you all. I’m Ed 

10 Thomas. I’m with GE Lighting. I’m also the chair of 

11 the ballast technical committee within the NEMA group. 

12 And I’d like to talk to you a little bit about test 

13 methodology. 

14 Of course, as Bob mentioned, we certainly 

15 want to thank the department for allowing us this 

16 opportunity. We also want to thank Navigant and the 

17 team of Navigant that we worked with very closely 

18 during a lot of testing and qualification that we were 

19 doing. And we’d like to continue to work with both 

20 the department and Navigant to finish off this work 

21 and move toward a ballast efficiency measurement. 

22 The advantages of ballast efficiency are 

23 many, more repeatable, less chance of errors, removes 

24 inaccuracies associated with lamp to lamp variation, 

25 manufacturer’s variation, and photometric variation. 

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1 It allows the accurate evaluation of a high 

2 performance product, but still there’s some issues. 

3 The proposed rule involves utilization of a 

4 standard fixed resistance load where it is designed 

5 for a normal light level ballast. As you know, the 

6 industry has several different light levels of 

7 ballasts, and if you were to try to engage a normal 

8 load on a low light level ballast, and impedance 

9 mismatch occurs, and therefore drives the ballast from 

10 its proper operating, high performance, efficiency 

11 point. And the same is true with the high ballast 

12 factor to normal ballast factor as well. 

13 And there was some discussion about scaling, 

14 saying that a certain percentage shift would be 

15 expected. That may be true on one particular type or 

16 a narrow range of types of ballast, but across the 

17 industry, that is not necessarily a true statement. 

18 To operate properly, the ballast would 

19 require a specific load for the specific light level. 

20 These loads, I think the people at Navigant are 

21 familiar with these loads, they’re very costly, 

22 precision-resistive networks, and you would require 

23 one per lamp channel and so a four lamp ballast would 

24 require four sets of these precise resistors, and then 

25 you would require a different bank for each particular 

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1 light level, and the necessity of arriving at these 

2 values come standardization of lamp types. As lamp 

3 types become available, they need to be standardized 

4 and the resistance value derived from them. 

5 So what our recommendation would be would be 

6 to utilize lamps as the load for testing the ballast. 

7 Ballasts are inherently designed to operate lamps. 

8 The lamp has a dynamic load. It adjusts to the light 

9 level provided by the ballast. Lamps are readily 

10 available. Lamps can be obtained from any 

11 manufacturer at low cost and provide a proper 

12 operating point for the ballast. 

13 We, as NEMA, have been working for a couple 

14 of years now on developing a ballast efficiency test 

15 procedure. It has recently circulated throughout our 

16 NEMA committees. It’s been balloted and approved, and 

17 I believe it is a handout here at this meeting today. 

18 So if you would refer to that, that would be helpful. 

19 Again, just to highlight a few 

20 characteristics. Electrical efficiency brings you 

21 independent of lamp load characteristics. As you 

22 know, fluorescent lamps are manufactured in high 

23 volume. There’s variation from manufacturer to 

24 manufacturer and lot to lot, and unfortunately, these 

25 variations affect the input wattage to the ballast, 

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1 over which the ballast has no control. And you 

2 combine that with some errors in the photometric 

3 system, then that leads to the inaccuracies of the 

4 present BEF photometric base system. However, even 

5 with a pure electrical measurement, some issues still 

6 exist with accuracy. 

7 When you’re looking at modern, high8 performance ballasts, they operate roughly in the 20 

9 through, basically 100 kilohertz region, and when 

10 you’re accurately measuring frequencies of that 

11 extent, you need a fairly sophisticated instrument. 

12 Just doing a quick back of the envelope calculation on 

13 the instrument, gives me a basic 1.5 percent accuracy 

14 for the instrument itself at that type of frequency, 

15 and this is not an inexpensive instrument. 

16 When you couple the current transducers and 

17 the wiring capacitances, that error increases a little 

18 bit more to the range that Mr. Erhardt had mentioned 

19 earlier. And even with these errors, you still get a 

20 more accurate, more repeatable measurement than if you 

21 use the existing photometric system. 

22 MR. ERHARDT: Could I make one comment, Ed? 

23 MR. THOMAS: Yes, sir. 

24 MR. ERHARDT: Each piece of equipment has 

25 about a one and a half percent. 

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1 MR. THOMAS: Yes. 

2 MR. ERHARDT: And when you’re doing ballast 

3 efficiency, you’re using two pieces of equipment, 

4 you’re taking the ratio, so it’s the addition of the 

5 two accuracies that you’re talking about. So if you 

6 have plus or minus a half, and plus or minus a half, 

7 one and a half, that’s where we’re getting our two and 

8 a half percent from. 

9 MR. RABA: Thank you, and your name and 

10 organization for the record? 

11 MR. ERHARDT: I’m sorry, Bob Erhardt, 

12 Philips Electric. 

13 MR. RABA: Thank you. 

14 MR. THOMAS: Just briefly here, measurement 

15 errors will affect the readings, and as we mentioned, 

16 the instrument alone is typically a couple percent. 

17 The photometric measurements are typically five 

18 percent or greater variability, and when you consider 

19 the fact that you have a light measuring system, you 

20 have a lamp that may vary in parameters, you have a 

21 ballast with electrical measurement in front of it -- 

22 all these errors cumulate through the existing 

23 photometric base system. And just to give an 

24 understanding, a typical ballast efficacy factor would 

25 be 1.58. Many people recognize CEE standards as a 

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1 more or less industry standard. If you start to apply 

2 the errors that cumulate through the system, you can 

3 see where the BEF numbers will vary greatly and 

4 there’s been talk of putting a third digit on the end 

5 of a BEF number, and based upon the accuracies that we 

6 see, that third digit doesn’t mean anything from a 

7 statistical viewpoint. 

8 Again, this is just a table for the CEE, 

9 showing where my 1.58 came from before. Just in 

10 tabular form, just showing a range of the numbers with 

11 a three percent error, the range of numbers with a 

12 five percent error. And just a -- roughly, this is a 

13 plot that I generated some time ago, and it appears my 

14 bar has shifted -- the black bar here is supposed to 

15 be at the point of 1.58. I don’t know how that 

16 happened. But anyways, the part I wanted to call your 

17 attention to is the error bars that are on the plot, 

18 that’s going to cover quite a range of BEFs versus 

19 efficiency. 

20 And again, this is just the table that the 

21 raw data come from, and the one point I’d call here is 

22 the relationship for a conversion factor. You look at 

23 this set of numbers for the Instant Start system, 

24 you’re seeing an average of about 1.7. Average of the 

25 numbers here, you’re seeing for Program Start systems, 

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1 a little bit less efficient. There’s about a 1.68, 

2 and we did notice somewhere through the documents that 

3 some of the performance ratings for Program Start 

4 systems seem to be a little bit higher than that for 

5 Instant Start systems, which is not really consistent 

6 with what we find in the industry. 

7 And again, this is a plot that was generated 

8 by our friends at the Lighting Research Center while 

9 working with Navigant, and we see distribution of 

10 ballasts that we tested during the work, and a 

11 clustering right around 89-90 percent efficiency, 

12 which is the mark that we were looking for. 

13 And that’s it. Any questions? Yes, ma’am. 

14 MS. GRAVES: Yeah, Ed. 

15 MR. RABA: Name please? 

16 MS. GRAVES: Linda Graves, Department of 

17 Energy. Your presentation will be part of the docket, 

18 part of the record of this meeting, so if you would 

19 like to submit a correction to that one slide, that 

20 would be fine. 

21 MR. THOMAS: I can do that, thank you. 

22 MR. RABA: Yes. Charlie Stephens. 

23 MR. STEPHENS: Charlie Stephens, Northwest 

24 Energy Efficiency Alliance. I just wanted to -- when 

25 you were using the term light level, that’s ballast 

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1 factor. As you using that for a synonym for ballast 

2 factor as you’re talking about the different -- in 

3 general when you use that term? 

4 MR. THOMAS: Right. That’s right. 

5 MR. STEPHENS: Okay. Thank you. 

6 MR. RABA: Other questions? Comments. Very 

7 good. Thank you. Very thorough. Very thorough. 

8 Thank you. Anyone else wish to make an opening 

9 statement? We did see a couple new arrivals. For the 

10 record, will you please, if you came in late, please 

11 state your name for the records and your organization 

12 affiliation. There’s a hot mike standing up behind 

13 you, and there’s a mike at the table. The green light 

14 should be on. You, sir. 

15 MR. deLASKI: Andrew deLaski, Appliance 

16 Standards Awareness Project. 

17 MR. RABA: And the back, please? 

18 MR. RAZON: Alvin Razon, National Rural 

19 Electric Cooperative Association. 

20 MR. RABA: Thank you, welcome. Proceed. 

21 TEST PROCEDURE: OVERVIEW AND EXISTING METHOD 

22 MR. WALKER: Thank you for those 

23 presentations. Let’s pick back up where Jim left off, 

24 throughout his presentation he presents particular 

25 issues on which it seeks comments in these blue boxes 

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1 you can see on this slide. These issues correspond to 

2 those 11 issues particularly identified in the Notice 

3 of Proposed Rulemaking, the one that was published a 

4 few weeks ago. 

5 These issues won’t necessarily be presented 

6 in this order in this presentation, and we just remind 

7 everyone that comments are welcome on any aspect of 

8 the analysis, not just these 11 issues. 

9 So the test procedure portion of the 

10 presentation will have four main parts. First, a 

11 discussion of the regulatory history and rulemaking 

12 process. Then a few slides on the existing test 

13 procedure, and a discussion of some of the 

14 alternatives that DOE considered, and then finally, 

15 some summary of the proposal in the Notice of Proposed 

16 Rulemaking. 

17 So a little history. In 1975 the Energy 

18 Policy and Conservation Act initially established the 

19 energy standards conservation program. Then in 1988, 

20 the National Appliance Energy Conservation Amendments 

21 amended EPCA to add fluorescent lamp ballasts to the 

22 program. This Congressional Act also required DOE to 

23 initially establish test procedure to set minimum 

24 efficiency standards for ballasts, and then it also 

25 required DOE to amend these standards two times. Also 

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1 within these -- this energy bill it was indicated that 

2 DOE could consider additional ballasts in its 

3 revisions of standards. 

4 Then in 1989 initially established the test 

5 procedure for fluorescent lamp ballast. In 2000, DOE 

6 published an energy conservation standard as the first 

7 amendment in accordance with the statute. And in 

8 2005, the Energy Policy Act of 2005 added new energy 

9 conservation standards for ballasts that operate 

10 energy saver lamps. In 2008, DOE published a 

11 framework document for the energy conservation 

12 standard that’s currently under development, and that 

13 is the standard that we’ll be discussing in the 

14 afternoon. It was at this meeting that DOE first 

15 received comment that it should review the active mode 

16 test procedure. 

17 Then in 2009, DOE published a final rule 

18 addressing standby and off-mode test procedures for 

19 ballasts. This was in response to a provision in the 

20 Energy Independence and Security Act of 2007, EISA 

21 2007. And finally, just a few weeks ago, on March 

22 24th, DOE published both the NOPR for the active mode 

23 test procedure, and Notice of Public Meeting, 

24 announcing the availability of the preliminary 

25 analysis for the standards rulemaking. 

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1 So from this point on, the presentation will 

2 focus on the test procedure. The test procedure in 

3 general consists of two parts. First, a NOPR, and 

4 then a final rule. DOE has published this NOPR on 

5 March 24th and it seeks comment both through oral 

6 comments at today’s meeting, and through written 

7 comments which are due by June 7, 2010, just about a 

8 month and a half from now. DOE will then review and 

9 consider all of these comments before publishing a 

10 final rule, which will be published on or before the 

11 same day as the final rule for the energy conservation 

12 standard rulemaking, which is about June 2011. 

13 The test procedure is very much 

14 interconnected with decisions that are made in the 

15 standards rulemaking, in particular the scope of 

16 coverage under consideration, so in order to 

17 synchronize the two rulemakings, DOE will publish both 

18 of them around the same time. 

19 The test procedure NOPR accomplishes several 

20 items. First it serves as the seven-year review of 

21 the active mode test procedure. One of the provisions 

22 of EISA 2007, one of the recent energy bills, requires 

23 DOE to review its test procedures every seven years. 

24 Next, the test procedure NOPR proposes to 

25 update ANSI references in the existing test procedure. 

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1 It then proposes a new test procedure based on ballast 

2 efficiency correlated to BEF for use with amended 

3 standards, and these amended standards are those that 

4 are currently under development and will be discussed 

5 in the afternoon. Finally, it proposes to set up 

6 certification requirements for use with both the 

7 existing standards and the amended standards. 

8 while there are currently energy 

9 conservation standards for ballast, manufacturers 

10 aren’t required to submit written documentation 

11 indicating compliance, so DOE is proposing to make a 

12 change. 

13 So at the bottom of this slide you can see a 

14 diagram that describes the timing of these provisions. 

15 First. on June 2011, the test procedure final rule and 

16 standards final rule will be published. Thirty days 

17 after that, the updates to the existing test procedure 

18 will be come effective, and that’s the updated ANSI 

19 references and the existing light output base method. 

20 Then in June 2012, DOE is proposing that manufacturers 

21 use the updated existing test procedure to indicate 

22 compliance with existing standards. 

23 Then in June 2014, the energy conservation 

24 standard will become effective, and on that same date, 

25 the new test procedure which uses ballast efficiency 

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1 correlated to BEF will also become effective. This 

2 test procedure will be located at Appendix Q-1 of the 

3 Code of Federal Regulations, whereas the existing test 

4 procedures, in Appendix Q. 

5 Then finally, in June 2015, one year after 

6 this new test procedure becomes effective, 

7 manufacturers will again be required to submit written 

8 documentation that indicates compliance with the 

9 amended standards using the new test procedure. 

10 So at this time we have our first issue for 

11 comment. This actually comes from the energy 

12 conservation standard preliminary analysis. Some 

13 manufacturers observed that there are non-compliant 

14 ballasts available in the marketplace, and DOE’s 

15 requesting comment on reasonable ways to enhance the 

16 certification and enforcement procedures for these 

17 ballasts. 

18 Floor’s open. 

19 MR. ERHARDT: Bob Erhardt, Philips Lighting 

20 Electronics, NEMA ballast section chair. I think 

21 we’ve commented before, and in California, the 

22 California Energy Commission requires that all test 

23 data be done by a certified laboratory, that there’s a 

24 certified copy of data available for inspection. 

25 We’ve already -- we are already submitting data in 

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1 this format. Laboratories that are certified by UL, 

2 CSA, or other recognized laboratories that -- if your 

3 lab is certified for doing UL work, meaning that you 

4 have an audit program and that you’re showing that you 

5 meet your ISO criteria, et cetera, that’s what 

6 California’s been using for their submission of data. 

7 We propose something common so we may use 

8 the same set of data, preferably. 

9 MR. RABA: Understandable. Thank you. Any 

10 other comments, please, at this time? 

11 MR. deLASKI: Andrew deLaski, Appliance 

12 Standards Awareness Project. Bob, this is a question 

13 for you. The slide there says manufacturers have 

14 observed non-compliant ballasts, and I’m wondering if 

15 you -- if the NEMA ballast section has a sense of 

16 where are those problems, you know, is it certain 

17 types of ballast? I mean, can you characterize the 

18 nature of the problems that the ballast section has 

19 observed? 

20 MR. ERHARDT: I don’t know, maybe I’ll let -

21 - actually Justin’s rather new with NEMA. I don’t 

22 know that our company has been the one bringing this 

23 to attention, but some of the NEMA companies have been 

24 bringing this up, that they’ve observed some offshore 

25 suppliers that are doing private labeling, don’t 

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1 necessarily meet the requirements that they’re 

2 claiming. But I can’t speak for my own company. I 

3 can open it up to the other NEMA company 

4 representatives. 

5 MR. RABA: And that was Bob Erhardt? 

6 MR. ERHARDT: And that was Bob Erhardt. 

7 MR. RABA: Thank you. Anybody else. Okay. 

8 MR. WALKER: All right. Great. So we’ll 

9 move on to the second section where we’ll discuss the 

10 existing test procedure, some of the comments we 

11 received on potential drawbacks. 

12 Existing procedures based heavily on 

13 ANSI82.2, the 1984 version which calculates ballast 

14 efficacy factor by first measuring ballast factor, a 

15 measure of relative light output, and dividing by the 

16 ballast input power, and multiplying by 100. In the 

17 NOPR, DOE is proposing to amend the existing test 

18 procedure by updating the ANSI reference from the 1984 

19 version of C82.2 to the 2002 version. In addition, 

20 it’s proposing to indicate particular ANSI standards 

21 for use with ballasts that operate at low or high 

22 frequency. 

23 At this time, we seek comments on the 

24 updates to the existing test procedure -- the updates 

25 -- the test procedure by updating the ANSI standards 

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1 and the appropriate use of the three standards 

2 mentioned on this slide. 

3 MR. RABA: Comments? Sir. You have 

4 comments on this? 

5 MR. THOMAS: Yes. Busy taking notes here, 

6 excuse me. Ed Thomas, GE Lighting. Yeah, we found 

7 issues with this system because it’s based upon input 

8 power for one. Lamps have variation and that 

9 variation relates to the wattage of the lamp that it’s 

10 actually going to operate at. With the efficient 

11 ballast, typically -- let’s just pick a number -- 90 

12 percent efficiency -- 90 percent of the input wattage 

13 that’s represented by the input power comes from the 

14 lamps. The ballast manufacturer has no control over 

15 that level of wattage. And so that number will vary 

16 around at the pleasure of the lamps being used in the 

17 test. And when you add to that, the errors associated 

18 with the photometric measurement, this is where we 

19 find large variations in ballast efficacy factor that 

20 can make a high performance ballast look not so good. 

21 And if one were to -- how shall I use the 

22 term -- shop for laboratories, you could find an 

23 improvement in your ratings, should you desire to do 

24 that. Not a recommended practice, but it has been 

25 heard of in the industry. So between the variations 

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1 between laboratories, variations in the lamp types, 

2 and even the skill between the different laboratories, 

3 even though the test method is defined, if you were to 

4 read through the test method, it’s not accurately 

5 defined, and there’s a lot of latitude that’s involved 

6 in the measurement. 

7 MR. RABA: Further comments? 

8 MR. ERHARDT: Yeah, Bob Erhardt, Philips 

9 Lighting and Electronics. We’d also like to comment, 

10 and when we’re talking about using ballast efficiency 

11 measurements, we currently have only developed 

12 correlations for instant start ballasts and ballasts 

13 that do filament cutout when operating at full output. 

14 ANSI test procedures for BEF will be required for 

15 rapid start and other lamp types that -- other ballast 

16 types that leave filament heating in place. 

17 There is a new version of ANSI 82.2 coming 

18 out. It is -- Ed maybe you can keep me corrected here 

19 -- but I believe it’s being voted on currently, is 

20 that right? 

21 MR. THOMAS: 82.2? 

22 MR. ERHARDT: Yes. 

23 MR. THOMAS: I believe it’s certainly in the 

24 works. I don’t know quite where it is now. 

25 MR. ERHARDT: Anyhow, we believe it’s out 

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1 for vote currently, and it’s publication will be 

2 imminent. So you may wish to consider using the 82.2, 

3 2010 I believe it would be. 

4 MR. RABA: Thank you. Anyone else please? 

5 Go ahead. 

6 MR. MCGARAGHAN: This is Mike McGaraghan on 

7 behalf of California investor-run utilities. We would 

8 generally support this shift to ballast efficiency, 

9 provided that DOE agrees with NEMA’s finding that it 

10 does decrease variation in lamp testing. But I do 

11 have a handful of questions, some of them may be best 

12 for DOE, some perhaps for NEMA. 

13 The first is if someone could provide a 

14 little more detail on the resistor bank method one 

15 used for program start ballasts. Does it capture 

16 cathode heating? The second question, does using a 

17 number of different resistors for different ballast 

18 factors accurately capture impedance in lamps? The 

19 variation of impedance? And the third question -- why 

20 don’t we start with those two? And if anyone has 

21 responses, that’d be great. And then I’ll get to the 

22 third question. 

23 MR. RABA: Restate the first question, 

24 please? 

25 MR. ERHARDT: I think I understood the 

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1 questions. First of all, I think -- 

2 MR. RABA: Bob Erhardt? 

3 MR. ERHARDT: Bob Erhardt, Philips Lighting 

4 and Electronics. I think we’ve already stated that 

5 for now we are only proposing ballast efficiency 

6 measurements for instant start ballasts and for 

7 program start ballasts that have full filament cutout 

8 at full operation, so when the filaments are not being 

9 heated. And getting back to what Ed was talking 

10 about, we are now proposing -- we have a preferred 

11 method of actually using reference lamps for doing the 

12 ballast efficiency measurement. The reason being that 

13 while, for a given ballast operating at a different 

14 power point, at a given ballast factor, a set of 

15 substitution resistors can be reasonably accurately 

16 developed, and resistors can offer some opportunity 

17 for ease of measurement. You can do just an RMS 

18 voltage across them if you know it’s a non-shifting 

19 precision resistor, for instance. 

20 However, the -- even small variations in 

21 ballast factor move the ballast away from its normal 

22 operating point when you’re using a common set of 

23 resistors for all ballasts, and it would -- we would 

24 propose that if you were to use resistors that you 

25 would at least have one for each class, which would 

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1 mean you would have to have separate resistors defined 

2 for low, medium, and high output, and maybe even 

3 further delineated because a high output ballast could 

4 be a one ballast factor, or it could be a 1.2 ballast 

5 factor, and you do start to see significant deviations 

6 from the proper operating point of the electronic 

7 ballast when you’re moving it away from its design 

8 operating point. 

9 We have found -- I’ve been in the industry 

10 28 years, we been using substitution resistors without 

11 any difficulty all along. Occasionally, you will find 

12 a ballast that operates differently on resistors than 

13 it does on lamps, and that is another factor to take 

14 into consideration. And one of the reasons why we 

15 would again propose that you look at using reference 

16 lamps to do ballast efficiency measurements, the lamp 

17 automatically compensates for the power level, and the 

18 ballast should be able to operate the lamps. There 

19 have been times when a ballast may not start properly 

20 if they’re connected with resistors, or there may 

21 other difficulties. 

22 MR. RABA: Is there any follow-on to the 

23 comments? Response. Next question? 

24 MR. MCGARAGHAN: So I just want to clarify. 

25 MR. RABA: Sure. 

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1 MR. MCGARAGHAN: NEMA’s proposing to use 

2 reference lamps. DOE has proposed to use resistors. 

3 In the DOE proposal using resistors, how do you intend 

4 to measure program start lamps without cathode cutout? 

5 MR. WALKER: I think I can answer your 

6 question. In the proposed method, a program start 

7 ballast that uses cathode cutout would have maybe just 

8 a residual amount of electroheating left. That would 

9 still be captured in an output power measurement, but 

10 it would be very similar to an instant start system. 

11 However, for a rapid start system that does 

12 include cathode heating, the heating power would be 

13 included in the output power measurement as the 

14 proposal stands at this point. 

15 MR. RABA: That was Matt Walker. Does that 

16 help your concerns? 

17 MR. MCGARAGHAN: Yes, thank you. And the 

18 last question I had was DOE indicated in the TSD, not 

19 in the test procedure NOPR, that it cannot -- it 

20 interprets -- I’m not sure if it’s referencing a 

21 statute, but it says that it cannot move away from the 

22 BEF metric, and that’s why it’s proposing BE into BEF. 

23 Can DOE provide more background on why it believe it 

24 cannot move away from BEF? 

25 MS. KOHL: I’m not sure -- this is Betsy 

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1 Kohl from DOE -- I’m not quite sure that we’re there 

2 yet, whether that was an error in the document or not. 

3 Do you have a citation you can give me and we can make 

4 sure -- 

5 MS. GRAVES: Could you speak into the 

6 microphone, please. 

7 MS. KOHL: Sorry. This is Betsy Kohl, DOE 

8 GC. And I was asking for a reference to the document 

9 where he’s looking. 

10 MR. MCGARAGHAN: On Page 221. 

11 MS. KOHL: Okay. 

12 MR. MCGARAGHAN: "Doe preliminarily 

13 determined that it cannot change their recorded metric 

14 from BEF." 

15 MS. KOHL: We will take a look at that. 

16 MR. MCGARAGHAN: The follow-on comment to 

17 that is that the California Investor-run utilities 

18 would support the transition to relative system 

19 efficiency, and believe that that could be done as a 

20 conversion from ballast efficiency to ballast efficacy 

21 factor, and then on to relative system efficiency. 

22 MR. RABA: Other comments. 

23 MR. THOMAS: Thank you. Ed Thomas, GE 

24 Lighting. I’d like to go back to the point that 

25 Matthew mentioned just a minute ago, when you 

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1 mentioned the testing of rapid start -- 

2 MS. GRAVES: Ed, we need you to speak into 

3 the microphone, please. 

4 MR. THOMAS: I’m sorry, yes. Going back to 

5 the point that Matthew mentioned about testing the 

6 rapid start systems and having the heating energy 

7 taken as part of the output. Therefore, there would 

8 be no difference in the performance level between a 

9 rapid start system that heats the lamps continuously 

10 and an instant start system that does not and 

11 transfers all of its energy to light. I can’t 

12 understand how those two would be equated. 

13 MS. GUPTA: Matthew, this is Mimi Gupta, 

14 Navigant. I think you misspoke, right. 

15 MR. MCGARAGHAN: I think I did mispeak. 

16 Thank you. 

17 MS. GUPTA: I think the cathode heating is 

18 not included in the outcome power to the lamp so a 

19 rapid start ballast would be less efficient than an 

20 instant start according to the test procedure. 

21 MR. THOMAS: Yeah, I guess the reason I 

22 raised that is I noticed how the groupings of systems 

23 were put together with rapid start grouped in the same 

24 categories as instant start. And with the power that 

25 is lost in the cathode heating, I’m just wondering how 

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1 that’s going to be rationed out, and where is that 

2 loss going to be assigned to, I guess would be the 

3 question that I actually have. 

4 MS. GUPTA: I get -- this is Mimi Gupta from 

5 Navigant Consulting. What do you mean, where would it 

6 be assigned to? You mean would the standard account 

7 for it? 

8 MR. THOMAS: More or less, yes. You have a 

9 certain amount of energy that’s in a rapid start 

10 system that would be transferred to the making of 

11 light, if you will, and there’s a certain amount of 

12 energy that’s transferred simply to heat the cathodes. 

13 Okay. That’s in a rapid start system. In an instant 

14 start system, all the energy is transferred into 

15 making light. Therefore it’s going to be more 

16 efficient system. 

17 What the present rule seems to have is a 

18 rapid start grouped in the same exact category as 

19 instant start, and I just need to understand how that 

20 can be. 

21 MS. GUPTA: Right. I think this gets to 

22 product classes, which is what we’ll discuss later 

23 this afternoon, but I think the idea is, does DOE -- 

24 DOE tries to determine whether there’s a unique 

25 utility between a T12 rap, four foot medium bi-pin rap 

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1 start system, and a T8 instant start system. And in 

2 the preliminary analysis, DOE determined there wasn’t 

3 a unique utility, so even though a rapid start system 

4 would have to expend some energy to keep those 

5 cathodes, there’s no additional utility between the 

6 two systems so that’s why they set the same standard 

7 for both and put them in the same product class. 

8 MR. ERHARDT: May I respond? 

9 MR. RABA: Yes. 

10 MR. ERHARDT: Bob Erhardt. Just a couple 

11 quick comments. One, at the risk of getting ahead 

12 into the product categories, rapid start systems fall 

13 somewhere more between instant start and program start 

14 as far as how well they treat the lamps. Before there 

15 was program start, rapid start was the preferred 

16 configuration for longer lamp life and frequent 

17 switching. 

18 I believe that Navigant answered the 

19 questions by saying that filament heating would be 

20 considered as losses in doing a ballast efficiency 

21 measurement, and I think that’s a clarification for 

22 Mr. Thomas. 

23 One small comment is that I don’t know 

24 exactly how significant it is, but filament heating 

25 will reduce cathode fall which could affect column 

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1 efficacy. It may only be on the order of one or two 

2 percent, but it’s not exactly pure losses because your 

3 cathode fall may go down a couple volts, and that 

4 could increase your column efficacy. 

5 MR. RABA: In the back, please? 

6 MR. STEPHENS: Charlie Stephens. So would 

7 that effect on the lamp cathode show up in a 

8 photometric measurement from the output from the lamp, 

9 as it’s currently -- as the test currently is done? 

10 MR. ERHARDT: Bob Erhardt. As the test is 

11 currently done, light output’s light output. So it 

12 take into account all effects and you’re looking at -- 

13 actually you’re looking at the column efficacy, and so 

14 in the current BEF, no, I guess the current BEF where 

15 you’re looking at just one portion of the two, would 

16 be very close to what Navigant has proposed. 

17 MR. STEPHENS: Okay, the reason I asked 

18 that, I think I recall something in the Federal 

19 Register Notice where there was some descriptions of 

20 this issue where it was reference to cathode heating, 

21 having an impact on the lamp efficacy and the light 

22 output of the lamp. And so the current test, if 

23 you’re measuring with a photocell, the output of the 

24 lamp, if there is an improvement in other words, of 

25 the light output of the lamp as a result of that, it 

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1 wouldn’t, as you suggested, be entirely losses. 

2 MR. RABA: Yes, Charlie Stephens. 

3 MR. STEPHENS: Charlie Stephens. 

4 MR. ERHARDT: Let me clarify. I may be 

5 back-tracking a little bit here. The column efficacy 

6 is -- there’s a -- the column discharge which is 

7 giving you light, and then there’s the cathode fall. 

8 And so the total lamp voltage, if you have a 130 volt 

9 lamp, for instance, 10-15 volts of that might be 

10 cathode fall that produces no light. It’s a power 

11 dissipation. That’s one of the -- and that is what 

12 filament heating can affect. So yes, heating the 

13 filaments can improve the efficacy -- well, can 

14 improve the efficacy of the column, but not enough to 

15 cover the losses you’re putting into the filaments by 

16 heating the filaments. 

17 I’m just saying that -- I’m getting into 

18 minutiae and perhaps we’re getting a little too 

19 detailed because I don’t think NEMA has any objection 

20 to putting rapid start with instant start for the 

21 purpose of classification. 

22 MR. RABA: I see a nodding of the head. 

23 Thank you Bob. Further comments? 

24 MS. GUPTA: Jim, can I -- 

25 MR. RABA: Mimi Gupta. 

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1 MS. GUPTA: I just wanted to ask a follow-on 

2 question, Bob. So you mentioned how there’s no 

3 ballast efficiency measurement method for rapid start 

4 that NEMA has come to a consensus on, is that correct? 

5 MR. ERHARDT: Well, we have not come to 

6 agreement on -- and I guess I read quite a bit of this 

7 document, I don’t claim to have read all of the 

8 document, and we have not come to consensus on how to 

9 treat the filament losses if we wanted to use a 

10 ballast efficiency. There have been proposals, but we 

11 haven’t done any testing to back it up, and we do have 

12 quite a bit of round robin testing and testing at 

13 certified labs, with the instant start configuration. 

14 We just have not done the diligence on the program 

15 start and the rapid start with filament heating in 

16 place. 

17 We think the Navigant proposal of including 

18 the filament heating with the losses is a good first 

19 pass approximation. We just have not done the due 

20 diligence to convince ourselves that we want to 

21 support that. 

22 MR. RABA: Thank you, Bob, very thorough. 

23 Questions to follow on? Comments? Matt? 

 24 

25 MR. WALKER: All right. This slide’s going 

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1 to hit on two of the things we just talked about, but 

2 I’ll go ahead and go through it again for 

3 completeness. At the framework document meeting, many 

4 -- DOE received many comments on potential sources of 

5 variation in the existing test procedure, both through 

6 lamp manufacturing, and differences in the measurement 

7 technique itself. As well, many commentors pointed 

8 out that the metric of BEF might have some 

9 limitations. 

10 First, for lamp manufacturing variation, 

11 some commentors indicated that ballasts tested with 

12 the reference lamp, the measured power of this 

13 reference lamp can deviate up to 2.5 percent of the 

14 rated lamp power, which then impacts the ballast input 

15 power and ultimately, BEF. 

16 Then in terms of differences in the 

17 measurement technique itself. DOE received comment 

18 that the same ballast tested at different facilities 

19 may exhibit different values of BEF. One possible 

20 source of this difference could be differences in 

21 ambient temperature from one facility to the next. A 

22 lamp is known to change its operating characteristics 

23 in response to temperature, and this can affect 

24 ballast input power, and again, ultimately BEF. 

25 Commentors also noted that to measure 

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1 ballast factor in electronic ballasts is often 

2 compared to reference circuit that operates at low 

3 frequency. DOE also received comment that lamps from 

4 different manufacturers may respond differently to 

5 this change between low and high frequency operation, 

6 which affects the consistency of the ballast factor 

7 measurement, and again, ultimately, the efficiency 

8 metric of BEF. 

9 And the finally, DOE received many comments 

10 on the fact that BEF cannot be used to directly 

11 compare ballasts that operate different total wattage 

12 loads, different wattage lamps, and different numbers 

13 of lamps. 

14 Along this same lines, several commentors 

15 suggested that the metric could be changed from BEF to 

16 an alternative, such as ballast efficiency or relative 

17 system efficacy. As we’ve described before, DOE has 

18 preliminarily setting standards in terms of BEF, but 

19 may consider alternatives. And in this proposal, DOE 

20 is proposing to measure ballast efficiency using a 

21 ballast resistor system, and then correlate this 

22 measured ballast efficiency to BEF. 

23 On this slide, DOE is just seeking comments 

24 on all aspects of the existing test procedure. I 

25 think we’ve already received a lot of comment to the 

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1 effect of this issue, but if there is any lingering 

2 thoughts? 

3 MR. ERHARDT: Bob Erhardt, Philips Lighting 

4 and Electronics. One small comment. I saw in the 

5 document, and you just said it again, BEF is related 

6 to the light output, not the power of the lamp. And 

7 so for that reason, you can conceivably use the same -

8 - you can compare BEFs for lamps with like light 

9 output, reference light output. But again, it’s -- 

10 one reason that you’re using BEF is that there is some 

11 variation in the light output of the lamp and since it 

12 is a photometric measurement, you want to be measuring 

13 the ballast, then, so you use a reference lamp and you 

14 do a comparison. 

15 But as I said in my opening comments, we 

16 agree you can use the same BEF limits for the two 

17 lamps you specified for your medium by-pin. You had a 

18 34 watt T12, and you had a 32 watt T8, but they had 

19 within a percent or so, the same lumen output. And in 

20 that case, when you’re assuming the same lamp, the 

21 same reference lamp, rating on the reference lamp, 

22 then I think it is fair to use the same metric, the 

23 same limits of BEF, when you have the same light 

24 output. It’s not power, it’s the light output. 

25 MR. RABA: Okay. 

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1 MR. HAKKAHANEN: Pekka Hakahanen, Lutron 

2 Electronics. One small comment is that while ballast 

3 efficacy factor is a photometric measurement, so is 

4 the relative system efficiency, or relative system 

5 efficacy metric, and suffers from these same problems 

6 that -- of inaccuracy that the BEF does. 

7 MR. RABA: Thanks. 

8 MR. deLASKI: Could you bring up the 

9 previous slide, please? 

10 MR. WALKER: Sure. 

11 MR. deLASKI: Andrew deLaski, Appliance 

12 Standards Awareness Project. In your last step, 

13 there, your last bullet here, to ... BE to BEF, so 

14 what’s the purpose of that step? 

15 MR. WALKER: I guess the purpose is to -- I 

16 feel like I’m saying the same thing -- the goal is to 

17 set standards in terms of BEF, so in order to reach 

18 that BEF value that we can set standards on, the 

19 measured efficiency metric needs to be correlated to a 

20 different number. Is that answering your question? 

21 MR. deLASKIV: Let’s hear what Bob has to 

22 say. 

23 MR. ERHARDT: This was NEMA’s proposal and 

24 in principle, the light output is proportional, at 

25 least to a first order approximation, to the output 

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1 power for an instant start system, and that’s why we 

2 have some -- we haven’t come to agreement yet on what 

3 to do when you’re still heating the filaments. But 

4 for an instant start system, the column power is 

5 almost directly proportional to the output power. So 

6 if you’re measuring ballast efficiency for an instant 

7 start system, and you’re measuring the output power 

8 over the input power, you’re measuring a parameter 

9 that has, we feel, a direct correlation to light 

10 output. Output power has a direct correlation to 

11 light output. 

12 And so that’s why we feel you can develop a 

13 correlation between BEF, which is a relative light 

14 output, and it’s the BF is the light output of the 

15 ballast over the reference light output. It’s a 

16 number. But again, it’s light output that you’re 

17 talking about. And output power has a correlation to 

18 light output, so you can develop a correlation -- if 

19 you agree that output power is proportional to light 

20 output, and that’s what our testing -- you know, we’ve 

21 done testing to show this -- then you can use a 

22 mathematical formula for a given lamp type, after 

23 you’ve developed -- after you’ve developed a lumens 

24 per watt, if you will, for a lamp, then you can just 

25 take that -- you can take that number and put it into 

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1 your output watts over input watts formula, and get 

2 light output over input watts, which is BEF. 

3 MR. deLASKI: Okay. 

4 MR. RABA: You look puzzled. 

5 MR. deLASKI: It’s okay. 

6 MR. ERHARDT: I have been accused of being 

7 over-detailed. 

8 MR. RABA: Thank you, Bob. We’ll study it 

9 later. The record. Thank you very much. Comment 

10 there, please? 

11 MR. MCGARAGHAN: Mike McGaraghan, California 

12 utilities. I just wanted to respond to the gentleman 

13 from Lutron, I’m sorry I missed his name. 

14 MR. RABA: Pekka. 

15 MR. MCGARAGHAN: Pekka. Mentioned a minute 

16 ago that RSE, relative system efficiency, would have 

17 the same negative aspects as ballast efficacy factor 

18 because it’s based on lumen output. But I just want 

19 to make sure -- my understanding is if you can 

20 correlate ballast efficiency to ballast efficacy 

21 factor with this set of mathematical equations, that 

22 you could do the same thing from ballast efficiency to 

23 relative system efficiency. And the benefit of 

24 relative system efficiency is that you can -- or one 

25 benefit -- is that you can compare ballasts operating 

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1 different numbers of lamps. So instead of 70 product 

2 classes, by my count, we’d be down to 18 or 20, I 

3 forget which. 

4 MR. RABA: Thank you. Yes, please. 

5 MR. HAKKAHANEN: Pekka Hakahanen, Lutron. 

6 Agree with your last comment. I just wanted to point 

7 out that the -- if it’s used in the form of 

8 photometric measurements, then it has the same 

9 problems. If we start with ballast efficiency, and 

10 then move to whichever metric, we avoid the problems. 

11 MR. RABA: Bob? 

12 MR. ERHARDT: This is Bob Erhardt. Just a 

13 couple of comments. One, yes, RSE does make -- give a 

14 set of numbers that are easier to understand. When 

15 you’re comparing for the same lamp, an RSE gives -- 

16 and you have different numbers of lamps, agreed, it 

17 gives you an indication of the efficiency of the 

18 ballast. 

19 Whether you can take the 40-odd number of 

20 medium by-pin categories and put them into -- cut them 

21 by a factor of 12 or more, you have to recognize that 

22 they have -- we have recognized that there are -- that 

23 high power ballasts are more efficient than low power 

24 ballasts, and Navigant has made a recommendation, and 

25 DOE has it in the preliminary analysis that the -- you 

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1 would effectively have a higher RSE - a lower RSE 

2 allowance for a one-lamp low power ballast, than you 

3 would a four-lamp high power ballast, because there 

4 are formulas for taking into account the relative 

5 efficiencies of different categories of ballasts. 

6 And the other issue with RSE. I think if it 

7 wasn’t for the T8 lamp being a 60 hertz referenced 

8 lamp, and that at high frequency it doesn’t run at 32 

9 watts, I think NEMA would be more open to RSE. But 

10 RSE gets a little confusing because it takes the rated 

11 lamp power and puts it into the equation. And for a 

12 T5 lamp, for instance, where the rated lamp power is 

13 at a ballast factor of one; for a T8 lamp, the rated 

14 light output with a ballast factor of one does not 

15 occur at 32 watts. So it still is not -- for 

16 differing lamp types, it’s still not -- it’s still not 

17 a direct reference. 

18 MR. RABA: Are you okay? 

19 MR. ERHARDT: Am I saying too much again? 

20 MR. RABA: No, you’re fine. Fine. Just 

21 want to make sure that we cover it so if there’s any 

22 more to draw out we can do that. Further comments, 

23 questions? Follow-on? Matt. 

24 TEST PROCEDURE: ALTERNATIVE METHODS 

25 MR. WALKER: Right. Matthew Walker. As a 

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1 follow-on to this discussion, DOE did then begin to 

2 consider some alternative methods after receiving 

3 comments that the existing test procedure may have 

4 some deficiencies. Before looking at alternative 

5 metrics, DOE looked at improving the variation and the 

6 existing lineup of base method by looking at the 

7 particular specifications within this method. 

8 DOE believes that some of the variation in 

9 the ANSI-based light output base test procedure can be 

10 reduced by further specifying some key factors. The 

11 first would be to reduce the tolerance on lamp 

12 measured power for a reference lamp, from plus or 

13 minus 2.5 percent of rated wattage, to plus or minus 

14 one percent. 

15 Next, the tolerance on testing facility 

16 ambient temperature can be reduced from plus or minus 

17 one degree Celsius to plus or minus half a degree 

18 Celsius, from 25. 

19 The next three bullets provide some 

20 additional clarification on the ballast factor 

21 measurement. DOE could specify that a reference lamp 

22 be operated at constant voltage, that electric heating 

23 be used in the reference circuit for the purpose of 

24 ballast factor measurement, for ballasts of all 

25 starting methods that operate medium bi-pin, miniature 

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1 bi-pin, or recessed double-contact lamps. And finally 

2 for ballast factor measurement, DOE could specify that 

3 light output measurements be used for ballasts of all 

4 starting methods. 

5 And finally, in a improved light output6 based method, DOE would specify the type of lamp to be 

7 the most common wattage lamp and that the ballast 

8 operate the maximum it’s capable of operating for 

9 testing. 

10 So like any method, it has potential 

11 advantages and disadvantages. The procedure would be 

12 familiar to industry. The ballast does operate its 

13 natural load, such that measurements of its 

14 performance do reflect how it’s actually used in 

15 practice. And DOE does expect that measurement 

16 variation would be reduced by tightening these 

17 tolerances. 

18 However, the tighter tolerances will come 

19 with additional burden to those who are required to 

20 perform the testing, and the effects of lamp 

21 manufacturing variation are not eliminated through 

22 these improvements. 

23 So at this time we could maybe have a few 

24 comments on this improved light output-based test 

25 procedure as an alternative to the existing method? 

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1 MR. STEPHENS: Charlie Stephens. Could you 

2 go back to a previous slide. I’m getting lost in the 

3 terminology here a little bit. The second to last 

4 bullet down there, ballast factor. Do you literally 

5 mean "ballast factor" there? 

6 MR. WALKER: I do. 

7 MR. STEPHENS: Okay. 

8 MR. WALKER: Maybe I can just provide a 

9 little more context? 

10 MR. STEPHENS: Yeah, a little more 

11 explanation of that. 

12 MR. WALKER: You’re talking of this one 

13 here? 

14 MR. STEPHENS: Yes, what are you speaking to 

15 there? 

16 MR. WALKER: Right. In the 2002 version of 

17 ANSI C82.2, it specifies that light output 

18 measurements can be used for measuring the reference 

19 system and your ballast of interest for rapid start 

20 and program start ballast, whereas a power measurement 

21 can be used for instant start systems. And I guess 

22 earlier in this rulemaking process, DOE came under the 

23 understanding that it was industry practice to use 

24 light output measurements for ballasts of all starting 

25 methods. So this is an attempt to synchronize with 

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1 industry practice and to make sure things are 

2 consistent across all test facilities. Does that 

3 help? 

4 MR. STEPHENS: Yes. When people use the 

5 term "ballast factor" I’m -- I’m used to thinking of 

6 .88 and 1.0 and 1.2 as those numbers. So is that what 

7 you’re speaking about in that -- 

8 MR. WALKER: That is what we’re speaking 

9 about. 

10 MR. STEPHENS: So you’re using the light 

11 output essentially to determine that number? 

12 MR. WALKER: Right. 

13 MR. STEPHENS: Okay. Thank you. 

14 MR. THOMAS: Ed Thomas, GE Lighting. Just 

15 wanted to make a quick comment about the temperature 

16 control characteristics that you mentioned. 

17 Controlling a large photometric laboratory to within 

18 one half of a degree C is a pretty daunting task, with 

19 people and activities going on in a laboratory and 

20 trying to maintain that type of temperature would be 

21 somewhat of a burden, not only on my lab, but I guess 

22 on everybody else’s lab too. Would be resulting in 

23 upgrades of air conditioning, air handling controls, 

24 so there would be some cost associated with that, 

25 certainly. 

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1 MR. PARISELLA: This is Joe Parisella from 

2 Osram Sylvania. I would also say from a practical 

3 standpoint, normally the test laboratories, as opposed 

4 to the design laboratories, normally efficiency 

5 measurements are taken very frequently in the design 

6 laboratories, whereas there would have to be some 

7 correlation factor that the designers would have to 

8 use, or the manufacturing facilities would have to 

9 use, because using photometric measurements would be 

10 very time consuming and have to be some correlation 

11 there anyway. So I just wanted to point that out that 

12 traditionally in design laboratories efficiency 

13 measurements are very commonly taken. 

14 MR. ERHARDT: Just a short answer -- Bob 

15 Erhardt, Philips Lighting and Electronics. I think we 

16 would agree that tightening the tolerances on the 

17 reference lamp and the temperature would improve the 

18 accuracy of BEF. Holding temperature to within plus 

19 or minus half a degree would likely require some 

20 specialized equipment. You might have to have some 

21 type of test box or something. 

22 Also, I don’t know what the impact would be 

23 of requiring that plus/minus one percent tolerance on 

24 the lamp power. As it is, we don’t just pick up the 

25 phone and order a box of reference lamps. We order 

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1 boxes of lamps and test and test and test until we get 

2 a collection of reference lamps. Those reference 

3 lamps also only tend to remain reference lamps for a 

4 while, and then you test and test and test multiple 

5 boxes of lamps until you have reference lamps again. 

6 So that would of course increase the difficulty of 

7 keeping a cache of reference lamps. I think we can 

8 take it under consideration, but it’s practical to try 

9 to take that to one percent. 

10 MR. RABA: Good comments. Any further? 

11 MR. WALKER: All right. Matthew Walker 

12 again. So after looking at improving the light 

13 output-based method, DOE then began to consider 

14 alternative metrics that it could correlate back to 

15 BEF. As we’ve talked about already today and Ed 

16 presented on earlier, a NEMA ballast technical 

17 committee has drafted a test procedure that measures 

18 ballast efficiency with a lamp and ballast system. In 

19 general, the lamp and ballast system is energized, 

20 output power and input power are measured while the 

21 system is at steady state. Ballast efficiency would 

22 then be calculated as output power divided by input 

23 power. And then DOE currently would plan to convert 

24 this ballast efficiency to BEF using a transfer 

25 equation. 

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1 So again, we’ve already kind of heard this 

2 directly, but some advantages to the method are that 

3 it does accurately characterize the real life 

4 operating conditions of the system, particularly in 

5 comparison to a ballast and resistor system. The lamp 

6 is a dynamic load and is able to respond accurately to 

7 a different ballast factor, again in contrast to a 

8 resistor, which is specifically matched to one lamp 

9 impedance. 

10 And the calculation of ballast efficiency 

11 makes the method less sensitive to lamp power and 

12 environmental conditions because these variations 

13 impact both the input power and the output power, and 

14 the calculation of ballast efficiency tends to 

15 minimize these effects. A lamp is still involved in 

16 the system, so there may be some variation from lamp 

17 to lamp, so it may still be an issue. 

18 We’ve already talked about this method quite 

19 a bit, but if there are any additional comments on the 

20 lamp-based ballast efficiency method correlated to 

21 BEF, this is a good time to air some of those. 

22 MR. THOMAS: Ed Thomas, GE Lighting. I’d 

23 just like to point out that where you listed as 

24 potential disadvantages, lamp to lamp variation is not 

25 so much of an issue because any changes in the lamp 

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1 operating conditions aren’t going to be a ratiometric 

2 change that would be in the ratio for ballast output 

3 power divided by ballast input power. So if the lamp 

4 should run slightly higher in energy or slightly lower 

5 in energy due to design variation, manufacturing 

6 variation, it will still come out in the ratio as not 

7 really having a very large effect on the measured 

8 electrical efficiency of the system. 

9 MR. WALKER: Okay. Thanks. 

10 MR. RABA: Charlie? 

11 MR. STEPHENS: Charlie Stephens. As a 

12 follow-up to that, and I assume then that the 

13 reference lamp becomes not dependent at all on light 

14 output. It’s essentially taken into account. Would 

15 you still need a reference lamp? 

16 MR. THOMAS: Ed Thomas, GE. You would need 

17 a reference lamp only in terms of electrical 

18 characteristics. Reference lamps right now are 

19 defined primarily as electrical operating point under 

20 a given set of conditions on the lamp. There’s no 

21 representation of what the particular luminous output 

22 must be, at least in terms of an absolute scale. So, 

23 in this case, if you’re using the lamps strictly as 

24 electrical load, you’d just be using it as such, as an 

25 electrical load. 

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1 MR. RABA: Additional? 

2 MR. ERHARDT: Yeah, this is Bob Erhardt. 

3 Again, the use of the reference lamp is to keep it -- 

4 to keep the ballast at or near its design operating 

5 point. It’s, you know, the differences are minimized, 

6 but if you had a lamp that was running -- if they were 

7 five percent higher power, then your ballast would be 

8 at a different operating point than it was designed 

9 for. Now, the -- by taking an efficiency measurement, 

10 you are minimizing that effect, but by keeping -- the 

11 point of the reference lamp is to keep the ballast 

12 operating as close as possible, as practicable, to its 

13 design operating point. 

14 MR. RABA: I see heads nodding. Any others 

15 please? 

16 MR. WALKER: I’d like to ask a follow-on. 

17 This is Matthew Walker from Navigant. Does anyone, 

18 particularly NEMA, have suggestions or ideas on a 

19 correlation method between the lamp-based BE and BEF? 

20 In the proposed method, we measure both metrics, and 

21 find a correlation between the two using a line of 

22 best fit. Does that seem like a reasonable approach? 

23 MR. ERHARDT: NEMA -- the NEMA ballast 

24 companies -- sorry, Bob Erhardt, Philips Lighting and 

25 Electronics. The NEMA ballast sections approach had 

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1 been -- we had intended to bring in the lamp section 

2 and try to get an industry consensus, however, we do 

3 agree that if you have a set of certified data points, 

4 and we have done some round robin testing of -- at 

5 different certified labs, for the purpose of DOE 

6 rulemaking, we think the DOE could adopt something if 

7 we cannot get agreement with the lamp section in time. 

8 We think that’s quite reasonable. 

9 I’ll also comment that, similarly, while 

10 NEMA from an academic and standards point of view 

11 hasn’t agreed on the efficiency method for program 

12 start and rapid start, for the purpose of DOE 

13 rulemaking, I think you could make an assumption that 

14 filament heating is part of losses and we would take 

15 that into account when we discuss what the BEF levels 

16 should be. 

17 MR. THOMAS: Ed Thomas, GE Lighting. 

18 Earlier, in my presentation, there was a plot that 

19 showed a relationship between ballast efficiency and 

20 ballast efficacy factor. Again, based upon the data 

21 that Bob had mentioned. We had done some work like 

22 that and responding is a line of a best fit is 

23 probably an acceptable method at this time. As Bob 

24 mentioned as well, we’d like to get cooperation of the 

25 lamp companies to look at the transfer function that 

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1 we’re thinking about, and certainly we think that 

2 there would be one transfer function that would relate 

3 to instant start and full cathode cut systems, and 

4 other transfer functions would relate to systems that 

5 utilize some level of continuous cathode heating. So 

6 I don’t think it’s one transfer function. It could be 

7 a couple. In my presentation, I alluded to roughly 

8 two different transfer functions, just based on 

9 preliminary data that I had. 

10 MR. RABA: Thank you. Matt. 

11 MR. WALKER: All right. The final 

12 alternative that DOE considered was relative system 

13 efficacy, which has already come up today. Just to 

14 summarize again, RSE does use the same test method or 

15 could use the same test method as the existing test 

16 procedure. They also discussed that it could be an 

17 output of a transfer equation, if you measure 

18 something else, not just ballast efficiency. RSE then 

19 normalizes the BEF for ballast of different total 

20 rated lamp power or ballast loads of different total 

21 rated lamp power. 

22 You can see on the slide, RSE is then equal 

23 to BEF divided by 100 times total rated lamp power. 

24 Some advantages, as we’ve discussed, is that 

25 RSE could be potentially more comparable across 

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1 different ballast types in comparison to a BEF metric. 

2 It does use a familiar test procedure. I guess in 

3 this NOPR, DOE found that because RSE is, if you 

4 measure it directly using the BEF measurement 

5 technique, it’s based on the same varied inputs and 

6 doesn’t provide improvement in measurement variation, 

7 which was one of the main goals of this revision. 

8 So at this time we have a moment for 

9 additional comments on relative system efficacy. 

10 MR. RABA: State your name, please? 

11 MR. deLASKI: Andy deLaski, Appliance 

12 Awareness Project. Is this what you -- the 

13 methodology that you propose to use for RSE or a 

14 different methodology? 

 15 

16 MR. MCGARAGHAN: Mike McGaraghan, California 

17 utilities. I think Matt just addressed my concern 

18 that I raised earlier, or my suggestion was using RSE 

19 based on a set of transfer values from ballast 

20 efficiency, rather than using it based purely on BEF 

21 or photometric measurements. So the disadvantages 

22 shown there on the slide would not apply to the RSE 

23 proposal I made, and I think Matt acknowledges that. 

24 MR. deLASKI: Thanks. 

25 MR. RABA: Further? 

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1 MS. GUPTA: I’d like to ask a question. 

2 Mimi Gupta, Navigant. So is there an advantage to 

3 using RSE -- like if DOE were to use RSE as the 

4 metric, it would be changing the metric. Is there an 

5 advantage to using RSE over ballast efficiency? 

6 MR. MCGARAGHAN: This is Mike on behalf of 

7 the California utilities. The main problem that we 

8 see with either BEF or BE that has -- without some 

9 sort of normalization based on total rated lamp power, 

10 is it’s hard to compare, and in the marketplace, I 

11 think you’ll see an increased -- people will be able 

12 to take advantage of more efficient ballasts in their 

13 system designs. If you’re comparing a two lamp system 

14 to a three lamp system, you don’t know which ballast 

15 is more efficient, and in many circumstances, you 

16 could specify either that two lamp system or that 

17 three lamp system. So it would just be an extra tool 

18 for specifiers of lighting projects to take advantage 

19 of all the savings potential on the table. 

20 MR. RABA: Thank you. Mike, does that help? 

21 Head nod. Others? 

22 MR. ERHARDT: Yeah, I’ll just reiterate my 

23 comment and -- Bob Erhardt, Philips Electronics. I 

24 agree, RSE for a lamp type does make the numbers much 

25 easier to understand. The area where you need to be 

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1 careful is that if you’re going to -- if consumers are 

2 going to be comparing a T8 system with a T5 system, 

3 for instance, then they’re going to be misled by an 

4 RSE number, unless you have a good, high frequency 

5 power number for the T8. Because the T8 is -- T8 

6 lamps have high frequency, don’t have a ballast factor 

7 of one at 32 watts. They have a ballast factor of one 

8 at, I don’t know what the number is, 28 or something 

9 like that. 

10 And so if you’re comparing -- this is a 

11 legacy we have of the switch from 60 hertz systems to 

12 high frequency systems. All the new systems, T5, 

13 CFOs, et cetera, are referenced on a high frequency 

14 reference ballast. They already take into account the 

15 efficacy gains in the lamp at high frequency. The T8 

16 lamp is a old legacy, 60 hertz system, that -- it’s 32 

17 watt power rating is at 60 hertz, and it does not show 

18 the benefit of operating at the high frequency. So if 

19 you start dividing everything by 32 watts for a T8, 

20 and everything by 28 for T5, the T8s are going to look 

21 pretty bad. Much worse than they are. 

22 MR. deLASKI: Follow up for Bob. This is 

23 Andrew from Appliance Standards Awareness Project. So 

24 in your example here, comparing a T5 system to a T8 

25 system, does BEF or BE give you comparable metrics? 

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1 Metrics that enable a consumer to compare one with the 

2 other? 

3 MR. ERHARDT: Only when the lamp lumen 

4 outputs are the same. 

5 MR. deLASKI: Right. Okay. 

6 MR. ERHARDT: Now, I don’t have the 28 watt 

7 T5 memorized right now. I think they’re pretty close, 

8 so that might actually be closer. And actually, Mark 

9 Duffy, do you know off hand the lumen output rating of 

10 a T8 versus a T5? 

11 MR. DUFFY: Yeah, a 28 watt -- 

12 MR. RABA: Speak up please -- use the 

13 microphone up there if you would so we can all hear. 

14 State your name, please? 

15 MR. DUFFY: Yeah, Mark Duffy with GE 

16 Lighting. I’ve been asked to comment on the lumen 

17 output of a 28 watt T5 lamp that’s rated at 2800 

18 lumens, and for an F32 T8, depending on the type, you 

19 can have something on the order of 2950 lumens for the 

20 highest output types. 

21 MR. RABA: Okay. Thank you. Does that 

22 help, Andrew? 

23 MR. deLASKI: Sure. Thank you. 

24 MR. ERHARDT: Bob Erhardt. I think a 

25 summary of that would be that BEF might be closer in 

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1 that case, but still wouldn’t be accurate, because of 

2 the 2800 to 2900 lumen difference. So the -- you 

3 would expect the BEFs to vary by the ratio of those 

4 light output ratings. For similar systems, for 

5 similar efficaciousness. 

6 MR. deLASKI: Right. But if I could 

7 summarize, it seems to me that the disadvantages -- I 

8 mean there’s no approach that solves that particular 

9 problem of being able to compare your T5s to your T8 

10 system. There’s no metric that’s going to solve that 

11 particular problem, other than having -- the higher 

12 level of capacity --- 

13 MR. ERHARDT: Well ballast efficiency is a 

14 metric of the efficiency of the ballast, so we feel 

15 ballast efficiency is a better metric of comparing all 

16 systems, because that’s what we do. We can only work 

17 on the efficiency of the ballast. We’re not really 

18 affecting the -- well, filament heating, of course, is 

19 going to be affecting the efficiency -- efficacy of 

20 the lamp, if you will. But that’s one reason we’re 

21 proposing ballast efficiency, because ballast 

22 efficiency is the metric that rates the -- how energy 

23 frugal your ballast is, if you will. I mean it’s the 

24 energy efficiency of the ballast. Ballast efficiency. 

25 The second effect is of course the filament 

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1 heat. Filament heat on a -- if you’re providing 

2 filament heat, you’re providing extra losses. 

3 Navigant has proposed that you include those in the 

4 overall losses when you specify an efficiency. That 

5 is an approach to consider, as long as you recognize 

6 that systems that do program start are generally 

7 specified for lighting systems where you’ll have 

8 occupancy sensing with frequent switchings, which will 

9 save significant energy. So as long as you take these 

10 factors into account when you’re setting your 

11 requirements, it can be a good indication of the 

12 overall efficiency of the system, if you just put the 

13 filament losses in with the overall losses, and use 

14 efficiency as a metric. 

15 MR. RABA: I saw three hands go up. First, 

16 Charlie, then the back, young lady, and the gentleman 

17 up there too. Charlie. 

18 MR. STEPHENS: Charlie Stephens, Northwest 

19 Energy Efficiency Alliance. I just wanted to throw in 

20 too here, that the utility of RSE can kind of lose 

21 itself if you’re actually doing lighting design 

22 anyway. I mean you start getting into room cavity 

23 ratio, the fixture efficiency, fixture spacing, the 

24 requirements on the desk, you know, 55 lumens on the 

25 desk -- I mean you have to -- once you get into that, 

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1 you need so many lumens and you need it this many feet 

2 off the desk, and you start taking those into account. 

3 You’re not picking the fixture and the ballast and the 

4 lamp combination for its most efficient combination. 

5 You’re picking it, potentially, because you need that 

6 many lumens spaced at that many feet apart, this many 

7 feet above the desk. And you need this many of them 

8 in this room to provide the illumination after X 

9 number of hours of lamp degradation and everything. I 

10 mean there’s all these factors that go into this 

11 stuff. And in the end, you’re not really picking 

12 these things on just a one or two percent difference 

13 in a ballast efficiency. You’re picking a system, 

14 quite frankly, and so I’m not sure the RSE is going to 

15 be of that much utility to a lighting designer, in the 

16 end, compared to these other methods. 

17 MR. ERHARDT: Yeah, I guess -- commenting on 

18 that, for a lighting designer, you may very well be 

19 right, the BEF is maybe the better utility because he 

20 is picking a lamp for its lumens and BEF takes the 

21 ballast factor, which again, tells him his lumens, and 

22 then BEF tells him how much power he’s going to have 

23 based on the lumens he’s chosen. And if he had RSE, 

24 he’d have to do an extra conversion. 

25 MR. RABA: Saw a head nod there. In the 

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1 back, please. Comments, questions? Covered? 

2 PARTICIPANT: Yes, basically. 

3 MS. GUPTA: I have one follow-up. Mimi 

4 Gupta from Navigant. Just a quick follow-up question. 

5 So, in talking about metrics and comparability across 

6 different ballast types, is -- using ballast 

7 efficiency, could you compare a two-lamp ballast to a 

8 four-lamp ballast? 

9 MR. THOMAS: Ed Thomas, GE. Yes, you can 

10 because the ballast efficiency is going to give you a 

11 number, like say, 90 percent or 92 percent, and that 

12 will enable you to understand which ballast is a 

13 higher performance ballast. Now, to this gentleman’s 

14 -- to Charlie’s point -- yeah, when you couple this 

15 with a fixture and with a certain set of lamps, then 

16 the system becomes more complicated, but we’re -- 

17 we’re a couple steps back from that approach. We’re 

18 at the approach where the OEM manufacturer is deciding 

19 what product to put within the fixture or the ability 

20 for people to say, I want a more energy efficient 

21 product. I want to reduce the loads on my HVAC, and I 

22 want to make sure that I’m getting -- and energy cost 

23 is going to be the greatest percentage of the cost of 

24 ownership. So a ballast that will run cooler is more 

25 efficient, has less losses, can be expressed by 92 

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1 percent or some number that expresses the performance 

2 of that ballast, notwithstanding other circumstances 

3 in the system. 

4 All the measurements that we’ve talked about 

5 beforehand are all system-based measurements and 

6 interdependencies with ballast efficiency, you have 

7 the measurement of the ballast itself, then you 

8 combine your system from that point. 

9 MR. ERHARDT: Just a small comment -- Bob 

10 Erhardt, Philips Lighting and Electronics. Just a 

11 small comment and that is, from what I read of the 

12 intent of the DOE to go to the max tech approach in 

13 setting its guidelines, then you’re not going to have 

14 much difference in efficiency -- ballast efficiencies 

15 to be comparing for a given category. If you choose 

16 your, even your CSL2 levels, that’s pretty much going 

17 to correlate to our NEMA premium products and there’s 

18 not a lot of ballast efficiency left. 

19 If you consider a full range of possible 

20 ballast efficiencies, might be 85 to 91, 92 or so, but 

21 that’s really pushing it, you know, our NEMA premium 

22 comes in around 90, and there’s not a lot of variation 

23 once you start specifying a ballast efficiency of 89 

24 or 90. There’s just not that much there any more. 

25 MR. RABA: Okay. 

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1 MR. MCGARAGHAN: Mike McGaraghan, California 

2 utilities. I just wanted to respond to Charlie and 

3 others. I agree that a lighting designer with some 

4 degree of expertise is not picking ballasts based on 

5 RSE or the efficiency value of the ballast. They’re 

6 going to design a system, but I think there is a wide 

7 range of expertise in practice, and I think that’s 

8 actually something that will come up later when we 

9 discuss standards. I know in the lamp rule, DOE 

10 assumed different scenarios for level of expertise. 

11 High level of expertise and none, no expertise in 

12 lighting designer and retrofit situations. So that’s 

13 a question that I’ll bring up later for DOE to see 

14 kind of how they’re interpreting that for this rule. 

15 But certainly some retrofit situations and some design 

16 situations happen with less than optimal expertise., 

17 and that would be an advantage for RSE to help 

18 simplify it. 

19 MR. RABA: Matt? 

20 MR. WALKER: All right. This actually wraps 

21 up the discussion of alternative methods, and it might 

22 be a good time for a break. 

23 MR. RABA: Sounds good to me. Ready for a 

24 break? I think it’s a good time. You’ve done very 

25 well so far. We’ll take a 15-minute break right now. 

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1 Come back at, I don’t know, let’s make it on the hour. 

2 (Whereupon, a 19-minute recess off the 

3 record was taken.) 

4 MR. RABA: Welcome back. Okay, Matt, you 

5 want to start on the proposed procedures, that right? 

6 MR. WALKER: Sure thing. 

7 MR. RABA: Okay. 

8 TEST PROCEDURE: PROPOSED METHOD 

9 MR. WALKER: All right, the remainder of the 

10 morning we’ll discuss the proposal in the NOPR for the 

11 test procedure. 

12 So in 2008, DOE did have a chance to 

13 participate in the NEMA ballast committee’s round 

14 robin and its investigation of the resistor-based 

15 ballast efficiency method. In the proposal, DOE does 

16 proposed this ballast efficiency measurement, using a 

17 ballast and resistor system. 

18 The next few slides describe some of the 

19 measurements and techniques in more detail, but in 

20 general ballast input power and output power are 

21 measured, using a ballast and resistor system. 

22 Ballast factor is then measured using a lamp and 

23 ballast system so that the appropriate transfer 

24 equation can be selected. And then BEF is calculated 

25 from BE, using this transfer equation. 

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1 At the bottom of this slide, there’s a 

2 diagram that shows just what a resistor load bank 

3 might look like, or does look like. In the middle, 

4 you see a single resistor to the lamp arc. Then the 

5 remaining four resistors are for the electrodes. Each 

6 of these electrode resistors are assigned an 

7 equivalent resistance equal to half that one of lamp 

8 electrode. By assigning equivalent resistance to each 

9 of these electrode resistors, DOE is modeling the lamp 

10 arc traveling from the center of one lamp electrode to 

11 the center of the other. 

12 But to determine the actual resistance for 

13 each of these physical resistors, DOE used a 

14 combination of ANSI standard C78.81, 2005, as well as 

15 some empirical methods. C78.81 provides electrode 

16 resistance for all lamps while operating at any 

17 frequency, and then it provides select lamp arc 

18 resistances for certain operating frequencies. 

19 And this is sort of the legacy thing that 

20 Bob was alluding to earlier. So in the case that a 

21 lamp arc resistance was unavailable, for example, high 

22 frequency operation of a four-foot medium bi-pin T8 

23 lamp, DOE then needed to measure this lamp arc 

24 resistance empirically. 

25 So we mentioned before that a resistor can 

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1 only simulate a lamp while being operated at a 

2 particular ballast factor, however, a lamp can be 

3 driven at many different ballast factors, and can 

4 change impedance in response to this. The lamp 

5 impedance tends to decrease as ballast factor gets 

6 higher and higher. 

7 So rather than specify multiple ballast 

8 factors, specific resistors, in the NOPR DOE proposes 

9 to use a single resistor for testing a ballast of all 

10 ballast factor. During testing DOE found that when a 

11 ballast is tested with a resistor that does not 

12 exactly match its ballast factor, the measured ballast 

13 efficiency is different than if it’s tested with the 

14 appropriate resistor, or with a resistor that does 

15 exactly match the ballast factor. 

16 So to account for this change or this 

17 effect, DOE specifies multiple transfer equations, 

18 each one specific to a particular ballast factor bin. 

19 And DOE took this approach with the effort of reducing 

20 the testing burden by only requiring one resistor load 

21 bank per lamp. 

22 This time we have a moment for comments on 

23 the use of a ballast factor measurement for 

24 determining the appropriate transfer equation, as well 

25 as the effect of using a single resistor value for 

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1 measuring ballast efficiency of multiple ballast 

2 factor ballasts. 

3 MR. PARISELLA: This is Joe Parisella from 

4 Osram Sylvania. I think we’ve touched on this 

5 already, but one of the biggest issues is using that 

6 single resistor is that you are talking about having a 

7 scaling factor, but different ballasts will react 

8 differently. So if you have a single resistor, 

9 certain ballasts, the scaling factors are going to 

10 have to be different for different types of ballasts, 

11 and I think different ballasts will react differently 

12 to that same resistor value. Do depending on the 

13 circuitry and the way it’s tuned and things like that, 

14 so I think that could be an issue with that. 

15 MR. RABA: Thank you. 

16 MR. THOMAS: Ed Thomas, GE. I would just 

17 like to point out that ballasts are primarily designed 

18 to operate lamps, and it may not -- may not provide 

19 the same level of performance on a resistor as they 

20 would on a lamp. 

21 MR. RABA: Okay. Thoughts? Comments? All 

22 right. 

23 MR. WALKER: All right. We’ll move on. 

24 This slide provides a little more detail on the 

25 measurements included in the proposed method. First 

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1 for ballast efficiency, the electrical measurements 

2 are taken within one minute of energizing the ballast. 

3 These measurements include input voltage, current, 

4 power, as well as output power. In the proposal DOE 

5 specifies that ballast capable of operating at 

6 multiple input voltages should be tested at 277 volts 

7 for a commercial ballast, and then 120 volts for a 

8 residential and cold temperature sign ballast. 

9 Then for ballast factor, in the proposal DOE 

10 indicates ballast factors should be measured according 

11 to ANSI82.2, the 2002 version. And that includes some 

12 of the amendments discussed in the improved light 

13 output base method, those being the additional 

14 specifications, and just sort of clarifications on how 

15 ballast factor can be measured to make things 

16 consistent from one facility to the next, as well as 

17 to specify that a ballast be operated -- operate lamps 

18 of a particular wattage, this being the most common 

19 wattage lamp and the maximum number of lamps the 

20 ballast was designed to operate. Nd the test 

21 procedure. 

22 DOE does specify what this most common 

23 wattage is, so that there is clarity on that issue. 

24 So you have any comments on the test 

25 measurements? 

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1 MR. THOMAS: Yes, Ed Thomas, GE. I’d like 

2 to point out that when you’re taking electrical 

3 measurements within one minute, the ballast has not 

4 reached an optimal operating temperature. When 

5 ballasts are designed for an application, the 

6 application is typically a steady state application 

7 where certain electronic components achieve a rate of 

8 electrical efficiency that would be more 

9 representative of how they will operated during the 

10 long duration of operation. Certain diodes and 

11 certain magnetic materials actually become more 

12 efficient actually after they’ve had a time to reach 

13 the operating temperature that the ballast will be 

14 designed for. 

15 Taking the measurement within one minute may 

16 not present the ballast in its true level of 

17 performance, compared to a measurement taken after 

18 some period of time, after these components have 

19 reached some thermal operating point or thermal 

20 equilibrium, as they would see in your normal 

21 application. 

22 MR. RABA: Thank you, good information. 

23 MS. GUPTA: Mimi Gupta, Navigant Consulting. 

24 So, Ed, would you suggest that DOE amend this to say 

25 the measurement should be taken after some minimum 

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1 period of time? and what would that minimum be? 

2 MR. THOMAS: Ed Thomas. In the NEMA 

3 discussion that were presented, we talk about the 

4 stability of measurement anywhere between a time 

5 period of 15 minutes to within an hour, but it was 

6 talking about an overall system stability, which is 

7 the ideal characteristic. If I use this room as an 

8 example, the lights went on here probably six o’clock 

9 in the morning. By 11:30 now, they’ve reached, 

10 certainly reached a steady state equilibrium, and 

11 they’re operating in the condition that they’re going 

12 to operate in for the next eight or nine hours, 

13 whatever the case may be. 

14 Certainly if you immediately come into a 

15 room, turn them on and in one minute take a snapshot, 

16 you’re operating characteristics are going to be far 

17 different than if you allow them to operate and come 

18 up to proper operating temperature. I think that if 

19 you allow them to reach the point of designed 

20 efficiency, and with modern day electronics, we do 

21 understand that components operate differently at 

22 different temperatures. And that’s all taken in 

23 during the design consideration. 

24 Again, we design a ballast to operate over a 

25 long term, not for I guess momentary applications. 

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1 MR. RABA: Answer your question? 

2 MS. GUPTA: Uh-huh (yes). 

3 MR. RABA: Okay. Others? Back to you, 

4 Matt. 

5 MR. WALKER: Okay. Let’s now move on to a 

6 couple slides describing the process DOE used to 

7 develop transfer equations for converting the measured 

8 value of BE to BEF. 

9 DOE tested both of these metrics for 

10 multiple ballasts and key product classes. It used 

11 the proposed resistor-based method for the measurement 

12 of ballast efficiency. It then used the existing test 

13 procedure, based on light output measurements for the 

14 determination of ballast efficacy factor. 

15 Then using this test data, DOE found a 

16 linear relationship between BE and BEF. In assigning 

17 this line of best fit, DOE chose to anchor the line to 

18 the origin, such that when ballast efficacy equalled 

19 zero, BEF would also equal zero. And in doing this, 

20 the equation -- the transfer equation took the form 

21 BEF equals slope of the line times ballast efficiency. 

22 So DOE did have test extensive data in many 

23 product classes, but for those that did not have 

24 extensive data, DOE began to develop scaling 

25 relationships. I should also mention that the test 

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1 data that DOE collected during the process is 

2 available in Appendix 5-C of the energy conservation 

3 standard. 

4 So for those product classes that did not 

5 have extensive testing, DOE used extensive data from 

6 the four-foot medium bi-pin and eight-foot slim line 

7 ballast classes to calculate relationships between 

8 slopes for changes in starting method, number of 

9 lamps, ballast factor, and total rated lamp power. 

10 And just as an example, if you look along 

11 the horizontal line on this table, you can see the 

12 axis on which DOE would use a relationship for number 

13 of lamps. The vertical line would indicate the 

14 relationship based on ballast factor, et cetera. 

15 So at this time, we’d like to seek comments 

16 on the transfer equations, the actual equations used 

17 to convert BE to BEF, as well as the techniques used 

18 for scaling these equations. 

19 MR. STEPHENS: Charlie Stephens. Could you 

20 go back two slides please? On your graph there, I 

21 take it each little green dot is an individual ballast 

22 that was tested? 

23 MR. WALKER: Correct. 

24 MR. STEPHENS: Can you give me a sense of 

25 the order of magnitude of the variation from your nice 

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1 straight slope, to the individual green dots as far as 

2 how that compares to the discussion we had earlier 

3 about one and a half percent or two and a half percent 

4 measurement error? 

5 MR. WALKER: I don’t know if I can speak 

6 specifically to that variation. We did notice, just 

7 relatively speaking, at this point all I can say is 

8 that BEF did have maybe more spread in the data 

9 compared to BE for a particular ballast. I don’t 

10 really have my hands on the particular numbers. 

11 MR. STEPHENS: Yeah, I’m trying to get a 

12 sense of, you know, are we worried about two and a 

13 half percent in our measurements only to wash all that 

14 out in a slope that really doesn’t come all that close 

15 to the actual performance of individual ballasts by 

16 the time you’re done. 

17 MS. GUPTA: Yes, this is Mimi Gupta, from 

18 Navigant Consulting. I think you bring up a good 

19 point, that one aspect of this methodology is the 

20 correlation, and, you know, using the test data from 

21 four foot medium bi-pins, you see a fairly good 

22 relationship, but definitely for some ballast 

23 categories, that relationship was not so great. So 

24 it’s one drawback to this proposal and DOE seeks 

25 comment on whether doing this correlation is bringing 

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1 us backward. 

2 I think that though the resulting BEF may 

3 have some -- some error associated with it, I think 

4 using the ballast efficiency and correlating to BEF 

5 insures that manufacturer to manufacturer, test to 

6 test facility, you’re going to get a consistent 

7 measurement. MR. STEPHENS: This is Charlie 

8 Stephens. True, but you -- I think we were talking 

9 about an accurate representation about the efficiency 

10 of individual ballasts being selected by designers or 

11 whoever, manufacturers of fixtures in the marketplace. 

12 And I’m not sure that the accuracy or the consistency 

13 of those measurements is important if you’re going to 

14 wash it out by twice as much when they use the factor, 

15 whatever factor you use in the scaling here. 

16 MR. RABA: Response over here? 

17 MR. ERHARDT: Yeah, Bob Erhardt, Philips 

18 Lighting and Electronics. I guess I’m not sure I 

19 understand what your two-to-one concern is. I mean, 

20 this is a little bit of a confusing way to look at it 

21 because, I have to sit here and think about what we’re 

22 going through with it. What you’re really comparing 

23 is -- this slope, if I’m interpreting it correctly, 

24 and I had to think about it for about five minutes to 

25 convince myself, is that you’re getting kind of an 

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1 average BE over an average BEF by putting that slope 

2 through there, to get a conversion factor. 

3 And because what you really need to know is 

4 when you’re -- what we would have compared would have 

5 been, instead of putting all these plots on the same, 

6 do an individual by individual and then take an 

7 average, but that’s in effect what they’ve done by 

8 doing the fit. Because it’s going to be -- the BEF is 

9 light output over ballast efficiency -- I’m sorry, 

10 light output over watts, watts in, and BE is watts out 

11 over watts in. So when you take the ratio of them, 

12 you’re -- should be canceling out the watts out, and 

13 getting light -- I’m sorry, you should be canceling 

14 the watts in, and so your slope should then be light 

15 per ballast factor over watts out, is what this slope 

16 should be representing. Trying to do this in my head, 

17 I think that’s what you’ve got there. 

18 MR. STEPHENS: Yeah, this is Charlie 

19 Stephens. Let me just make it a little more clear. 

20 Look at the furthest right there at a BE of .92, plus 

21 or minus, it says its ballast efficiency or ballast 

22 efficacy factor is 1.55. It will, according to that 

23 slope, it would receive a rating of about 1.57, not 

24 1.55. My question is, if you -- if the accuracy of 

25 your measurement delivered a BE of .92, if the actual 

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1 BE was, you know, .907 or .909 or whatever, how much 

2 worse is that than the .02 going from 1.55 to 1.57 in 

3 its delivered rating via this equation? 

4 MR. RABA: I think a response in the back. 

5 MR. ERHARDT: It would be 1.5 -- 

6 MR. RABA: Sorry, go ahead Bob, sorry. 

7 MR. ERHARDT: It would -- okay, so you’re 

8 looking at one point and you’re saying what would be 

9 the error on that one point, and you’re saying it 

10 would be -- and I guess you’ve done the calculation, 

11 it would be 1.57 -- 

12 MR. STEPHENS: No, I’m just looking at the 

13 graph, it’s rating, based on that nice average line 

14 would be 1.57. Direct graphically, I’m seeing a BEF 

15 of 1.57 -- 1.566 and -- the fact is, I’m trying to 

16 interpolate between the lines there. But what I’m 

17 saying is there’s an error in the reported BEF at any 

18 given BE -- and I’m trying to compare the magnitude of 

19 that error on this, using these transfer equations. 

20 MR. ERHARDT: Okay. And I guess I -- again, 

21 Bob Erhardt. I guess our response to that is two 

22 points on 1.55 is one and a half percent. Okay. The 

23 BEF measurement itself has a five percent error. So 

24 the one and a half percent is kind of a wash when you 

25 -- and the idea is we’re trying to cancel the five 

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1 percent by taking an overall average of all these BF 

2 measurements using light, okay. 

3 We’re going to try to come up with a 

4 correlation factor. We’ve done round robin testing of 

5 at least three labs, maybe it was four or five, I 

6 don’t remember actual certified testing organizations, 

7 CSA, TL, UL, et cetera. I think LRC. And we’re going 

8 to compare their measurements, their BEF measurements 

9 for the same sets of lamps and try to get a 

10 correlation based on the average of all these, so to 

11 get a wash out of this plus/minus five percent. And 

12 then we’re going to put that in -- and so then we’re 

13 going to take that correlation factor. 

14 Now, using that correlation, which in effect 

15 may be -- they’ve done here, some of these were high, 

16 some of them are low. Although they might have done 

17 this on one testing lab. Was this all done all on 

18 LRC? 

19 MR. WALKER: It was all in one testing lab, 

20 and actually each of these points represents an 

21 average of three samples of a particular ballast. 

22 MR. ERHARDT: In any case, the idea is we’ve 

23 tried to wash out the five percent tolerance by taking 

24 averages of many BEF measurements, many light output 

25 measurements, we’re trying to wash out that error by 

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1 taking an average that we can agree to, and then 

2 coming up with a correlation factor that then is 

3 applied to a metric that has a two and a half percent 

4 error, instead of one that -- and use it instead of 

5 taking the five percent error. 

6 MR. RABA: The gentleman in the back has 

7 been very patient. Go ahead, sir. 

8 MR. COOK: Keith Cook from Philips Lighting. 

9 I guess maybe expanding upon this a little bit. Matt 

10 touched upon it. Is, what is the repeatability of 

11 this test setup? I mean if you have a particular 

12 ballast and a particular lamp, and you put it all 

13 together and you run a test, then you tear it all 

14 down, and you have a different operator come in and he 

15 puts it all together, did you run any testing to see 

16 how consistent this approach is using even the same 

17 ballast and lamp? 

18 MS. GUPTA: So -- this is Mimi Gupta from 

19 Navigant Consulting. We had the Lighting Research 

20 Center do all these tests for us, and unfortunately we 

21 don’t have a representative of them here. But as I 

22 understand it, and I think manufacturers, you probably 

23 know this better, the Lighting Research Center is a 

24 certified lab, so I think they do continuous tests 

25 like on the calibration -- 

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1 MR. COOK: That has nothing to do with my 

2 question. My question -- I agree that their test 

3 results may be very accurate, but there’s still the 

4 way you set it up and the way you take the readings is 

5 inducing another amount of error. And that can have 

6 an effect upon, you know, the test results. And 

7 that’s what I’m trying to understand, is how 

8 repeatable is the test setup. 

9 MR. RABA: Bob? 

10 MR. ERHARDT: Yeah, this is Bob Erhardt, and 

11 we’ll be given a more detailed response in our written 

12 response, but we have done -- we have tried exactly -- 

13 to deal exactly that effect, Keith, by doing round 

14 robin testing of multiple test labs, with the same 

15 lamps and the same ballasts. So we are actually 

16 looking at the repeatability of the test, and the 

17 average of the test, and that’s how we come up with 

18 our five percent number for this BEF accuracy. And we 

19 want to use the average correlations from these 

20 multiple test labs, multiple certified test labs, on 

21 the same ballast and the same lamps, to come back with 

22 a formal response to your question on a correlation 

23 factor. 

24 MR. RABA: Was that helpful? 

25 MR. COOK: Yes. 

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1 MR. RABA: Thank you. And you can always 

2 submit your questions or comments later on in written 

3 statements and all too. Thank you, and likewise to 

4 you, Bob. Further? Yes, sir. 

5 MR. PARISELLA: Joe Parisella, Osram 

6 Sylvania. I’d just like to get some further 

7 clarification on the graph here. Is this -- this was 

8 done with a normal ballast factor ballast. Did you do 

9 the same test with a low ballast factor and a high 

10 ballast factor, ballast with the same resistor, and 

11 did you get the same slope, or not? 

12 MR. WALKER: Right, so we -- we would do the 

13 same test using the same resistor and ballast with 

14 different ballast factors, and you would actually get 

15 a different slope. And that sort of comes -- due to 

16 the fact that the resistor is not the exact match for 

17 the ballast factor of the ballast. So the different 

18 slope attempts to account for that effect. 

19 MR. PARISELLA: And that’s where the scaling 

20 factor comes in? 

21 MR. WALKER: Well, so we actually -- we 

22 would have -- let’s see. 

23 PARTICIPANT: Go to the next slide. 

24 MR. WALKER: Yeah, I’ll just point to this 

25 table here. For example, this slope and this one were 

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1 all based directly on test data. And then we would 

2 establish a ratio between the high and normal to 

3 establish a ballast factor scaling ratio. 

4 MR. PARISELLA: Okay. 

5 MR. WALKER: So there was an initial test 

6 based on test data directly used to develop the 

7 scaling ratio. Does that help? 

8 MR. PARISELLA: Yep. Thank you. 

9 MR. WALKER: Okay. 

10 MR. THOMAS: Ed Thomas, GE. Matt, I’m just 

11 curious if any effect of the lamps under -- when doing 

12 the BEF measurements, if you looked at efficacy of the 

13 lamps under full power loads versus low light level 

14 loads, did you find that the efficacy of the lamp 

15 varied between a normal light level and a low light 

16 level ballast, or a normal light level and a high 

17 light level ballast, given the watts loading in the 

18 tube? 

19 MR. WALKER: I don’t think we -- I don’t 

20 think we have data that answers that. 

21 MR. ERHARDT: Yeah, just one comment. I’m 

22 sorry, Bob Erhardt, Philips Lighting and Electronics. 

23 And one comment concerning scaling factors. We agree 

24 that scaling factors can be valid. We will be 

25 supplying in our written report, in our written 

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1 comments, again I said -- and I have in front of me, 

2 but it’s much too much to put on the screen. I’ve got 

3 -- I took 400 medium -- I took from the California 

4 Energy Commission, 400 medium bi-pin test data. I 

5 looked at the, from the four major manufacturers, I 

6 took the highest BEFs for each category in your 

7 matrix, and I did averages of those, and I developed 

8 some correlation factors that are pretty close to what 

9 you came out with, but you may wish to analyze the 

10 further data if you haven’t done so, and I will be 

11 supplying it to you. 

12 MR. RABA: Thank you. Matt? 

13 MR. WALKER: All right. We’ve move on to 

14 the transfer equations. So this is the final content 

15 side for the ballast test procedure. And I think it’s 

16 come up earlier today, it is the case that during 

17 testing we did find that some ballasts did not operate 

18 resistors. We then confirmed that the ballast did 

19 properly operate lamps, and while this wasn’t a 

20 widespread problem, ballasts that operate different 

21 types of lamps -- well, what am I trying to say? This 

22 phenomenon was observed for different ballast types. 

23 It was only a few, it wasn’t a widespread problem. 

24 But in the case that a ballast is unable to 

25 operate a resistor, DOE is proposing that the light 

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1 output base test procedure described in Appendix Q of 

2 the CFR be used for these ballasts. 

3 In the issue box, you can see number six, 

4 DOE is seeking comment on why some ballasts may not 

5 operate a resistor load bank while they are able to 

6 properly operate a lamp. We also invite comments on 

7 other approaches for testing these ballasts. 

8 DOE is also seeking comment on the 

9 effectiveness of the proposed resistor-based method, 

10 as well as comment on its assessment of anticipated 

11 test burden. Bob. 

12 MR. ERHARDT: Yeah, we’ve already made some 

13 comment on the resistor requirements and having to 

14 have one for each category. Concerning your issue 

15 six, it’s not uncommon for some self-oscillating 

16 ballast to not have enough drive if you load them at 

17 start up, and so would not be uncommon for a ballast 

18 that had a self-oscillating output stage to not start 

19 if you had it resistively loaded. We accommodate this 

20 in production because we do resistive loads to test 

21 our ballasts in production -- my company does anyway -

22 - by starting the ballast without the resistive load, 

23 and then introducing the resistive load. 

24 But again, NEMA does propose that -- and you 

25 would not have this issue with lamp loads either, so 

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1 again, NEMA prefers a lamp load efficiency 

2 measurement. 

3 MR. RABA: Comment, Ed? 

4 MR. THOMAS: Ed Thomas, GE. If we’re going 

5 to use a system where some equivalent ballasts are 

6 tested on the BEF method, and some are going to be 

7 tested on the resistive method, is there going to be 

8 some means of denoting which methodology is used? 

9 Because, as we saw a couple slides earlier, there is 

10 some variation between what the outcome will be. This 

11 may be favorable or unfavorable to certain 

12 manufacturers. So how does the department intend to 

13 address that particular issue? 

14 MS. GUPTA: Mimi Gupta, Navigant Consulting. 

15 I think the current proposal is not to denote whether 

16 the ballast has been tested with one procedure or the 

17 other, and both would be subject to the same standard. 

18 So if stakeholders have comment on this issue of 

19 whether it should be denoted and any modifications 

20 that need to be made, DOE would definitely be 

21 receptive to that. 

22 MR. THOMAS: Well, I think there needs to be 

23 some sort of indication, because we’ve seen that test 

24 methodologies that utilize the photometrics tend to 

25 have a larger percentage of error than test 

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1 methodologies that utilize either a resistive load or 

2 a lamp load relating to ballast efficiency. So I 

3 think there is going to need to be some delineation of 

4 the test method used for a particular ballast if 

5 alternate methods like this can be used. 

6 The suggestion would be to utilize lamp 

7 loads and thereby eliminating this problem entirely. 

8 MR. deLASKI: This is our last round on this 

9 method? 

10 MR. WALKER: This is the last slide. 

11 MR. deLASKI: Okay. I just want to come 

12 back to -- 

13 MR. RABA: Andrew deLaski. 

14 MR. deLASKI: -- the issue that was raised 

15 earlier on about DOE choice of metrics. Mike raised 

16 this earlier in his remarks about the authority to go 

17 to an RSE metric, and Betsy, I appreciate that you 

18 look into this further. But I think Matt, in this 

19 docket, we’re working under the assumption that we 

20 were stuck with the BEF. So if the department now 

21 thinks we are not stuck with the BEF, it would really 

22 help in preparing our comments to know that. And I 

23 think a lot of what you just saw in the previous slide 

24 is some -- a lot of work going on, Bob, what NEMA’s 

25 been doing and what the department’s been doing to try 

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1 to work within this BEF construct. But yet it seems 

2 that quite possibly the department’s not stuck in that 

3 construct, of that particular metric. So I don’t know 

4 if there’s a method for that. 

5 But I guess I’ll just make a couple more 

6 comments is that it strikes me that ... some other 

7 dockets that the department, for example, with clothes 

8 washers, the initial statutory requirement was energy 

9 factor, and it was changed to modified energy factor. 

10 So the department has changed requirements for the 

11 metric by which things are measured in other dockets, 

12 and we’re having a conversation in another docket, 

13 which Betsy, you know very well, about the air 

14 conditioner test method. And we think the department 

15 has wide discretion in that docket as well to use 

16 other than those that are named in the statute. 

17 But in this case, the particular barrier 

18 that the department has identified as being a 

19 potential concern in that docket isn’t one in this 

20 docket. So it strikes me that it would really help 

21 the commentors to know, you know, does the department 

22 think you’re stuck with BEF or do you think that there 

23 may be more discussion. 

24 MR. RABA: Follow comment? Tim Ballo with 

25 EarthJustice. 

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1 MR. BALLO: Tim Ballo from EarthJustice. 

2 Second a lot of what Andrew said, and from reading the 

3 TSD it’s not clear, at least in the language I’m 

4 looking at in 2.4.1.2, that the department has 

5 expressed that it is compelled to stick with BEF, that 

6 seems to be one reading that one could take of the 

7 language that you’re using for consistency with ... 

8 statute, DOE preliminarily determined that it cannot 

9 change their point of metric. That seems to be a 

10 legal conclusion, but there’s no rationale, there’s no 

11 explanation of how the department arrived at that 

12 conclusion and why the department feels -- believes 

13 that the statute compels them to stick with BEF. 

14 I’m not saying that should be the 

15 department’s conclusion. I would argue just the 

16 opposite. But there has to be some rationale for 

17 commentors to comment on, and here all we have is just 

18 a facial conclusion of the statute -- it seems to be 

19 saying that the statute compels this, but we don’t 

20 know why. 

21 MS. KOHL: This is Betsy Kohl from DOE. I 

22 think the proposal was written the way it was for 

23 consistency with the Congressionally laid out 

24 standards for these lamps in 6295. 

25 MR. RABA: Speak up, Betsy. 

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 1 

2 MS. KOHL: And seven -- it’s in the 

3 document that you were reading from, but I don’t think 

4 that necessarily means that we have concluded that we 

5 therefore have to use BEF forever. So send us comment 

6 on that issue, and then you can also send us comments 

7 on what it should be if it were not. 

8 MR. deLASKI: This is a follow up -- Andrew 

9 deLaskiv. Betsy, is there any mechanism for the 

10 department to give a view prior -- we have comments to 

11 the end of June, I think. Is there a mechanism for 

12 the department to express a view on this during -- 

13 MS. KOHL: It would probably be another 

14 Federal Register notice, to let the world know. But I 

15 don’t know whether we have plans to do that. It 

16 certainly is something we can think about though. 

17 That would help commentors. 

18 MR. ERHARDT: Bob Erhardt, Philips Lighting 

19 and Electronics. Just a small clarification -- a 

20 small correction to one of my earlier statements, now 

21 that I’ve had my coffee and my esteemed colleague here 

22 has brought it to my attention. 

23 I had the RSE BEF relationship for T5 And T8 

24 inverted. It is the T5 that comes up looking of poor 

25 quality when compared with an RSE compared to a T8. 

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1 MR. RABA: Good catch. Yes, Mike. 

2 MR. MCGARAGHAN: Mike McGaraghan. I just 

3 wanted to point out that the comment deadline is June 

4 7th, as far as I can see from the NOPR on the test 

5 procedure. 

6 MR. RABA: Further comments on this? Yes, 

7 sir. 

8 MR. DUFFY: This is Mark Duffy from GE 

9 Lighting. If you could back up a couple slides to the 

10 scaling transfer equations -- right there. If you 

11 take a careful look at this, and you realize that 

12 ballast efficiency is output watts divided by input 

13 watts, the fact that the scaling factors are different 

14 for high, normal and low ballast factor is going to 

15 create a bias that’s going to force high ballast 

16 factor or low ballast factor ballast to have more 

17 efficient operation, if you lay a line on ballast 

18 efficiency factor. So I thin you should be careful to 

19 realize that while you get a lot of variation when 

20 you’re measuring with ballast efficiency factor, and 

21 so those scaling factors could have a lot of variation 

22 to them. The reality is, if you’re going for watts 

23 out divided by watts in as a figure of merit for 

24 ballasts, then those number should be uniform across 

25 the vertical direction. Thank you. 

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1 MR. RABA: Mike. 

2 MR. WALKER: I think your comment makes 

3 sense. I just wanted to point out one thing about -- 

4 maybe one reason for why the scaling relationships are 

5 different between ballast factor. Because a ballast -

6 - any ballast factor is tested with the same resistor, 

7 a low ballast factor ballast, or a high ballast factor 

8 ballast measured ballast efficiency is not the same as 

9 if it was measured with the appropriate resistor. 

10 So for that reason, we try to scale -- we 

11 try to bring the ballast efficiency to the correct BEF 

12 using a different number, does that help? 

13 MR. DUFFY: Yeah, that helps clarify, 

14 Matthew, I appreciate that. And I guess it makes one 

15 more statement that the use of lamps as a load is -- 

16 would take that factor out of the picture. 

17 MR. RABA: Yes. 

18 MR. ERHARDT: Bob Erhardt, Philips Lighting 

19 and Electronics. If you like I can give you a couple 

20 of quick indications of what I found when I looked at 

21 larger populations of lamps. I found that the -- 

22 going from a one lamp to a two lamp is about a two 

23 percent -- I’m sorry here. Can be as high as a three 

24 percent BEF with the two lamp being three percent 

25 higher efficiency than the one lamp. And going up to 

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1 a four lamp, the four lamp can actually be more 

2 efficient than the two lamp by about two percent. 

3 So actually here, I have a lot of data here. 

4 I have program start, instant start, two lamp to four 

5 lamp, low wattage to high wattage. These are based on 

6 average BEFs of the four highest BEF models from the 

7 four major manufacturers of each category. And the 

8 average overall is three and a half percent lower BEF 

9 for a one lamp compared to a two lamp, and about two 

10 percent higher for a four lamp compared with a two 

11 lamp. 

12 Going from low to high, the overall average, 

13 it’s about plus or minus -- about plus or minus one 

14 percent, relative to a two lamp. A low wattage is 

15 about one percent less efficient, and a high wattage 

16 is about one percent higher efficiency. 

17 MR. RABA: Thank you. Yes, sir, in the 

18 back? 

19 MR. ANDERSEN: Eric Andersen, Pacific 

20 Northwest National Laboratory. Matt, if you’d go back 

21 to issue 11, I just want to make sure we don’t skip 

22 over that. I heard it mentioned a little bit earlier 

23 that there were some concerns about perhaps having to 

24 do some facility modifications in order to conduct 

25 some of this testing, and I’m wondering if there are 

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1 other things that are of concern with regard to 

2 implementing this test procedure and the burden 

3 imposed by that? 

4 MR. THOMAS: Ed Thomas, GE Lighting. 

5 Certainly the need to acquire multiple banks of 

6 precision resistors would be a concern. The resistors 

7 utilized in the NEMA testing were between one and 

8 $2000 a set. And that was for one specific load bank. 

9 We may need multiples of that, depending upon what the 

10 final outcome of the rule is, and these resistors will 

11 be basically in a closet until they’re needed for 

12 testing, and then with different ballast types and 

13 different lamp times still in development. Additional 

14 resistors will need to be purchased as different types 

15 of systems come on to the market. Again, it’s a case 

16 for lamp utilization. 

17 And I think also, a little bit on issue 12, 

18 if existing BEF measurements are still required, the 

19 ability to control the temperature is going to be a 

20 costly proposal. 

21 MR. RABA: Okay. More on burden? Anything 

22 else. Matt? 

23 MR. WALKER: I think we’re all set. Thank 

24 you for your attention. Thank you. 

25 MR. RABA: So, as you note, the comment 

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1 period test procedures closes June 7th. We’ve got a 

2 lot of good information here to think about. Go back 

3 and formulate and submit to the department your 

4 comments, anything else, you can contact the project 

5 manager as well, Linda Graves, for any questions you 

6 might have along the way. 

7 We’re pretty much right on schedule here. 

8 Well, actually a little ahead. So let’s do this. 

9 Take a lunch break right now. There are two places 

10 you might go for lunch, again, down below, the ground 

11 floor, there’s a Dunkin Donuts and a Subway. Or to 

12 the West Building, on the ground floor and just follow 

13 the crowd, I would say, to the far end, past the 

14 auditorium, up the escalator, the second level and 

15 there’s a cafeteria there. You have to go out of the 

16 building, so to speak, check in with the card, check 

17 in again. So take your visitors passes with you. 

18 And we’ll return -- start -- we’ll say we’ll 

19 give you one hour. Promptly at 12:45, so keep on 

20 schedule. We’ve a lot more to cover on standards. 

21 Any questions so far? Yes, sir. 

22 MR. HAKKAHANEN: May we leave our -- this 

23 will be locked? 

24 MR. RABA: Yes, we’ll keep this room secure 

25 for you. I would say if you leave the building, the 

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1 campus, it’s kind of hard to get back in, you’d have 

2 to have someone like us to bring you back in, so stay 

3 in the building somewhere, if you would, just for your 

4 own convenience’s sake 

5 Again, thank you very much, good round of 

6 comments, and discussion. See you back in an our. 

7 (Whereupon, at 11:45 p.m., the meeting was 

8 recessed, to reconvene at 12:45 p.m., this same day, 

9 Monday, April 26, 2010.) 

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1 A F T E R N O O N S E S S I O N 

2 12:48 p.m. 

3 MR. RABA: Welcome back. I’ve been asked to 

4 start again. People who are missing will probably get 

5 back shortly. 

6 Is there anyone here who is new in this half 

7 of the public meeting, this part being Standards, or 

8 who hasn’t introduced him or herself earlier in the 

9 day. 

10 Yes, sir. Say your name, please, for the 

11 record, and your organization and affiliation. 

12 MR. CARPENTER: Yes, Fred Carpenter with the 

13 Acuity Brands Lighting. 

14 MR. RABA: Thank you very much. Thank you. 

15 Anybody else? 

16 MR. GALLANT: Pierre Gallant, Natural 

17 Resources Canada. 

18 MR. RABA: Say again, please? 

19 MR. GALLANT: Pierre Gallant, Natural 

20 Resources Canada. 

21 MR. RABA: Thank you. And you gave -- 

22 Brenda’s got your information? 

23 MR. GALLANT: Oh, yeah, I was here from the 

24 beginning. Maybe just a couple minutes after everyone 

25 presented themselves. 

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1 MR. RABA: Okay. And thanks for catching up 

2 with us. Or are we catching up with you. 

3 To start this out is Energy Efficiency 

4 Standards and preliminary analysis view point. And to 

5 lead off is Ali Lehr. Ali. 

6 MS. KOHL: Okay. Thank you. I’m sorry. 

7 This is Betsy Kohl from DOE. Just to clarify on an 

8 issue that we were talking about. 

9 MR. RABA: Betsy Kohl. 

10 MS. KOHL: The metric issue that we were 

11 talking about before we broke for lunch. I just kind 

12 of wanted to reiterate again that we’re still 

13 reconsidering what the appropriate metric would be. 

14 So I don’t know that another Federal Register notice 

15 on that issue would be of any use. So I just wanted 

16 to let you guys know that that issue is still under 

17 consideration so if you can let him know it would be 

18 great. 

19 Thank you. 

20 MR. RABA: Thanks for filing us in. 

21 Yes, please. 

22 MR. HAKKARAINEN: Pekka Hakkarainen from 

23 Lutron. Betsy, when would we expect a decision on 

24 that issue? 

25 MS. KOHL: Well, I mean, that’s part of this 

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1 rulemaking. I mean, you can supplement if you want. 

2 But in the Notice of Proposed Rulemaking for the test 

3 procedure we laid out the BEF, but then we laid out 

4 the BE, we laid out the RSE, so, I mean, that’s why 

5 you guys submit comments and we consider them and then 

6 for the final test procedure, which is the next step, 

7 that’s when it would come out. Okay? 

8 MR. HAKKARAINEN: It might be June of next 

9 year then? 

10 MS. KOHL: Yes. 

11 MR. RABA: Yes, please. 

12 MS. MAUER: Just a clarification. 

13 MR. RABA: Your name, please? 

14 MS. MAUER: Joanna Mauer. I think part of 

15 the question was just whether DOE thinks it can 

16 establish a metric that’s different from BEF even 

17 though there are several different options for what 

18 that alternative metric could be. 

19 MS. KOHL: Yeah, and I think those 

20 statements from the TSD we need to clean those up, but 

21 we are still considering what the appropriate metric 

22 would be. We proposed them as BEF for consistency 

23 with the standards that Congress had set. But we are 

24 still looking at what the best metric would be. 

25 MR. RABA: And Joanna, with the Appliance 

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1 standards project? 

2 MS. MAUER: Yes. 

3 MR. RABA: Okay. Thank you. 

4 Anyone else? Good follow on, Betsy. Thank 

5 you. 

6 Anything else? 

7 Okay. Now, Allison, if you would please. 

8 MS. LEHR: Thanks. 

9 ENERGY CONSERVATION STANDARD INTRODUCTION, 

10 STATUTE, AND CONTEXT 

11 MS. LEHR: All right. This afternoon we are 

12 going to be talking about the preliminary analysis 

13 stage for the fluorescent lamp ballasts standards 

14 rulemaking. 

15 Okay. So I’m going to start by giving an 

16 overview of the standards rulemaking to date and then 

17 we’ll talk about each analysis in more detail. And 

18 finally we’ll end by talking about the analysis for 

19 the NOPR and the next steps in the rulemaking process. 

20 There are typically four major stages in a 

21 DOE standards rulemaking. The framework document, 

22 preliminary analysis, notice of proposed rulemaking 

23 and final rule. 

24 Each stage includes a Federal Register 

25 notice to place information in public view. At 

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1 multiple points in the process DOE invites both oral 

2 and written comments on its analysis. These comments 

3 can be in response to not just the Federal Register 

4 notice, but also any technical support document and 

5 analytical spreadsheets that may be posted on line. 

6 Stakeholders are invited and even encouraged 

7 to participate during each of the public meetings and 

8 comment periods. 

9 This rulemaking started I early 2008 with 

10 the publication of a framework document. Just last 

11 month DOE published a notice in the Federal Register 

12 announcing the availability of the preliminary 

13 analysis and the date of this meeting. 

14 Later this year DOE plans to publish a NOPR 

15 and hold another public meeting to receive comments on 

16 that proposal. 

17 Six months after that DOE plans to publish a 

18 final rule. Any amended standards would take effect 

19 three years after the final rule is published which 

20 DOE estimates to be June 2014. 

21 So now we’ll start to talk in more detail 

22 about the analyses. As I mentioned, we are currently 

23 in the preliminary analysis phase. This slide 

24 summarizes all the analyses conducted during this 

25 stage. 

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1 I’m going to start by talking about the 

2 market and tech assessment, screening analysis and 

3 engineering analysis. These analyses serve as the 

4 foundation for the life cycle cost analysis and 

5 national impact analysis which we’ll be discussing 

6 later on today. 

7 In the market and technology assessment DOE 

8 determines the scope of coverage for this rulemaking. 

9 DOE also characterizes the fluorescent lamp ballast 

10 market, identifies several measures to improve the BEF 

11 of a ballast, known as technology options, and 

12 establishes product classes for all covered products. 

13 The screening analysis considers the technology 

14 options and determines whether they meet the four 

15 screening criteria described by EPCA. 

16 Technology options that meet the screening 

17 criteria are called “design options” which are input 

18 for the engineering analysis. 

19 EPCA defines a fluorescent lamp ballast as a 

20 device which is used to start and operate fluorescent 

21 lamps by providing a starting voltage and current and 

22 limiting the current during normal operation. 

23 Several fluorescent lamp ballasts are 

24 already subject to energy conservation standards and 

25 they are summarized in the table on this slide. In 

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1 general, only T12 ballasts that operate four-foot 

2 medium bi-pin, eight-foot single pin slimline and 

3 eight-foot high-output lamps are included in coverage. 

4 There are currently three types of ballasts 

5 exempt from standards. And these exemptions include 

6 dimming ballasts, residential ballasts, and ballasts 

7 designed for use in cold-temperature outdoor signs. 

8 As part of this rulemaking DOE considered 

9 expanding the scope of coverage to include addition 

10 fluorescent lamp ballasts. When expanding the scope 

11 DOE considered three main criteria. The first was the 

12 potential for a ballast type to demonstrate 

13 significant energy savings. As part of this criteria, 

14 DOE also considered ballast types whose shipments may 

15 not currently be high volume but have the potential to 

16 grow such as in the case that they become a substitute 

17 for a regulated ballast. 

18 And, finally, DOE considered improving the 

19 BEF of a certain ballast type was both technologically 

20 feasible and economically justified. 

21 DOE concluded that several additional 

22 ballast types met the criteria to be included in the 

23 scope of coverage. 

24 This slide summarizes all the ballasts in 

25 the preliminary determination of scope. 

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1 In general DOE is extending coverage to 

2 ballasts that operate additional lamp types such as 

3 four-foot T5 lamps, ballasts that operate additional 

4 lamp diameters such as T8, four-foot medium bi-pin 

5 lamps in addition to T12 and ballasts that operate 

6 additional numbers of lamps. 

7 Please note that DOE did not include dimming 

8 ballasts in this preliminary determination of scope. 

9 However, DOE invites comment on all aspects of the 

10 expanded scope of coverage including those ballasts 

11 that DOE chose not to include. And DOE also reminds 

12 stakeholders that any expansion of scope from that 

13 presented in this preliminary analysis would require a 

14 modification to the test procedure presented earlier 

15 today. 

16 A test procedure must exist for any covered 

17 product and therefore DOE asked stakeholders to 

18 comment on appropriate test procedures for any ballast 

19 that they wish to include in an expanded scope. 

20 MR. RABA: Thoughts on the scope that’s been 

21 presented? Charlie. 

22 MR. STEPHENS: I’m Charlie Stephens. Could 

23 you tell me how one knows an outdoor -- well, lamps 

24 that are designed to operate in cold temperature for 

25 outdoor signs? 

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1 MS. LEHR: Sure. They in general have a 

2 designation that they’re able to operate and they’re 

3 usually referred to as “sign ballasts” and they would 

4 say that they’re able to operate down to negative 20 

5 degrees Fahrenheit. 

6 MR. STEPHENS: What about a ballast that’s 

7 just labeled “outdoor”? I mean, I have -- 

8 MS. LEHR: All right. Someone behind you 

9 can answer the question. 

10 MR. RABA: Yes, please? 

11 MS. ANDERSON: Susan Anderson, Osram 

12 Sylvania. If it’s just labeled “outdoor” it’s 

13 probably that the case is moisture resistant. 

14 MS. LEHR: Okay. 

15 MS. ANDERSON: As opposed to the cold 

16 temperature which means that it can start at a lower -

- 17 

18 MR. RABA: Wait, wait, stop. Forgive me. 

19 My bad. Would you please use the stand up microphone 

20 so we can all hear you. Thank you very much. 

21 MS. ANDERSON: Certainly. If a ballast is 

22 labeled “outdoor” it means it can be exposed to 

23 moisture or is moisture resistant. As opposed to cold 

24 temperature starting might still need to be enclosed -

25 - suitably enclosed, but it can start the ballast at 

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1 colder starting -- start the lamps at colder starting 

2 temperatures. Typically minus 20 degrees Fahrenheit. 

3 MR. RABA: Thank you. 

4 MR. STEPHENS: Okay. Charlie Stephens back 

5 again. So that would mean that if it was simply 

6 labeled “outdoor” but not labeled to start at minus 20 

7 Fahrenheit, then it would be covered? 

8 MS. LEHR: Right. 

9 MR. STEPHENS: And if it’s labeled to start 

10 at minus 20 then it’s not covered? 

11 MS. LEHR: No, well -- 

12 MR. STEPHENS: It’s not supposed to be 

13 covered, but is not covered now? 

14 MS. LEHR: Right. I guess what we’re 

15 looking for is any suggestions you would have. These 

16 ballasts are currently exempted from the scope of 

17 coverage. And so there’s language in the Code of 

18 Federal Regulations for which type of ballasts are 

19 exempted. And so for including them the scope of 

20 coverage for any future phase we would need to have 

21 suggested regulatory language for how to define what’s 

22 covered and what’s not. If you had recommendations 

23 for how we should define this -- I guess this part, 

24 this ballast type, we would be willing to take any 

25 suggestions. 

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1 MR. RABA: Suggestion here? 

2 MR. ERHARDT: I’m just commenting that 

3 Navigant has proposed that they do include outdoor 

4 ballasts. They’re only giving them a different level 

5 to meet. And they are specifying the cold temperature 

6 rating with that. All they’re proposing is that they 

7 make some allowance for cold temperatures starting in 

8 the BEF requirement. 

9 MR. STEPHENS: Okay. Charlie Stephens 

10 again. I’m just having trouble with language as I try 

11 to translate this and then I don’t know how many 

12 people here in the room have bought a ballast in the 

13 last six weeks or so, or six months through the 

14 system. I do. I buy them fairly regularly. I 

15 haven’t succeeded recently in buying one that isn’t 

16 labeled “outdoors”. But I don’t know what that means. 

17 And I don’t know what electronic means anymore either. 

18 So I’m trying to get straight on what is and isn’t 

19 covered. It’s hard to make recommendations on what to 

20 cover if I’m not straight on what is covered. So -- 

21 MR. RABA: Can you help us? 

22 MR. ERHARDT: Yeah. There are UL safety 

23 ratings for outdoor and there’s Type 1 outdoor, Type 2 

24 outdoor and they are based on moisture resistance 

25 whether you need just a basic enclosure around them or 

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1 if you need some kind of hermetic enclosure that will 

2 keep all moisture away from them, et cetera, whether 

3 they’re fully encapsulated or not. 

4 That, as I understand, is not the 

5 eliminating factor in these proceedings. When they 

6 talk about outdoor, they are giving an allowance for 

7 cold temperature starting for sign ballasts and that 

8 when you do have cold temperature starting you have 

9 higher VAs in your product and you -- you know, it’s 

10 harder to meet the BEFs. So, as I understand the 

11 general Type 1 or Type 2 outdoor rating as applied to 

12 all products is not an eliminating factor only on the 

13 sign ballasts. 

14 MR. RABA: Okay. That last comment was from 

15 Bob Erhardt. 

16 MR. ERHARDT: Bob Erhardt, Philips 

17 Electronics. 

18 MR. RABA: Philips. And Charlie I see you 

19 nodding? 

20 MR. STEPHENS: Yeah. The second one is that 

21 in the Federal Register notice DOE used the term 

22 “electronic” in a lot of cases. And I can’t tell if 

23 you are using that to refer to a high frequency 

24 ballast or just a ballast that has electronic 

25 components. Because I’ve bought -- when I’ve gone in 

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1 and asked for an electronic ballast I’ve been handed a 

2 60 Hertz ballast and I’ve been handed a high frequency 

3 ballast and it’s not always the same thing. Though 

4 you can tell if it’s a program start ballast it’s got 

5 some electronics to it. So I’m not sure when DOE uses 

6 that term what they’re referring to, but I wish it 

7 were consistent and that I understood what it was. 

8 MR. ERHARDT: My only comment is that that 

9 hasn’t been a factor in setting the requirements, the 

10 electromagnetic or cathode cutout semi-electronic, if 

11 you like, or the full electronic all have to meet the 

12 same BEFs. So in the end I don’t think it’s 

13 important. I think they use those terms to describe 

14 ballast types. And as I read the report, it would 

15 appear that they are talking about high frequency 

16 versus low frequency given that high frequencies pick 

17 up efficacy in the lamp and therefore when they’re 

18 talking about a given regulation only being able to be 

19 met by an electronic they’re talking about a BEF that 

20 is high enough that if they don’t have the extra 10 

21 percent efficacy pick up from the lamp you’re not 

22 going to be meeting it. That was my interpretation 

23 from reading the report. 

24 Again, Bob Erhardt, Philips Lighting 

25 Electronics. 

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1 MR. RABA: Mimi, are you turned on? 

2 Microphone turned on. 

3 MS. GUPTA: Oh, it’s out of batteries. 

4 MR. RABA: Give it a moment to warm up, 

5 please. 

6 MS. GUPTA: Mimi Gupta, Navigant Consulting. 

7 Bob is correct. When we say “electronic” we do mean 

8 high frequency in the literature. But your comment is 

9 well taken about the terminology and we will 

10 definitely try to be clearer moving forward. So, 

11 thank you. 

12 MR. STEPHENS: And I would just suggest that 

13 if you mean high frequency that you say high 

14 frequency. Because when you look at the ballasts that 

15 are out there, it’s not consistent. 

16 MR. RABA: Thank you. 

17 MR. deLASKI: Andrew deLaski Appliance 

18 Standards Awareness Project. We had commented at the 

19 framework stage in favor of expanding the scope of 

20 coverage. And I think the Department has, by and 

21 large, gone in the direction in which we recommended 

22 at that time in covering both residential ballasts and 

23 low temperature ballasts. So we certainly applaud 

24 that correction and support it very strongly. 

25 I think as I read through the analysis here 

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1 it strikes me -- I’m really struck that the energy 

2 savings in this docket is in the newly covered 

3 products. And the analysis shows that even though the 

4 sales were relatively small, the savings are in these 

5 things that are newly covered. So it is in this area 

6 in coverage at the very beginning of this presentation 

7 today that we’re seeing the decisions that actually 

8 drive the savings in this docket so. We can make 

9 decisions here. 

10 I do have a question which is your rationale 

11 for not covering the dimming? So what’s driving that 

12 particular -- because we had recommended the framework 

13 stage covered dimming as well. So I’m curious as to 

14 why you came to a different conclusion on that one 

15 relative to say the outdoor or the residential? 

16 MS. LEHR: It was predominantly the low 

17 market share that we were able to detect for dimming 

18 ballasts. It was less than 1 percent. The market we 

19 were looking at was the primary driver. 

20 MR. ERHARDT: This is Bob Erhardt, Philips 

21 Lighting Electronics. I’ll also point out in the 

22 report they were commenting that, you know, dimming 

23 ballasts because of their expense are not going to 

24 represent a loophole that people aren’t going to be 

25 buying them as a way to not have to meet efficiency 

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1 levels because a dimming ballast is significantly more 

2 expensive. 

3 I will also comment that NEMA has commented 

4 asking that dimming ballasts not be covered in the 

5 rulemaking given that when a dimming ballast by its 

6 specification is there to be part of a high-efficiency 

7 system that can realize much higher energy savings 

8 than a fixed output ballast on its own. 

9 The other issue that NEMA wishes to bring up 

10 concerning dimming ballasts are that rating a dimming 

11 ballast at its full output can be misleading because 

12 dimming ballasts, if they are specified, are generally 

13 not operated at their full output and a means of 

14 determining the overall energy efficiency of a dimming 

15 ballast has not been well defined in our opinion and 

16 will be quite cumbersome. You’ll find dimming 

17 ballasts, especially if they’re used with -- 

18 especially if they’re used with daylight harvesting 

19 and can realize savings of 30, 40, even 50 percent on 

20 energy if you have significant daylight available. 

21 And it’s when you’re operating in these dim modes that 

22 we’re not covering their efficiency. And there are 

23 significant differences in the efficiency of dimming 

24 ballasts in these dim modes. And we haven’t come up 

25 with a practicable, if you will, method of looking at 

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1 the overall efficiency of a dimming system. 

2 MR. RABA: That covers a lot. Good 

3 question, Charlie. Go ahead. Thanks bob. 

4 MR. deLASKI: So just a follow-on. You 

5 know, I think we’re -- 

6 MR. RABA: deLaski. 

7 MR. deLASKI: -- going to address the new 

8 ballast in our written comments. But I hear both the 

9 arguments, both in terms of the sales volumes and in 

10 terms of the measurement issues. 

11 MR. RABA: Yes, in back please. 

12 MS. ANDERSON: (Off mike.) 

13 MR. RABA: Can you speak up. 

14 MS. ANDERSON: (Off mike) might want to talk 

15 about the New York Times Building and the actual 

16 energy use there as opposed to the design -- 

17 MR. RABA: We can’t hear you up front, 

18 please. 

19 MS. GUPTA: Susan, do you want to come up to 

20 the table? 

21 MR. RABA: Yeah, come on up. Yeah, please. 

22 Thank you. Good call. Welcome. 

23 MS. ANDERSON: Susan Anderson, Osram 

24 Sylvania. I speak a lot for NEMA. And one of the 

25 examples that we give people in proposing that they 

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1 consider the idea of dimming ballasts is one of the 

2 Lutron success stories which is the New York Times 

3 Building which is actually operating at less than 40 

4 percent of its designed watts per square foot because 

5 of the fact that they are using dimming ballasts 

6 incorporated as part of a daylight -- day lighting 

7 system. 

8 So I think they’re at something like .38 

9 watts per square foot. And it was supposed to have 

10 been around 1.2, 1.29. They’re operating at about 70 

11 percent less than what they had anticipated in the 

12 designed watts per square foot. 

13 MR. RABA: Very interesting. Thank you. 

14 Further? 

15 MR. ERHARDT: Yeah, Bob Erhardt, Philips 

16 Lighting Electronics. One comment on exemptions that 

17 we just actually talked about last night at dinner. 

18 And we haven’t had a full vetting of the discussion, 

19 but we’re not -- we don’t even have necessarily a 

20 proposal that maybe hopefully we will for our written 

21 comments. 

22 Currently for EMI sensitive environments 

23 electromagnetic ballasts are used. And the proposals 

24 for efficiency levels that are being made here will 

25 not allow electromagnetic ballasts. And we would like 

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1 to propose some type of consideration and I would know 

2 how it would be worded, but somehow can we come up 

3 with some kind of a rating for EMI sensitive -- I 

4 understand the difficulty of enforcement and, you 

5 know, you don’t want people filling their whole 

6 building with electromagnetic, but from what we know 

7 there is still common practice -- the normal practice 

8 for hospital environments to be using electromagnetic 

9 product. 

10 MR. RABA: Good point. Go ahead, sorry. 

11 MR. THOMAS: Ed Thomas, GE Lighting. I 

12 would just like to further the point that Bob just 

13 made. Occasionally there are situations in critical 

14 care suites, surgery suites of hospitals, also areas 

15 that will be critical in the life support function, 

16 let’s say a control tower of an aircraft landing or an 

17 airport rather. We certainly have situations where 

18 ballasts that generate no or low EMI are needed. 

19 I got an inquiry from one of the research 

20 labs at Princeton about ballasts for their nuclear 

21 medicine laboratories. They wanted to see if they 

22 could still maintain with magnetic systems for 

23 specialized applications. Certainly not for general 

24 lighting, but, again, for specialized applications 

25 there should be some exemptions involved. 

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1 MR. deLASKI: Andrew DeLaski, Appliance 

2 Standards Awareness Project. I think Bob put his 

3 finger on, you know, the challenge here which is how 

4 do you define the exemption in a way that it prevents 

5 a loophole. And this has been a problem with lighting 

6 standards in particular. You know, because the market 

7 buys what you offer, or has the opportunity to buy 

8 whatever you offer, and you don’t necessarily control 

9 who buys which products as manufacturers. So I think 

10 the challenge is in finding that. So I would really 

11 put it back to you guys to think about how are you 

12 going to define -- how can we define the exemption -- 

13 an exemption in a way that prevents it from becoming, 

14 you know, the new energy saver. You know, we had -- 

15 we thought we had to revise the law in 2005 to deal 

16 with the energy saver ballasts. And you know, we have 

17 to -- we are still wrestling with the BR lamp 

18 exemption and condenser reflector lamp docket. So, 

19 you know, one docket after the other with lighting 

20 products we find the market kind of -- you squeeze it 

21 in one way and it comes out somewhere else. So we 

22 have to define these in ways that are really bullet 

23 proof. 

24 MS. GUPTA: Mimi Gupta, Navigant Consulting. 

25 So I have a question. It was my understanding that 

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1 coming standards for fluorescent ballasts were going 

2 to eliminate -- no these ones that we’re talking 

3 about, but the ones that are coming effective I think 

4 in 2010 or something like that. 

5 MS. LEHR: Like July 2010? 

6 MS. GUPTA: Yeah. They were going to 

7 eliminate most electromagnetic ballasts except for 

8 maybe the high output variety; is that not your 

9 understanding? 

10 MR. ERHARDT: Bob Erhardt, Philips Lighting 

11 Electronics. We’re going to have to look at this 

12 because this came up over dinner last night and this 

13 is the first time we’re, as NEMA companies, addressing 

14 it. We are going to have to take a look at this 

15 situation. We don’t know, maybe this is something we 

16 missed. And we my have to try to correct it. But 

17 this is something that, you know, we’ve been very 

18 wrapped up in the shift to electronic product and 

19 focused on it and then the shift to control systems 

20 and this is something we may have overlooked. We’ll 

21 try to address it in our written comments. 

22 MR. RABA: Written comments, remember that. 

23 Thank you. 

24 Anybody else, please? 

25 Ali? 

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1 MARKET AND TECHNOLOGY ASSESSMENT; SCREENING 

2 ANALYSIS 

3 MS. LEHR: So DOE establishes separate 

4 standards for different groups of products called 

5 “product classes”. To do this DOE considered the type 

6 of energy used, the capacity, and any performance7 related feature that would require a different 

8 standard level. Of these criteria DOE focused on the 

9 last one where a difference in the BEF of a ballast 

10 was accompanied by a difference in consumer utility. 

11 Using this methodology DOE established 

12 product classes based on these six factors: Lamp 

13 length, number of lamps, lumen package, lamp diameter 

14 for T5 lamps, starting method and market sector. 

15 DOE found that features that affected the 

16 input power of a ballast also affected its BF. In 

17 general longer lamps tended to have higher wattages 

18 than shorter lamps. And therefore a ballast that 

19 operated in longer lamps had lower BEFs. Similarly 

20 the more lamps a ballast operated, the larger the 

21 ballast input power and the lower the BEF. 

22 DOE believes that both lamp length and 

23 number affect the ability of a lamp and ballast system 

24 to be used in a particular fixture. For example, 

25 ballasts operating eight-foot lamps would require 

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1 physically larger fixtures than ballasts operating 

2 four-foot lamps. Additionally ballasts operating six 

3 lamps would require more physical space than ballasts 

4 operating two lamps. 

5 Because of this impact on both BEF and 

6 consumer utility DOE established separate product 

7 classes for ballasts that operate different maximum 

8 numbers of lamps and ballasts that operate four9 versus eight-foot lamps. 

10 DOE also considered features that affected 

11 the lumen output of a lamp and ballast system. DOE 

12 found that high output systems tended to have higher 

13 input powers and therefore lower BEF’s compared to 

14 standard output systems. Similarly DOE found that 

15 ballasts with high or low ballast factor had lower 

16 BEFs than normal ballast factor ballasts. 

17 DOE believes that consumers use systems with 

18 different lumen packages for different applications. 

19 For example, high lumen output systems may be 

20 installed in a high ceiling or outdoor applications 

21 where large quantities of light are needed. 

22 Alternatively, low-lumen package systems might be 

23 installed in lower ceiling applications such as 

24 offices or hospitals where the distance between the 

25 light source and the illuminated surface is not as 

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1 large. 

2 Given the impact on both BEF and consumer 

3 utility DOE established separate product classes for 

4 standard versus high output systems and ballasts that 

5 operate low, normal, and high ballast factor. Similar 

6 to the test procedure DOE created three bins to 

7 delineate ballast factor with divisions at .78 and 

8 1.1. 

9 DOE also considered lamp diameter as a 

10 potential class setting factor. Because the most 

11 common wattage lamp associated with each lamp 

12 diameter, T12 ballasts typically have lower BEFs than 

13 T8 ballasts which in turn have lower BEFs than T5 

14 ballasts. However, DOE did not establish product 

15 classes based on lamp diameter alone because not all 

16 lamp diameters provide a unique consumer utility. 

17 For example, DOE kept both T8 and T12 

18 systems in the same product class because they are 

19 direct replacements for each other. However, because 

20 T5 systems offer a similar total lumen package as T8 

21 or T12 systems, but over a much smaller surface area, 

22 DOE believes these lamps are not suitable for direct 

23 lighting applications. 

24 For this reason DOE established a separate 

25 product class for ballasts that operate T5 lamps. 

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1 This approach is consistent with the July 2009 final 

2 Rule that amended energy conservation standards for 

3 general service fluorescent lamps. 

4 DOE also considered starting method as a 

5 potential class setting factor. DOE found that both 

6 program start and rapid start ballasts have lower BEFs 

7 than instant start ballasts due to electo heating. 

8 Even though there is a difference in BEF, DOE did not 

9 establish a separate product class for rapid start 

10 ballasts because rapid start and instant start 

11 ballasts are commonly used as substitutes for each 

12 other. 

13 However, occupancy sensors are almost 

14 exclusively used in combination with program start 

15 ballasts. For this reason DOE feels there’s unique 

16 utility associated with program start ballasts. 

17 Because of this utility and the associated decrease in 

18 BEF DOE established a separate product class for 

19 program start ballasts. 

20 Last, DOE considered features related to the 

21 market sector or application in which the ballast was 

22 used. DOE noticed that residential ballasts had more 

23 stringent EMI requirements and less stringent power 

24 factor requirements than ballasts that operate in the 

25 commercial sector. Due to the EMI requirements, a 

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1 commercial ballast cannot be used as a substitute in 

2 the residential market. 

3 According to test data the more stringent 

4 EMI requirements seem to result in lower BEFs than 

5 commercial ballasts. For these reasons DOE 

6 established a separate product class for ballasts that 

7 are designed for use in the residential sector. 

8 Last, DOE noticed that ballasts designed for 

9 use in cold temperature outdoor signs have lower BEFs 

10 than ballasts that are not designed for cold 

11 temperature environments. Because regular ballasts 

12 cannot be used as substitutes DOE established a 

13 separate product class for ballasts that are used in 

14 cold temperature outdoor signs. 

15 So, in total, for the entire scope of 

16 coverage DOE established 70 product classes. This 

17 slide just shows an example of the product class 

18 structure for ballasts that operate four-foot medium 

19 bi-pin lamps in the commercial sector. You can see 

20 that after accounting for divisions in starting 

21 method, ballast factor and number of lamps there were 

22 36 product classes for ballasts that operate this lamp 

23 type. 

24 DOE requests comment on the factors it used 

25 to establish product classes especially the ranges 

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1 identified for high, low and normal ballast factor. 

2 MR. RABA: Charlie? 

3 MR. STEPHENS: Charlie Stephens. Could you 

4 go back over the residential list there? I mean, I’m 

5 somebody whose house is full of high frequency 

6 ballasts for four-foot and three-foot T8. So I’m kind 

7 of trying to figure out what the problem is here. 

8 MS. LEHR: I guess I’m not sure what you 

9 mean by what the problem is. 

10 MR. STEPHENS: You have more stringent EMI 

11 requirements in the residential sector? 

12 MS. LEHR: That’s correct. It’s an FCC 

13 requirement. 

14 MR. STEPHENS: Okay. But I’m not sure I 

15 understand those. I mean, do they just -- what’s the 

16 purpose of those? 

17 MR. RABA: I think we have a comment over 

18 here from -- 

19 MR. ERHARDT: I’ll respond. 

20 MR. RABA: Bob Erhardt. 

21 MR. ERHARDT: Bob Erhardt, Philips Lighting 

22 Electronics. FCC has differing requirements for 

23 residential and for commercial. As my shorthand 

24 description which might not be entirely accurate, but 

25 in residential -- in commercial it’s assumed if you’re 

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1 disturbing yourself, that’s fine. But in residential, 

2 if you’re in an apartment and you don’t want to 

3 disturb your neighbor. In any case, there are more 

4 stringent requirements for residential EMI than there 

5 are for commercial as an FCC regulation. 

6 So, yes, you should find that class B FCC 

7 rating for your residential ballasts that are in your 

8 home. 

9 MR. RABA: Charlie, you look puzzled. 

10 MR. STEPHENS: Well, only because I don’t 

11 understand the FCC requirement. But, you know, if 

12 it’s an FCC requirement that’s fine. You know, like I 

13 said, I don’t -- I don’t know when that was set, but 

14 there’s no evident impact that I can detect. 

15 MR. ERHARDT: The more stringent FCC class B 

16 requirement does require a more sophisticated EMI 

17 filter which will result in slightly higher losses. 

18 Although the lower power factor requirement more than 

19 offsets it. So you’re probably not noticing much of 

20 an impact on your residential efficiencies, if you 

21 will, because the -- when you can allow a .6 power 

22 factor and 200 percent THD, you can eliminate a whole 

23 stage of your ballast which has a much bigger impact 

24 than the addition of one more EMI component. 

25 MR. RABA: Mimi. 

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1 MS. GUPTA: Yes, Mimi Gupta. 

2 MR. RABA: Turn on. 

3 MS. GUPTA: Mimi Gupta, Navigant Consulting. 

4 So, Bob, are you saying that residential ballasts can 

5 actually achieve a higher efficiency than commercial 

6 ballasts due to the power factor requirement? 

7 MR. ERHARDT: I’ll be supplying my -- you 

8 know, you can go to the California Energy website -- 

9 California Energy Commission website as well and a 

10 dedicated residential ballast that has a low power 

11 factor can have higher efficiency than a full 

12 communication ballast. 

13 MR. RABA: Charlie, is that helpful? 

14 You could always send a written comment or 

15 concern about that too later on. 

16 MR. STEPHENS: Yeah, I’ll have to do a 

17 little digging. 

18 MR. RABA: Thank you. Bob? 

19 MR. ERHARDT: I’ll make some other comments 

20 in the request for comments. 

21 On your subdividing of product classes for 

22 low, normal, and high ballast factor, I would say the 

23 industry for T8 will typically talk about a normal 

24 ballast factor is about a .85 to generally .995. For 

25 a T5 a normal ballast factor would be a ballast factor 

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1 of one. We’ll supply written comments. But I think 

2 that having the normal range extend all the way down 

3 to .78 is on the low side and having it go all the way 

4 to 110 by -- for T8, certainly, that’s pretty high. 

5 If you have a 1 or a 105, you may wish to consider if 

6 that’s going to be -- well, you may wish to see how 

7 products break out in your analysis. 

8 Also, on low and high ballast factor 

9 ballasts both having lower BEFs than normal ballast 

10 factor, as we commented earlier during the measurement 

11 phase, I think some of this is based on your 

12 measurement procedures where you’re using the same -- 

13 as I understand you’re using the same resistors for 

14 low, normal and high. And that likely might -- will 

15 have affected the results. We have some comments that 

16 we’ll be giving that, again, I have -- we’ll be 

17 supplying my analysis of the California Energy 

18 Commission database and not that we don’t appreciate 

19 it, but high ballast factor ballasts don’t necessarily 

20 have lower efficiency. They tend to have higher 

21 efficiency. 

22 But the low ballast factor may have -- we 

23 may look for some additional relief on that side. The 

24 same thing with one versus four ballasts -- four lamps 

25 on a ballast. The one lamp ballasts tend to be 

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1 trended towards low efficiency. And that’s just an 

2 empirical observation. But they do. And the higher -

3 - the four lamps have slightly higher efficiency than 

4 the two lamps. 

5 MR. RABA: Thank you. Thank you. 

6 MS. GUPTA: Can I just ask one follow on. 

7 Mimi Gupta, Navigant. So, Bob, when you say 

8 “efficiency” just for clarity, do you actually mean 

9 ballast efficacy factor? 

10 MR. ERHARDT: I’m talking about ballast 

11 efficiency. 

12 MS. GUPTA: You’re talking about ballast 

13 efficiency? 

14 MR. ERHARDT: Ballast efficiency. Which 

15 will translate to BEF. 

16 MS. GUPTA: Okay. 

17 MR. ERHARDT: Because, you know, if the 

18 ballasts are operating the same lamps then ballast 

19 efficiency will, you know, translates to BEF. 

20 MS. GUPTA: Okay. 

21 MR. ERHARDT: Well, actually, okay, let me 

22 back off. The data I analyzed was BEF though 

23 actually. So I should -- I’ll leave it at -- I will 

24 withdraw my statement. I’ll say this data was based 

25 on BEF. I don’t know if the lamps are going to move 

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1 in one way or another based on a .88 versus 1.1 

2 ballast factor. There may be some contribution there. 

3 But the analysis -- the California Energy Commission 

4 numbers are BEF numbers, actual light output BEF 

5 numbers that I analyzed. 

6 MR. RABA: A lot to think about. Good 

7 comments. Thank you. 

8 Anything else, please? 

9 MR. deLASKI: Andrew deLaski, Appliance 

10 Standards Awareness Project. And this is a question 

11 for the industry or for Navigant. For a non-technical 

12 person can you just give me a brief description of 

13 what is it about a cold temperature ballast that makes 

14 it more difficult for it to reach a given efficiency 

15 level? 

16 MR. ERHARDT: This is Bob Erhardt, Philips 

17 Lighting Electronic. Higher ignition voltages. So 

18 you’re going to need more VAs in the -- you know, more 

19 turns on the secondary transformer, more I squared R 

20 losses. VAs volt amps, it’s the throughput of the 

21 product. VAs affect efficiency. If you have -- for 

22 the same power, if you have more VAs you have lower 

23 efficiency. So if you have two HO ballasts and one 

24 has a higher open circuit voltage than the other, the 

25 one with the higher open circuit voltage will like -- 

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1 can be expected to have lower efficiency. 

2 MR. deLASKI: Thanks. 

3 MR. RABA: Further on the scope? 

4 (No response.) 

5 MR. RABA: Back to you, Ali. 

6 MS. LEHR: So in the technology assessment 

7 DOE identifies all possible technology options that 

8 can improve the BEF of a ballast. To do this DOE 

9 looked at commercially available ballasts, 

10 manufacturer literature, patents research papers, and 

11 considered input from both stakeholders and technical 

12 experts. As a result DOE identified several 

13 technology options to improve the BEF of covered 

14 ballasts. Some of these options included using an 

15 electronic ballast instead of a magnetic one. Within 

16 the same product class using a T8 instead of T12 

17 system. Improving the efficiency of internal 

18 components such as transformers, diodes, capacitors 

19 and transistors. And finally improving the circuit 

20 design such as incorporating cathode cutout technology 

21 or using an instant start instead of a rapid start 

22 ballast. 

23 DOE invites comment on all of the technology 

24 options identified to improve the BEF of the ballasts. 

25 MR. RABA: So comments on these options, any 

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1 additional ones? Anybody? Please. 

2 MR. PARISELLA: This is Joe Parisella from 

3 Osram Sylvania. Some of the comments made regarding 

4 the components as in -- there seemed to be a tradeoff 

5 between efficiency and cost. With the active 

6 rectification you would have a higher cost to get 

7 about a 1 percent savings in efficiency that would 

8 probably be prohibitive in why the industry isn’t 

9 doing that right now. And especially at higher 

10 voltages that will be measured at 277 the impact of 

11 efficiency would be much less. They mentioned using 

12 silicon carbide Schottky diodes. 

13 Typically in the input section it would be 

14 cost prohibitive. In other parts of the circuit like 

15 the PFC, the power factor correction circuit, 

16 typically ballasts that we’re talking about are in the 

17 range of about 100, 120 watts or so. And these would 

18 be much more effective at higher power levels using 

19 different types of power factor correction circuits. 

20 Transformers, what I saw there, they were 

21 mentioning -- it looked like they were talking about 

22 laminations used in older style ballasts. And if they 

23 were mentioning ferrites or something, then I think 

24 that in the higher frequency, different material would 

25 be more effective, but the frequency range to be using 

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1 right now seem like materials appropriate. 

2 So I think my main point is that I think the 

3 suggestions were really good, but I think it’s a 

4 tradeoff between costs and efficiency and it seems 

5 like some of these suggestions might be cost 

6 prohibitive. 

7 MR. RABA: Yes. 

8 MR. ERHARDT: This is Bob Erhardt again. I 

9 also have a comment. There was a discussion to use 

10 some Schottky diodes on the input. Unless there’s 

11 been some development I’m not aware of, I don’t think 

12 you have shock key diodes in the voltage ranges that 

13 are used on the input. Shock key diodes tend to be 

14 low voltage devices and input voltage diodes you’re 

15 going to want something on the order of 600 to 1,000 

16 volts for input rectifiers. 

17 Integrated circuits, I agreed with the 

18 Navigant observations that topologies that use 

19 integrated circuits can have higher efficiencies. 

20 It’s not the integrated circuit itself that is 

21 providing the efficiency, but it’s the topology that 

22 uses an integrated circuit. 

23 There are some issues with that though in 

24 that generally the integrated circuits are used with 

25 series lamp topologies and when you go to a parallel 

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1 lamp operation and you want to use a resonant topology 

2 the control becomes much more complicated and it’s not 

3 clear that -- well, it’s not -- again, as Joe says, 

4 there’s going to be some significant cost 

5 considerations when you want to go from a self6 oscillating to a resonant type design and keep the 

7 same functionality. The market has a strong 

8 preference for independent lamp operation. We’re 

9 finding that out with dimming products where the 

10 market is pushing us towards independent lamp 

11 operation when it becomes quite complicated to do so 

12 in a dimming application. So it’s not -- it’s not an 

13 easy analysis to look at the effectiveness of -- cost 

14 effectiveness. 

15 MR. RABA: Thank you. 

16 Comment? 

17 MR. McGARAGHAN: Mike McGaraghan, California 

18 Utilities. I just wanted to dig a little bit deeper 

19 on some of the technologies that Navigant identified 

20 that may be currently in use in power supplies. I 

21 know active rectification was one of them. It sounds 

22 like that should be cost prohibitive in ballasts, but 

23 has there been any analysis into sign or power supply 

24 technology and the differences that might exist there 

25 that has allowed it to make its way into that 

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1 technology? Or do you intend to look into that at 

2 all? 

3 MR. RABA: Takes a moment to warm up. 

4 MS. GUPTA: Mimi Gupta, Navigant. So let me 

5 just be clear, your question is, have we looked into 

6 other types of like power supplies and the 

7 technologies used in those not ballasts that can be 

8 utilized potentially in ballasts; that’s correct? 

9 MR. McGARAGHAN: Yeah. And if they can be 

10 cost effective. 

11 MS. GUPTA: Right. I think that’s a great 

12 question. Well be asking for a comment on this issue 

13 later today. I think we tried to put together a 

14 technology option list that was comprehensive. Later 

15 when we get into the engineering analysis with regards 

16 to MaxTech, I think we have a comment to ask for a 

17 comment from stakeholders on what is the maximum 

18 technologically feasible level for this technology 

19 because our engineering analysis right now caps out at 

20 commercially available. So, that’s what we want to 

21 know from industry and from you folks. 

22 MR. ERHARDT: This is Bob Erhardt again. I 

23 can make a general comment. I think there’s more 

24 specific questions coming up later, but when you look 

25 at the -- what we’ve delineated as our NEMA premium 

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1 type products, you’re getting to the point of 

2 diminishing returns if you’re going to try to go much 

3 beyond that when you’re talking about efficiency. 

4 Active rectification on the front end to pick up an 

5 extra 1 percent on ballast efficiency we feel it does 

6 not justify the engineering resources. 

7 And as I stated in my opening comments, we 

8 feel that the fixed output ballast is a mature 

9 technology. We agree with Navigant’s conclusion that 

10 the state-of-the-art product on the market today does 

11 represent a high performance product that is cost 

12 effective. 

13 Going beyond that, I would say considering 

14 the engineering resources that would be pulled from 

15 things like control systems and solid-state lighting 

16 and new light sources would not justify the return and 

17 we request -- we agree with Navigant’s conclusions and 

18 we would like the DOE to look very strongly at writing 

19 regulations that the existing high performance 

20 products can meet. 

21 MR. RABA: Okay. Anybody else to hear? 

22 (No response.) 

23 MR. RABA: That cover that. Ali. 

 24 

 25 

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1 ENGINEERING ANALYSIS 

2 MS. LEHR: In the screening analysis DOE 

3 considers whether technology options meet the four 

4 screening criteria outlined on this slide. 

5 The screening criteria include technological 

6 feasibility, practicability to manufacturer install 

7 and service, adverse impacts on product utility or 

8 availability to customers and adverse impacts on 

9 health or safety. As a result of this analysis DOE 

10 screened out one option using laminated sheets of 

11 amorphous steel to improve transformer efficiency. 

12 DOE found that this option would increase the size and 

13 weight of the ballast which would affect its ability 

14 to be installed. DOE also believes that increasing 

15 the size and weight would affect consumer utility 

16 because it may limit the places a consumer could use 

17 the ballasts in a building. 

18 DOE invites comment on this technology 

19 option that was screened out. 

20 MR. RABA: Or was screened out -- was 

21 screened in. Thoughts and comments perhaps. 

22 MR. ERHARDT: Bob Erhardt, Philips Lighting 

23 Electronics. I think Joe said it quite succinctly. 

24 This would be an option for an electromagnetic 

25 product, electronic product going through an amorphous 

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1 steel is a step down in efficiency compared with 

2 ferrite. And if I’m clear that amorphous steel would 

3 even bring electromagnetic up into the range that 

4 you’re looking for given that you’re limited to the 60 

5 hertz and you’re starting it at 10 percent efficacy 

6 handicap already due to the low frequency. 

7 MR. RABA: Okay. That was good. Comment, 

8 Earthjustice? 

9 MR. BALLO: Tim BALLO with Earthjustice. 

10 I’m sorry if this displays my ignorance of the 

11 product, but when talking about the amorphous steel 

12 and how it would affect size and weight, did you look 

13 into what are the sort of size and weight constraints 

14 within which you operate when you’re putting lights in 

15 a building? It seems like there would probably be a 

16 substantial amount of space, you know, surrounding the 

17 fixture. How much of an increase are you talking 

18 about in size and weight? 

19 MS. LEHR: I guess all increase is relative. 

20 We looked at -- we considered whether or not it would 

21 require essentially the ballast to step outside of its 

22 existing footprint. That in general the trend in 

23 industry is to get smaller and smaller and to have 

24 smaller ballasts instead of larger. And so we were 

25 just looking at things that would require enlarging of 

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1 the existing ballast footprint. 

2 MR. BALLO: Are you saying that the 

3 footprint would affect the fixture it goes into? The 

4 screw holes would match up, for example? 

5 MS. LEHR: Right. I mean, there could be 

6 additional changes that go along. I guess if you had 

7 any comments on what you felt was appropriate to look 

8 at for changes in size we would welcome those. 

9 MR. BALLO: I was just getting at it seems 

10 odd to talk about size and weight constraints unless 

11 you define, you know, the constraints that you are 

12 actually operating in. I understand you may affect 

13 the size or the weight -- 

14 MS. LEHR: Right. 

15 MR. BALLO: -- but at what point does it 

16 become a problem? 

17 MR. RABA: Charlie, follow-up? 

18 MR. STEPHENS: I’m Charlie Stephens. I’ve 

19 been doing, like I said, a lot of ballast work lately. 

20 And all of the ballasts that I’ve been installing are 

21 all quite a bit smaller as a package than what they -- 

22 than the one I removed. They still fit in the same 

23 slot, they’re designed to fit in the same space, but 

24 the newest ones are quite a bit smaller and lighter 

25 than the old ones. It’s not to say that you couldn’t 

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1 put them back toward the size of the one I replaced 

2 was. And I’m only talking about four-foot, you know, 

3 and eight-foot fixtures here, for the most part. It’s 

4 different in the small compact fluorescent type 

5 fixtures, of course. But I don’t know that you 

6 couldn’t expand the size of the package at least 

7 somewhat and still have it be smaller than what I’m 

8 taking out of the fixture now. 

9 MS. LEHR: Okay. 

10 MR. ERHARDT: Yeah, I have -- Bob Erhardt, 

11 Philips Lighting Electronics. I have a response for 

12 that, yes. On retrofits, if you’re talking about 

13 luminaires from 10, 15 years ago, they were designed 

14 around the -- what’s called the “old style” ballasts. 

15 The newer ballasts have a cross-section that have 

16 allowed luminaire manufacturers to reduce the size of 

17 their luminaires and use less material and in some 

18 cases have better optics. And, no, you may not 

19 increase the cross-section. Length luminaire 

20 manufacturers tend to be able to accommodate, but the 

21 cross-section is what generally determines, you know, 

22 it’s the width and the height. And I know we had a 

23 big industry discussion on whether or not the new 

24 standard should be 1.1 inch or 1.18 inches or one inch 

25 because this affects the ballast cover design in the 

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1 luminaire. Maybe Fred Carpenter can comment. 

2 MR. CARPENTER: Fred Carpenter, Acuity 

3 Brands Lighting. Everything that Bob said is 

4 completely accurate. If you’re talking about, you 

5 know, retrofitting a product that was made five, ten, 

6 15 years ago, then there was plenty of room. As the 

7 ballasts have gotten smaller, the luminaires have 

8 gotten smaller, there have been optical efficiency 

9 gains in doing that. And, you know, as Bob pointed 

10 out, there are a number of luminaire designs that can 

11 accommodate, can increase in length of the ballast, 

12 but many of the luminaire designs out there now are 

13 designed around the current smaller size of the 

14 ballasts. 

15 MR. RABA: Yes, comment in the back? 

16 MR. COOK: Keith Cook from Philips Lighting. 

17 Even on the length you have to be careful because we 

18 have run into considerations for luminaires that have 

19 emergency ballasts also in there. And so you do end 

20 up with a constraint sometimes for that accommodation 

21 also. 

22 MR. RABA: Interesting point. Thank you. 

23 Ali. 

24 MS. LEHR: Okay. So now we’re going to move 

25 on to the engineering analysis. 

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1 The purpose of the engineering analysis is 

2 to develop a relationship that identifies the 

3 manufacturers’ selling price necessary for achieving 

4 increased BEF. The results of this analysis are then 

5 used downstream for the lifecycle costs and payback 

6 period analysis and the national impact analysis. 

7 This slide shows step-by-step the general 

8 methodology DOE used for the engineering analysis. 

9 DOE began by looking at all 70 product classes and 

10 choosing a few representative product classes to 

11 analyze in more detail. Within those representative 

12 product classes DOE identified baseline models which 

13 generally represented the lowest BEF, most common 

14 ballast in that product class. DOE then selected 

15 higher BEF substitutes for the baseline models while 

16 trying to maintain similar light output. 

17 For both the baseline and higher BEF 

18 substitutes, DOE calculated manufacturer production 

19 costs using teardown information when possible. After 

20 developing candidate standard levels for 

21 representative product classes, DOE then scaled those 

22 levels to product classes that were not directly 

23 analyzed. 

24 Of the 70 total product classes DOE selected 

25 ten to be representative. DOE bases its selection on 

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1 those product classes with the highest volume 

2 shipments. DOE selected a representative product 

3 class for ballasts that operate each lamp type and 

4 within the most popular category which were ballasts 

5 that operate four-foot medium bi-pin lamps in the 

6 commercial sector. Doe selected four representative 

7 product classes. 

8 After selecting these representative product 

9 classes DOE then selected a baseline ballast. 

10 Typically the baseline ballast either just met the 

11 existing energy conservation standard or represented 

12 the most common lowest BEF ballast available in that 

13 class. In some cases DOE selected multiple baseline 

14 ballasts to ensure consideration of different ballasts 

15 and their associated consumer economics. 

16 For example, for ballasts that operate two, 

17 four-foot, medium bi-pin lamps in the commercial 

18 sector DOE selected both a T12 rapid start and T8 

19 instant start ballast as baselines. 

20 After identifying baseline ballasts DOE then 

21 selected higher BEF substitutes. This slide shows an 

22 example of the baseline and higher BEF units for the 

23 ballasts that operate two, four-foot, medium, bi-pin 

24 lamps in the commercial sector. As you can see, 

25 there’s both the T8 and T12 baseline and both BEF and 

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1 ballast deficiency increase with increasing CSLs. 

2 For ballasts for which DOE did not have test 

3 data for the measured BEE or BEF, DOE intends to 

4 conduct additional testing for the NOPR. 

5 DOE invites comments on its selection of 

6 representative product classes baseline ballasts and 

7 higher BEF substitutes. By statute DOE is required to 

8 evaluate the maximum technologically feasible level in 

9 each product class. DOE recognizes that commercially 

10 available ballasts may not include the max tech level. 

11 DOE conducted manufacturer interviews to see if any 

12 working prototypes existed that had higher BEF’s than 

13 commercially available ballasts. Although there were 

14 no prototypes there was some indication that the BEF 

15 could be improved by using improved components. 

16 DOE invites comments on the max tech level 

17 which represents the highest CSL identified for each 

18 product class. 

19 MR. RABA: Comments on product classes, 

20 representative product classes, baseline ballasts and 

21 the systems chosen? 

22 MR. ERHARDT: Bob Erhardt, Philips Lighting 

23 Electronics, Chairman of the NEMA Ballast Section. 

24 Actually in our discussions in the NEMA Ballast 

25 Section, we felt Navigant did a pretty good job with -

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1 - a very thorough job with defining product classes 

2 and we think they did a good overall analysis of the 

3 industry. 

4 We have some comments, again, as we said, 

5 about scaling factors. And now that I understand that 

6 your scaling factors and some of your levels came from 

7 using the same resistor for BEE measurement thing 

8 become a little clearer and we’ve already commented on 

9 using lamps for differing resistors. But overall we 

10 thought that the overview of the industry was quite 

11 thorough and balanced. Our only question, and we’ll 

12 get into that in the next sections are, you know, do 

13 some of the volumes of some of the areas justify 

14 having 72 classes? 

15 We do understand though that reducing them -

16 - the number of classes will be difficult. We may 

17 actually be asking you to increase the number of 

18 classes when you get to HO and say, you’ve lumped T8s 

19 and T12s into the same category on the HO level, 

20 although we don’t object to having T8s and T12s in the 

21 same category on medium bi-pin. 

22 But, overall, we feel that Navigant did a 

23 good job. 

24 MS. GUPTA: Mimi Gupta, Navigant Consulting. 

25 I just wanted to make a clarification when it comes to 

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1 the use of the same resistor over multiple valve 

2 factor ins. There’s two scalings that we’re dealing 

3 with here. For the test procedure one resistor was 

4 used for all three ballast factor bins. But then in 

5 the correlation from BEE to BEF, that we tried to 

6 account for that fact so that we ended up with a BEF 

7 that was representative of a low and high ballast 

8 factor. So, if the scaling that you see and we’ll 

9 talk about later in the preliminary analysis energy 

10 conservation standard doesn’t look representative of 

11 low, medium -- or low, normal, and high ballast factor 

12 ballasts then that should be -- because of the -- 

13 MR. ERHARDT: All right. Bob Erhardt again. 

14 I think your scaling factors are pretty close. I 

15 didn’t find big differences. Like I said, I think you 

16 had plus/minus 2 percent on one of them and when I did 

17 an analysis of actual product I had minus 3.5 and plus 

18 1. That’s pretty close considering there were two 

19 different approaches taken to the analysis. So 

20 overall we think that the analysis was pretty close 

21 and we’re just going to have some comments on some 

22 small areas where we would like to tweak things a 

23 little bit. 

24 Oh, and I’ll make this comment again. I 

25 don’t think I can make it enough. To redesign a 

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1 product line is a significant undertaking. And we 

2 strongly recommend that you try to accommodate. We do 

3 have lines -- all of the major manufacturers have 

4 lines of premium products that are pretty close, I 

5 guess we would call them your max-tech. We can argue 

6 with they can be increased another percent or so in 

7 efficiency, but we really question the return on 

8 investment there. Because of the -- you know, it 

9 could cost a million dollars to redesign a whole 

10 product line by the time that you put the engineering 

11 resources into it, and you put your -- the disruption 

12 to your factor when you do engineering builds and your 

13 testing. And, as I say, we’re -- we consider this a 

14 mature technology. We don’t think there are big gains 

15 to be made beyond our quote/unquote “max-tech”. And 

16 we hope you will take a good look at our existing 

17 premium products and try to accommodate existing 

18 products on the market with the regulations. 

19 Again, I think all of us are looking at 

20 controls. You’ve just heard how a building is saved 

21 60 percent energy savings by using building -- by 

22 using dimming controls. You know, don’t make us go 

23 after another 1 or 2 percent when 30 to 50 percent and 

24 even 60 percent energy savings are out there for us to 

25 go after. 

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1 MR. RABA: Go ahead. 

2 MR. McGARAGHAN: Mike McGaraghan, California 

3 Utilities. I wanted to find out a little bit more 

4 about testing that DOE did of these products that 

5 resulted in the various CSLs proposed. My 

6 understanding is that DOE conducted its own testing 

7 because values from catalogues or CEC database or CEC 

8 database are often not accurate enough for your 

9 purposes. But we aren’t able to translate. We don’t 

10 know which ballasts you tested. So it’s hard for us 

11 to comment on whether you’ve captured the most 

12 efficient products. 

13 The tables that you provide in the Appendix, 

14 I think it’s 5C, there’s actually some formatting 

15 issues in them. And in one of the columns it’s 

16 supposed to show the number of lamps. It doesn’t. 

17 And the numbers have gotten mixed up in a different 

18 column, I think. So that would be one thing that 

19 would be really helpful is just to see that 

20 reformatted. 

21 Another thing that would be very helpful is 

22 to see that table with the catalogue BEF values. 

23 The best we can do is take a look at the 

24 existing product lists and catalogues and databases 

25 out there. And from everything that we’ve seen, the 

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1 values are much higher than the CSLs proposed here. 

2 For example, for the main product class, two-lamp 

3 normal ballast factor instant start, the CEC database 

4 has several models there that are up at 1.64, 1.65 and 

5 even one at 2.0. And that may be an outlier, but your 

6 max-tech is, I think, 1.55. So that would be one 

7 thing that we would appreciate. 

8 In addition, I think what we found is a 

9 bigger range of efficiencies in the existing product 

10 databases. So even if the numbers are just shifted 

11 down a little bit, it still seems like maybe you 

12 haven’t captured as much of the market as you could 

13 have potentially. I think in some of the product 

14 classes the range of even the CEC list which is 

15 supposed to be just efficiency products, the range 

16 inefficiency in that product class is often bigger 

17 than the range that DOE has provided from their 

18 baseline to their one CSL. So maybe various people 

19 have comments on why that’s happened or the background 

20 behind that. 

21 MR. RABA: Bob. Thank you. Thank you, 

22 Mike. 

23 MR. ERHARDT: There are -- you have a 

24 reference to a 1.64 -- there’s a 1.64 BEF on a two 

25 lamp normal on the CEC database. And it’s shown four 

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1 times by the same manufacturer under four different 

2 names. It’s one ballast. And we can question other 

3 than that it drops down to then if you go after the 

4 next product you’re dropping down to 1.6 and the CSL 3 

5 number that DOE has talked about is 1.56. Well, the 

6 difference -- it’s only a 2.5 percent difference 

7 between the 1.56 and the 1.6. It’s not a dramatic 

8 difference. We do think that Navigant did a pretty 

9 good job. 

10 When you look at the -- when you look at 

11 what the top four manufacturers can supply in a two12 lamp normal output, the range is from -- these are the 

13 highest efficiency ballasts offered on the California 

14 Energy Commission website from the four major 

15 manufacturers that ranges from 1.525 to 1.64. Those, 

16 again, that’s the highest from the four major 

17 manufacturers. So if you’re going to try to set 

18 something -- and one of those numbers doesn’t even 

19 meet, and it’s from a high-efficiency series from that 

20 manufacturer, that doesn’t even meet the 1.56 that DOE 

21 is requiring. So I think if you look at -- in general 

22 -- the numbers proposed by Navigant, they do represent 

23 the state-of-the-art of what’s on the market today. 

24 MR. RABA: I think it would be most helpful 

25 -- I know you’re both are familiar with visual things 

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1 that we can’t see here in the room. 

2 Any other thoughts or comments? And perhaps 

3 in your written comments you might want to illustrate, 

4 with your comments, your concerns, your questions, and 

5 likewise, Bob, what you found too, and in your finding 

6 as well. Some visual presentation because we can’t 

7 imaging this in our heads what you’re looking at 

8 there. I think it would be good content both, but I 

9 just can’t visualize it. 

10 MR. deLASKI: I think the question is really 

11 one for Navigant or for the Department which is that 

12 we observe, looking at published data, BEFs higher 

13 than what you have shown to be the highest possible. 

14 I’m asking the Department how did you screen out or 

15 how did you eliminate? Bob is giving one hypothesis 

16 but I’m interested in the Department’s view on how you 

17 got rid of those values that are higher than what are 

18 in the document. 

19 MR. RABA: I’ve got four hands here coming 

20 up right away. Let’s go around. 

21 MS. LEHR: If I can just make an initial 

22 comment, I guess. 

23 MR. RABA: Fine. 

24 MS. LEHR: We didn’t take any steps to 

25 eliminate values that we thought might be too high. 

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1 All the data that we obtained for this analysis is 

2 provided in that TSD chapter and if the formatting is 

3 incorrect, then we’ll correct it. 

4 We, in general, found from our testing that 

5 the tested values were lower than the catalogue 

6 values. And we also found that the range of values 

7 was much smaller than what the catalogue value showed 

8 there was. So I guess your observations are similar 

9 to ours and we tried to provide the test data so that 

10 everyone would have access to what we had access to. 

11 MR. deLASKI: So, as a follow-up, could you 

12 check on that table and find out if it is formatted 

13 improperly so we just find that out today? That would 

14 help us to be able to evaluate the data. 

15 MS. LEHR: Sure. 

16 MR. McGARAGHAN: Can I add just real quick 

17 that there’s two sides to that question. One is the 

18 formatting of the table. The other is providing the 

19 BEFs, the catalogue BEFs of those products so that we 

20 could see. Otherwise we have no frame of reference so 

21 we don’t know which products were tested and we don’t 

22 know whether to recommend or how to comment on whether 

23 you’ve captured the whole market or not. 

24 And this is just for setting up a max-tech 

25 level. Not even talking about standards yet, just 

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1 establishing max-tech. 

2 MR. RABA: Follow-up, Bob? 

3 MR. ERHARDT: Yeah. I am puzzled. I have 

4 another important comment I wanted to make. The 

5 California Energy Commission website and the CEC 

6 websites should, by definition, be test data from 

7 certified laboratories, catalogues are not. You know, 

8 we have a long history of we talk about commercial 

9 data and we talk about certified data. 

10 And I can comment a little it about what I 

11 think was going on with Navigant because when I see 

12 their max-tech, what do they have, a 1.56. Well, I 

13 see a product on the CEC website from actually the 

14 largest ballast manufacturer that is coming in at 

15 1.58. Well, that’s pretty darn close and I think what 

16 they did was try to take products from their 

17 representative categories of max-tech products and 

18 different manufacturers on their max-tech lines, one 

19 will be higher than the other in this model and one 

20 will be higher than that model in the other model. 

21 There are also some differences even on the certified 

22 measurement with the -- between labs. And remember, 

23 we are still saying you’re going to have a 3 percent 

24 difference. You have a plus/minus 3 percent 

25 difference even using the ballast deficiency test 

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1 method. 

2 Our experience is that our testing is, we 

3 think, conservative. We compare our test data. We 

4 benchmark against other manufacturers. And, for 

5 instance, we talked earlier about whether you allow a 

6 one-minute warm-up or whether you allow 15 minute to a 

7 half hour warm-up. When we do our measurements, we do 

8 them one-minute warm up which, actually, to our 

9 surprise was making us very conservative because the 

10 ballasts do pick up another percent or two when you 

11 run them for 15 minutes or a half hour or an hour. 

12 So there are still some differences on the 

13 test data, but if you’re going to be looking at the 

14 data, again my approach was to look at the highest 

15 technology products form the four major ballast 

16 manufacturers and draw some conclusions from that 

17 because that is the maximum technology. I mean, it is 

18 the filament cut out, it is the -- you know, when 

19 you’re talking about these program starts and it is 

20 the -- this is the NEMA premium stuff. And so this is 

21 what the four major manufacturers have for their high22 end product. 

23 There’s going to be -- you know, yes, there 

24 are a couple percent, three -- you know, 3 percent 

25 difference between manufacturers in measurement method 

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1 and maybe in their technology. But, again, is that 

2 worth redesigning product lines for, I guess, is our 

3 question? Or, you know, is it going to -- is the 

4 market better served by getting rid of the other 80 

5 percent of the product that don’t meet the high tech 

6 level of the major manufacturers premium product 

7 lines. 

8 MR. RABA: Mimi? 

9 MS. GUPTA: Mimi Gupta, Navigant Consulting. 

10 So, just to respond to your questions. The way the 

11 analysis was conducted is that we did purchase the 

12 highest efficiency products from the major 

13 manufacturers and tested them. And of those that we 

14 tested, we chose the highest efficiency one as our 

15 highest standard level. 

16 I mean, another -- we’ve discussed a couple 

17 of possible sources of why the data is different than 

18 CEC than catalogue. Another one is that we 

19 implemented a different test procedure. We used the 

20 ballast efficiency test procedure and correlated it to 

21 ballast efficacy factor which might account for some 

22 of that change depending on how good the correlation 

23 is. 

24 In terms of the appendix, unfortunately, my 

25 version of the TSD is before it was PDFed. So the 

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1 appendix looks fine in my version. You’re welcome to 

2 come and take a look at it. But if it looks 

3 incorrect, the web will definitely fix that. I see no 

4 problem with including the catalogue BEFs as the 

5 source of reference is that would be helpful. 

6 MR. McGARAGHAN: What about, as Bob 

7 mentioned, the catalogue BEFs are provided by the 

8 manufacturers, the CEC lists have to go through a 

9 certified lab, could you provide those CEC values 

10 instead, or does that create more -- 

11 MS. GUPTA: So you mean do a cross-reference 

12 to the CED database? We’ll have to look into that. I 

13 can’t answer that right now. 

14 MR. McGARAGHAN: I guess just as long as 

15 whatever you provide is labeled if it’s from catalogue 

16 or if it’s from CEC -- 

17 MS. GUPTA: Sure. 

18 MR. McGARAGHAN: -- that would be helpful. 

19 Thank you. 

20 MR. RABA: I’m sorry. Heading on back there 

21 to you, sir. Comment? 

22 MR. PLASKON: Jeff Plaskon, GE Lighting. 

23 MR. RABA: Use the microphone, please? 

24 MR. PLASKON: I think I can talk loud 

25 enough. Jeff Plaskon, GE Lighting. Just as a 

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1 benchmark from our round robin testing that we did 

2 validating the BEE metric, five major manufacturers 

3 were tested and the test results were anywhere between 

4 89.8, I believe, up to 92 percent for that two-lamp 

5 normal. So the highest being the 92 percent listed 

6 for max-tech. So I think what’s important is to look 

7 at ballast efficiency as a good benchmark of where 

8 that BEF should be as opposed to our catalogue ratings 

9 of backing into a ballast deficiency. 

10 I think that’s one of the reasons why we’re 

11 trying to lead to a more accurate measurement with 

12 ballast efficiency to get moved back up the ladder to 

13 BEF. Because we’re avoiding that error measurement 

14 with the lamp. 

15 MR. RABA: Did you get that? Most of it. 

16 Okay. 

17 MR. PARISELLA: Joe Parisella, Sylvania. 

18 Yeah, I want to elaborate on what Jeff said. 

19 Basically I think the problem lies here with a 

20 correlation between the ballast efficiency and BEF. 

21 And there’s some distribution that goes around that. 

22 So if, let’s say the nominal value at 90 percent was 

23 1.58 as we might expect from CEE, but if you have a 

24 distribution on one side of the BEF and then in the 

25 efficiency measure was on the other side, you could 

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1 see some type of variation here. You might even see a 

2 variation in the other direction. 

3 So, I don’t know if we have a good 

4 correlation right now of BEF versus ballast efficiency 

5 but, you know, I think that’s something that we have 

6 to take into consideration. 

7 MR. RABA: Charlie. 

8 MR. STEPHENS: Charlie Stephens. Yeah, I 

9 think this is a real important set of issues to get 

10 around. I can understand why the catalogue values 

11 might be different. But just speaking about CEC 

12 numbers and CEE numbers, and correlations, I mean, if 

13 you get a .05 difference in BEF that is kind of what 

14 we’re talking about here, you know, the difference 

15 between 1.58 and 1.53, say, something like that, 

16 you’re kind of implying that several 2.5 percent, 2 

17 percent difference in ballast deficiency here, we’re 

18 arguing over whether we should talk about 1 percent 

19 increase in the ballast efficiency. So there’s -- we 

20 really need to get this straightened out and find out 

21 whether the correlation is a problem or what the 

22 problem is. Because I hate to be arguing over 1 

23 percent ballast efficiency improvements when we can’t 

24 even get the correlation straight within 3 percent or 

25 4 percent. So, somewhere along here I would like to 

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1 know what numbers we’re working with for regulatory 

2 purposes. 

3 MR. RABA: Can you respond? 

4 MR. ERHARDT: Yeah, I don’t think it was -- 

5 this is Bop Erhardt again. I don’t think it was a 

6 correlation that gave -- well, maybe we can have an 

7 off-line discussion. But, again, Navigant found a 

8 1.56. I see a product that is listed in the CEC site 

9 at 1.58 that from our testing has the highest BEF, 

10 higher than the one that is on the CEC website at 1.64 

11 from our testing. Again, we benchmark -- the 1.58 is 

12 our product. We benchmark it against our competitors 

13 and when we test one against the other in the lab our 

14 1.58 was higher than the 1.64. And Navigant says the 

15 highest one they found, if it was us, they came up 

16 with 1.56. Well, 1.56 to 1.58 is pretty darn good 

17 correlation, if you ask me. If that’s indeed what 

18 happened. 

19 MR. STEPHENS: Charlie Stephens. 

20 MR. RABA: Wait. 

21 MR. STEPHENS: Yeah, I want to follow-up on 

22 that. 

23 MR. RABA: Okay. Follow-up on that Charlie. 

24 MR. STEPHENS: Yeah, but again we’re getting 

25 it down to where we’re talking about a percent or two 

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1 on the ballast deficiency side within those two or two 

2 and a half points. 

3 MR. ERHARDT: The BEF measurements. 

4 MR. STEPHENS: Right. And if I take a 2.5 

5 point what you were talking about, I mean, it equates 

6 over to a 1 percent or so -- 

7 MR. ERHARDT: 1 percent. 

8 MR. STEPHENS: BE difference which is what 

9 we’re arguing potentially about. So I don’t want to 

10 just understand where it comes from and I’m thinking 

11 it might come from the way -- you aren’t using diodes; 

12 right? 

13 (Simultaneous conversation.) 

14 MR. STEPHENS: -- using resistors to do your 

15 testing? 

16 MR. ERHARDT: No, this was a real ANSI BEF 

17 measurement. 

18 MR. STEPHENS: And were you using resistors 

19 to do your testing or the proposed method or -- 

20 MS. LEHR: Right. The BEF numbers that are 

21 reflected in these tables are based on the test 

22 procedure being discussed this morning. 

23 MR. STEPHENS: Being proposed. 

24 MS. LEHR: So they would be a ballast 

25 efficiency measured with a resistor and then using the 

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1 correct slope to translate that to BEF. 

2 MR. STEPHENS: Okay. So maybe that’s 

3 something of what we’re seeing here. But whatever it 

4 is, I would love to see it get resolved. Thank you. 

5 MR. RABA: In the back first, please? 

6 MS. GUPTA: Can I just make one comment 

7 related to this, Jim? Sorry. 

8 MR. RABA: There you are. 

9 MS. GUPTA: Mimi Gupta. In the appendix 

10 when you guys can actually read it properly, there’s 

11 also the measured BEF for the ballasts for which that 

12 was tested based on the light output measurements. So 

13 -- 

14 MS. LEHR: Right. So the appendix -- 

15 (Simultaneous conversation.) 

16 MS. LEHR: The appendix would have ballast 

17 efficiency according to the resistor based test method 

18 and BEF according to the current test procedure which 

19 is the using the lamp to measure BEF. 

20 MR. RABA: I saw a big not and a thumbs up 

21 from Charlie Stephens. You can’t see that in the 

22 record, you know. 

23 MR. STEPHENS: Now you can. 

24 MR. RABA: Yeah, sure. 

25 In the back, sir, you had a comment? 

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1 MR. PLASKON: Jeff Plaskon. I was just 

2 going to make -- 

3 MR. RABA: We can hear you here, but the 

4 court reporter is kind of hiding back here and having 

5 difficulty. 

6 MR. PLASKON: Thank you. Jeff Plaskon, GE 

7 Lighting. I was just going to use as an example the 

8 normal ballast factor with the CEE ratings of 1.58 for 

9 the ballast efficacy factor. Using the slope that 

10 would equate to 93.1 percent efficiency. And in our 

11 round robin testing that we’ve done, we didn’t find 

12 any valves that operated at 93 percent efficiency. So 

13 there’s obviously an error or a measurement error 

14 associated with the lamp aspect of it. So, again, 

15 important to reference back to ballasts electrical 

16 efficiency as a practical measurement that we should 

17 focus on. 

18 MR. RABA: Okay. Good. Thank you. 

19 Some more comments over here, follow-on? 

20 MR. McGARAGHAN: Just one more that I just 

21 have 

22 MR. RABA: And you are, sir? Mike? 

23 MR. McGARAGHAN: Sorry. Mike McGaraghan. 

24 MR. RABA: Thank you. 

25 MR. McGARAGHAN: I want to make sure the 

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1 discussion stays on max-tech. I understand that we 

2 would likely not land at a standard level that 

3 couldn’t be met by the major four manufacturers. But 

4 if DOE is attempting to identify that max-tech 

5 commercially available, there would be no reason to 

6 limit yourselves to just the major four. So that may 

7 explain why there are certain values that were above 

8 the round robin -- values that came out of that. 

9 MR. RABA: Follow-on? Thank you. Follow10 on? 

11 MR. PLASKON: Follow-on. 

12 MR. RABA: Jeff Plaskon 

13 MR. PLASKON: The alternative to -- 

14 alternatively there’s a compliance problem, you know. 

15 And that came up the first thing this morning, but, 

16 you know, that’s something else that, you know, I 

17 think folks in this room should have an interest in 

18 bringing to the Department’s attention. If there’s a 

19 compliance problem people out there claiming 

20 efficiencies that aren’t being achieved in the 

21 marketplace, let’s know about it. I mean, you’ve seen 

22 that the Department has been much more enthusiastic 

23 over the past several months and worrying about 

24 compliance problems, so, please, you know, let’s get 

25 it out in the open so that these folks who aren’t 

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1 complying can be identified and brought into 

2 compliance. 

3 I have a follow-on, but on a different 

4 topic. So -- 

5 MR. RABA: Okay. 

6 MR. PLASKON: -- I’ve got some arms up. 

7 MR. ERHARDT: This is Bob Erhardt. This is 

8 exactly the point that we are bringing up. Why we 

9 bring up measurement accuracy, the CEC website data 

10 has a plus/minus 5 percent accuracy. So it’s not to 

11 say that -- and we want to bring up this point because 

12 we feel it’s important that the Department of Energy, 

13 when they set these limits, don’t take the highest 

14 claimed measurement that you’ve seen and say that 

15 everyone has to meet that. Because you have this 

16 measurement accuracy you have to deal with. When I 

17 say that this 1.64 that we saw that’s compared with 

18 1.58, that’s -- okay, that’s 4 percent difference. If 

19 you are looking at a plus/minus and you’re looking at 

20 a life output, it’s within the measurement error. 

21 It’s not that they’re out of compliance. And we want 

22 the DOE to consider this that when you’re either in 

23 setting the limits or in determining compliance, you 

24 know, that if you’re going to use the published data 

25 and we would recommend you then take some averages or 

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1 something, you know, worst case of -- I’ll call it 

2 “worst case max-tech” is what I would like to 

3 encourage, but consider either in writing the 

4 regulation either then if it’s a 5 percent measurement 

5 write in an extra 5 percent. Well, maybe you don’t 

6 want to do that, but at least put it into the 

7 compliance that you’re only going to say they’re 

8 noncompliant if they’re up more than 5 percent. 

9 Because there is this -- this is real variation in 

10 measurement. This is lab to lab people -- diligent 

11 people trying to do the right job. This was in our 

12 round robin too, we found these differences. And it’s 

13 real. It’s just, you know, how long -- in this case 

14 it was -- like I said, we turn ours on and measure it 

15 one minute and low and behold we find, oh, yeah, you 

16 leave it on for 15 minutes or an hour and you pick up 

17 an extra couple percent. Then that gap closes quite a 

18 bit. And it’s one person’s equipment versus another. 

19 And there’s -- we’re trying to bring up how difficulty 

20 it is to do these measurements and to take this into 

21 consideration when you’re looking at compliance and/or 

22 setting a limit. 

23 MR. RABA: Reemphasize this morning’s test 

24 procedure discussion with accuracy. 

25 Yes, sir. 

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1 MR. COOK: Keith Cook from Philips Lighting. 

2 I guess I need a little clarification. I’m a little 

3 confused. For your CSLs that you’ve got here, are you 

4 proposing these as being minimum values or average 

5 values? 

6 MS. GUPTA: Well, we need to hear from 

7 Navigant. They would be minimum values that you would 

8 have to comply with. So whatever average -- yeah, you 

9 have to test four ballasts and then you report 

10 something like that, is it the 95th percent confidence 

11 interval? Yeah, you use some equation with those four 

12 tests of the ballasts to determine the reported 

13 ballasts efficacy factor. Currently that’s the way it 

14 is. And then this would be the minimum standard you 

15 need to meet with that. 

16 MR. RABA: Thank you. Charlie. 

17 MR. STEPHENS: Charlie Stephens. Half of my 

18 working life is centered on statistical analysis these 

19 days. And I’ve got to say, I mean, there’s got to be 

20 some sort of statistically valid method for how you 

21 report these things. Because if what we are seeing 

22 out there is not plus or minus 5 percent, but minus 

23 zero plus 10, then we’ve got a problem. And I don’t 

24 know if that’s what we’re seeing. But if there is 

25 any statistical validity to what’s being reported, and 

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1 that’s what I look for in my business, then it should 

2 bill plus of minus 5 or plus or minus 2.5. It 

3 shouldn’t be minus zero plus 10 consistently. So, I’m 

4 hoping that we’ll come out with some sort of what was 

5 referred to earlier as an average value statistically 

6 valid also. 

7 MR. RABA: Over here first and then in the 

8 back second. 

9 MR. ERHARDT: Yeah, what I just heard from 

10 Navigant actually has me concerned if we’re supposed 

11 to have a 95 percent -- this Bob Erhardt -- if we’re 

12 supposed to have a 95 percent confidence level that 

13 all our products meet this. Because these numbers 

14 that you’re working from are, we consider, nominal 

15 representative numbers. And when you look at the 

16 California Energy Commission compliance, somebody help 

17 me here, I think I recall that you test five ballasts 

18 and three have to comply. So it is a nominal that 

19 you’re nominal product has to meet this minimum 

20 requirement. And it’s not a 95 percent confidence 

21 level that all of your product is going to meet this 

22 requirement. If that’s the case, then we really have 

23 strong objections to the levels that you’ve come up 

24 with. 

25 MR. RABA: Interesting. 

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1 More on that is subject and topic? 

2 MR. PARISELLA: Joe Parisella, Osram 

3 Sylvania. 

4 (Simultaneous conversation.) 

5 MR. RABA: Yes, Earthjustice? Forgive me. 

6 Sorry, Joe. 

7 MR. BALLO: This is Tim Ballo, Earthjustice. 

8 I think I’m asking the same question maybe. But I 

9 take it the Department didn’t actually follow the 

10 compliance testing parameters when it tested ballasts 

11 to come up with the numbers that it used in the 

12 preliminary TSD for CSLs or for the baseline rather? 

13 MS. GUPTA: Mimi Gupta, Navigant Consulting. 

14 These do represent average numbers. That’s correct. 

15 So, I mean, if stakeholders feel that DOE should use 

16 that same equation in developing the standard levels, 

17 then we welcome that comment and we’ll consider it and 

18 revise if necessary. 

19 MR. RABA: Go ahead, Bob. 

20 MR. ERHARDT: Yeah, you can’t use average 

21 values I setting a limit and then say 95 percent of 

22 the product has to meet it. There needs to be some 

23 consistency. And to develop a 95 percent confidence 

24 level you need a significant sample size to get the 

25 statistics from it and recognize that this is a test 

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1 that each time you test one ballast it might take you 

2 two hours to test one ballast. So if you’re going to 

3 have to do 10 or 20 ballasts to get some statistically 

4 significant data out of it -- out of multiple 

5 production lots out of -- et cetera, this is a highly 

6 burdensome requirement. I mean, you’re going to have 

7 70 categories and you’re going to require us to do 10 

8 or 20 three-hour tests for each category. This is 

9 highly burdensome. 

10 MR. RABA: Follow-on, please? 

11 MR. PARISELLA: Yeah, Joe Parisella, Osram 

12 Sylvania. What Bob just said is really what I was -- 

13 something very similar to what I was going to say. 

14 Thank you. 

15 MR. RABA: Yes, thank you. 

16 Yes, sir. 

17 MR. THOMAS: I would just like to go on 

18 record -- Ed Thomas of GE -- as agreeing with both Bob 

19 and Joe in the matter that this would be extremely 

20 burdensome to require this statistical significance 

21 like this. 

22 MR. RABA: Good to know that. Thank you. 

23 Both sides. 

24 MS. MAUER: Joanna Mauer. I just had a 

25 specific question on the previous slide, the table. 

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1 Is there a reason on the CSL3 level why the input 

2 power and therefore the annual energy consumption is 

3 actually higher for CSL3 than CSL2? 

4 MS. LEHR: Sure. There’s a small difference 

5 in ballast factor. And so if you normalized the input 

6 power based on ballast factor the CSL3 would be less 

7 than the other levels. This is an abbreviated version 

8 of a table to fit on the slide. 

9 MR. RABA: And there’s more detail in the 

10 TSD, you’re saying? 

11 MS. LEHR: Yeah, there’s more detail in 

12 Chapter 5 of the TSD. 

13 MR. RABA: Mike? 

14 MR. McGARAGHAN: Mike McGaraghan. Is there 

15 also going to be more discussion on this later in the 

16 presentation? 

17 MS. LEHR: On normalized input power? 

18 MR. McGARAGHAN: Yeah, on normalized input 

19 power. 

20 MS. LEHR: I believe that later slides cover 

21 that, yes. 

22 MR. McGARAGHAN: Thanks. 

23 MS. GUPTA: Mimi Gupta, Navigant. John 

24 actually just mentioned something to me that is 

25 important to mention. So it does use -- the current 

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1 reported value calculation does use some sort of 

2 confidence interval. I don’t have it by memory. But 

3 then it also divides it by a number which bumps that 

4 number up a little bit. So I would encourage you all 

5 to look at that equation in the regulations. And make 

6 comment on whether you feel like the standards 

7 represented represent what those ballasts comply and 

8 if not how they should be shifted. 

9 MR. ERHARDT: I guess I’ll -- this is Bob 

10 Erhardt. I guess I’ll turn that back and say how does 

11 Navigant see their proposals when they’re testing. In 

12 the case of T5 your report said you tested one 

13 ballast. And you generated eight categories out of 

14 it. Is that what the report said? 

15 MS. LEHR: I don’t think so. 

16 MR. ERHARDT: Okay. I’ll look for it. But 

17 the sample size that Navigant used is not 

18 statistically significant. It’s just a -- you know, I 

19 think I heard a sample size of three. That’s not 

20 going to -- that’s not a statistically significant 

21 sample size, especially when you bought it from one 

22 location with one date code. And so if you’re going 

23 to require compliance with a statistical confidence 

24 level, then, yes, we would like to know how you’ve 

25 come up with requirements that show what products can 

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1 meet with that confidence level, how you’re basing 

2 your requirements and saying that they can be met with 

3 that confidence level. 

4 MS. GUPTA: Mimi Gupta. For the preliminary 

5 analysis I believe we tested three ballasts of each 

6 model that we tested. And then these numbers 

7 represent an average of those. If stakeholders 

8 believe that that number should be increased, the 

9 number of ballasts tested per model should be 

10 increased in order to set a minimum efficiency 

11 standard, then I would encourage you to submit 

12 comments saying that and how many it should be. 

13 MR. RABA: Much to think about; written 

14 comments, please, we welcome those. Most helpful. 

15 We’ve captured what we’ve spoken about today so far. 

16 And additional thoughts as you think about it when you 

17 go home. 

18 But is there more on this discussion for 

19 this particular topic? 

20 (No response.) 

21 MR. RABA: Should we move on? Let’s do 

22 that. 

23 Ali. 

24 MS. LEHR: After CSLs were developed DOE 

25 calculated manufacturer production costs. These costs 

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1 were calculated from a tear-down analysis. In a tear2 down a ballast is taken apart so that all the 

3 components can be identified. With this information 

4 DOE then estimates the material and labor costs 

5 required to assemble the ballasts. However, DOE is 

6 not able to tear down all ballasts due to potting. 

7 For those ballasts that were not able to be torn down, 

8 DOE developed manufacturer production costs by 

9 comparing retail prices to tear down results. 

10 After determining manufacturer production 

11 costs DOE then used publicly-available information to 

12 determine manufacture mark-ups. DOE found the average 

13 manufacturer mark-up to be 1.5 and therefore applied 

14 this mark-up to calculate manufacturer selling price. 

15 Calculations were verified with confidential prices 

16 provided by manufacturers. 

17 The following table shows the manufacturer’s 

18 selling price associated with each CSL for ballasts 

19 that operate two, four-foot, medium, bi-pin lamps in 

20 the commercial sector. As you can see, the MSP for T8 

21 ballasts was determined using tear down information. 

22 However, the MSP of the T12 baseline ballast was 

23 determined using the retail price scaling method 

24 because this ballast was potted. 

25 As you can see, the prices of the two 

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1 baseline ballasts are significantly different 

2 indicating different economics for these two 

3 consumers. This difference is consistent with 

4 information from manufacturers and trends observed in 

5 retail prices. 

6 Similar to the fact that DOE could not tear 

7 down the T12 baseline ballasts there were five 

8 representative product classes for which all ballasts 

9 were potted. For these classes DOE used the retail 

10 price scaling method to determine manufacturer 

11 production costs. DOE requests comment on the scaling 

12 method and also it requests comments on its estimates 

13 for overhead and manufacturing markup. 

14 MR. RABA: Scaling techniques, markup? 

15 Comments? Questions? 

16 (No response.) 

17 MR. RABA: Wow. Last call. Quickly. 

18 MR. ERHARDT: Yeah, we commented -- this is 

19 Bob Erhardt, Philips Lighting Electronics, NEMA 

20 section chair. 

21 We find that using teardown analysis to 

22 develop end product costing to be very difficult even 

23 when we’re doing competitor analysis and we know what 

24 our production costs are and we know what we pay for 

25 components. And we feel that Navigant has taken on a 

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1 very ambitious undertaking by trying to come up with 

2 accurate cost analysis using teardown analysis. 

3 NEMA -- we appreciate the difficulty and the 

4 reason we haven’t been able to give you data before 

5 and we know the reason you had to do this was because 

6 we didn’t give you the data. We are attempting to 

7 come up with some confidential sanitized 

8 differentiation numbers for our written comments. 

9 It’s not clear we’re going to be able to accomplish 

10 this but through our confidential NEMA business unit 

11 we’re going to try to supply from each company, at 

12 least on the -- you know, at least where we see some 

13 issues such as more efficient ballasts are cheaper to 

14 build than less efficient ballasts. We’re going to 

15 try to come up with some better representation of 

16 those numbers for you. 

17 MR. RABA: Thank you. Let’s keep moving. 

18 Quickly, Andrew. 

19 MR. deLASKI: I think that’s great. I think 

20 it’s really valuable to have the industry provide that 

21 kind of data and we see it in other dockets both with 

22 NEMA and with other trade associations have been very 

23 helpful in providing that kind of data. 

24 I also think it’s critical that the 

25 Department continue with the teardown approach as 

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1 well. Because having both I think is a robust way to 

2 approach the docket. Especially given that you’re not 

3 sure you’re going to be able to get the data. 

4 MR. RABA: That was Andrew deLaski. 

5 Okay. Let’s just move on now. 

6 MS. LEHR: No more request for comment. 

7 In response to framework document, DOE 

8 received comments that upcoming safety and hazardous 

9 material regulation could affect the price and 

10 efficiency of commercially available ballasts. So DOE 

11 requests more information on the specific impact these 

12 regulations might have so that DOE can assess how the 

13 requirements may affect payback calculations? 

14 MR. RABA: Safety requirements, system 

15 requirements? 

16 MR. ERHARDT: Bob Erhardt, Philips Lighting 

17 Electronics. Yeah, I think this comes from our 

18 comments from two years ago. There has been some 

19 progression and it’s still not clear to us if there’s 

20 going to be impact from some of this safety 

21 regulation. The IEC which is the international 

22 standards body for -- and it has a lighting section, 

23 has just adopted requirements for end-of-life 

24 circuitry on T8 lamps. Previously it had only been on 

25 T5 and narrower diameter lamps. At this time we don’t 

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1 know if it’s going to be a U.S. requirement. 

2 Now, ANSI has not -- American National 

3 Standards Institute -- the T8 lamp in this country is 

4 not an IEC lamp. So by one interpretation we would 

5 not have to add end-of-life circuitry to the T8 

6 ballasts. End-of-life circuitry especially for a 

7 parallel lamp product is costly and will affect 

8 efficiency. The reason it has not been a requirement 

9 in the United States is our lamps run at half the lamp 

10 current, our T8 lamps and the European lamps. And so 

11 there is a lower risk of overheating at end-of-life. 

12 But we don’t have the formal statements and 

13 regulations in place where we know that we won’t be 

14 needing that meet lists. We do know that both CSA and 

15 UL have adopted the IEC requirements for the narrower16 diameter lamps for end-of-life. If they were to adopt 

17 the IEC requirements for T8 lamps, then it would 

18 become a U.S. requirement and we would have to start 

19 redesigning our products to accommodate it. 

20 MR. RABA: Thank you. Yes, sir. 

21 MR. COOK: Keith Cook from Philips Lighting. 

22 Under the hazardous materials portion another thing 

23 that may be coming about is Rohaus compliance. And 

24 that does drive up capital costs, and it also drives 

25 up some component costs. And right now that’s being 

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1 considered as part of a NEMA call to action initiative 

2 which may be included in the Tosca Bill this year. 

3 MR. RABA: I missed some of that only 

4 because I don’t know the subject. But you can make 

5 written comments, if you wish, the bill and all. 

6 Thank you. 

7 Yes. 

8 MR. ERHARDT: Bob Erhardt. I don’t know if 

9 it’s in this question or if it’s in another. We’ve 

10 also had discussions that some of the RoHS 

11 requirements, lead-free solder, for example, will have 

12 an impact -- well, can have an impact on product 

13 reliability and we just don’t have enough experience 

14 to know how significant that impact is and how it 

15 would affect the payback analysis. 

16 We do know that, you know, we’re in a 

17 learning curve for lead-free solder. We do know that 

18 lead-free solder has this effect called “dendrite 

19 formation” which can cause shorts between different 

20 parts of ballast circuitry. So there is a potential 

21 for lead-free solder to have an adverse effect on 

22 ballast reliability and life time. 

23 Manufacturers are in a learning curve. Our 

24 European sister companies are on the leading edge, 

25 shall we say, and we’re learning about this. But it’s 

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1 still not known if there will be an impact on lifetime 

2 significant enough to affect the payback analysis. 

3 MR. RABA: That was a RoHS amendment to a 

4 bill, did you say? 

5 MR. ERHARDT: Well, the world is moving to 

6 elimination of hazardous materials. 

7 MR. RABA: Right. And -- 

8 MR. ERHARDT: Lead-free solder is probably 

9 the most significant impact to ballasts. And lead10 free solder can have an effect on ballast lifetime. 

11 MR. RABA: Okay. Thank you. And the bill’s 

12 name is? 

13 MR. COOK: It’s called TSCA. It’s Toxic 

14 Substances Control Act. 

15 MR. RABA: Ah, thank you. 

16 MR. PARISELLA: Joe Parisella, Osram 

17 Sylvania. Yeah, stricter EMI requirements will also 

18 affect efficiency as well. 

19 MR. RABA: Electromagnetic interference? 

20 MR. PARISELLA: Yes. 

21 MR. RABA: Thank you. 

22 More? 

23 (No response.) 

24 MR. RABA: Okay. Move on, please? All 

25 done? 

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1 MS. LEHR: Almost. 

2 MR. RABA: Okay. Keep going. 

3 MS. LEHR: So after developing CSLs for 

4 representative product classes DOE then had to scale 

5 these levels to product classes not directly analyzed. 

6 To do that DOE needed to develop a relationship 

7 between ballasts that operate different numbers of 

8 lamps, have different starting methods and have 

9 different ballast factors. To develop these scaling 

10 factors DOE focused its effort on the large amount of 

11 test data obtained for ballasts that operate four-foot 

12 medium bi-pin lamps in the commercial sector. 

13 Using this data DOE found a strong 

14 correlation between BEF and total rated lamp power. 

15 DOE used the equation outlined on this slide to scale 

16 from ballasts that operate two or four lamps to 

17 ballasts that operate one, three, five, or six lamps. 

18 DOE also found an average increase in BEF associated 

19 with program start ballasts and DOE therefore uses 2.2 

20 percent reduction to scale the program start ballasts 

21 when necessary. 

22 And last, DOE found an average decrease in 

23 BEF associated with high or low ballast factor 

24 ballasts and therefore DOE use a 3.4 or 1 percent 

25 reduction when scaling to high or low ballast factor 

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1 product classes. 

2 So DOE requests comment on the methodology 

3 used to scale the nonrepresentative product classes. 

4 MR. RABA: Yes, sir. 

5 MR. ERHARDT: Bob Erhardt, Philips Lighting 

6 Electronic. We’ve commented a couple times already. 

7 We will be supplying data. I have done some analysis 

8 and will be providing it in our written response from 

9 California Energy Commission data. I do find some 

10 minor differences. The averages that I used showed a 

11 3 percent difference between instant start and program 

12 start rather than the two. The low ballast factor and 

13 high ballast or one lamp and the four lamp we found 

14 3.5 and 1 instead of 2.2 and 2.2. And we’ll be 

15 reporting on this. 

16 On this comment again, and maybe I’m 

17 misinterpreting it and maybe you can clarify for me 

18 because I just asked a question about sample size for 

19 T5 HO. I’m reading now from page 5-49, 5.10.1. It 

20 says, “For the two lamp, four-foot, mini bi-pin and 

21 T5HO normal BF product class designated by product 

22 class 44 in Table 5.10.1 hereafter referred to as the 

23 four-foot T5 mini bi-pin HO representative product 

24 class, DOE chose to analyze one baseline ballast.” 

25 What does that mean? 

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1 MS. LEHR: That means it selected one 

2 baseline for that product class instead of two. So, 

3 for example, for the four-foot medium bi-pin product 

4 class we chose both a T12 and T8 baseline. And so 

5 what that is saying is that there’s just one baseline 

6 from which to measure improvements and energy 

7 efficiency. 

8 MR. ERHARDT: And then what was that three 

9 samples of that one model? 

10 MS. LEHR: Well, there was additional 

11 testing done, but we have one representative unit we 

12 are showing for the baseline. 

13 MS. GUPTA: Right. Mimi Gupta, Navigant. 

14 The baseline -- the purpose of the baseline is to feed 

15 that into analyses like the life-cycle cost in NIA 

16 where you’re saying, well, what’s the energy 

17 consumption of my baseline? What’s the cost of my 

18 baseline? And let me compare it to a higher 

19 efficiency unit. So in terms of that T5, we took the 

20 lowest efficiency T5 we saw during tests and said, 

21 that’s our baseline. And then we took the higher 

22 efficiency ones to compare against that baseline. 

23 MS. LEHR: And in the T5 specifically the 

24 baseline is actually magnetic. So that wasn’t a 

25 ballast we tested. That was a ballast that we 

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1 essentially created to show what could enter the 

2 market if standards didn’t exist. 

3 MR. RABA: Was that helpful? 

4 MR. ERHARDT: Well, I still don’t see 

5 anywhere in the report what -- how you developed your 

6 CSL numbers. You’ve given some verbal comment, but -- 

7 MS. LEHR: I would say in general for the 

8 report product classes we had a large number of 

9 ballasts that we tested within that product class. 

10 And in general the CSLs reflects natural divisions in 

11 the test data. So, you know, the three CSLs were 

12 four-foot mini bi-pins would reflect three natural 

13 divisions in what we observed in the test data. 

14 MR. ERHARDT: Okay. All right. I’ll have 

15 to look in more detail at the report, I guess. 

16 MR. RABA: Okay. Last, go ahead. 

17 MR. McGARAGHAN: Mike McGaraghan. I just 

18 wanted to ask, and I apologize if this was covered 

19 earlier, but did the product classes that you chose as 

20 the representative product classes, were those based 

21 on market share? 

22 MS. LEHR: Right. Shipments. 

23 MR. McGARAGHAN: And so all two-lamp and 

24 four-lamp fixtures basically the ten product classes 

25 that you analyzed were the ten highest shipment 

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1 products? 

2 MS. LEHR: Correct. 

3 MR. McGARAGHAN: Okay. 

4 MR. STEPHENS: Charlie Stephens. Was there 

5 anything -- did you focus any testing on -- based on 

6 where the savings from the standards are? Like the 

7 products that will deliver the most savings so that 

8 they’re well defined and well tested and well -- and 

9 somewhat rigorously analyzed? 

10 MS. LEHR: I guess I believe those would be 

11 included in the ballasts that we chose to test. We 

12 chose ballasts from a range of efficiencies, not just 

13 the low end of the market, but also the very high end 

14 of the market. 

15 MR. STEPHENS: I was just thinking about, 

16 more, you know, focused on the stuff that’s not 

17 covered right now and that, you know, is -- you 

18 focused on -- I know you focused on this heavy 

19 shipment stuff which if you set a significant increase 

20 in the standard would deliver significant savings, but 

21 my concern is that you’ve focused a lot of analysis on 

22 something that will maybe increment a standard a tiny 

23 bit and deliver a few savings and you may not have 

24 rigorously analyzed some of the other product that has 

25 much lower shipments but where significant savings are 

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1 because -- 

2 MS. LEHR: I guess we have testing for, for 

3 example, sign ballasts as well, which shipments wise 

4 might not have huge shipments, but have some of the 

5 largest energy savings of what we’re looking at. So 

6 we have testing done for them as well. 

7 MR. STEPHENS: Okay. Thank you. 

8 MR. RABA: All good. All good. Let’s move 

9 on now to the next -- thank you very much Ali. 

10 I don’t want to fall too far behind because 

11 it’s all good discussion. Good things are bringing 

12 out. 

13 I think the next thing now is Energy Use and 

14 Markup Analysis. And we have Bob Lingard, PNNL, 

15 Pacific Northwest National Laboratory. Bob. 

16 ENERGY USE AND MARKUP ANALYSIS 

17 MR. LINGARD: Thanks, everybody. I’m Bob 

18 Lingard with PNNL. 

19 I’m going to talk about the energy use 

20 characterization and the markup analysis. These form 

21 sort of a bridge between the engineering analysis and 

22 the economic analyses. The LCC and the NIA analyses 

23 that my colleague Gavin McCormick will discuss 

24 shortly. 

25 So specifically the markup -- the markups 

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1 analysis and the energy use examining two basic 

2 questions. One, what is the annual energy consumption 

3 of our representative systems that we’ve evaluated in 

4 the engineering analysis? And, two, what are the 

5 typical markups that are applied to the manufacturer 

6 selling prices that were also developed in the 

7 engineering analysis? 

8 Let’s take a look at energy use first. It’s 

9 a rather simple equation to get to annual energy 

10 consumption. It’s the system input power times the 

11 annual operating hours. And we take a look at two 

12 different system power ratings in our analyses. I 

13 think this will get to an earlier question. One of 

14 them is the rated -- the rated system input power. 

15 The other one would be the normalized system input 

16 power. We’ll take a look at each of these. 

17 We have an example table here on this slide. 

18 In the fourth column of this table you’ll see what 

19 we’re calling the system input power. This would 

20 correspond with the measured input power for 

21 representative lamp and ballast systems developed in 

22 the engineering analysis. 

23 Here we have a baseline system and we have 

24 an energy efficient substitute. You can see we have 

25 different system input powers. The CSL1 uses less 

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1 input power than the baseline. And they have 

2 different light outputs. 

3 The next column over, the system mean lumen 

4 or mean light output. Basic criterion that applied to 

5 most of the representative lamp and ballast systems 

6 evaluated in the engineering analysis was that they 

7 had similar light output, generally within about 10 

8 percent. Now, there were some exceptions to that, but 

9 that was the general rule. 

10 So we have two scenarios that we would apply 

11 this measured system input power and normalize system 

12 input power to. The first would be a replacement 

13 scenario. And this is where much like this conference 

14 room you have a fixed layout of fixtures in the 

15 ceiling. And you don’t have the option of moving 

16 fixtures around, so it would be important to you that 

17 you have similar light output between a baseline and a 

18 substitute system. So therefore again we chose 

19 representative systems that generally had light output 

20 within 10 percent. In this case we would use the 

21 measured system input power. 

22 The other scenario we examined in the 

23 economic analysis was a new construction renovation 

24 type scenario where you’re not married to a fixed 

25 lighting layout in the system and you can actually 

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1 look at things on an equal lumens basis. So if you 

2 look over to the right-hand side of this table you’ll 

3 see where we’ve normalized the light output for the 

4 baseline system and the substitute system based on the 

5 baseline system’s light output and have normalized the 

6 system input power. So obviously the story here is 

7 for equal lumens the standards system is consuming 

8 less or it has a lower input power rating. 

9 So those are the two input powers we used 

10 for that first part of our annual energy consumption, 

11 the system input power. 

12 Now, looking to annual operating hours. DOE 

13 developed annual operating hours data from a number of 

14 DOE surveys, some of which I’m sure you’ll recognize 

15 as the lighting market characterization study, the 

16 commercial buildings energy consumption, the 

17 manufacturer energy consumption and residential energy 

18 consumption surveys. The LMC gave us annual operating 

19 hours by building type, lamp type, and different 

20 applications within these building types. We would 

21 marry that with data from the energy consumption 

22 surveys, the CBECS, the other energy consumption 

23 surveys which basically provide a distribution of U.S. 

24 buildings across census divisions in large states. We 

25 merged these data types, the operating hours by 

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1 building type, lamp type application along with the 

2 distribution of building types and this allows us to 

3 develop an operating hours distribution by census 

4 division and by large states. 

5 Now, presented on this slide you see 

6 weighted average values and these are what we used in 

7 our preliminary analyses. However, as we’ll discuss 

8 with the LCC and the NIA, we also have the capability 

9 of doing a variability or a Monte Carlo analysis which 

10 would allow you to tunnel into the different building 

11 types, lamp types, applications represented in this 

12 source data. So based on DOE’s analysis of this data, 

13 we came up with the following weighted average annual 

14 operating hours for different sectors of use, 

15 commercial, industrial, and residential. 

16 What I would like to bring your attention to 

17 on this slide is a subset of the commercial operating 

18 hours where for our preliminary analyses we took a 

19 look at the impact of lighting controls on operating 

20 hours in the commercial sector. Based on our 

21 preliminary literature review, we arrived at a value 

22 of approximately 30 percent energy savings based on 

23 lighting controls. Now, we’ve already heard some 

24 examples here today that Susan brought up and Bob 

25 echoed as well with the New York Times Building. So 

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1 there’s obviously a range of possible energy savings, 

2 there’s some exceptional cases such as the New York 

3 Times Building with 60 percent-plus energy savings. 

4 Based on our literature review we developed 

5 a 30 percent energy savings or assumed 30 percent 

6 energy savings. And we basically translated this into 

7 a 30 percent reduction in operating hours. So that 

8 would explain the difference you see in the 3400 hours 

9 and the approximately 2400 hours you see for program 

10 start ballasts on occupancy sensors. And that leaves 

11 the remaining operating hours for industrial and 

12 residential. 

13 This leads us to a couple of requests for 

14 comments. For issue number 11, we would seek your 

15 comments, no only the basis and the assignment of 

16 these end-user profiles which are detailed in 

17 considerable detail in the TSD. And in a related 

18 issue we also invite comments on the use of lighting 

19 controls. And that has been a conversation topic 

20 today and would certainly welcome your input on the 

21 scale and the timing of penetration of lighting 

22 controls and their effects on annual operating hours. 

23 MR. ERHARDT: Bob Erhardt, Philips Lighting 

24 Electronics. The NEMA discussion on this, our 

25 consensus was we have no objection. We have no better 

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1 analysis than what you’ve proposed. We think it’s 

2 reasonable. 

3 MR. deLASKI: Andrew deLaski. The biggest 

4 savings when you get to the NIA are in the sign 

5 ballasts. What did you use for hours -- operating 

6 hours on the sign ballasts? 

7 MR. LINGARD: We ran both the commercial and 

8 the industrial scenarios and my colleague Gavin will 

9 detail that in the discussion of the NIA, recognizing 

10 that they would occur in -- that they could possibly 

11 occur in those two sectors. 

12 MR. deLASKI: So you did some weighted 

13 average, we’ll get to that, I guess, but you did some 

14 weighted average. 

15 MR. RABA: And NIA is National Impact 

16 Analysis? 

17 MR. LINGARD: You’re correct, sir. 

18 MR. RABA: Okay. Thank you. Further? 

19 (No response.) 

20 MR. RABA: Wow, that was good. Keep going. 

21 MR. LINGARD: Next, to speak about our 

22 markups analysis. This is where we bridge the 

23 manufacturers’ selling price with an assumed or an 

24 estimated end-user ballast prices. And there has been 

25 some discussion of the manufacturer markups. We’re 

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1 going to focus here on the distribution chain. This 

2 happens after the manufacturer lets the ballast go. 

3 You’ll see a diagram on the left representing two 

4 potential distribution chains for fluorescent lamp 

5 ballasts. One being for fixture ballasts, the other 

6 being for replacement ballasts. The main distinction 

7 being that the fixture ballast distribution chain will 

8 involve an OEM fixture manufacturer. So basically add 

9 another step and another markup. 

10 We looked at distribution channel 

11 percentages for our preliminary analyses we based on a 

12 breakdown used also in the 2000 ballast rule. As 

13 you’ll see, we’re assuming approximately 63 percent 

14 through the OEM distribution chain and 37 percent 

15 through the wholesaler chain. The actual markups were 

16 based upon an evaluation of publicly available SEC 

17 Form 10K data. This is a pretty standard method for 

18 evaluating financial data for publicly traded 

19 companies. Such variables as net sales, cost of 

20 sales, gross profit. 

21 A small version of this analysis was done to 

22 develop the manufacturer markup for the manufacturer 

23 selling price. Based on that analysis, what you might 

24 find of interest is the markups for the OEM 

25 manufacturer are 1.51. I believe that’s pretty 

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1 similar to what was found for the ballast 

2 manufacturers, somewhere around 1.5 and then as you go 

3 down the distribution chain through electrical 

4 wholesalers lower values approximately 1.4 for the 

5 electrical wholesalers and a standard assumed value of 

6 1.13 for electrical contractors. And you’ll see 

7 baseline and incremental markups. The baseline, being 

8 basically a manufacturer -- a multiplier to take you 

9 from the manufacturers’ selling price to the end user 

10 selling price for a baseline product. The incremental 

11 as it relates to higher efficiency products is 

12 generally lower because it’s assumed certainly within 

13 the distribution chain that fixed costs such as labor 

14 and occupancy would not change significantly between 

15 efficiency levels that the labor required to 

16 distribute an energy-efficient ballast would be 

17 similar to that for a baseline ballast. So as you 

18 would expect, these incremental markups are slightly 

19 lower. 

20 And the sales tax was based on a survey of 

21 national and local and state sales taxes weighted by 

22 census data. So this is basically a weighted national 

23 average. But we also have this data on a state-by24 state and a census division level for use in more 

25 detailed variability analyses. 

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1 And that finally resulted in the weighted 

2 overall baselines markup and the weighted incremental 

3 markup that you see at the bottom of that table. And, 

4 again this flows into our LCC and our NIA analyses. 

5 And as we kind of previewed, as Bob Erhardt 

6 indicated earlier, NEMA is going to try to provide 

7 more detailed sanitized manufacturer price data. We 

8 would also seek input on typical distribution chain 

9 markups as well as detailed pricing data. You’re 

10 going to hear this echoed in our economic analyses 

11 discussion particularly with shipments any detailed 

12 data that you can supply will help us further refine 

13 our preliminary analyses as we head into the NOPR 

14 phase. 

15 So, with that I’ll open the floor for issue 

16 13. 

17 MR. RABA: Are there any confidentiality 

18 agreements on that last statement? 

19 MR. LINGARD: Very good question. We do 

20 currently have a confidentiality agreement in place 

21 with NEMA and there were some obstacles leading up to 

22 this. But we would like to continue that discussion 

23 and see if we -- actually it was in place for 

24 shipments data. I’m getting ahead of myself. 

25 So to your point with the price data, we’ll 

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1 certainly welcome that to help us validate pricing 

2 assumptions and markup assumptions. 

3 MR. ERHARDT: Bob Erhardt. Philips Lighting 

4 Electronics. Are you indicating that we could have a 

5 confidentiality on price as well? 

6 MR. LINGARD: I would need to get back to 

7 you on that. I was -- my head jumped ahead to 

8 shipments and I was -- and my mouth was saying 

9 pricing. So I’ll get back to you on that. 

10 MS. LEHR: Hello? 

11 MR. RABA: Hello. Go. 

12 MS. LEHR: Just in terms of the manufacturer 

13 selling price data that you referenced back, as much 

14 data as you can give in the public sector would be 

15 helpful because then we can actually use that data in 

16 our analysis. In terms of confidential data we’re 

17 willing to take whatever data you have is great. 

18 MR. ERHARDT: Yeah, this is Bob Erhardt. 

19 We’ve discussed -- we’ve put out a solicitation for 

20 the data to the manufacturers. What we are suggesting 

21 that we supply is without giving the absolute levels 

22 that we give you the incremental. And that can help. 

23 We thought that’s what you would need for the payback 

24 analysis. So that’s what we’re attempting to pull 

25 together. 

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1 MR. RABA: Okay. Susan. 

2 MS. ANDERSON: Susan Anderson, Osram 

3 Sylvania. Something that we also discussed in looking 

4 at the wholesalers -- electrical wholesalers, very few 

5 of them are publicly traded companies. So you find 

6 very little of the SEC formed data out there for the 

7 majority of the electrical wholesale distributors. 

8 And when we did look up -- looked on line to see what 

9 we could find, for instance, we looked at Westco, 

10 that’s one that I looked at, and they appeared to be 

11 one of the ones that was included in the analysis 

12 based on their percentage. But the market was across 

13 all their product lines. They had absolutely nothing 

14 specific to lighting much less to ballasts. 

15 MR. LINGARD: You’re correct. 

16 MS. ANDERSON: So it could be very 

17 misleading information. And our suggestion was that 

18 you go to the National Association of Electrical 

19 Distributors and see if through some of their members 

20 you could get some more accurate information in terms 

21 of wholesaler markups. 

22 MR. LINGARD: Thank you. That’s excellent -

23 - excellent suggestion. 

24 MR. RABA: Thank you. More on this? 

25 MR. HAKKARAINEN: Can I go back to issue 12? 

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1 MR. RABA: Quickly. 

2 MR. HAKKARAINEN: Quickly. 

3 MR. RABA: Quickly. Thank you. 

4 MR. HAKKARAINEN: Pekka Hakkarainen, Lutron. 

5 Bob, on the issue of use of lighting controls, there 

6 is some data available that I’m aware of for 

7 commercial buildings on energy savings. And 

8 specifically to the use of occupancy centers that you 

9 cited in the previously slide, we have reports that 

10 indicate savings anywhere between 17 to 60 percent on 

11 occupancy centers depending on the application in 

12 commercial buildings. So your 30 percent sounds 

13 reasonable as an average. 

14 As an industry I need to comment that we 

15 have -- you’re asking for the residential sector, we 

16 don’t have good data for the energy savings data 

17 currently. We are trying to develop it in residential 

18 applications. 

19 MR. LINGARD: We would welcome that input. 

20 Certainly we were focused on the commercial sector at 

21 this point. 

22 MR. RABA: That was very helpful. Thank you 

23 very much. 

24 Anything further? 

25 MR. deLASKI: Just a little follow-on. 

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1 Andrew deLaski. 

2 You know, I agree it would be great to go to 

3 get additional data from the manufacturer or from the 

4 wholesalers. Public data is best, obviously. We like 

5 the SEC data because it’s been filed with the SEC and 

6 it’s on public record and I guess folks do lie to the 

7 SEC sometimes, but we hope they don’t. And I think 

8 it’s good solid data in which to work the analysis. 

9 So to the extent that we get concerned about data 

10 that’s black-boxed to stakeholders other than those 

11 who actually have submitted it. So, we want to urge 

12 you to try to get that data out on the record as you 

13 have. 

14 MR. RABA: SEC is Security and Exchange 

15 Commission? 

16 MR. LINGARD: Yes, sir. 

17 MR. deLASKI: Think so. 

18 MR. RABA: Okay. Great. Thank you. 

19 Last call? 

20 (No response.) 

21 MR. RABA: Well, good discussion, good give 

22 and take, good back and forth. Let’s take a break, 

23 please. We are running a little behind now. So we’re 

24 going to speed up a little bit more. But keep your 

25 comments coming, they’re very good. 

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1 We’re going to be back at a quarter past 

2 three, by that clock. Let’s see, my watch is 

3 different. Fifteen minutes, Linda? Is that enough, 

4 too much? Fifteen minutes. 

5 (Brief recess taken at 3:04 p.m.) 

6 MR. RABA: Okay. Let’s get started. Thank 

7 you. The fun is over. 

8 You should find two things at your place, 

9 one the evaluation sheet, pull out -- the Department 

10 is most interested in your comments about today’s 

11 public meeting and also you should each have a copy of 

12 the attendance here by business card or otherwise. 

13 You didn’t hear that? I’ll repeat. 

14 Thanks for coming back from break. We have 

15 a lot to cover yet this afternoon. You’ll find at 

16 your places a comment sheet. You know, what can I 

17 say, they call me a lot of things, but lower the 

18 volume, I never heard, thank you very much. 

19 And also you’ll find, and hopefully if don’t 

20 let me know. We’ll give you this attendance record 

21 here for everyone who is in the room to identify. 

22 Okay. 

23 Let’s move on now. 

24 Our next presentation coming up is about the 

25 life cycle cost and payback with Gavin McCormick, 

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1 PNNL. Gavin. 

2 LIFE-CYCLE COST AND PAYBACK PERIOD ANALYSIS 

3 MR. McCORMICK: Yes, I’m Gavin McCormick 

4 from PNNL here to present some of the economic 

5 chapters today starting with the life-cycle cost and 

6 payback period analysis. So the LCC and payback 

7 period analyses are two different ways of combining 

8 the information from the markups and energy use 

9 characterization sections. And essentially what they 

10 both do is take a look at the first costs of a more 

11 efficient unit coming out of the markups section and 

12 combine that with the cost over time coming out of the 

13 energy use time characterization. More energy use at 

14 a given price is of course the major component of cost 

15 over time. 

16 The economic evaluation in the LCC and 

17 payback period analysis both take place from the point 

18 of view of a single consumer. Later the national 

19 impact analysis will take place from the point of view 

20 of all consumers in America. And, again, there are 

21 two different ways of calculating the same 

22 information. So, the lifecycle cost analysis is 

23 essentially the sum of all costs that a ballast 

24 consumer would pay over the life of one ballast. And 

25 the key input or the key output, excuse me, of that, 

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1 is the lifecycle cost savings that you might or might 

2 not experience between a base case and standards case 

3 ballast. 

4 The way that the LCC is calculated is a 

5 fairly straightforward input. You sum up the costs in 

6 each year in the base and standards case for costs 

7 that occur in the future, you convert them to present 

8 value at a discount rate. I’ll cover that more in a 

9 moment. And then you simply subtract the difference 

10 between the base and standards cases. 

11 The payback period analysis is only slightly 

12 more complicated. It’s essentially dividing the first 

13 cost of the more efficient unit into the operating 

14 costs. And both of those, excuse me, are the delta 

15 between the base case and the standards case. So 

16 classic example in the payback period would be if you 

17 spend 50 extra dollars to buy a more efficient ballast 

18 and it saves you $10 a year, the payback period is 50 

19 over 10 or five years. 

20 The payback period that we use in this 

21 analysis is known as a simple payback period because 

22 it does not take into account a discount rate. So you 

23 could imagine other ways to calculate it, but this is 

24 simply the increasing costs divided by essentially a 

25 single year’s operating cost change. And both of 

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1 these are just two different ways of getting at the 

2 same problem which is if in the typical situation a 

3 more efficient unit costs more money initially, but 

4 costs less money over time, is that or is that not a 

5 good deal for a consumer? And you can imagine 

6 different ways to answer that question. That’s why we 

7 have two independent analyses on the same subject. 

8 So, the most important input probably to the 

9 LCC and payback period analysis are electricity 

10 consumption. And we get the energy use straight from 

11 the energy use characterization so that’s nothing 

12 novel there. But then electricity prices are a very 

13 important section here. DOE actually calculates 

14 electricity prices for this purpose by combining two 

15 different sources of estimates. 

16 The first is EIA, Energy Information 

17 Administration form 861 data and that essentially is a 

18 record of prices that people have actually paid in 

19 different sectors in different states in recent 

20 record. So we go back 12 months and we combine the 

21 most recent form 861 data. 

22 You can see in this slide here we, for the 

23 preliminary analysis actually just stuck with the 2007 

24 form 861 data. We will update that to the very most 

25 recent available 12 months of most recent information 

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1 for the next stage and for the final rule. 

2 So that very precise high detail data from 

3 recent historical information is then combined with 

4 estimates of growth in electricity prices over time. 

5 And for that we turn to EIA’s Annual Energy Outlook 

6 which is one of the more sophisticated models of the 

7 entire U.S. energy economy over the next 30-year 

8 period. And the reason that we do this combination is 

9 that the form 861 data can be pulled very, very high 

10 detail and very recent information. But the annual 

11 energy outlet numbers from NEMs are typically more, 

12 rather are the only source for long-run energy 

13 estimates. So what we do is we take the recent 

14 electricity prices by state and grow them by the 

15 percentage growth rates coming out of the AEO. 

16 Once we have electricity prices another 

17 important cost input to the LCC and payback periods 

18 are insulation costs. And we actually just calculate 

19 those at the moment in the same way as the 2000 

20 ballast rule and the 2009 lamps rule. Those are based 

21 on that information as well as RS means and labor 

22 statistics data. And the basic method for that is 

23 that we find a certain number of minutes that it takes 

24 to relamp a ballast and lamp system or to actually 

25 swap out the ballast and lamp and add up the cost of 

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1 so and so many minutes of time for an electrician and 

2 one electrician’s assistant. 

3 The ballast lifetime is another very 

4 important input to the LCC. And actually even more so 

5 later to the shipments analysis. As I’ll cover in a 

6 minute. 

7 The ballast lifetime information that we are 

8 using is the same as the 2000 ballast rule and the 

9 2009 lamps rule. So we have not found a reason to 

10 change that information. But we did independently 

11 rederive it. And one interesting result is that 

12 because of the much longer operating hours in the 

13 industrial sector that my colleague Bog Lingard had 

14 mentioned in the energy use characterization, because 

15 of that many more hours per year, although you can see 

16 the commercial and industrial sectors, both share a 

17 large number of hours lifetime. You do not actually 

18 see that the commercial and industrial have the 

19 longest lifetimes in terms of years. Because you’re 

20 using the lamps in the industrial sector much more 

21 intensively. So they last more hours, but that 

22 translates into fewer years. And the reverse is true 

23 in the residential sector. The lamps actually are not 

24 typical -- I keep saying lamps, excuse me, that’s not 

25 right. The ballasts have shorter lifetimes in the 

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1 residential sector, but actually end up lasting more 

2 years because in the residential sector you typically 

3 use your lamps and your ballasts for fewer hours in a 

4 year. They’re off a lot more. 

5 One important thing that we do with our 

6 lifetimes is that we have a fairly narrow band of 

7 assumed lifetimes. One could imagine great variation 

8 in ballast lifetimes. And we have a pretty narrow set 

9 of assumptions that we have found around these average 

10 ballast lifetimes. So something that we are looking 

11 into and would be interested in input on is sources of 

12 variation in estimates of ballast lifetimes. 

13 But, for the most part, we are assuming that 

14 all ballasts last either the average lifetime, one 

15 year or two years less than that. We don’t have 

16 variation of ballasts lasting two years or 30 years. 

17 Another very important source of input data 

18 for the LCC and PBP analyses are the discount rates. 

19 There are different ways to trade off current money 

20 for money in the future. And the form of discount 

21 rate that DOE uses in the LCC and PBP analyses is the 

22 actual rate at which you could trade money now for 

23 money later. So, for the commercial and industrial 

24 sector, that comes to the weighted cover cost of 

25 capital which is to say, a company that actually had a 

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1 million dollars at the moment could trade that for, 

2 for example, $1,700,000 next year based on the 

3 interest rates that they are currently paying and 

4 receiving on their own money. 

5 So this is different from placing less value 

6 on the future. This is a discount rate which is your 

7 actual ability to trade money intertemporally. 

8 And in the residential sector, the way we 

9 make an analogous calculation is by looking at the 

10 sources of money that residential consumers have both 

11 that they are borrowing from and lending to. So, for 

12 example, we have credit card rates and mortgage rates 

13 which have particular rates of interest. And we look 

14 at the share of money that your average residential 

15 consumer has in different sources of income and 

16 savings and we calculate an average rate that they are 

17 either saving or spending on interest. 

18 So why are we doing this? This is all a 

19 calculation that lets us know, what is the rate at 

20 which consumers are currently trading money now for 

21 money later. This is a good way to determine the 

22 tradeoff between operating cost savings that occur in 

23 the future and increased costs that occur in the 

24 present. 

25 I’m seeing a confused look or two. Should I 

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1 clarify something there? 

2 (Simultaneous conversation.) 

3 (Off microphone.) 

4 PARTICIPANT: Well, I’ll take 1.7 million 

5 next year if you’re going to give it to me. 

6 (Laughter.) 

7 MR. McCORMICK: I meant to say 1.07. I 

8 apologize, yes. 

9 (Laughter.) 

10 MR. McCORMICK: Thank you for clarifying 

11 that. So, the key to this section is very much the 

12 methodology, but I’m going to present three different 

13 results and these are cherry picked to show the three 

14 different sorts of outcomes we can have here. And the 

15 results you actually see here have been updated. So 

16 if you’re going to start looking at the precise 

17 numbers, you’ll want to look at the handout you 

18 received today. Don’t have a copy in front of me. 

19 So a couple of the lifecycle cost numbers 

20 turned out to have just a cell reference error in the 

21 EXCEL spreadsheet that was calculating them. And so 

22 you can see if you’re going to follow the exact 

23 details here, an updated table for the life cycle cost 

24 information has been provided to you in today’s 

25 handout. And that will all be available in the 

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1 technical support document. 

2 MR. deLASKI: And just to follow-up, you’re 

3 going to post a new revised chapter to the TSD, or 

4 what’s going to happen? So we know when to look and 

5 what to look for. 

6 MR. McCORMICK: Right. I believe actually 

7 the answer to that is for the NOPR stage we’ll be 

8 publishing the latest numbers. 

9 Did you have something to say, Bob? 

10 MR. RABA: That last question was from 

11 Andrew deLaski. 

12 Go ahead Bob Lingard. 

13 MR. LINGARD: This is Bob Lingard with PNNL. 

14 The answer to your question is, yes. We’ll have 

15 revised TSD materials posted shortly that correspond 

16 with these revised materials you have in hard copy 

17 today. 

18 MR. McCORMICK: And as long as we’re on that 

19 subject although it’s a different chapter, one of the 

20 tables in the executive summary to deal with the 

21 national impact analysis results disagreed with the 

22 equivalent table in Chapter 10 and the Chapter 10 

23 table was correct. And we are updating the executive 

24 summary table to all agree. And that will happen in 

25 the same document. 

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1 MR. deLASKI: If I could just request -- 

2 MR. McCORMICK: Uh-huh. 

3 MR. deLASKI: -- this is Andrew deLaski -- 

4 when you do that, can you somehow just mark that as 

5 “revised” because those of us who downloaded the prior 

6 one, you know, it would be helpful to track, this 

7 thing has been changed. And I would even request that 

8 if you could e-mail your list to let us know when 

9 you’ve done it that way we know to go check that the 

10 document has been revised. The LCC chapter is a 

11 critical chapter for those of us. 

12 MR. McCORMICK: Certainly. I’m seeing some 

13 nods that that’s doable. So, great. 

14 Yes, apologies for that and that is just a 

15 simple cell reference error in the EXCEL spreadsheet 

16 unfortunately. But the methodology is unchanged. And 

17 the key result that I am focusing on here are the 

18 three possible outcomes of an LCC analysis. So in the 

19 top bullet what we are seeing is the sort of standard 

20 expected outcome from more efficient equipment that 

21 the installed cost, the installed price of the 

22 equipment is higher as the efficiency increases. So 

23 as you go from the baseline or CSL0/1 row on this 

24 table here, to higher CSLs your efficiency is 

25 increasing and the installed price is increasing. So 

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1 this is a very common and expected result. 

2 The flip side of that is that the operating 

3 costs are decreasing. So we have here operating cost 

4 savings. They’re marked in dollars and they should 

5 actually be marked in dollars per year. The operating 

6 cost savings also will increase although not 

7 necessarily monotonically. So you’re going to see 

8 lower operating costs with more efficient equipment is 

9 a typical outcome. It’s not a necessary outcome as 

10 I’ll explain in a moment. 

11 But a typical outcome of an LCC analysis or 

12 a PBP analysis is that you have higher installed 

13 costs, lower operating costs, and you can determine 

14 the number of years for your PBP that it would take to 

15 earn the money back that you spent in the first year. 

16 And it may or may not be depending on the discount 

17 that you use that you ultimately have lifecycle cost 

18 savings. You could imagine a case where the installed 

19 cost is so much higher that you never end up making 

20 your money back. And you could imagine other cases 

21 where you make quite a bit of money back from the 

22 savings. 

23 So that is the most standard case. We also 

24 encountered the sort of two less likely cases. And we 

25 encountered both of them in our preliminary results 

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1 for this rule which is quite interesting. 

2 On the lower half of this same slide, you 

3 see a result of negative payback period of values. 

4 And that is the result that we’ve already heard NEMA 

5 refer to today in which the installed price is lower 

6 for more efficient equipment. So this is certainly 

7 not theoretically impossible, but it’s considered 

8 pretty unusual. And so we’ve already heard comments 

9 that it will be helpful to get more access to cost 

10 data to confirm, validate or possibly reexamine these 

11 outputs. So in this case what we are seeing is the 

12 installed price is going down as the ballasts become 

13 more efficient, which, if true, is fantastic. And if 

14 untrue needs to be reexamined. 

15 And then -- 

16 MR. deLASKI: Just a follow-up question. Do 

17 you know what’s going on there? What’s happening in 

18 the engineering? 

19 MR. McCORMICK: Uh-huh. I actually don’t. 

20 I’m an economist by training. I believe that -- I’m 

21 going to not answer that question. Is there someone 

22 else who could jump in there? 

23 MS. GUPTA: This is Mimi Gupta from Navigant 

24 Consulting. That’s just the outputs from the 

25 teardown. We looked at the teardown results trying to 

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1 locate exactly which part of the components or which 

2 components might be more expensive, but we couldn’t 

3 find any trends in terms of what makes that -- I mean, 

4 so for the T12 baseline we found in retail prices that 

5 the T12s are actually more expensive than T8s being 

6 sold. So that part is consistent in terms of the fact 

7 that, no, maybe a CSL2 T8 is less expensive than a 

8 CSL1 T8, that’s just the result of the teardown. And, 

9 you know, we were hoping to get some input from 

10 manufacturers on why -- why those results came out and 

11 I think hopefully we’ll get some data. 

12 MR. deLASKI: Okay. Thanks. 

13 MR. McCORMICK: I would agree. And then an 

14 additional comment on that is that if this is the case 

15 you would expect to see that the market would 

16 gradually shift away from the baseline technology in 

17 this case, not necessarily instantaneously, but that 

18 would be the direction. And that’s exactly the 

19 assumption that we make in the shipments analysis, 

20 that although it would not happen instantaneously or 

21 completely, even in the base case with no regulation, 

22 the market would tend to shift away from this baseline 

23 equipment because from purely cost perspective there 

24 is no upside of this type of equipment given the 

25 assumptions that feed into this model. 

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1 We also saw the third possible case of a 

2 payback period or LCC analysis in which the operating 

3 cost does not decrease with increased efficiency. And 

4 so in this case you pay a higher installed price for 

5 more efficient equipment and never earn your money 

6 back. So the payback periods are effectively 

7 infinite. And it’s worth pointing out that the only 

8 case in which we saw this is a fairly particular case. 

9 This is the case in which more efficient ballasts lead 

10 to many more lumens. So if you are seeing a ballast 

11 that produces quite a bit more light given the 

12 appropriate lamps, you could imagine that you are more 

13 efficiently producing more light but that actually 

14 means that you are using slightly more power. 

15 And so in this case we have the two 

16 different purchasing events that you can imagine. My 

17 colleague Bob Lingard spoke already about normalizing 

18 costs and in a case where you can normalize the lumens 

19 and the costs. So for example, in new construction if 

20 a ballast produces 50 percent more light, you could 

21 have fewer of those ballasts. And recoup your costs. 

22 But, for example, if we were to try to retrofit this 

23 room with more efficient ballasts, you wouldn’t 

24 necessarily reduce the number of lamps that you were 

25 using and so you might end up using more energy, but 

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1 having a much brighter room. And that’s the case in 

2 which we see higher operating costs. And from a cost 

3 alone perspective never getting sort of your 

4 additional price back. 

5 And so -- were there any questions on that 

6 before I proceed? 

7 (No response.) 

8 MR. McCORMICK: Great. Issue number 14 has 

9 to do with demand load profiles and peak shaving. The 

10 costs that I have spoken to you about so far are all 

11 using average electricity prices over the course of a 

12 year. But you could imagine that lamps are used at 

13 particular times of day in which electricity prices 

14 have particular patterns, or that there are impacts on 

15 market electricity prices from the savings of more 

16 efficient ballasts. And DOE is interested in any 

17 comments that stakeholders might have on this effect. 

18 MR. RABA: Comments on load profiles or 

19 demand? 

20 (No response.) 

21 MR. RABA: No comments? 

22 Okay. That’s good. We have one from Mike, 

23 please? 

24 MR. McGARAGHAN: This is Mike and I actually 

25 did want to go back to the last slide. And wondered 

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1 if we could just get a little more information perhaps 

2 from your engineering team on this retrofit and are 

3 they -- have they determined that it’s impossible to 

4 maintain light level in certain situations or just 

5 likely that there will be an increase in light level? 

6 Provide a little more detail, please? 

7 MS. LEHR: This is Ali from Navigant. This 

8 product class in particular was pretty difficult. 

9 This is four-foot medium bi-pin lamps in the 

10 residential sector. And the reason you’re seeing the 

11 difference in light level was because we found 

12 significant differences in ballast factor. And it’s 

13 also difficult to try and figure out what correct 

14 representative units to use because the majority of 

15 ballasts in the residential sector are shipped already 

16 in fixtures. And a lot of these come from offshore 

17 suppliers and it’s been very hard to find catalogue 

18 information about these ballasts and to figure out 

19 which ones are truly the most popular representative 

20 units to use because I guess we don’t have 

21 accompanying fixture information right now. And if 

22 you have any suggestions about how to remedy that 

23 problem we would welcome any suggestions. 

24 MS. ANDERSON: Yeah, I think here the real 

25 question is, are there going to be equal lumen 

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1 replacements available? I think when we looked on the 

2 market we didn’t find that. We found, you know, 

3 varying ballast factors with differences in efficiency 

4 that resulted in engineering analysis in which, you 

5 know, we got different lumen outputs. So is this 

6 something, you know, should we expect given -- if 

7 these products were regulated that manufacturers would 

8 start to develop products that maintain lumen output 

9 with a higher efficiency and that’s just not what we 

10 see on the market right now. 

11 MR. RABA: I saw Charlie up first and Bob. 

12 MR. STEPHENS: Charlie Stevens. As I look 

13 at the residential stuff here, it occurred to me that 

14 I hadn’t heard anything earlier or I didn’t notice 

15 earlier that there’s nothing in the markup analysis 

16 about the residential channel. So I’m kind of 

17 wondering where the numbers are coming from for the 

18 purchase price and everything here especially since as 

19 absurd as it sounds, Home Depot and Lowe’s have 50 

20 percent or more of the home improvement retail market 

21 combined and so they have a pretty big influence over 

22 this thing. And I’m not sure the notion of 

23 replacement versus new is as relevant there when in 

24 the residential market. 

25 I mean, I’m not sure too many people will 

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1 replace the ballast. I think they tend to just 

2 replace the whole fixture. And, again, 50 percent of 

3 them or more, probably come from Home Depot and 

4 Lowe’s. And so I’m kind of trying to figure out how I 

5 should be understanding your analysis here in that 

6 context. 

7 MR. LINGARD: This is Bob Lingard with PNNL. 

8 You’re correct that we didn’t break out a separate 

9 distribution chain for residential products in the 

10 preliminary analysis. I think probably the closest 

11 fit we have at this point is that distribution chain 

12 that includes the one on the right, the replacement 

13 ballast market versus the OEM distribution chain. 

14 Looking at the publicly available finance 

15 data we did -- I think we did have at least one big 

16 box retailer in that. But to your point, no, we 

17 didn’t specifically contemplate that. But that 

18 replacement ballast distribution chain is, at least 

19 for the preliminary analysis, the closest we came to 

20 addressing your particular question. 

21 MR. RABA: Bob? 

22 MR. ERHARDT: Bob Erhardt, Philips Lighting 

23 Electronics. I did look at your analysis of 

24 residential and the reason the numbers come out like 

25 this was the electromagnetic product has a .58 ballast 

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1 factor. And if you’re running an instant start T8 you 

2 can’t run that low, the lamp life will just take a 

3 nosedive. And so if you’re talking about -- and that 

4 is the -- the typical low-cost electronic replacement 

5 for a residential. I did see a comment in there 

6 though where they thought that you could change 

7 luminaire spacings in a residential to utilize the 

8 extra lumen output and I highly question that because 

9 I think you have one luminaire in your kitchen and 

10 you’re not changing spacings or you have one luminaire 

11 over your work bench or in your garage and so I don’t 

12 know that you’re going to make up that -- you’re going 

13 to come up with anything other than more light output. 

14 If you go to a -- you know, if you go to a 

15 rapid start electronic for the residential market, 

16 then you open up some possibility of lower ballast 

17 factor product. 

18 MR. RABA: Thank you. 

19 Okay. Anything on the forecasting part? 

20 Mike, have something? 

21 MR. McGARAGHAN: I just wanted to clarify. 

22 You’re saying that the ballast factor that would be 

23 needed to maintain that light level with a T8 system 

24 is too low to operate on? 

25 MR. ERHARDT: Certainly too low for instant 

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1 start. 

2 MR. McGARAGHAN: Thank you. 

3 MR. RABA: Yes. 

4 MS. ANDERSON: Or you could sell dimming 

5 ballasts. 

6 (Laughter.) 

7 MR. RABA: Susan. Okay. 

8 Comment, Joanna? 

9 MS. MAUER: Joanna Mauer. I had a question 

10 on table 8.5.6 which is the eight-foot RDC high output 

11 product class with a T12 baseline. I was just 

12 confused. It looks like there are two different CSL1 

13 levels, one with a BEF of 0.5 and one with a BEF of 

14 0.55. 

15 MR. RABA: Which slide was that, please? 

16 MS. MAUER: It’s actually -- it’s not in the 

17 slides, it’s in the updated LCC tables that we were 

18 given this morning. 

19 MR. RABA: Okay. Thank you. 

20 MR. McCORMICK: Yes. And so if you look 

21 through those tables you’ll actually see several 

22 different product classes in which there is more than 

23 one CSL0 or more than one CSL1. When there’s more 

24 than one CSL0, it’s a fairly straightforward case that 

25 you have different baselines that you might be 

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1 considering. So from certain kinds of T12 and certain 

2 kinds of T8 ballasts you can actually imagine 

3 upgrading into the same more efficient equipment. 

4 For the case that you’re referring to in 

5 which there’s more than one CSL1, I believe that is 

6 due to an expected change in the T12 market. But I 

7 would want to get back to you with the specifics on 

8 that. I think that DOE will have write a written 

9 response to that. 

10 MS. ANDERSON: And just a follow-up question 

11 also. CSL2 has a slightly lower BEF than CSL1 so 

12 CSL2’s BEF was 0.549 and then one of the CSL1’s is 

13 0.55, so I was just confused about that as well. 

14 MS. GUPTA: I think I can respond to that. 

15 That’s coming out of the engineering. This is Mimi 

16 Gupta from Navigant. So, yeah, I think that eight17 foot high output product class as Ali mentioned 

18 earlier this morning is one of those that we’ve 

19 identified for further testing. 

20 We didn’t have test data for all of those 

21 ballasts that have been indicated. Actually the only 

22 one that was actually tested was the CSL2 ballast. 

23 And the reason why you have this interesting behavior 

24 is that the CSL2 ballast actually had a catalogue 

25 efficiency of .560. And when it was tested, it was 

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1 tested at .549. So the expectation and hopefully will 

2 be validated through further testing is that, you 

3 know, when analyzing a .55 which is a catalogue BEF, 

4 so that also should have been, I think probably 

5 detailed a little better. But that BEF will also be 

6 lowered. So, we look forward to seeing the results of 

7 that analysis. 

8 Any -- 

9 MR. ERHARDT: Bob Erhardt, Philips Lighting 

10 Electronics. Just, again, I made a comment to begin 

11 with on the eight-foot HO and you do have here that 

12 the mean lumen output is lower. And when you look at 

13 system efficacy, a T12 with a -- I forgot what my 

14 numbers were, but something like a BEF of .52 has a 

15 higher system efficacy than a T8 with a .55. And if 

16 you’re talking -- especially if you’re talking about 

17 replacement market, if you have a shop -- a small 

18 business that is running T12s, if he started with 110 

19 watt T12s and went to 86’s he already took a small cut 

20 in light output. Are you justified in cutting his 

21 light output for his workspace? And so I think you 

22 should take into consideration a 13 percent higher 

23 lumen output of the T12 lamps or the T8 in that case. 

24 MR. RABA: Thank you. 

25 Nothing further, I presume on the methods 

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1 and other data sources. Can we go on to the next 

2 discussion question the general trend to smaller 

3 fixtures? And ballast enclosures at issue? 

4 MR. McCORMICK: Fifteen. 

5 MR. RABA: Okay. 

6 MR. McCORMICK: Yes. So issue 15 revolves 

7 around the comments that we have heard, that more 

8 efficient ballasts may operate at a cooler temperature 

9 and therefore have longer lifetimes. And for the 

10 preliminary analysis what DOE assumed is that given 

11 the general trend towards smaller fixtures, the 

12 operating temperature would not fall by as much as you 

13 would expect. The smaller unit is roughly assumed to 

14 be offsetting the slightly lower heat output giving 

15 similar temperatures and therefore no particular 

16 change in lifetimes with more efficient units. And we 

17 would request any input on this assumption. 

18 MR. ERHARDT: Bob Erhardt, Philips Lighting 

19 Electronics. In our NEMA discussions we agree with 

20 Navigant’s conclusion that you’re not going to see 

21 appreciably better lifetime because exactly is what 

22 you say, there’s miniaturization in the luminaire 

23 field to take advantage of the smaller ballasts and if 

24 anything we are constantly being asked to operate at 

25 higher temperatures. Our hotspot temperature 

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1 specification has traditionally been 70C or so and now 

2 they’re asking for 80C and 90C hotspot temperatures. 

3 So we agree with your conclusion. 

4 MR. RABA: Great. Shall we move on then? 

5 One more from Andrew deLaski. 

6 MR. deLASKI: So this is a question on the 

7 LCCs the part that you haven’t shown today. And I 

8 want to focus in a little bit on the products where 

9 the savings are the greatest, you know, in the docket. 

10 And I’m looking at the sign ballasts, you know, which 

11 based on the Department’s preliminary analysis the 

12 potential savings are over three quads. So it’s huge. 

13 It’s a rulemaking unto itself in terms of looking at 

14 other opportunities for the Department and for energy 

15 savings. 

16 So I’m curious if somebody questioned from 

17 industry the Department is showing savings on the 

18 order of a third on those products. 

19 MR. RABA: Where is that coming from, 

20 please? 

21 MR. deLASKI: It’s from the LCC analysis. 

22 MR. RABA: Okay. In the TSD. Thank you. 

23 MR. deLASKI: I don’t have a table 

24 reference. 

25 MR. RABA: Okay. 

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1 MR. deLASKI: Do you have a table reference? 

2 MR. McCORMICK: One could see that in table 

3 8.5.15 on today’s handout, I believe. 

4 MR. deLASKI: So this drives, you know, 

5 enormous national savings and I’m wondering if the 

6 industry has any input on that? I’m curious, you 

7 know, are these numbers -- do they corroborate with 

8 what you’re seeing in the marketplace? 

9 And as you go through here, you know, you 

10 see that, you know, for many of the ballast types 

11 being evaluated there’s savings of 2 to 6 percent, you 

12 know, as Bob pointed out, the savings aren’t that big, 

13 you know, on a percentage basis. 

14 (Simultaneous conversation.) 

15 MR. deLASKI: -- here where we’re seeing 

16 really big savings. 

17 MR. ERHARDT: Okay. This is Bob Erhardt. 

18 On sign ballasts, electronic sign ballasts are a 

19 relatively new development and you do pick up efficacy 

20 when you run at high frequency. I have -- we didn’t -

21 - there weren’t any sign ballasts in the CEC data that 

22 I was analyzing and so I -- we only looked at the 

23 levels and saw if we had any heartburn over that. 

24 In principal you will see an improvement in 

25 efficacy running a T12 HO lamp on electronic ballasts 

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1 compared with electromagnetic just going form 60 hertz 

2 to 50 kilohertz you will pick up automatically on the 

3 lamp. You get about 10 percent better efficacy. And 

4 so it is reasonable. I don’t know if it’s 20 percent 

5 when you consider the ballast efficiency, but it is 

6 possible. 

7 We were focusing primarily on our big 

8 runners and in our written comments we’ll address it. 

9 (Simultaneous conversation.) 

10 MR. deLASKI: By “big runners” you mean 

11 those that sell a lot? 

12 MR. ERHARDT: Right. 

13 MR. deLASKI: We have this unusual 

14 rulemaking where the savings are looking like they’re 

15 where you have things you sell fewer of. It’s really 

16 uncommon. 

17 MR. ERHARDT: Well, yes. And we will -- 

18 well, it’s a high power product. In our written 

19 response we will give a more accurate response than 

20 I’ve just given you, but there is energy to be saved 

21 and I’m going to electronic sign ballasts, yes. 

22 MR. RABA: Thank you. Comment in the back, 

23 please. 

24 MR. COOK: Keith Cooks from Philips 

25 Lighting. I guess I’ve got a concern though with this 

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1 significant savings in sign ballasts. My concern is 

2 the fact that did you account for the conversion we’re 

3 seeing to solid state lighting in signs? Because we 

4 do see a significant conversion here, rather rapid, 

5 because of the fact that there’s significant 

6 improvement in maintenance and they operate much, much 

7 better at low temperatures than conventional 

8 fluorescent signs do. And so has that been accounted 

9 for? 

10 MR. McCORMICK: The Department’s treatment 

11 of solid-state lighting is to displace fluorescent 

12 lamps entirely in many cases. So where you would see 

13 that is in the shipments chapter. You would see just 

14 fewer shipments of signed ballasts that are 

15 fluorescents. With solid-state lighting sign ballasts 

16 are not covered in this rulemaking. Did that answer 

17 your question? 

18 MR. COOK: Well, I guess I’m not sure what 

19 you’ve forecast. The shipments is only history. 

20 Right? 

21 MR. McCORMICK: Oh, sorry. The shipments 

22 chapter will also include forecasted future shipments. 

23 And that takes into account assumed rates of 

24 penetration for solid-state lighting. 

25 MR. COOK: And what are you showing then for 

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1 penetration of solid-state lighting in signs? 

2 MR. McCORMICK: I don’t know the number off 

3 the top of my head, but I can direct you to the 

4 technical support document which has those numbers. 

5 MR. LINGARD: This is Bob Lingard with PNNL. 

6 I know we did address emerging technology penetration 

7 in a number of product classes in the shipments NIA. 

8 To your point I would need to verify this, but I don’t 

9 -- yet we did not -- we did not address solid-state 

10 lighting specifically in the sign ballasts. So your 

11 comment is timely and welcome. Thank you. 

12 MR. RABA: All good. All good. 

13 Let’s move on now. Let’s continue and move 

14 forward. We are going to start slipping here. 

15 National Impact Analysis, let’s move on to that, 

16 please? 

17 NATIONAL IMPACT ANALYSIS 

18 MR. McCORMICK: So the section entitled 

19 here, National Impact Analysis also includes the 

20 shipments analysis which is very much part of that so 

21 the two are hand in hand. And as you can see here, 

22 the sort of a way to think of it is that the lifecycle 

23 cost analysis provides cost information for one 

24 typical ballast and the shipments analysis basically 

25 tells us how many of these we need to account for, for 

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1 the national impact analysis which, to put it crudely, 

2 more or less multiplies those to get the total 

3 national impact. 

4 So I’m going to talk about the shipments 

5 analysis first. And it’s worth pointing out that 

6 that’s also a stock analysis. So, to know the 

7 incremental costs of purchasing more efficient 

8 ballasts, you need to know the number of shipments 

9 going forward, but to know the energy cost associated 

10 with that you need to know the number of more 

11 efficient units that will be on the market, not just 

12 sold in any given year. 

13 So the primary source of information DOE had 

14 to estimate either shipments or stock was the U.S. 

15 Census Industrial Reports information which covers 

16 historical ballast shipments. The Department’s 

17 current estimates of historical stock are based 

18 entirely on extrapolations from numbers about 

19 historical shipments and lifetimes. So we would 

20 certainly welcome any data that were available on 

21 historical stock numbers, the number of ballasts in 

22 operation at any given time in the United States. 

23 Given this data source, however, we first 

24 disaggregated historical ballast shipment numbers 

25 according to product classes and efficiency types. 

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1 One very important assumption that was made there 

2 that’s worth highlighting is the assumption that 69 

3 percent of all ballasts in any given product class are 

4 at the baseline efficiency level. We had very little 

5 data to go on in terms of distribution by product 

6 class, what share of ballasts are more efficient, so 

7 we would welcome any information available about the 

8 share in the market of more or less efficient ballasts 

9 already in place in the base case. And the reason for 

10 that is that for the national impact analysis we need 

11 to know what the baseline share of efficient units 

12 would be in order to know the impact of the rule. 

13 So, DOE extrapolated from the lifetimes and 

14 the shipment numbers stock estimates using a pretty 

15 simple accounting framework that if you count, for 

16 example, 15 years of an average ballast lifetime in 

17 the commercial sector you can simply count 15 years 

18 after those units ship, they’re no longer in use. So 

19 if you have 15 years of shipments data, you can know 

20 how many units are in use at any given time in the 

21 market. 

22 So DOE’s method was to first estimate 

23 historical shipments by product class and efficiency 

24 level based on the U.S. Census information. And we’ve 

25 already heard today we might, from NEMA, get 

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1 additional data on shipments which would be most 

2 welcome if possible. And other sources would be very 

3 welcome. 

4 From that we extrapolate stock and then we 

5 use the historical stock records to estimate future 

6 shipments and stock records -- excuse me, stock 

7 numbers based on growth rates and replacement trends. 

8 So, the primary growth rate we assume is the same as 

9 the growth rate of the buildings stock in the Energy 

10 Information Administrations NEMS model and the Annual 

11 Energy Outlook. The major source of ballast shipments 

12 in future then is replacements of current ballasts as 

13 they expire. And there’s also a certain amount of 

14 growth. 

15 We also have a number of scenarios, for 

16 example, the emerging technology scenario covers the 

17 aforementioned question of emergence of solid-state 

18 lighting. The emerging technology scenario assumes 

19 simply fewer shipments of fluorescents as the years go 

20 on as the market is penetrated by other forms of 

21 lighting which may or may not have to be LED lighting. 

22 But that is certainly the most obvious example. 

23 We also assumed two different scenarios in 

24 terms of shipments; the rollup or shift scenarios. 

25 The rollup scenario essentially says that if the 

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1 requirement is some particular efficiency level, for 

2 example, efficiency level two, then no one in the 

3 market would manufacture or sell a less efficient 

4 ballast. And that would be the only change. 

5 The shift scenario assumes that those who 

6 are currently purchasing ballasts that are more 

7 efficient than the minimum baseline might choose to 

8 become -- to purchase more efficient ballasts that are 

9 still more efficient than a new standard. 

10 So, for example, someone who is currently 

11 purchasing a ballast that’s roughly equivalent to CSL1 

12 if the standard went to CSL1 might actually decide to 

13 go CSL2 equivalent as a way of staying slightly ahead 

14 of the market. And DOE provides both of those 

15 scenarios and does not pick one as more likely than 

16 the other. 

17 So we have emerging versus existing 

18 technology scenarios that cover different possible 

19 rates of penetration for LEDs and other technologies. 

20 And we have shift versus rollup scenarios that cover 

21 whether those who purchase highly efficient ballasts 

22 now might increase their efficiency in the presence of 

23 a standard. 

24 One of the most important results from the 

25 preliminary analysis is that replacement ballasts 

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1 dominate the shipments in the future. And a very 

2 interesting pattern showed up. The cyclical shipments 

3 pattern here which NEMA has already referred to in its 

4 comments the pattern that you see here is roughly 

5 equivalent -- is in fact, almost precisely equivalent 

6 to the historical growth rate in the shipments of 

7 ballast numbers that the Department was able to find. 

8 So, approximately every ten to 15 years you see the 

9 market having a spike or a valley which refers to what 

10 was happening one lifetime ago. And you could imagine 

11 different factors explaining this of which the most 

12 important is that the Department assumes ballast 

13 lifetimes that do not vary around an average very 

14 much. So we assume, for example, that in the 

15 commercial sector where ballasts last about 15 years 

16 that almost every ballast lasts almost exactly 15 

17 years rather than two to 30 years. 

18 And what this would mean is that the every -

19 - every lifetime of a ballast the market would 

20 experience a similar pattern to what happened 15 years 

21 ago as a bunch of ballasts fail at the same time, 

22 they’re all replaced at the same time. So if you see 

23 a very strong growth or fall in shipments, you would 

24 see that repeated over time. And so the driving 

25 effect on this -- this somewhat unusual outcome is the 

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1 striking growth that DOE observed in historical 

2 ballast shipments. So, we certainly do welcome any 

3 other information on ballast shipments or stock in the 

4 historical period, but what we have indicates a very 

5 strong growth rate in the period, I believe it’s 1992 

6 to 2005 which does not seem entirely consistent with a 

7 mature market. This is approximately on the order of 

8 12 percent growth per year in ballast shipments which 

9 seems although possible in shipments, very unlikely 

10 that the number of installed ballasts in the country 

11 was growing at approximately 12 percent a year. And 

12 so in the current absence of other data, DOE’s best 

13 explanation for this phenomenon is the swap out of 

14 older ballast types with newer ballast types. So what 

15 we have assumed for the preliminary analysis is that 

16 the stock from the period 1992 to 2005 was not growing 

17 as fast as the shipments numbers. 

18 The graph you see here, the higher line is 

19 the total shipments observed in the historical period 

20 that we have data for. And the Department has assumed 

21 that 12 percent growth in stock is just not consistent 

22 with what you would expect in a mature market. And we 

23 would certainly welcome comments in a minute about -- 

24 from stakeholders about that effect. 

25 And so we’ve assumed that at most the stock 

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1 must have been growing by only about 2 percent a year 

2 which is only slightly higher than the rate of 

3 installed building space in the country. And so we 

4 have essentially assumed that a large share of all 

5 ballasts shipped in the historical period 1992 to 2005 

6 were due to replacements of existing ballasts that had 

7 not yet failed. If we did not make this assumption, 

8 the shipments oscillations, that you see here, would 

9 be even more dramatic. So this is a very interesting 

10 issue that we would love any additional input on. 

11 And I’ll get to that in a moment. But one 

12 of the key inputs to this unusual cyclical effect is 

13 the lifetime. So DOE assumed that the average ballast 

14 lifetime is a pretty good approximation of the actual 

15 ballast lifetime and that there is a relatively low 

16 variation around that. 

17 We are certainly seeking comment on that in 

18 part because if this assumption were not true, then 

19 this striking cyclical pattern would be less 

20 pronounced. 

21 MR. THOMAS: Ed Thomas, GE Lighting. I 

22 think the historical data is probably good. However, 

23 predictions about what is going to happen in the near 

24 future with the advent of the lead-free solder and we 

25 still don’t know quite what the lifetimes are going to 

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1 be on these types of products, so we’re a little bit 

2 concerned about large projections for life beyond, you 

3 know, the rated guidelines that we have test data for 

4 at this time. 

5 MR. RABA: Thank you. Bob. 

6 MR. ERHARDT: Bob Erhardt, Philips Lighting 

7 Electronics. This is a very large document and I saw 

8 some conflicting data on historical. The graph you 

9 showed here did not account for electromagnetic 

10 ballasts. In 1992 our company alone shipped more 

11 electromagnetic ballasts than what you showed there 

12 for the total market. 

13 MR. McCORMICK: That’s very interesting to 

14 know. 

15 MR. ERHARDT: So when you showed the T8s 

16 going from, I don’t know, 30 million to 100 million, I 

17 think it more likely that the electromagnetics went 

18 from 100 million to 30 million in the same period. I 

19 don’t think there’s been a large fluctuation. 

20 Concerning ballast lifetime, I can tell you 

21 that I had a question come up -- this is -- okay, this 

22 is going back two years ago, but I had called out an 

23 electromagnetic ballast model and I had to go all the 

24 way back to 1969 to even find a reference for that 

25 ballast model because it was obsolete in 1969. It 

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1 turned out the ballast was older than I was. It was 

2 over 50 years old. Electromagnetic ballasts, it’s 

3 still not uncommon for me to hear about ballasts from 

4 the ‘60s that are over 40 years old. We don’t have 

5 30, 40, 50 years experience with electronic ballasts. 

6 They’ve only been around for about 30 years and the 

7 ones we built 30 years ago weren’t very good. 

8 It’s only within the last 25 years, I think, 

9 that we’ve had a rather consistently reliable product 

10 and so 25 years of historical experience doesn’t give 

11 you a lot of data on how much the variation is around 

12 the 15-year lifetime. But there are installations, I 

13 think, that are over 15 years old. 

14 Now, another factor that you should be 

15 taking into account is not everybody waits for the 

16 luminaire to die to change out -- the ballast to die 

17 to change out the luminaire. 

18 In the commercial sector when a building 

19 space changes ownership often they’ll do a redesign, 

20 redecorating, and it’s not uncommon to have luminaire 

21 changed out at ten years just as part of renovations 

22 of buildings as new tenants take occupancy in 

23 buildings. 

24 Maybe Fred can say something if he knows 

25 something about luminaire lifetimes. But I think 

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1 there will be significant variation. You do have the 

2 installations where people have left the same 

3 luminaires in place for, like I say, up to 50 years. 

4 And then you have others where they’re changed out 

5 before anything fails at ten years or so. 

6 MR. RABA: Additional data on the shipments. 

7 Thank you very much. Addition data on the shipments 

8 will be very helpful, written comments, and the other 

9 things, but the magnetic as well, if you could. 

10 Follow-on. Charlie? 

11 MR. STEPHENS: Charlie Stephens. Yeah, 

12 there’s a few things that I think you -- and I would 

13 echo what Bob said. I absolutely agree. I’m finding 

14 magnetic ballasts that are 35 and 40 years old that 

15 are being changed out. I think they have an economic 

16 lifetime rather than a physical lifetime. They get 

17 changed out, as Bob suggested, because the fixture 

18 gets changed or the occupant of the space gets 

19 changed, or whatever. 

20 In that regard there were a couple of things 

21 that were going on in the ‘90s and past 2000 that are 

22 absolutely reflected. I think you will find there’s 

23 an enormous correlation in your curves between utility 

24 energy efficiency programs that were ramping up and 

25 paying people to change their fixtures. And that ramp 

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1 is still going on. I don’t know how long it will go 

2 on, but it is going on now. 

3 The company I work part-time for is now 

4 working with twice as many utilities in the United 

5 States as it was three years ago in developing these 

6 programs and implementing these programs. So you can 

7 continue that ramp. 

8 The other thing is that it’s absolutely 

9 consistent and I think you’ll find an excellent 

10 correlation with the real estate bubble. 

11 MR. RABA: Fred, do you want to follow on 

12 also? 

13 MR. CARPENTER: No, I didn’t have anything 

14 to add. 

15 MR. RABA: Okay. Great. That’s good. 

16 Fine. 

17 Yes. 

18 MR. NEUMANN: Justin Neumann of NEMA. There 

19 are a few things I want to share in a kind of analysis 

20 our NEMA biz group did over at NEMA. 

21 NEMA concedes that the great difficulty 

22 involved in forecasting economic variables over the 30 

23 years, however NEMA disagrees with some of the 

24 assumptions and methodology that DOE utilizes in 

25 obtaining historical and projected ballast shipments. 

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1 NEMA believes these factors are critical since DOE’s 

2 installed ballast stock estimates projections under 

3 the various CSL scenarios are influenced by these 

4 assumptions and methodological choices and ultimately 

5 have an appreciable impact on the net energy savings 

6 that stem from the rulemaking change. 

7 DOE’s choice of attributing the substantial 

8 growth in ballast market shipments between 1990 and 

9 2005 largely to retrofits rather than to absolute 

10 growth in the stock of ballasts is questionable. 

11 Several new technologies did evolve over 

12 this 15-year time period and new federal regulatory 

13 changes contributed to a significant increase in 

14 retrofits. But the 1990-2005 time period also 

15 contained very robust growth in non-residential 

16 construction activity that would explain the larger 

17 share of the new ballast demand than DOE assumes. 

18 DOE should also examine how changes in this 

19 assumption will affect both its historical estimates 

20 and forecast projections. Variations are present in 

21 the historical fluorescent ballast market data as one 

22 would expect driven by economic forces and replacement 

23 rates. However, DOE shipments projections show a much 

24 more pronounced up and down pattern than can be 

25 attributed to these factors. Even if one assumes 

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1 slower growth overall in ballast market demand going 

2 forward as DOE does, such a wavelike pattern of 

3 shipments driven almost entirely by product failure 

4 replacement is unlikely and not supported by the past 

5 performance of ballast data or similar product 

6 markets. 

7 An example that NEMA Biz gave is the base 

8 case existing tech scenario for four-foot T8 MBPs 

9 predicts a 50 percent drop in shipments between 2017 

10 and 2021. And only to return to 90 million shipment 

11 units by 2030. 

12 While shipments could register a decline 

13 like that predicted in Figure ES2.2 it would largely 

14 occur as a result of dramatic declines in commercial 

15 construction activity or a significant amount of 

16 business retrofitting their existing lighting systems 

17 neither of which has been observed to this degree in 

18 the historical ballast data. 

19 MR. RABA: Are those the written comments 

20 that you’ve submitted? 

21 MR. NEUMANN: No, these are some NEMA -- we 

22 have a kind of economic business department at NEMA. 

23 MR. RABA: Okay. 

24 MR. NEUMANN: That prepared -- 

25 MR. RABA: Will you submit them for the 

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1 record, then? 

2 MR. NEUMANN: Yeah. 

3 MR. RABA: Okay. Thank you. 

4 MR. NEUMANN: -- that prepared some comments 

5 for us to share today. 

6 MR. RABA: Okay. 

7 MR. NEUMANN: Are you okay if I continue? 

8 There’s a little bit more. 

9 MR. RABA: Briefly. Quickly. 

10 MR. NEUMANN: Okay. Sorry. They gave us a 

11 lot of economic info here. So -- shipments rebounding 

12 to their prior levels after experiencing such a major 

13 decline would also be improbable. The majority of 

14 existing building owners with T8 lamps will likely 

15 keep these systems in place for obvious reasons. In 

16 that regard DOE’s assumption about replacement demand 

17 driving future shipments is correct. However, energy 

18 efficient T5s are already commercially available and 

19 can be more easily retrofitted into many existing 

20 lighting systems without installing entirely new 

21 fixtures. Consequently retrofits to T5s and other 

22 existing technologies will likely dampen any 

23 rebounding in future T8 shipments. 

24 NEMA agrees with DOE’s methods of 

25 calculating lifecycle costs net present values, 

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1 rebound rates and evaluation of environmental benefits 

2 stemming from the proposed rulemaking. If it proves 

3 feasible DOE should examine the applications of higher 

4 discount rates on the projected values of net energy 

5 savings. When consumers, businesses, or households 

6 are faced with the savings that occur over a longer 

7 time horizon, they will discount future benefits 

8 heavily and place a much larger weight on the 

9 products’ first costs. 

10 MR. RABA: That’s very beneficial. Thank 

11 you and welcome those -- 

12 (Simultaneous conversation.) 

13 MR. NEUMANN: We are gathering more 

14 information on this stuff and others. 

15 MR. RABA: Excellent. Thank you. Thank you 

16 very much that was well said. 

17 Moving on, please? 

18 I’m sorry, one more quickly. Andrew? 

19 MR. deLASKI: I have a question about 

20 shipments. If you can go back to your graph. So 

21 you’re showing that the bottom line, the dotted line 

22 across the bottom shows that T12 ballast shipments go 

23 to zero? 

24 MR. McCORMICK: That’s right. So that’s 

25 another important element of this. There are on top 

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1 of the replacement rate assumptions and the relatively 

2 small growth assumptions for the total market certain 

3 assumptions DOE makes about transitions between types 

4 of product classes of which the most pronounced that 

5 you’re seeing is that magnetic T12 ballasts will have 

6 shipments that fall very rapidly compared to their 

7 current level. And those are all documented in the 

8 TSD. 

9 MR. deLASKI: That’s due to the lamp rule 

10 that the -- or just to the 2000 -- 

11 (Simultaneous conversation.) 

12 PARTICIPANT: (Off microphone.) 

13 MR. deLASKI: Right. That’s what I thought. 

14 So what I’m puzzled by is I’m looking at the results 

15 for that national impact analysis which shows in Table 

16 ES.2.9 a substantial savings for T12 baseline as the 

17 baseline. So I’m having trouble reconciling, you 

18 know, large savings for a product category that is 

19 being predicted to go away in the base case. 

20 (Simultaneous conversation.) 

21 MR. deLASKI: What I’m looking at is Table 

22 ES.2.9 and in the third -- no, in the first box in the 

23 third column -- third row down, two lamp -- ballast 

24 factor for four-foot medium bi-pin and instant start 

25 and rapid start T12 baseline predicting a large 

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1 savings from a product that shows no sales. So I’m 

2 trying to understand, what am I misinterpreting? 

3 MR. McCORMICK: Sure. It’s first of all 

4 worth pointing out these are preliminary results. But 

5 more importantly, there are very large numbers of 

6 shipments of that category which includes many T8s. 

7 So although the baseline is T12s, the various other 

8 CSLs are not T12s in that product class. So, for 

9 example, CSL1, I believe is a T8. So you can imagine 

10 -- 

11 MR. deLASKI: Let me just follow. Let me 

12 stop you there. But if a consumer has a T12 today, if 

13 there is no new standard when they replace it, they’re 

14 going to put in a T8 because they can’t get a T12. 

15 MR. McCORMICK: That’s right. That’s 

16 exactly what we assume. 

17 (Simultaneous conversation.) 

18 PARTICIPANT: That’s not true. You can get 

19 an electronic T12. 

20 MR. deLASKI: So the base case is a T12 

21 electronic? 

22 MR. McCORMICK: I’m trying to remember this 

23 off the top of my head. I believe the base case is a 

24 T12 magnetic. But the logical replacement will be the 

25 next level up. I would want to check whether that’s a 

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1 T12 electronic or T8. 

2 MR. deLASKI: But correct me if I’m wrong, 

3 but the T12 electronic is more expensive than T8 

4 electronic in the market? 

5 MR. RABA: Who are you addressing your 

6 question to, across the table to Susan? 

7 MS. ANDERSON: Yes, in general that would be 

8 correct. 

9 MR. deLASKI: So I guess it’s important, you 

10 know, maybe we’re not going to get to this today, but 

11 that it’s not clear to me that in this the base case 

12 needs to model what the consumer would do absent, you 

13 know, regulation. So I’m just not clear on how that’s 

14 been captured here. 

15 MR. McCORMICK: Perhaps it is best to get 

16 back to you in writing given time constraints. But 

17 the essential overview I would suggest to you is that 

18 if the consumer is assumed not to go to that precise 

19 CSL level, they might not necessarily go to the 

20 highest alternative CSL level. And the table you’re 

21 looking at, ES.2.9, I believe was calculated at the 

22 max-tech. So there is actually a lot of “wiggle room” 

23 if you will, between CSL1 and CSL3 for additional 

24 savings. Given the large volume of shipments in that 

25 product class, it doesn’t take an enormous incremental 

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1 efficiency between those to get fairly substantial 

2 savings. 

3 MR. deLASKI: I guess what I’m suggesting is 

4 that it strikes me given the realities in the market 

5 today that the baseline is a T8 ballast. You know, 

6 because a T12 electronic -- a T12 magnetic doesn’t 

7 exist anymore. That’s what I just heard. And a T12 

8 electronic is more expensive than T8 electronic. So 

9 the market is going to move to T8. 

10 MR. McCORMICK: Sure. And we will consider 

11 that as an alternative. 

12 MR. RABA: We may have had some 

13 enlightenment over here from Mimi. 

14 MS. GUPTA: Yeah. I think -- I think 

15 something was misspoken before. The baseline is a T12 

16 electronic. So we analyzed two baselines for this 

17 product class, a T12 electronic and a T8 electronic 

18 and maybe you, Bob, can explain a little bit more 

19 about the base case shipments. But the lamps rule in 

20 June -- July proposed standards that could potentially 

21 eliminate the T12 lamp which is why, you know, we 

22 think that -- which is why we basically analyzed two 

23 because we don’t know if it will for sure eliminate 

24 the T12 lamp. So that’s why we kept a T12 baseline 

25 electronic ballast. I’m not explaining this very 

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1 well. But am I -- 

2 MR. deLASKI: It’s helping. 

3 MS. GUPTA: Are you understanding? So, that 

4 was my clarification. 

5 MR. RABA: Thank you, Mimi. 

6 Bob? 

7 MR. ERHARDT: Bob Erhardt, Philips Lighting 

8 Electronics. I think you make a very good point 

9 though that T8 instant start is becoming the baseline 

10 ballast. NEMA has some data where we can show -- and 

11 actually, I think you showed in one of your graphs. I 

12 saw two sets of data in two different parts of this 

13 document where one did have the magnetics declining 

14 and the electronics coming up which is what the 

15 industry has observed. And then another that I think 

16 results in this where you said electromagnetic has 

17 always been 10 million or 7 to 10 million the whole 

18 time. 

19 Yes, it is true that the magnetic did start 

20 probably at around 100 million and came down to 

21 something today of 5 million or 10 million. And 

22 electronic has gone from 92 probably 30 million up to 

23 the 100 million. And as far as T12, T8, by far T8 

24 electronic instant start is the dominant ballast sold. 

25 It is the baseline, I would say, sold. 

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1 MR. deLASKI: Then just to follow-up on 

2 that. I mean, from the rulemaking last summer, you 

3 know, the prediction is that, sure, there may be some 

4 T12 lamps available in the market but they’re going to 

5 be expensive. And a T12 ballast also is going to be 

6 expensive. You know, so really the cheap -- the low7 cost option is a T8 system. You know, so it strikes 

8 me as -- 

9 MR. ERHARDT: Yeah, I think you’ll have a 

10 situation where if somebody has a T12, they could -- 

11 it’s going to get more and more expensive for them to 

12 maintain a T12 system. And somewhere along the line 

13 it will pay them back to retrofit with T8. And it’s 

14 just a matter of what the sensibilities of the 

15 business are and what their cash flow is that will 

16 determine if they get nickeled and dimed by the T12 or 

17 if they take the plunge and switch over to T8. 

18 MR. RABA: Susan Anderson. 

19 MS. ANDERSON: Well, there will be some low20 cost T12s left in the market in terms of lamps. The 

21 problem with them is that they are very low lumen 

22 output lamps. So, it will -- where they might be 

23 suitable in a residence -- 

24 MR. deLASKI: Okay. 

25 MS. ANDERSON: -- I think a commercial 

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1 establishment would find them too low output. And the 

2 fact does remain that based on the 2000 ballast ruling 

3 -- 2005, electronic T12 ballasts do meet those 

4 standards. 

5 MR. deLASKI: Okay. Thanks. 

6 MR. RABA: Comment in back? Follow-on? 

7 MR. COOK: Keith Cook from Philips. This 

8 does require very careful analysis though. Because 

9 what’s going to happen is a lot of these T12s are in 

10 residential. They’re in basements and shop lights and 

11 things like that. And a person is not going to 

12 replace the ballasts. A residential person will not 

13 do that. And it’s going to come back through the Home 

14 Depot and Lowe’s channel in which case the ballast is 

15 going to go through the OEM. It’s going to be going 

16 through acuity and those kind of places and so it’s 

17 not going to show up as just a replacement ballast 

18 only. And if they replace them with a T8, they 

19 definitely are going to be coming through with the OEM 

20 channel then. 

21 Whereas you got the ESCOs on the industrial 

22 and commercial side which will replace a ballast only. 

23 So you will see them taking the T12s and replacing 

24 them with a T8. Totally different market. You need 

25 to look at them independently to get a good analysis 

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1 here. Because now all of a sudden you’re payback is 

2 going to change significantly when you replace the 

3 entire luminaire as opposed to a ballast only for 

4 residential. 

5 MR. RABA: Valuable. Thank you. Susan 

6 Anderson. 

7 MS. ANDERSON: So basically we would say 

8 when you look at the residential market the only 

9 scenario you should look at is a new luminaire? 

10 MR. deLASKI: I think in the -- this is 

11 Andrew again -- in the standards in the lamp analysis, 

12 this was the standards in retrofit. I mean, the 

13 standard is driving, you know, you replace the 

14 luminaire. 

15 MR. RABA: Yes, in the back, please? 

16 MR. PLASKON: Jeff Plaskon with GE Lighting. 

17 I don’t know if I quite agree. I do have a little 

18 evidence that there’s millions of ballasts being sold 

19 in the residential channel and the split through in 

20 home center could be up to about 50/50 split between 

21 T12 and the T8 systems. So I would argue that many of 

22 those or a portion of those are being transferred from 

23 T12 to T8 systems or purchased by contractors. But it 

24 is probably added up to an estimate of probably over a 

25 couple million ballasts. 

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1 MR. RABA: Back to you, Susan Anderson. 

2 MS. ANDERSON: The one thing you have to 

3 remember about especially when you look at the DIY 

4 channel, there are a lot of small contractors that buy 

5 based on credit cards with Lowe’s or Home Depot or 

6 Menards or whomever it is that quite frankly can’t get 

7 credit at the electrical wholesale distributor and 

8 they buy -- or someone that’s an electrician that does 

9 freelance work over the weekend outside of their 

10 normal job working for a contractor and, I mean, that 

11 does happen that you have a lot of that particularly 

12 in your Main Street, small business owner, the 

13 contractor that’s servicing him is very likely to buy 

14 through Home Depot. So you have a good bit of 

15 commercial business through Home Depot, Lowe’s 

16 Menards, et cetera. 

17 MR. RABA: Thank you. Thank you. We should 

18 move on, please. 

19 We’ve done well on this subject. Let’s keep 

20 going. 

21 MR. McCORMICK: The next two issues, I 

22 believe have been more or less covered so far. The 

23 sub-issue -- starting on the bottom here actually is 

24 the relationship between historical shipments and 

25 historical stock. I believe we’ve covered that well 

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1 enough. 

2 MR. RABA: She nods yes. Okay. Move on. 

3 MR. McCORMICK: And now moving to the one on 

4 top. DOE’s method relied on disaggregating the U.S. 

5 Census Bureau information according to product classes 

6 and efficiency levels as best we could. And we would 

7 most certainly welcome any additional data or input on 

8 that approach. 

9 MR. RABA: Written comments will be very 

10 valuable at this point with that approach as well. 

11 Next issue. Next. 

12 MR. McCORMICK: The next issue is one that 

13 we’ve also sort of touched on already. The impact of 

14 other regulatory processes going on at this time or 

15 about to happen or that have just happened that would 

16 influence our ballast shipment projections. So of 

17 which the most interesting one is perhaps the T12 

18 discussion we were just having. 

19 Are there any other comments any 

20 stakeholders would like to make about impacts of other 

21 regulation on ballast projections? 

22 MR. RABA: Cumulative effect perhaps. 

23 (No response.) 

24 MR. RABA: Good regulations; right? 

25 Joanna. 

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1 MS. MAUER: I actually just had a question 

2 about one of the shipment tables in the TSD and how to 

3 interpret the numbers. 

4 MR. McCORMICK: Sure. 

5 MS. MAUER: So Table 9.5.1 which is the 

6 cumulative ballast shipment impacts. And it explains 

7 in the text above it, it says that it’s the cumulative 

8 shipments impacts caused by each of the three 

9 standards cases for each of the four shipment 

10 scenarios. But it looks to me that both the rows and 

11 the columns are labeled as CSL levels. I don’t know 

12 if you could help me about how to interpret the 

13 numbers that are in that table. 

14 MR. McCORMICK: Yes, I could. The two types 

15 of CSLs that we’re referring to there are the one CSL 

16 is for types of equipment. So you can imagine that an 

17 individual ballast could be the baseline or CSL1, 2 or 

18 3. The other form of CSL is the standard that DOE 

19 could set. So it could require all ballasts to be of 

20 the baseline only or CLS1 or 2 or 3. 

21 I don’t think I have the table in front of 

22 me to clarify which is which though, which is probably 

23 the most important information to you. Do you have -- 

24 thank you, Bob. 

25 (Pause.) 

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1 MR. McCORMICK: I believe the CSLs going 

2 from left to right are types of equipment and CSLs 

3 going from top to bottom are standards. But I would 

4 want to clarify that by looking back at the origin of 

5 the table. So we’ll have to -- 

6 MS. MAUER: This is Joanna again. Could you 

7 say what you mean by “types of equipment”? 

8 MR. McCORMICK: Yes. So, there are two 

9 different ways to think about the word “CSL”. One is 

10 an individual ballast, what type of equipment is it? 

11 What efficiency level is that ballast? The other is 

12 what is the efficiency level that -- for the purpose 

13 of the analysis we are assuming DOE was requiring in 

14 that scenario. So it’s examining the impact of DOE 

15 setting an efficiency level of CSL1 or of CSL2. 

16 MR. LINGARD: Gavin, this is Bob Lingard 

17 with PNNL. I think to clarify what you were just 

18 saying, I believe the ones across the top underneath 

19 the shipment scenarios those CSLs describe the 

20 shipments. The standard scenarios that you were 

21 speaking of and that the ones going down the left-hand 

22 column are the product specific CLSs that you referred 

23 to. 

24 MR. McCORMICK: Thank you, Bob. That’s 

25 exactly right and that’s very helpful. So you can see 

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1 that from top to bottom zero, one, two, three are your 

2 options. That’s types of equipment. And since the 

3 baseline scenario there’s no point in presenting the 

4 impacts of a baseline scenario. Going from left to 

5 right where it’s only one, two, three are your 

6 options, those are the three possible standard levels 

7 that DOE could adopt. 

8 MR. RABA: That was in the TSD, Table 9.5.1 

9 and 2. 

10 Okay. 

11 MR. McCORMICK: Great. Any other questions 

12 on issue 18? Or comments on issue 18? 

13 (No response.) 

14 MR. McCORMICK: So that was the shipments 

15 analysis which is by far the more complicated part of 

16 the national impacts analysis. And the rest of it is 

17 a quite straightforward calculation. Given that we 

18 now have estimates of shipments and stock in the 

19 future, and given that we have now gathered all the 

20 economic information about the costs, one can simply 

21 add up the expected costs and the expected consumer 

22 financial benefits of this regulation. And you can do 

23 that to get the net present value which is taking into 

24 account the increased costs of many consumers 

25 purchasing more efficient ballasts. And the savings 

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1 of many consumer using more efficient ballasts and 

2 therefore paying less in electricity costs and other 

3 costs over time. That’s your net present value. 

4 The other output of the national impacts 

5 analysis is the national energy savings which is 

6 simply what is the reduced amount of energy used by 

7 these more efficient ballasts over time. 

8 And the only original input in the national 

9 impacts analysis that does not flow directly out of 

10 other chapters is the discount rate. This analysis 

11 also uses discount rates to assume that savings in the 

12 future are less valuable than savings now. But they 

13 do not use the same discount rates that are in the LCC 

14 analysis. That is because the discount rates that are 

15 in the LCC analysis are for individual consumers, the 

16 rate at which individual consumers can borrow or loan 

17 money. The discount rates used for the national 

18 impacts analysis are 3 and 7 percent and those are 

19 considered to be society’s discount rates. So they 

20 are not linked to particular costs of capital. They 

21 are linked to society’s preference for savings now as 

22 opposed to the future. And those 3 and 7 percent 

23 rates are interagency rates that are use for many 

24 forms of regulation. They are not specific to this 

25 rule, and they are not calculated for this rule. 

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1 Given time pressure, I don’t think I need to 

2 go into great detail, but this graph is a typical 

3 shape that you see of net present value and national 

4 energy savings. They rise over time as you have more 

5 ballasts that are covered, and then they fall over 

6 time due to the impacts of discounting. Meaning that 

7 you value the future less than you do immediate 

8 savings. 

9 Having hurried through that a little bit, 

10 DOE acknowledges that there may be certain 

11 externalities associated with energy savings that are 

12 not covered by the financial savings to consumers. 

13 Environmental and energy security related benefits of 

14 saving energy are often cited examples. And we invite 

15 comment on the nature and magnitude of any such 

16 externalities. 

17 (Pause.) 

18 MR. RABA: Comment? 

19 MR. ERHARDT: Bob Erhardt, Philips Lighting 

20 Electronics. A small comment and it comes to the T5 

21 lamps and ballasts pointing out the T5 lamps and 

22 ballasts and systems use significantly less raw 

23 materials and less mercury than the T8 and that can be 

24 a beneficial factor. 

25 MR. McCORMICK: Thank you, that’s very 

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1 helpful. 

2 MR. RABA: Thank you. Small comments, big 

3 comments? 

4 (No response.) 

5 MR. RABA: Next issue. 

6 MR. McCORMICK: The next issue is the 

7 translation of candidate to standard level CSLs into 

8 trial standard levels TSLs. A quick summary would be 

9 that DOE will move from having many candidate standard 

10 levels to possibly fewer trial standard levels for the 

11 next round of the analysis. We are essentially 

12 winnowing down the different possibilities. And we do 

13 invite comment on the best method to select TSLs from 

14 the current CSLs. 

15 MR. deLASKI: Just a comment. 

16 MR. RABA: Andrew deLaski. 

17 MR. deLASKI: That you can’t do much 

18 winnowing because you don’t have many levels. You may 

19 be relative to other dockets, you may have done 

20 winnowing in other dockets, but in this one you’ve 

21 only got three CSLs, and for most products you have 

22 one. One or two. 

23 MR. McCORMICK: Thanks for the comment. 

24 MR. deLASKI: I hope that we will find more 

25 -- I hope there are more CSLs out there, but that 

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1 depends on what you come up with through the 

2 engineering. 

3 MR. RABA: Mimi Gupta. 

4 MS. GUPTA: Mimi Gupta, Navigant Consulting. 

5 I think an important point that the Department request 

6 comment on related to this is how the combinations of 

7 standard levels and how -- so the national impacts 

8 analysis looks at the national impacts of setting 

9 standards for all the products being considered. But 

10 we’ve established different standard levels for each 

11 product. So, how to pare them, you know, should the 

12 standard level three on T8s be or on four-foots be 

13 paired with candidate standard level one with, you 

14 know, T5s or -- I don’t know, there’s many different 

15 permutations that you can make. 

16 MR. deLASKI: Yeah, I think the Department -

17 - this is Andrew deLaski, I think the Department’s 

18 approach in the past has been an effective one which 

19 is, you know, look at one CSL consist of the maximum 

20 cost effective and -- and you gap fill. I think that 

21 approach has been an effective approach in the past 

22 and would work for this docket too. 

23 I think the gap fill ones are important too, 

24 to make sure that we’re capturing what’s in between. 

25 MR. RABA: All set? 

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1 MR. deLASKI: So on that, I do have another 

2 follow-up question, Jim, before Gavin goes away. How 

3 do you do shipments on sign ballasts? You know, sign 

4 ballasts, as I said before is a huge piece. 

5 MR. McCORMICK: Right. And you’re referring 

6 to the commercial versus industrial -- 

7 MR. deLASKI: Shipments. The shipments -- 

8 how many are shipped? How did you come up with that 

9 number? 

10 MR. McCORMICK: Right. So we approached it 

11 the same way that we did with the other product 

12 classes. And so the main source of shipments for sign 

13 ballasts is replacements. And we also looked at 

14 growth in the sectors in which they are installed, 

15 commercial and industrial. The growth rate of the 

16 building stock assuming a roughly constant intensity 

17 of sign ballasts per -- I’m saying building in terms 

18 of square feet, but it’s really the building type is -

- 19 

20 (Simultaneous conversation.) 

21 MR. deLASKI: Let me ask the question more 

22 precisely which is, how did you get historic 

23 shipments? How do we know what the shipment is 

24 assigned by? Is there census data on that or is that 

25 from the manufacturers or -- 

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1 MR. McCORMICK: That’s a question for -- 

2 MR. LINGARD: This is Bob Lingard with PNNL. 

3 That was also disaggregated from the U.S. Census data 

4 based on an assumed percentage of those magnetic HO 

5 type ballasts. So, again, our starting point was the 

6 census data. 

7 MR. deLASKI: And it gave you enough of a -- 

8 you were able to tell from the census data that 

9 something is a sign ballast? There’s data in there? 

10 MR. LINGARD: That was based on preliminary 

11 assumptions. No, it wasn’t identified -- it was not 

12 identified in the census data as sign ballasts. So we 

13 had to make some assumptions. 

14 PARTICIPANT: Where did you get your 

15 percentage? 

16 MR. LINGARD: That was compiled from looking 

17 across manufacture interviews. However, we do, again, 

18 we request more precise data, suggestions. Again, we 

19 were starting from a pretty broad brush with the 

20 census data. 

21 MR. RABA: This being preliminary data 

22 analysis throughout, this sort of data, comments are 

23 most welcome at this point and very valuable to look 

24 at more thoroughly as we go through the rulemaking 

25 process over time. 

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1 Thank you. Let’s continue, please. 

2 That’s all. Thank you very much, Gavin. 

3 And Rob Carmichael will present now on the 

4 preliminary manufacturing impact analysis. Rock and 

5 roll. 

6 MR. CARMICHAEL: Ninety minutes? 

7 (Laughter.) 

8 PRELIMINARY MANUFACTURER IMPACT ANALYSIS 

9 MR. CARMICHAEL: Okay. Good afternoon. My 

10 name is Rob Carmichael. I’m with Navigant Consulting 

11 and I’m going to go over two topics today. The first 

12 is DOE’s normal procedure for conducting the 

13 manufacturer impact analysis. And the second is a 

14 review of a preliminary MIA. So our initial round of 

15 interviews with manufacturers. 

16 So obviously the purpose of the manufacturer 

17 impact analysis with the MIA is to qualitatively and 

18 quantitatively assess the impacts of amended energy 

19 conservation standards on manufacturers of ballasts. 

20 DOE normally does this in three phases. 

21 In the first phase DOE creates an industry 

22 profile that builds on the market and technology 

23 assessment and uses that to inform its interviews with 

24 manufacturers in subsequent discussions. And also 

25 uses it to identify the key levers that will go into 

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1 the industry cash flow analysis. 

2 And that brings in phase two which is when 

3 DOE conducts -- builds a strawman industry cash flow 

4 model. We use the government regulatory impact model 

5 or the GRIM to forecast free cash flows in the 

6 industry throughout the entire analysis period and 

7 then discount them back both on the base case and in 

8 the standards case to calculate an industry net 

9 present value or an INPV and use the comparison of 

10 those two values as the output of the main output of 

11 the manufacturer impacts analysis. 

12 Also in phase two, DOE uses what we’ve 

13 learned here today and in your written comments to 

14 inform and develop an interview guide that DOE will 

15 use to guide its subsequent discussions with 

16 manufacturers in the full-blown MIA interviews. And 

17 those being in phase three. And in those interviews I 

18 just want to make one point on the interviews, first 

19 of all we’ll begin scheduling them rather soon. And 

20 also second, those are nearly always conducted under a 

21 nondisclosure agreement so no proprietary information 

22 is disclosed throughout the course of the rulemaking. 

23 And so following the manufacturer interviews 

24 DOE completes its analyses in the end of -- in phase 

25 three and looks at also some qualitative analyses 

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1 including manufacturer capacity, employment impacts, 

2 and impacts on competition. 

3 So, switching from process to content, this 

4 is a summary. This slide shows a summary of the four 

5 main issues that came up during the initial round of 

6 preliminary MIA interviews. There were manufacturers 

7 in general related these concerns. First there’s 

8 impacts on profitability from energy conservation 

9 standards. That can be due to several reasons, one 

10 being an inability to pass on some or all of the 

11 incremental costs associated with a new standard. The 

12 second being it may eliminate an up-sell opportunity 

13 in the product mix of the manufacturer. And the third 

14 being that it could cause some consumers to switch 

15 from fluorescent technology to some other lighting 

16 type, thereby reducing sales and revenue. 

17 The second is a similar concern, one of the 

18 diminishing returns to consumers. It’s been raised 

19 here today dealing with the tradeoff between a small 

20 increase in efficiency versus some high conversion 

21 costs that manufacturers might face. 

22 And the third reason also has been raised 

23 today deals with the impact on product innovation. 

24 Essentially it’s the opportunity costs that 

25 manufacturers would lose as they devote resources to 

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1 upgrading existing product lines rather than putting 

2 those resources into product development. 

3 And then lastly, regulatory burden, part of 

4 the MIA is to look at the cumulative regulatory 

5 burden. So those other regulations that impact 

6 manufacturers of those specific products, few of those 

7 have been mentioned today, RoHS, hazardous material 

8 regulations and then also other international 

9 standards, electromagnetic requirements as well. 

10 So at this time DOE requests comment on its 

11 characterization of the key issues in here and as well 

12 in more detail in the TSD. 

13 MR. ERHARDT: Yeah, this is Bob Erhardt 

14 again. And I wish to reiterate on the industry is in 

15 the middle of a market conversion, if you will, and 

16 the NRE, nonrecurring engineering costs on redesigning 

17 fixed output ballasts, the payback -- we expect the 

18 volumes of these to be going down and there is going 

19 to be significant impact in being able to recover 

20 these costs because the market is shifting to control 

21 systems that are different ballast type and the market 

22 is shifting to solid-state lighting which is a 

23 different lighting type. And unlike other more 

24 constant markets, this is a market that’s in a 

25 dramatic transition right now. Much more so than in 

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1 the 25 to 28 years that I’ve been in this business. 

2 And so you’re traditional models of payback on 

3 development costs probably aren’t going to fit because 

4 this is a mature -- I would call it an “end-of-life” 

5 product category. This is a product category that in 

6 the next 20 years is going to be minimized to almost 

7 nothing. And the opportunity for getting payback on 

8 investment is going to be severely diminished. 

9 So, again, we encourage you to take into 

10 consideration the costs of having to develop new 

11 products to meet rules because you really need to look 

12 at -- there are projections that, you know, in 20 

13 years are in much less -- in five to ten years, solid14 state lighting could have 50 percent of the market. 

15 And controls could have the other 45 percent. So, 

16 where’s the -- I’m pulling these numbers out of the 

17 air. But if you combined everybody’s projections for 

18 alternative technologies, there’s a negative market 

19 for this product in ten years. It’s probably not 

20 going to be the case, but it will be a significantly 

21 diminished market in the ten to 20 year time frame. 

22 PARTICIPANT: Wait and see. 

23 MR. RABA: Thank you. Very interesting 

24 comment. Any others, please? 

25 (No response.) 

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1 MR. RABA: Wow. Okay. That was too easy. 

2 We’re going to start wrapping up here. We 

3 have the NOPR analysis, Bob Lingard is coming back 

4 from PNNL. 

5 NOPR ANALYSES 

6 MR. LINGARD: Yeah, we spent all day talking 

7 about what’s happened already, now we get to talk 

8 briefly about what’s to come in the NOPR stage of the 

9 rulemaking. In addition to refining and revising the 

10 preliminary analyses there are a number of analyses 

11 unique to the NOPR phase. I’m going to give you, in 

12 the interest of time, and agenda, a quick review of 

13 these different analyses. 

14 The first being the LCC subgroup analyses. 

15 Basically a focus or a specific LCC analysis for 

16 identifiable consumer subgroups and business types 

17 that could be disproportionately affected by standard 

18 levels. This could vary with ballast type and the 

19 subgroups of energy prices. Operating hours could 

20 vary from subgroup to subgroup. So, again, this is 

21 well, literally what it says, a subgroup of the LCC 

22 analysis. 

23 The manufacturer impact analysis will 

24 continue. The utility impact analysis, these are 

25 effects on electric utilities. You’ve heard reference 

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1 to the NEMS, the National Energy Modeling System model 

2 today looking for interactions between supply and 

3 demand and forecasting how efficiency levels or 

4 standards could affect capacity generation, sales and 

5 prices of electricity. Another modeling analysis. 

6 The employment impact analysis, we touched 

7 on the MIA which speaks more to the direct effects on 

8 employment. The employment impact analysis here will 

9 focus more on the indirect effects on national 

10 employment. This would be outside of the 

11 manufacturers who are regulated, the net jobs created 

12 or eliminated, looking to substitution effects, income 

13 effects, that’s just another way of saying, how 

14 expenditures might shift among goods or how overall 

15 expenditures may be affected by efficiency or standard 

16 levels. 

17 The environmental assessment. This is also 

18 using the NEMS model. Quantifying and monetizing 

19 reduced power plant emissions as a result of reduced 

20 energy use. This is also the subject of an appendix 

21 in this rulemaking and interagency report on the 

22 monetization on the social cost of carbon. So this is 

23 an emerging area and I would invite you to take a look 

24 at that appendix and that we will also be requesting 

25 some comment or input on monetization of reduced 

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1 emissions. 

2 And finally, regulatory impact analysis. 

3 Again, where the manufacturer impact analysis would be 

4 looking at existing or pending regs and their impacts. 

5 This analysis will look to non-regulatory approaches. 

6 To offer an example, consumer or manufacturer tax 

7 incentives, rebates, bulk government purchases, and 

8 these will become the basis for essentially 

9 alternative scenarios, standard alternative scenarios 

10 in the NIA model. And that is a very quick summary of 

11 the NOPR analysis. 

12 We have one specific request for comment. 

13 This regards the environmental assessment. We do plan 

14 on monetizing emission reductions that could result as 

15 a matter of this rulemaking. You’ll see some of the 

16 more recent dollar per metric ton figures assigned for 

17 CO2. And, again, this was the subject of the 

18 interagency report and study on the social costs of 

19 carbon which is part of Appendix EA-SCC in this 

20 particular docket. 

21 DOE invites comments on the approaches for 

22 monetizing. And with that I will open the floor 

23 again. 

24 MR. RABA: Comments from the floor? 

25 (No response.) 

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1 MR. RABA: Written comments are welcome on 

2 that. I think that’s good for now. 

3 Thank you, Bob. 

4 Great. Last, but not least, we have Linda 

5 Graves to request your final comments, questions and 

6 invite final discussion on any topic we’ve had today. 

7 Linda. 

8 FINAL QUESTIONS/DISCUSSIONS AND CLOSING 

9 MR. GRAVES: You’ve been a great group. 

10 You’ve been really cooperative, that back and forth 

11 from especially among different groups stakeholders 

12 has been especially appreciated. This is your last 

13 chance. We’ve covered a lot of specifics. This would 

14 be the last chance for any other points of view you 

15 want to express, any overarching comments. We’re just 

16 about out of time, but if there’s still something you 

17 would like to say, please do. 

18 MS. MAUER: Joanna Mauer. Just a quick 

19 question. Do you know when the analytical 

20 spreadsheets might be posted to the website? 

21 MR. GRAVES: Really soon. 

22 MR. LINGARD: This is Bob Lingard with PNNL. 

23 Those were -- the preliminary models were posted late 

24 last week. So they should be available to you the 

25 next time you log on. 

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1 MR. GRAVES: Anyone? 

2 MR. STEPHENS: Yes, Charlie Stephens. The 

3 comment period closes in two weeks on something that I 

4 think based on our conversation today is a little 

5 slippery. We’ve still got some ground here that looks 

6 more like quicksand when it comes to trying to 

7 understand what we have to chew on and whether -- and 

8 how much of it is accurate and well-founded and all 

9 that. And the test period comment period ends in 

10 June. And that isn’t firm either. Is there some 

11 reason why you’ve got the standards rulemaking on May 

12 10th and the test procedure rulemaking, which is 

13 arguably simpler, sometime in the first week in June 

14 instead of the other way around? 

15 I would argue it would be really helpful to 

16 us if it were the other way around. 

17 MR. GRAVES: Those dates -- this is Linda 

18 Graves. Those dates are driven by the requirements 

19 that apply to regulatory requirements, that apply to 

20 public comment period. Otherwise, we might be doing 

21 May 10th for everything. 

22 But the point being that we’re on a 

23 schedule, we postponed the date of this public meeting 

24 to accommodate scheduling issues. That’s how we ended 

25 up with this date rather than an earlier date. And in 

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1 order for that teams to make the final rule dates and 

2 have the test procedure and standards come together, 

3 we really do need the comments as soon as possible. 

4 And so, it’s changing the dates that have been 

5 published in the Federal Register is not a fun thing 

6 to try to do. 

7 MR. STEPHENS: Okay. I guess I will just 

8 have to tell you then that based on the fact that I 

9 doubt we’re going to get the information back from 

10 USDOE, and perhaps some better information from other 

11 sources, I don’t think the comments you’re going to 

12 get by May 10th on this particular issue are going to 

13 be very complete or potentially very accurate given 

14 that later will get information that would perhaps 

15 cause us to want to change our comments fairly 

16 substantially. So I’m not sure you’re helping 

17 yourselves here by having it that near in the future 

18 without -- while we’re missing so much information. 

19 MR. GRAVES: I would just say it is a 

20 preliminary analysis stage. 

21 MR. RABA: Preliminary there’s far more to 

22 do, certainly, but thank you, Charlie. We have 

23 certain constraints we can’t avoid. We’re aware of 

24 that, we’re going to work on it. Thank you very much. 

25 Good comment. 

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1 Mike? 

2 MR. McGARAGHAN: Mike McGarahan, first of 

3 all just on behalf of California Utilities, thanks for 

4 the opportunity to provide comment today and written 

5 comments as well. 

6 And last clarification I just wanted to make 

7 that the next meeting would only address the 

8 standards, NOPR and that the test procedure would not 

9 be covered until the final rule is issued the 

10 following year. Is that correct? 

11 MR. RABA: A response to that? 

12 MR. McGARAGHAN: Sure. Since we’re at the 

13 NOPR stage for the test procedure now, will the next 

14 meeting cover the test procedure at all or will it 

15 just focus on standards and we’ll see a final rule for 

16 test procedure -- 

17 MS. GUPTA: Yeah, unless DOE decides to 

18 issue a supplemental NOPR test procedure. If it 

19 decides it wants to change its approach beyond the 

20 scope that was discussed today, then you’ll just be 

21 seeing a final rule. 

22 MR. RABA: Final? 

23 All right. Considering you’ve accomplished 

24 a lot today, this has been really two days worth into 

25 one. A lot of good information has passed across the 

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1 table. Written comments are invited to our 

2 preliminary analyses and DOE welcomes anything more 

3 you have to add. 

4 Please, the court reporter says -- a bright 

5 spot, the transcript will be available this week, 

6 later on. So contact Linda Graves for further 

7 information on that if you wish, or just kind of watch 

8 for it later either on the website or from the Court 

9 Reporter. They can provide copies on the website as 

10 well. 

11 A couple things to wrap up before Linda’s 

12 closing remarks, please. Turn your comment sheets in 

13 to Brenda on the way out. And also, when each of you 

14 who brought laptop computers came into the room, into 

15 the building, you were issued, I presume, a receipt, 

16 some piece of paper saying that was your computer. 

17 You can’t leave that building with that machine 

18 without showing the security guard that receipt you 

19 got for your computer. So, make sure you have that 

20 piece of paper, it’s a very important valuable 

21 document. Okay. Got that? 

22 Final comments? Linda. 

23 MR. GRAVES: I think I already made them, 

24 Jim, but thank you very much everyone. And please do 

25 fill out your survey forms. We very much appreciate 

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1 your feedback on whether this compressed format is 

2 working for you. 

3 I’ll ask my boss if he wants to say anything 

4 further. 

5 MR. CYMBALSKY: Yes, it was kind of my idea 

6 to try to get all of this done in one day. So if it 

7 felt rushed or anything like that, it’s my fault. 

8 But, you know, I think everyone made good comments and 

9 we’re going to take them all into consideration and 

10 we’ll move on from there. And thanks for coming. 

11 MR. RABA: Thank you. Give yourself a round 

12 of applause. 

13 (Whereupon, at 5:03 p.m., the meeting was adjourned.) 

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REPORTER’S CERTIFICATE

This is to certify that the attached proceedings 

before:

U.S. DEPARTMENT OF ENERGY 

In the Matter of:

 PUBLIC MEETING ON ENERGY CONSERVATION STANDARDS 

PRELIMINARY ANALYSIS AND TEST PROCEDURE NOPR FOR 

FLUORESCENT LAMP BALLASTS 

Were held as herein appears and that this is the 

original transcript thereof for the file of the 

Department, Commission, Board, Administrative Law Judge 

or the Agency.

Further, I am neither counsel for or related to any 

party to the above proceedings.

 

Wendy Greene 

 Official Reporter 

Dated: April 27, 2010 

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