1

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### Department of Energy 1

2

3

4

5 

### Ceiling Fan Light Kits 6

7

8

9 

### 9:31 a.m. to 3:08 p.m. 10 

### Tuesday, November 18, 2014 11

12 

### U.S. Department of Energy 13 

### 1000 Independence Avenue, SW 14


### Room 8E-089 15 

### Washington, D.C. 20585 16

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### PEOPLE AROUND THE TABLE: 1 

### DOUG BROOKMAN - Facilitator 2


### JOHN CYMBALSKY - DOE 3


### ASHLEY ARMSTRONG - DOE 4


### LUCY DEBUTTS - DOE 5


### JENNIFER TIEDEMAN - DOE 6

7 

### From the Industry: 8 

### RICHARD UPTON - American Lighting Association 9 

### CLARK LINSTONE - Lamps Plus 10


### DAVID TURNER - Hunter Fan 11


### BILL WALKER - Hunter Fan 12 

### ALLEN ROO – Emerson Electric 13 

### NATHAN FRAMPTON - Fanimation 14 

### TIM FLANNERY - The Minka Group 15 

### MARIANNE DIMASCIO - Appliance Standards Awareness 16 

### Project 17 

### DAVID GATTO - Westinghouse Lighting 18


### ALEX BOESENBERG - NEMA 19


### VAN SMITH – Van Ness Feldman 20

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### Consultants: 1 

### AISHA HUSAIN - Navigant 2


### MOHAN GANESHALINGAM - LBNL 3


### COLLEEN KANTER - LBNL 4 

### JULIE PIERCE - Navigant 5 

### ALI MCDONALD - Navigant 6

7 

### Also present: 8 

### TERRY MCGOWAN - American Lighting Association 9


### LOUIS-BENOIT DESROCHES - LBNL 10 

### MICHAEL WEEMS - American Lighting Association 11


### KENT MATHIS - HKC 12 

### CHUCK MATTHEWS - Matthews Lamp Company 13


### LAURA BARHYDT - DOE 14 

### VICTOR TAYLOR - Navigant 15

16


### On the Phone: 17


### ANTHONY FRYER 18


### DOUG SMITH 19

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


### MR. BROOKMAN: Let's start. Good 2 

### morning, everyone. 3 

### This is the U.S. Department of Energy's 4 

### public meeting on Test Procedure, Notice of 5 

### Proposed Rulemaking and Energy Conservation 6 

### Standards Preliminary Analysis for Ceiling Fan 7 

### Light Kits. 8 

### Today is Tuesday, November 18th, 2014, 9 

### here in the Department of Energy in Washington, 10 

### D.C. Thanks for joining us this morning. So 11 

### good to see you all here. We're going to start 12 

### this morning with welcoming remarks from John 13 

### Cymbalsky. 14 

### MR. CYMBALSKY: Thank you, Doug. I'm 15 

### John Cymbalsky. I'm the Program Manager for 16 

### Appliance Standards here at DOE. I just want to 17 

### welcome everyone to the public meeting for 18 

### ceiling fan light kits. We have a lot of 19 

### material to cover today. Hopefully we can get 20 

### through most of it in due course. Again, we 21 

### appreciate all of your verbal comments here at 225

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### the meeting, but we also appreciate you following 1 

### up with written comments for the record so that 2 

### we can build our administrative record cleanly 3 

### and move forward with the rulemaking. Thank you. 4 

### MR. BROOKMAN: We always start with 5 

### introductions and I'll start to my immediate 6 

### left. You can get used to turning these 7 

### microphones both on and off. Please say your 8 

### name and organizational affiliation. 9 

### If we could do this a little slowly so 10 

### our court reporter can capture everyone's name 11 

### around the room? Okay. Use the microphone, on 12 

### and off, name and organizational affiliation. 13 

### MR. SMITH: Van Smith. Van Ness Feldman 14


### LLP. 15 

### MR. BOESENBERG: Alex Boesenberg, 16 

### National Electrical Manufacturer's Association. 17 

### MR. GATTO: David Gatto, Westinghouse 18 

### Lighting. 19 

### MS. DIMASCIO: Marianne Dimascio, 20 

### Appliance Standards Awareness Project. 21 

### MR. FLANNERY: Tim Flannery, the Minka 226

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### Group. 1 

### MR. FRAMPTON: Nathan Frampton, 2 

### Fanimation. 3 

### MR. WALKER: Bill Walker, Hunter Fan. 4 

### MR. TURNER: David Turner, Hunter Fan. 5 

### MR. LINDSTONE: Clark Linstone, Lamps 6


### Plus. 7 

### MR. UPTON: Dick Upton, President of the 8 

### American Lighting Association. 9 

### MS. TIEDEMAN: Jennifer Tiedeman, DOE 10 

### Office of General Counsel. 11 

### MS. ARMSTRONG: Ashley Armstrong, DOE. 12 

### MR. CYMBALSKY: John Cymbalsky, DOE. 13 

### MR. BROOKMAN: That microphone ought to 14


### work. 15 

### MS. HUSAIN: Aisha Husain, Navigant. 16 

### MS. MCDONALD: Ali McDonald, Navigant. 17 

### MS. PIERCE: Julie Pierce, Navigant. 18 

### MS. KANTNER: Colleen Kantner, Lawrence 19 

### Berkley National Lab. 20 

### MR. GANESHALINGAM: Mohan Ganeshalingam, 21 

### Lawrence Berkley National Lab. 227

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### MR. BROOKMAN: Please introduce 1 

### yourselves. 2 

### MR. DESROCHES: Louis Desroches, Lawrence 3 

### Berkley National Lab. 4 

### MR. MCGOWAN: Terry McGowan, Director of 5 

### Engineering for American Lighting Association. 6 

### MR. BROOKMAN: It's probably sufficient 7 

### if you just stand. Yes. 8 

### MR. WEEMS: Michael Weems, American 9 

### Lighting Association. 10 

### MR. MATHIS: Kent Mathis, HKC. 11 

### MR. MATTHEWS: Chuck Matthews, Matthews 12 

### Lamp Company. 13 

### MS. BARHYDT: Laura Barhydt, DOE. 14 

### MR. GOERING: Steve Goering, DOE. 15 

### MR. TAYLOR: Victor Taylor, Navigant. 16 

### MS. DEBUTTS: Lucy deButts, DOE. 17 

### MR. BROOKMAN: Yes, I'm Doug Brookman, 18 

### Public Solutions, Baltimore. Nice to see you all 19 

### here. Apologies for a slight delay getting going 20 

### this morning. 21 

### All of you received a packet of 228

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### information, I hope, as you entered the building 1 

### this morning and also an agenda. I'm going to do 2 

### a very brief agenda review. 3 

### Immediately following this agenda review 4 

### there is an opportunity for anyone that wishes 5 

### to, to make brief opening remarks; opening 6 

### statements about matters that are of importance 7 

### to you. Following that we'll have a test 8 

### procedure regulatory history and rulemaking 9 

### overview, and then moving on from there, existing 10 

### product classes, metrics, and test procedures 11 

### proposed amendments to current test procedures, 12 

### proposed test procedures to support standards 13 

### rulemaking. 14 

### We'll take a break midmorning round about 15 

### 10:50 or so. Returning from the break we'll have 16 

### clarifications to the Energy Conservation 17 

### Standards determination of represented values. 18 

### And then closing remarks, an opportunity 19 

### for anyone that wishes to, to make supplementary 20 

### comments, closing comments on the test procedure 21 

### notice of proposed rulemaking. 229

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### We will pause for lunch around about 1 

### noon, or whenever we get there. And then when we 2 

### return from lunch we'll take up the Energy 3 

### Conservation Standards portion of today's 4 

### meeting. We'll start with opening statements, 5 

### we'll have a rulemaking overview, we'll move on 6 

### from there to scope and market technology 7 

### assessment, screening analysis, engineering 8 

### analysis, product price determination. 9 

### We'll take a break mid afternoon around 10 

### about 12:20, 12:30 or so. And following the 11 

### break: energy use, life cycle cost analysis, 12 

### shipments analysis, national impact analysis, 13 

### preliminary manufacturing impact analysis, NOPR 14 

### analysis and then finally at the end of the day, 15 

### whenever we get there, having covered all this 16 

### material, another opportunity for comment. 17 

### Another opportunity for you to say things that 18 

### haven't been covered fully during the course of 19 

### this meeting today. Okay? 20 

### Everybody with me on that? All of you 21 

### have a packet of information that looks like 2210

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### this. I'd ask for your consideration. Please 1 

### speak one at a time, please say your name for the 2 

### record each time you speak. There will be a 3 

### complete transcript of this meeting available. 4 

### Be concise, share the airtime. If you could keep 5 

### the focus here, turn your cell phones on silent 6 

### mode, limit sidebar conversations. You already 7 

### got used to turning the microphones on and off. 8 

### Webinar participants, we welcome you. 9 

### The Department of Energy wants very much to make 10 

### these meetings totally accessible to all via the 11 

### web. If you would keep your telephone on mute 12 

### and raise your hand in the software provided to 13 

### be recognized to speak, we ought to be able to 14 

### hear you in the room and you can join the 15 

### conversation here. 16 

### All the stakeholders who are present on 17 

### the web are also reminded to join in submitting 18 

### written comments to the Department after the 19 

### meeting is concluded. So please, don't neglect 20 

### that opportunity to provide your written 21


### comments. 2211

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### Do you want to do the purpose of the 1 

### public? 2


### MS. DEBUTTS: Sure. 3 

### MR. BROOKMAN: To Lucy deButts. 4 

### MS. DEBUTTS: All right. So good 5 

### morning, everyone and welcome again. Let's talk 6 

### about the purpose of the public meeting today. 7 

### What we're going to be doing is reviewing the 8 

### statute and the DOE actions for the ceiling fan 9 

### light kits. 10 

### We're proposing the test procedures so 11 

### we're going to review those as Doug stated. We 12 

### also review energy conservation standards that 13 

### we're considering and the pre-analysis that were 14 

### conducted already, so we'll be presenting the 15


### results. 16 

### Again, we invite everyone to provide us 17 

### with any additional data or any kind of 18 

### information that will help DOE in establishing 19 

### energy conservation standards, and this is going 20 

### to be in the form of a dialog so we'll present 21 

### the materials we are inviting you to share your 2212

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### thoughts with us. 1 

### And as I stated again, written comments 2 

### are more than welcome because they will help us 3 

### in the long run to establish the standard that is 4 

### beneficial to the society and the manufacturers 5


### as well. 6 

### All right. And that's the purpose of the 7 

### meeting today. 8 

### All right. So, what we're going to do, 9 

### throughout the presentation we're going to have 10 

### issues boxes. So these issues boxes are showing 11 

### the -- they correspond to the issues that are 12 

### lined up in the pre-analysis and in the notice. 13 

### And if you have any additional information on any 14 

### of the issues we welcome that to be submitted 15 

### through regulations.gov, via your written 16 

### remarks, and of course when we do this with test 17 

### procedures we ask that you consider the docket 18 

### number, and you can also find all the information 19 

### related to the test procedure on the 20 

### regulations.gov, following the link that is 21 

### showed on this file -- slide. 2213

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### Just as a reminder, the deadline for 1 

### submitting written comments on the test procedure 2 

### NOPR is January 14th, 2015. 3 

### I already kind of touched on this on how 4 

### to submit to the written comments. But again, 5 

### please mention the test procedures docket number 6 

### and the RIN ID for rulemaking when you're 7 

### submitting your comments. 8 

### The e-mail address for submitting written 9 

### comments is also shown on this slide, and if you 10 

### don't have access to electronic sources you of 11 

### course can send it via postal service or courier, 12 

### although we encourage electronic submissions more 13 

### than anything else. 14 

### Once again, January 14th is the deadline 15 

### for submission, comments on the test procedure. 16 

### So now to opening remarks. 17 

### MR. BROOKMAN: Thank you. One or two 18 

### individuals told me they have some opening 19 

### remarks. Dick is one of them. Dick, do you want 20


### to start us off? 21 

### MR. UPTON: I'm Dick Upton, the President 2214

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### and CEO of the American Lighting Association. 1 

### ALA is made up of 1,450 members in the United 2 

### States, Canada, and the Caribbean. They include 3 

### retail showrooms, manufacturer's reps, and 4 

### manufacturers of various lighting products, 5 

### including ceiling fans and controls. 6 

### Twenty-two ceiling fan members have come 7 

### together to bring our comments and positions to 8 

### you, and 13 of those companies are with me today. 9 

### I would point out that the ceiling fan industry 10 

### is a highly competitive industry and I'm very 11 

### proud of these people for being able to come 12 

### together and being able to deliver the industry's 13


### response. 14 

### We also have with us our Washington legal 15 

### counsel who has been helping us significantly and 16 

### we think a real asset to these discussions. 17 

### For some comments, we have a number of 18 

### areas that I think you're aware that we agree 19 

### with DOE's proposals. We also have a number of 20 

### areas where we strongly disagree. And we'll 21 

### deliver factual responses during these two days 2215

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### to back up our positions, including data from a 1 

### second survey that we just concluded last week, 2 

### of consumers, that we think you'll find 3 

### interesting and helpful to you in making your 4 

### decisions. 5 

### We would say to you that it's been a bit 6 

### challenging to prepare for this session given the 7 

### short period of time and notice that we've had to 8 

### get ready. As it turns out this particular 9 

### period is exceptionally challenging for the 10 

### ceiling fan industry in their year of doing 11 

### things. So you'll probably see us being more 12 

### complete and effective in our written comments as 13 

### opposed to what we're going to deliver in oral 14 

### comments, both today and tomorrow. 15 

### Two specific comments and one call for 16 

### action. We think it's important to spell out 17 

### first this morning, that a ceiling fan is an 18 

### energy efficient device. And that gets lost 19 

### along the way sometimes, but it is. And we think 20 

### the fact that hundreds of millions of these 21 

### products have been sold to the American consumer 2216

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### is proof of that, because if it wasn't then as 1 

### Mr. Linstone stated in an earlier meeting, if a 2 

### ceiling fan doesn't do a job for the consumer 3 

### then they're buying them for entertainment value 4 

### for watching the blades go around. 5 

### Lastly, we think there is an action that 6 

### you can take now and we would recommend it to 7 

### you, John, and that's why not eliminate the 190 8 

### watt power limit on integrated light kits because 9 

### as an integrated product on LED they can't exceed 10 

### 190 watts. And to have to wait a number of years 11 

### for that, to us, seems expensive not only for the 12 

### industry, but certainly expensive for the 13 

### consumer and unnecessary expense as well. 14 

### Thank you very much. 15 

### MR. BROOKMAN: Thank you, Dick. 16 

### Additional comments here, or opening statements 17


### here at the outset? 18 

### I'm looking around. Nothing additional 19 

### at this time? 20 

### (No audible response.) 21 

### Okay. Then we will launch into the 2217

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### content in your packet. 1 

### MS. DEBUTTS: All right. So back to me, 2 

### Lucy deButts here. 3 

### This slide shows the rulemaking schedule 4 

### as we are projecting it right now. And as you 5 

### can see, the test procedure NOPR published on 6 

### October 31st of this year, which started the 75 7 

### day comment period. Comment period will expire 8 

### on January 14th as I mentioned, of 2014 (sic). 9 

### We are projecting the final rule to 10 

### establish any test procedures for the ceiling fan 11 

### light kits to be published in the third quarter 12 

### of 2015, and the test procedure will become 13 

### effective for the Appendix V for the current test 14 

### procedure 30 days after the final rule 15 

### publication. 16 

### Our test procedure compliance date, which 17 

### projected for purposes of ceiling fan light kits 18 

### test procedures and proposed in Appendix V1, 19 

### which will support the ceiling fan light kit 20 

### standards, will be effective in the second 21 

### quarter of 2019. 2218

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### Okay. So we can go into the regulatory 1 

### history for now. And this slide just shows the 2 

### history of the test procedure. EPCA gave the DOE 3 

### the authority to regulate certain consumer 4 

### products. And in 2005 it was amended and 5 

### published the conservation standards for ceiling 6 

### fan light kits as well as it required the test 7 

### procedure for ceiling fan light kits. 8 

### On December 8th of 2006 DOE published the 9 

### final rule which codified the test procedure for 10 

### ceiling fan light kits. 11 

### And the last bulletin here shows the 12 

### authority that DOE has to conduct the test 13 

### procedure rulemakings for ceiling fan light kits. 14 

### With the establishment of the 15 

### requirements during the EISA 2007, DOE got the 16 

### authority to actually review test procedures 17 

### every seven years to make sure that they're still 18 

### current, or you know, if they need updating to do 19 

### so. So we're conducting this test procedure in 20 

### accordance with that authority. 21 

### The existing test procedure for ceiling 2219

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### fan light kits are specified in Appendix V, and 1 

### it could be found in the Federal Register, Title 2 

### 10 of CFR part 430, Subtitle B. 3 

### The scope of this rulemaking will cover 4 

### the ceiling fan light kits as the equipment 5 

### designed to provide light from a ceiling fan. 6 

### And these can be either integral, which are 7 

### attached to the ceiling fan at the time of sale, 8 

### or they can be attachable and sold separately 9 

### next to the ceiling fan. So therefore, any 10 

### equipment designed to provide light from the 11 

### product that are defined as ceiling fans under 12 

### the ceiling fan rulemaking will be included in 13 

### the scope of the ceiling fan light kit 14 

### rulemaking. 15 

### Any questions? 16 

### (No audible response.) 17 

### MS. DEBUTTS: Okay. Well, that concludes 18 

### the part of the scope and the history. And now 19 

### with the existing product classes, metrics, and 20 

### the test procedures I will ask Colleen Kantner 21 

### for the Lawrence Berkley National Lab to assist 2220

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### me with her presentation. 1 

### MS. KANTNER: Thanks, Lucy. I'm Colleen 2 

### Kantner. I'm with Lawrence Berkley National Lab. 3 

### MR. BROOKMAN: Is your microphone on? 4 

### MS. KANTNER: Oh. Is this better? 5


### UNIDENTIFIED SPEAKER: Louder. 6


### MS. KANTNER: Just talk louder? 7


### UNIDENTIFIED SPEAKER: Yes. 8 

### MS. KANTNER: Okay. EPACT 2005 9 

### established energy conservation standards for 10 

### three groups of ceiling fan light kits, those 11 

### with medium screw base sockets, those with pin12 

### based sockets for fluorescent lamps, and all 13 

### other ceiling fan light kits. 14 

### Of particular note is that the efficiency 15 

### metric is different for each product class. For 16 

### the first product class, CFLKs with the medium 17 

### screw base sockets, the efficiency metric is lamp 18 

### efficiency. For CFLKs with pin-based fluorescent 19 

### sockets, the efficiency metric is system 20 

### efficacy. And by “system” we mean the lamp plus 21 

### the ballast it was packaged with. And for the 2221

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### third product class the efficiency metric is 1 

### essentially wattage, because unlike the other two 2 

### product classes there is a design standard to 3 

### include a wattage limiter rather than test 4 

### procedures to determine efficacy. 5 

### It's also worth noting that CFLKs with 6 

### medium screw base sockets must be packaged with 7 

### lamps to fill all those sockets, and medium screw 8 

### base CFLs must meet additional specifications in 9 

### Energy Star Program Requirements for Compact 10 

### Fluorescent Lamps, version 3.0. 11 

### CFLKs with pin base sockets must also use 12 

### an electronic ballast and be packaged with lamps 13 

### to fill all sockets. 14 

### DOE's current test procedures are in 15 

### Appendix V to Subpart B of Part 430 of Title 10 16 

### of the Code of Federal Regulations. Test 17 

### procedures for CFLKs with medium screw base 18 

### sockets reference Energy Star Program 19 

### Requirements for CFLs, version 3.0, which in turn 20 

### references the 2000 version of LM-66. Test 21 

### procedures for CFLKs with pin-based fluorescents 2222

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### reference Energy Star requirements for 1 

### residential light fixtures, which in turn 2 

### reference the 2000 version of LM-66 for pin-based 3 

### CFLs and the 1999 version of LM-9 for circlines. 4 

### And again, there's no test procedure for 5 

### the third product class because they are subject 6 

### to a design requirement to use a wattage limiter 7 

### instead. 8 

### It's worth noting that both the Energy 9 

### Star program procedures and the IES test 10 

### procedures mentioned here are no longer current. 11 

### DOE is planning to update these test 12 

### procedures in a two-phase process. In general, 13 

### when DOE amends a test procedure it must consider 14 

### to what extent the proposed test procedure would 15 

### alter the measured energy efficiency. DOE can 16 

### only make a change to a test procedure that is 17 

### not simultaneous with a change in the 18 

### corresponding energy conservation standard if the 19 

### energy efficiency measured will not change. DOE 20 

### believes that there are some updates that can be 21 

### made without altering the measured efficiency. 2223

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### So first DOE proposes to make minor 1 

### clarifications in amendments to the current test 2 

### procedures. This is just updating test procedure 3 

### references. And because the amendments will not 4 

### change the measured CFLK efficiency, DOE proposes 5 

### that the test procedure will be effective 30 days 6 

### after publication and that manufacturers must 7 

### make any representations with respect to the 8 

### energy efficiency of ceiling fan light kits 9 

### beginning 180 days after publication of the final 10


### rule. 11 

### Then, later, DOE proposes to add new test 12 

### procedures that would revise the methods for 13 

### measuring energy efficiency of ceiling fan light 14 

### kit to support the concurrent energy conservation 15 

### standards rulemaking. DOE proposes that these 16 

### new test procedures would be required at the 17 

### compliance date for a potential amended CFLK 18


### standard. 19 

### And now we'll discuss the proposed 20 

### amendments to the current test procedures. These 21 

### are the proposed amendments DOE is planning to 2224

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### make during phase one. 1 

### DOE's intention with the proposed changes 2 

### to the current CFLK test procedure is to 3 

### harmonize the represented values of lamp 4 

### efficacy, wherever possible, with covered lamp 5 

### regulations. DOE believes that this will reduce 6 

### burden on CFLK manufacturers if they purchase 7 

### covered lamps rated pursuant to DOE's regulations 8 

### to be packaged with their CFLKs. 9 

### DOE proposes to make amendments to the 10 

### current test procedures for product classes one 11


### and two. 12 

### DOE is proposing to replace the current 13 

### reference to Energy Star requirements for CFLs 14 

### with a reference to the DOE test procedures for 15 

### medium screw based CFLs which are located in 16 

### Appendix W. And this Appendix W in turn 17 

### references the 2011 version of LM-66. 18 

### DOE examined the methodologies in each 19 

### version and doesn't believe that there are any 20 

### differences between the 2000 and 2011 versions of 21 

### LM-66 that would yield differences in the 2225

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### measured values of lamp efficacy. 1 

### DOE is also proposing to replace Energy 2 

### Star program requirements for residential light 3 

### fixtures, Version 4.0, with LM-66, the 2011 4 

### version of LM-66 for pin-based CFLs, and the 2009 5 

### version of LM-9 for circlines. 6 

### MR. BROOKMAN: David, please? 7 

### MR. TURNER: Yeah, David Turner with 8 

### Hunter. Without knowing the exact content of 9 

### what the Product Class 1 would change to, would 10 

### the requirement be that you would have to pack in 11 

### a CFL lamp if it's a medium screw base socket, or 12 

### just a lamp that met the efficiency of -- 13 

### MS. KANTNER: If it's a medium screw 14 

### based CFL then there are certain additional 15 

### requirements from Energy Star. If it's a medium 16 

### screw based lamp that is not a CFL it's just 17 

### efficacy. 18 

### MS. ARMSTRONG: That's not true. So, 19 

### it's just a lamp that meets the requirements is 20 

### the answer, if it has a medium screw base socket. 21 

### MR. BROOKMAN: Thank you, Ashley. Okay. 2226

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### Additional questions here on these changes? 1 

### MS. KANTNER: I did just want to note 2 

### that in order to maintain representations, the 3 

### current representations of efficacy, DOE will 4 

### continue to use system efficacy where the lamp is 5 

### measured with the ballast it's packaged with. 6 

### And it's worth noting that both LM-66 and LM-9 7 

### allow for testing with either a reference ballast 8 

### or a commercial ballast. 9 

### As with the update to medium screw base 10 

### lamps DOE believes that the update to these more 11 

### recent versions of the industry test procedures 12 

### will not result in any changes in measured 13 

### efficiency. 14 

### Now we have a couple of items for 15 

### comment. DOE requests comment on the proposed 16 

### changes for existing test procedures for CFLKs 17 

### packaged with medium screw base lamps. 18 

### MR. BROOKMAN: Yes, David. 19 

### MR. GATTO: Dave Gatto, Westinghouse 20 

### Lighting. Just a question on CFLKs with medium 21


### screw base. 2227

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### If it's an existing CFLK model with a CFL 1 

### packaged in that's already been tested to Energy 2 

### Star current standard does DOE -- are you looking 3 

### for additional testing, or when we recertify 4 

### those if there's no change in the test results 5 

### then -- no change in the -- I guess what I'm 6 

### saying is, do we have to retest the lamps that go 7 

### into the light kits? 8 

### MR. BROOKMAN: Ashley Arm -- 9 

### UNIDENTIFIED SPEAKER: Ready to answer. 10 

### MR. BROOKMAN: Ashley Armstrong. 11 

### MS. ARMSTRONG: I'm going to carefully 12 

### answer this one. 13 

### So, currently you should be testing to 14 

### the version of the Energy Star document which 15 

### incorporates by reference a certain industry 16 

### standard and a specific version of that for 17 

### federal minimums. 18 

### To the extent EPA has gone past that and 19 

### adopted different test procedures for their 20 

### program they have diverged from what's required 21 

### for federal minimums. Does that make sense? 2228

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### So, the answer is no -- I mean, so what 1 

### we have done here, and the intent at least for 2 

### the clarifications in Phase 1 was to harmonize 3 

### with the lamp procedures. When EPACT 05 came out 4 

### it had different versions that we ultimately 5 

### ended up adopting for lamp test procedures versus 6 

### CFLKs that are packaged with those same lamps. 7 

### So we are trying to eliminate that with 8 

### this proposal by harmonizing the lamp procedures 9 

### across the board where applicable to reduce 10 

### burden. So if you buy an otherwise compliant 11 

### lamp to package with your CFLK, yes it's still 12 

### the CFLKs responsibility -- manufacturer's 13 

### responsibility, you are on the hook. It is the 14 

### CFLK that is a covered product. But the lamp 15 

### manufacturer has to do this testing anyway and in 16 

### theory that's how this should work. We have 17 

### harmonized the rated values. So as long as the 18 

### rated values were developed in accordance with 19 

### the lamp procedures, you know, you should be 20 

### going forward. 21 

### So the answer is, we're trying to reduce 2229

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### burden, not require retesting. The lamp 1 

### manufacturer should already be doing this because 2 

### that's what's federally required for them now. 3


### MR. BROOKMAN: So back to Dave. 4 

### MR. GATTO: So, Dave Gatto, Westinghouse. 5 

### MS. ARMSTRONG: Kind of answers your 6 

### question in a roundabout way. 7 

### MR. GATTO: It sort of does. So I just, 8 

### I would say -- because we're both, and I think 9 

### we're unique in that, that for Energy Star 10 

### typically we're not certifying to the old 3.0 11 

### when there's now 1.0 and we're certifying to 12


### that. 13 

### However, I'm not necessarily retesting 14 

### all of the efficacy to move the 1.0. There might 15 

### have been only specific tests that had to be run 16 

### to certify. So, if we haven't gone through the 17 

### full test procedure because we've taken an 18 

### existing model that were already Energy Star 3.0, 19 

### which is well above the minimum efficacy, which I 20 

### know is what DOE is concerned with, and have 21 

### recertified to 1.0, the new lamp specification 2230

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### that covers both solid state and CFL, would we 1 

### need to go back and retest and then have that 2 

### test data specific to the CFLK? 3 

### I don't know if you can answer it 4 

### directly. I get that, Ashley, but we know lamp 5 

### is going to pass, but I know that part of the 6 

### issue that is if we don't have the underlying 7 

### test report -- 8 

### MS. ARMSTRONG: Yes, you are required by 9 

### federal -- you know, the DOE regulations require 10 

### a certain version of a test procedure to be run 11 

### and that's the data you must maintain. There is 12 

### one test procedure allowed to be used. Not 13 

### different versions, not variations thereof, even 14 

### if they wouldn't change or might not change the 15 

### measures of efficacy. 16 

### That being said, in Lamps 1.0 what you 17 

### will see is DOE worked closely with EPA for 18 

### covered products referenced to CFR. So in 19 

### theory, if you look at all the details they 20 

### should all be harmonized. If we had a misstep, 21 

### let's talk about it. 2231

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### MR. GATTO: Okay. 1


### MS. ARMSTRONG: So take a look because we 2 

### did work pretty hard with EPA in the last version 3 

### of the lamps that went out to harmonize for 4 

### covered lamps. So CFLs would reference to CFR. 5 

### Also there would be one test procedure, 6 

### one set of test data, everyone is doing the same 7 

### thing for ratings to reduce burden. 8 

### MR. GATTO: So Dave Gatto, Westinghouse. 9 

### I knew you did and thank you. It's just that the 10 

### devil is in the details. 11


### MS. ARMSTRONG: I know. 12 

### MR. GATTO: And when we're referencing 13 

### something that's referencing something else, and 14 

### then references back to it -- 15 

### MS. ARMSTRONG: So the key here is CFR 16


### matters. 17 

### MR. GATTO: Yes, I know it does. Thank 18


### you. 19 

### MR. BROOKMAN: Dick. 20 

### MR. UPTON: Ashley, Westinghouse is 21 

### unique to our manufacturing group in that they're 2232

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### a lamp manufacturer as well as a ceiling fan 1


### manufacturer. 2 

### If I understood you correctly, if all the 3 

### other manufacturers purchase a lamp that's been 4 

### tested and approved, and it's with the product 5 

### and packaged in the box, they don't need to 6 

### retest that lamp with the fixture? 7


### MS. ARMSTRONG: So there are some 8 

### nuances. The answer is, mostly yes. 9 

### MR. UPTON: Thank you. 10 

### MS. ARMSTRONG: The responsibility is on 11 

### the CFLK manufacturer. So no, there's no 12 

### retesting requirement per se, but you need to 13 

### make sure that, you know, whoever is supplying 14 

### your lamps that they have the test data, that you 15 

### trust the data, that's your responsibility, you 16 

### know, if you want to. But if they have the test 17 

### data that's done in accordance with the DOE 18 

### regulations there's nothing that makes you test 19 

### twice. That's the point of our proposal. 20 

### MR. UPTON: Very well. 21 

### MS. ARMSTRONG: Thank you. 2233

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### MR. BROOKMAN: Okay. Thank you, Dick. 1 

### Additional comments? We have two comment boxes 2 

### here, one on pin-based fluorescent lamps. Any 3 

### additional comments on these two? 4 

### (No audible response.) 5 

### MR. BROOKMAN: Nothing additional at this 6 

### time. Okay, we're moving on. 7 

### MS. KANTNER: Okay. Moving on to Phase 8 

### 2, the proposed test procedures to support the 9 

### standards rulemaking. 10 

### DOE is proposing to use efficacy as the 11 

### efficiency metric for all CFLKs instead of using 12 

### efficacy for some product classes and a wattage 13 

### limit for others. The current variability in 14 

### approach makes it difficult to compare the 15 

### efficiency of different CFLKs. Moving to an 16 

### efficacy-based approach allows DOE to move away 17 

### from the problems associated with the wattage 18 

### limiter approach, including the technical issues 19 

### associated with the wattage limiter raised by 20 

### stakeholders, and also the fact that wattage 21 

### alone is not necessarily indicative of the 2234

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### lighting service provided by the CFLK. 1 

### An efficacy metric is a universally 2 

### accepted metric. It's used by lighting industry 3 

### organizations and government bodies to 4 

### characterize the efficiency of both lamps and 5 

### luminaires. So DOE will be more closely 6 

### harmonizing with this universally accepted 7 

### approach. 8 

### And again, this is the overall goal with 9 

### these proposed test procedures, to harmonize with 10 

### DOE and industry test procedures wherever 11 

### possible. 12 

### So DOE is proposing to update the active 13 

### mode test procedures to reference DOE test 14 

### procedures if they exist or will exist by the 15 

### compliance date of the standards rulemaking and 16 

### to reference current industry test procedures if 17 

### DOE test procedures don't exist. 18 

### As suggested in the framework document, 19 

### DOE is not proposing to incorporate any energy 20 

### consumption in standby or off mode into the CFLK 21 

### efficiency metric. Energy consumption in standby 2235

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### mode for ceiling fan light kits packaged with 1 

### ceiling fans will be measured as part of the 2 

### proposed ceiling fan test procedure and will be 3 

### discussed tomorrow. And DOE does not believe 4 

### that CFLKs consume power in off mode. 5 

### As mentioned in the previous slide, DOE 6 

### proposes to use efficacy measured in lumens per 7 

### watt to quantify the energy efficiency of all 8 

### CFLKs. To the extent that it is technologically 9 

### feasible, DOE proposes to use lamp efficacy as 10 

### the measure of efficiency. 11 

### For CFLKs with externally-ballasted 12 

### lamps, DOE proposes shifting from the current 13 

### approach, which uses system efficacy as measured 14 

### on the ballast packaged with the CFLK, to one 15 

### that uses lamp efficacy as measured on a 16


### reference ballast. 17 

### Note that for CFLKs for which lamp 18 

### efficacy is the metric, the same lamp model may 19 

### be used in multiple CFLK models and lamp 20 

### manufacturers may have already tested these lamps 21 

### according to the required test procedures since 2236

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### the proposed test procedures harmonize with DOE 1 

### and industry test procedures. Then, at least in 2 

### theory, the lamp manufacturers could provide 3 

### those test reports to the CFLK manufacturers. 4 

### When it is not technically feasible to 5 

### use lamp efficacy, DOE proposes to use luminaire 6 

### efficacy. Some ceiling fan light kits with solid 7 

### state lighting have designs for which it is not 8 

### technically feasible to measure lamp efficacy 9 

### without destructive disassembly of the CFLK 10 

### circuitry, or even if it's possible to 11 

### disassemble the light kit in a non destructive 12 

### manner, the resulting measurements may not be 13 

### accurate or consistent representations of the 14 

### light source efficacy. 15 

### Specifically, luminaire efficacy would be 16 

### applicable to CFLKs with integral solid state 17 

### lighting circuitry, which will be described on 18 

### the next slide. 19 

### The luminaire efficacy of each basic 20 

### model of ceiling fan light kit with integral SSL 21 

### circuitry would need to be tested, and the term 2237

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### “CFLKs with integral SSL circuitry” means either 1 

### a ceiling fan light kit that has SSL drivers or 2 

### light sources that are not consumer replaceable, 3 

### or CFLKs that have SSL drivers and light sources 4 

### that are consumer replaceable but the driver and 5 

### the light source are separated by some additional 6 

### intermediate circuitry. 7 

### So, for example, there's wiring between a 8 

### replaceable driver and a replaceable light 9



### source. 10 

### So this is illustrated on the next slide. 11 

### So, on the left we see that lamp efficacy is 12 

### applicable to all consumer replaceable lamps. So 13 

### these are lamps that can be removed from the 14 

### light kit as a single integrated piece with a 15 

### standard base. If either the light source or the 16 

### driver are integrated into the CFLK and not 17 

### consumer replaceable, then the CFLK is subject to 18 

### luminaire efficacy testing. This is straight 19 

### forward in the case of the light source, but 20 

### since there aren't reference drivers for LEDs in 21 

### the same way that there are reference ballasts 2238

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### for CFLs, then luminaire testing is required even 1 

### if only the driver is not consumer replaceable. 2 

### Testing this way is consistent with LM3 

### 79, which applies to either integrated lamps or 4 

### entire luminaires, but not to light sources by 5


### themselves. 6 

### Luminaire testing is also required in 7 

### this third case, that was described in the 8 

### previous slide, where the light source and driver 9 

### are both consumer replaceable but they are 10 

### separated by some intermediate circuitry. And 11 

### again, this is based on the scope of LM-79. 12 

### In general LM-79 applies to either 13 

### integrated lamps or whole luminaires where the 14 

### testing is done on the entire fixture, and that 15 

### includes all components that could affect 16 

### electrical, thermal, or optical properties. 17 

### MS. ARMSTRONG: So if anybody has 18 

### questions you guys can feel free to chime in, 19 

### even though we're just kind of rolling through 20 

### these. You can stop us at any time and make 21 

### comments or questions, or tell us you agree with 2239

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### us, or don't agree with us, or whatever you'd 1 

### like. It's a quiet group. We might be done 2 

### before lunch if we keep going like this. 3 

### MR. BROOKMAN: Yes. Tim. 4 

### MR. FLANNERY: So, would you consider a 5 

### driver limiting device? 6 

### MS. ARMSTRONG: Going back to my favorite 7 

### question of the limiting device, let's just go 8 

### ahead and get that one out of the way. It's not 9 

### teed up until later, but -- so we've heard the 10 

### requests that we reinterpret, you know, our 11 

### requirement for the 190 watt on a limiter. I 12 

### would say it's well received at the Department. 13 

### We believe in order to do something like that we 14 

### need to do it through a rule. It was established 15 

### by a rule. So it can be considered as part of a 16 

### CFLK standards rulemaking. That's not an issue. 17 

### I'm asking you guys to help us to come up 18 

### with the data and the evidence, some of which 19 

### you've already provided, that will give some 20 

### background and some rationale as to why certain 21 

### types of lamps, mainly LEDs, would never exceed 2240

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### the 190 watt requirement and do not need a 1 

### limiter. 2 

### So if you can help with that in your 3 

### comments, if you would be willing to provide data 4 

### for that, obviously the Department is open to 5 

### that. We need to do it through a rule, so we 6 

### need to do it -- you know, the later half of this 7 

### presentation is going to be talking about 8 

### standards in the future. We could reinterpret -- 9 

### we could consider reinterpreting applying the 10 

### limiter for the current standards as part of that 11 

### rule, and we would be willing to do so and work 12 

### with you if you could help us with that data. 13 

### Okay? 14 

### MR. BROOKMAN: Please. And your name, 15 

### and use the microphone, thank you. 16 

### MR. MCGOWAN: Terry McGowan, Director of 17 

### Engineering for the American Lighting 18 

### Association. Actually, the situation we have 19 

### here is very closely related to number 2, where 20 

### you have pin-based fluorescent systems, and the 21 

### regulation thereof. An LED manufactured to 2241

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### provide a certain light output and a fixed power 1 

### input has all of the characteristics described 2 

### there except the LEDs are not replaceable, 3 

### they're fixed. So you could reinterpret that 4 

### with fixed lamps and have exactly what we're 5 

### trying to say, that the power input, and 6 

### therefore the efficacy is rated according to the 7 

### power input and the lumen output of the light 8



### sources. 9 

### MS. ARMSTRONG: No, I was just -- I mean, 10 

### so I question whether that gets you to where you 11 

### want to be for the current standards. Right? I 12 

### get that that might get you to where you want to 13 

### go for future standards, but the current 14 

### standards right now we're dealing with are in 15 

### terms of either for screw base sockets, efficacy, 16 

### for pin bases sockets, system efficacy, as long 17 

### as they have pin-based sockets. And for 18 

### everything else we've interpreted that shall not 19 

### be capable of operating as requiring a wattage 20 

### limiter. So it's really that bucket I think 21 

### we're dealing with, correct? 2242

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### MR. MCGOWAN: Yes. 1 

### MS. ARMSTRONG: That the ask is for. 2 

### That's my understanding. 3 

### MR. MCGOWAN: Okay. Terry McGowan again. 4 

### If you go then to the interpretation 3, 5 

### the fact is then the phrase, "by design," applies 6 

### because those devices by design cannot be changed 7 

### once they are designed and installed because they 8 

### are limited by a fixed number of LEDs and by a 9 

### current limiting device, the driver, which states 10 

### and limits the power being drawn by that system. 11 

### MS. ARMSTRONG: So, I think DOE is 12 

### asking, while we understand by design, what does 13 

### that mean in terms of what is the data behind it? 14 

### Why is it by design that they cannot? I mean, 15 

### just because someone claims by design, what if 16 

### they had one LED integrated with other bulb 17 

### types? Does that exclude them by design? 18


### MR. MCGOWAN: There are no -- 19


### MS. ARMSTRONG: And what does that mean? 20 

### MR. MCGOWAN: By design means there are 21 

### no replaceable parts. 2243

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### MR. BROOKMAN: So, Terry, that was 1 

### helpful. Do you want to add on, Dave? 2 

### MR. GATTO: I do, because I want to ask 3 

### Ashley a question, please. 4 

### MR. BROOKMAN: Microphone on. 5 

### MR. GATTO: Oh, yes, I'm sorry. Yeah. 6 

### Dave Gatto, Westinghouse. Alex, you normally are 7 

### right there with me, reminding me. 8 

### MS. ARMSTRONG: Alex, you have coffee 9 

### already. Come on, get in here, buddy. This is 10 

### the quietest I've ever seen you. 11 

### MR. GATTO: We come into this meeting 12 

### knowing I'm not going to get that right, I'm not 13 

### going to turn it on, I'm not going to say my 14 

### name. I'm not Joe Howley. 15 

### MR. BROOKMAN: You're doing well. You're 16 

### doing well. Keep going. 17 

### MR. GATTO: So it sounds like what you'd 18 

### like, and you know, we can put this together in 19 

### our comments is the technical reasons why under 20 

### class 3 integrated LED light sources, which 21 

### wouldn't include these other light sources, would 2244

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### meet the definition of self-limiting. That's 1 

### really what you're looking for is the technical 2


### reasons for -- 3


### MS. ARMSTRONG: Yes. 4 

### MR. GATTO: Because we can give that. I 5 

### don't know that you need it here, but it sounds 6 

### like that's really what you want. 7 

### MS. ARMSTRONG: I think that's the ask. 8 

### You know, the language that Congress gave us was, 9 

### "Shall not be capable of operating." So why is 10 

### it that -- what are the technical reasons? What 11 

### is the data to support that integrated LEDs or 12 

### LEDs that are not replaceable, you know, meet 13 

### that definition. 14 

### MR. GATTO: Yes, I think we can do that. 15 

### I think that's more than possible. 16


### MS. ARMSTRONG: And what are the bounds 17 

### around that in terms of, you know, is it an 18 

### infinite number of them if somebody put thousands 19 

### of LEDs in a CFLK because they thought that was a 20 

### good idea? You know, I’m just kind of being 21 

### egregious with my comments here, but to show you 2245

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### the thought process that we have to go through 1 

### because the language is fairly clear in the 2 

### statute about shall not be capable of operating. 3 

### MR. GATTO: Yes, so if we included 4 

### something in the technical reasons that included 5 

### -- I think we'd all agree, we would never make a 6 

### 190 watt or higher LED but I would actually say 7 

### that in our comments we could probably agree that 8 

### if one did exceed that it would be subject to, 9 

### because by design it's now over 190, so. 10 

### MS. ARMSTRONG: And I'm going to turn it 11 

### around and say, how would you know? 12 

### MR. GATTO: We're going to have to get 13 

### that in the technical. There's literally, the 14 

### short answer is there is no way for a -- if it's 15 

### designed to use 22 watts there's really no way 16 

### for it to use 190. 17


### MS. ARMSTRONG: Sure. 18 

### MR. GATTO: I will give you that. 19


### MS. ARMSTRONG: Great. 20 

### MR. BROOKMAN: But, Dave, that was a very 21 

### useful restatement earlier. So thank you for 2246

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### that and I think you've set marching orders for 1 

### you and your association to fulfill DOE's wishes 2 

### here, right? Okay. So I think we got clarity on 3


### that. 4 

### Additional questions, comments at this 5 

### stage? Dick. 6 

### MR. UPTON: I would only ask our members, 7 

### is there any other aspect of 190 watt power 8 

### limiter that you want to address other than what 9 

### we've talked about right now? Is there any other 10 

### product? 11 

### MR. BROOKMAN: Tim. No? 12 

### MR. FLANNERY: No, I'm good. 13 

### MR. BROOKMAN: Okay. 14 

### MS. ARMSTRONG: Okay. And I just want to 15 

### clarify, you know, one of the reasons I think 16 

### we're bringing this up now and as part of this 17 

### public meeting, it's not because -- you guys have 18 

### been asking us to consider this for a while and I 19 

### think we've been fairly consistent in our 20 

### response. We believe we need to do it through a 21


### rule. 2247

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### So this is the right time for this. This 1 

### is the right time to do it. This is the right 2 

### time to work together to figure out a way forward 3 

### for this, but we need the rule to go through, to 4


### be -- 5


### MR. BROOKMAN: Back to Dave. 6 

### MR. GATTO: Sorry. Dave Gatto, 7 

### Westinghouse. 8 

### So when you said earlier that you would 9 

### consider reinterpreting, what we took that to 10 

### mean is -- or what I was hoping it would mean, 11 

### and I'm just going to ask you to point out, is 12 

### that we would reinterpret the Class 3 design rule 13 

### as currently written to allow solid-state 14 

### lighting that met the statutory definition of not 15 

### capable of operating, if we were able to provide 16 

### you the technical details that that's true. 17 

### MS. ARMSTRONG: So, I can't I guess, 18 

### predetermine the outcome of a rule, but we could 19 

### consider such an outcome. 20 

### MR. GATTO: Thank you. 21 

### MR. BROOKMAN: Yes, Dick? 2248

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### MR. UPTON: If we got that to you in this 1 

### time frame we're talking about when could you 2 

### take an action to, for lack of better words, 3 

### terminate the requirement of power limiter? 4 

### Thirtieth of December? 5 

### MS. ARMSTRONG: No. At the very least 6 

### we'd have to put out a proposed rule for comment 7 

### and then finalize. So, you know, right now we 8 

### just have a preliminary analysis out. We would 9 

### gather comment to inform our proposal, we'd put a 10 

### proposal out for comment, then we could finalize. 11 

### So no, it wouldn't be a holiday present, 12 

### unfortunately, this year. But we could work 13 

### something -- we could understand the -- we 14 

### understand the urgency, so. Okay. 15 

### MR. UPTON: Ninety days? 16 

### MR. CYMBALSKY: Didn't you have it 17


### scheduled? 18 

### MS. ARMSTRONG: Are you going to ask for 19 

### a comment period extension? 20


### MR. UPTON: We'll see about that. 21


### MS. ARMSTRONG: Let's make a deal. 2249

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### MR. BROOKMAN: Either Bill or David. 1 

### Bill, I think you. Yes. 2 

### MR. WALKER: Bill Walker, Hunter fan. So 3 

### the statement about shall not be capable of 4 

### operating. So, we had this discussion in the 5 

### last meeting for like two light candelabras, 6 

### where a light kit that just has two light socket 7 

### candelabras, 60 watts, you know, both of them 60 8 

### watts, 120 watts max is all you can put in there. 9 

### Will that be in consideration too for this shall 10 

### not be capable of operating? 11 

### MS. ARMSTRONG: I would say you can -- so 12 

### previously one of the -- so, I will say, 13 

### previously DOE made its original interpretation 14 

### based on the fact that it says, "Shall not be 15 

### capable of operating." And for replaceable bulbs 16 

### there's nothing that says, you know, you can't 17 

### replace them with something with a higher 18 

### wattage. Now, you know, without that limiting 19 

### device in there. 20 

### Now perhaps there are technical reasons, 21 

### things that have changed over time. In your 2250

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### comments you are more than welcome to bring up 1 

### any issues you would like to consider for the 2 

### Department. But I would say there are -- a 3 

### reason before we made our decision, so if you're 4 

### asking us to revisit that rationale you should 5 

### point to anything that might have changed since 6


### then. 7 

### If it hasn't, then -- 8


### MR. BROOKMAN: Dave. 9 

### MR. GATTO: Dave Gatto, Westinghouse. So 10 

### my question would be then, if the thing that 11 

### changed was the EPACT effect on candelabra and 12 

### intermediate based lamps, because I don't believe 13 

### that was promulgated at the time that the limiter 14 

### was discussed, would that represent -- the fact 15 

### that there's no products available that would 16 

### exceed those wattage limits, would that be 17 

### something DOE would consider? It's really more 18 

### of a, is it worth pitching the idea to you or 19 

### not, I guess is where I'm at, because I'd love to 20 

### be able to point it at the current EPACT rule, 21 

### but if you've got some concern that that would 2251

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### not actually prevent consumers from doing it, we 1 

### won't waste our time. 2 

### MS. ARMSTRONG: I can't tell you what 3 

### your -- your comments are not limited. We 4 

### welcome any comments that you would like to make 5 

### for DOE consideration. I think I'll leave it at 6


### that. 7 

### MR. BROOKMAN: Yes, please, Clark. 8 

### MR. LINSTONE: Clark Linstone, Lamps 9


### Plus. 10 

### So, it sounds like barring a test of the 11 

### product, say we're talking about a solid state, 12 

### that if it's physically possible to create a 13 

### 38,000 watt light kit that -- I mean, 38,000 14 

### lumens, excuse me -- that you would need some 15 

### test procedure to basically show that, you know, 16 

### it can't operate above, you know, a certain 17 

### wattage because yeah, 38,000 lumens might be the 18 

### 190 watts that we were trying to avoid. 19 

### MS. ARMSTRONG: So this is Ashley from 20


### DOE. 21 

### So I was a little bit trying to play, for 2252

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### lack of a better term, devil's advocate there 1 

### with that example. Just to ask, you know, when 2 

### you do consider making your comments and asking 3 

### the department to do this reinterpretation and 4 

### why, are there any reasonable bounds you would 5 

### think to put around it? 6 

### I'm not necessarily advocating a test for 7 

### LEDs. We don't have one now, you know for that 8 

### 190 watt. That's different than what we're 9 

### proposing in the future. But, you know, if 10 

### that's what you feel is necessary that's fine 11 

### too. But I was just more asking about -- the 12 

### language in the statute is open-ended and it's 13 

### just very cut and dry. Shall not be capable of 14 

### operating. 15 

### So, when I you know -- how things work at 16 

### the Department, when I come up with this 17 

### technical proposal and I, it's a collective group 18 

### here of Is, but when we come up with our 19 

### technical proposals my lawyers are going to ask 20 

### me, Ashley, how does that meet the shall not be 21 

### capable of operating language? So put yourself 2253

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### in my shoes, and what would you say and why? 1


### That's the ask. 2 

### MR. BROOKMAN: Okay. Terry, please. 3 

### MR. MCGOWAN: Terry McGowan, American 4 

### Lighting Association. 5 

### All ceiling fan light kits have a label 6 

### or a specification sheet that says maximum 7 

### wattage on it. So, what we're proposing here is 8 

### that that maximum wattage not be over 190 watts. 9 

### Is that sufficient when you state maximum wattage 10 

### or the rated wattage of the product, if it's 11 

### under 190 it's acceptable, if it's over it's not? 12 

### MS. ARMSTRONG: So I will say that's 13 

### something that was brought up in the original 14 

### rule and that's something, at least a notion 15 

### originally the department rejected based on the 16 

### fact that, you know, we did find that the CFLK 17 

### could be capable of operating above that rated 18 

### wattage, even though it may not have been 19 

### originally intended for that. 20 

### So, I will say that was something we 21 

### considered before and ultimately ended up at our 2254

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### wattage limiter decision. However, if we are 1 

### reinterpreting if there are reasons or facts that 2 

### have changed as to why that rated wattage is 3 

### different now on the label than it was 4 

### previously, obviously we're open to considering 5


### all the facts. 6 

### MR. MCGOWAN: Well, that's my point, I 7 

### guess because what we're talking about is a 8 

### device that has no replaceable parts. So the 9 

### rated wattage on the box and the specification is 10 

### the wattage and it can't be anything else. 11 

### MS. ARMSTRONG: Right. So I think the 12 

### answer is different for replaceable versus not 13 

### replaceable, perhaps, and maybe you can make 14 

### those nuances in your comments. You know, we've 15 

### kind of gone back and forth of, will you consider 16 

### something as broadly as reinterpreting the whole 17 

### thing for replaceable lamps. And, you know, I'm 18 

### not an expert in CFLKs or lamps by any means, but 19 

### you would have to show -- we came to that 20 

### decision for a variety of facts; based on a 21 

### variety of facts at that time. You would have to 2255

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### show something has changed. 1 

### Now, obviously for LEDs, especially 2 

### nonreplaceable LEDs, things have changed. The 3 

### market has changed a little bit and maybe the 4 

### facts have changed, and that is something you 5 

### have been asking for a long time and we are 6 

### willing to open to considering that. 7 

### MR. MCGOWAN: That's useful. Thank you. 8 

### MS. ARMSTRONG: Yep. 9 

### MR. BROOKMAN: Thank you, Terry. Tim. 10 

### MR. FLANNERY: And I hate to circle back 11 

### here. This is Tim Flannery. 12 

### But if in fact a limiter is not capable 13 

### of going over 190 watts, okay, would that be 14 

### considered a limiting device? 15 

### UNIDENTIFIED SPEAKER: So you mean an LED 16 

### light? 17


### MR. FLANNERY: An LED. 18 

### UNIDENTIFIED SPEAKER: LED driver. 19 

### MS. ARMSTRONG: Yeah, driver? 20 

### MR. FLANNERY: I'm sorry. With the 21 

### driver. 2256

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### MS. ARMSTRONG: I don't know. I mean, 1 

### that's not something I think -- like I said -- 2 

### MR. FLANNERY: But if a driver -- if 3 

### we're able to provide information that the driver 4


### cannot exceed 190 watts would we need an 5 

### additional ruling because it falls within the 6 

### current ruling of a limiter. 7


### MS. ARMSTRONG: So we haven't had an 8 

### opinion on that. If you want to make the case to 9 

### me, happy to consider it separately as a 10 

### different -- that's something I'm not going to be 11 

### able to answer on the spot. But we could talk 12 

### about it, definitely. 13 

### MR. FLANNERY: Okay. 14 

### MS. ARMSTRONG: Yep. If it's simply that 15 

### we need -- you know, it could be that -- I don't 16 

### know if we could do it through guidance, or 17 

### something like that, something quicker, if that's 18 

### what you're asking. 19 

### MR. FLANNERY: Okay. I guess my point 20 

### is, is if the driver is not capable of exceeding 21



### -- 2257

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### MS. ARMSTRONG: Right. 1 

### MR. FLANNERY: -- 190 watts it should 2 

### fall within the existing rule. 3 

### MS. ARMSTRONG: You're asking us to 4 

### interpret the driver as the equivalent of a 5 

### limiter. I get it. 6 

### MR. FLANNERY: Well, it is a limiting 7 

### device. 8 

### MS. ARMSTRONG: I get your ask. 9 

### MR. FLANNERY: Thank you. 10 

### MS. ARMSTRONG: The answer is, I don't 11


### know. 12 

### MR. BROOKMAN: So this has been 13 

### productive. Now additional comments or questions 14 

### in this stream of content before we move on? Any 15 

### additional clarifications from anyone? 16 

### Okay, yes. Colleen. 17 

### MS. KANTNER: I don't know if there -- we 18 

### talked about the wattage limiter for a while. 19 

### Are there any questions or comments on the 20 

### proposed efficacy metrics? 21 

### MS. ARMSTRONG: So just to kind of get 2258

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### back to where we are, for the future rule, not 1 

### the standards today but for standards we're 2 

### considering in this afternoon's presentation, 3 

### we're proposing to move everything to efficacy. 4 

### So there would be no more wattage limit, there 5 

### would be no more limiter. Moving everything to 6 

### efficacy, either lamp based efficacy or some type 7 

### of luminaire type efficacy depending on the type. 8 

### But that's what the proposals are. We 9 

### have a -- you can say you agree with us. That 10 

### would be helpful. 11 

### The court reporter can't actually write 12


### down that. 13


### MR. BROOKMAN: Yeah. Dave. 14 

### MR. GATTO: Dave Gatto, Westinghouse. 15 

### I think that this is something when we 16 

### get to the proposed standards that we'll probably 17 

### talk about a little bit. I think the only 18 

### concern I would have is an efficacy measurement 19 

### is fine as long as the standard potentially, and 20 

### I'm not sure that we even need this, but it may 21 

### need to allow for more flexibility than what the 2259

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### standards that are being proposed are because of 1 

### the way you combine classes. 2 

### But from an efficacy standpoint I think 3 

### that just for Westinghouse's standpoint, we agree 4 

### with, I do agree with you that lamp efficacy is 5 

### the best method. For now I think CFLKs with 6 

### integral SSL luminaire efficacy is acceptable. 7 

### MS. ARMSTRONG: Because it's what we're 8 

### going to get? 9 

### MR. GATTO: Yeah, it's kind of -- it's 10 

### what we're doing now and I know you needed test 11 

### procedure to change that. So unless something 12 

### happens further down the line on luminaires with 13 

### Energy Star that gives you something you could 14 

### tie your cart to, I think that that's fine. 15 

### MR. BROOKMAN: As Ashley said, it's 16 

### useful for stakeholders, for interested parties 17 

### to comment if DOE is getting it right. If you 18 

### like what they're doing it's nice to have that 19 

### acknowledged, so that that's clear. 20 

### Okay. Any final comments, additional 21 

### comments on these two issue boxes, issue box 5 2260

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### and 7 as listed here because we're about to move 1


### on? 2 

### (No audible response.) 3 

### MR. BROOKMAN: Okay, Colleen. 4 

### MS. KANTNER: Okay. So here are the 5 

### proposed test procedures in active mode. This is 6 

### again in Phase 2, to support the Energy 7 

### Conservation Standards rulemaking. 8


### MR. UPTON: It's hard to hear. 9 

### MS. KANTNER: Okay. Sorry about that. 10 

### Again, DOE wants to harmonize with 11 

### existing DOE test procedures whenever possible, 12 

### and with industry test procedures otherwise. 13 

### It's worth noting that DOE is currently engaged 14 

### in two test procedure rulemakings for lamp types 15 

### that are currently used in CFLKs. These are test 16 

### procedures for CFLs and for integrated LED lamps 17 

### which DOE expects to be in force prior to the 18 

### compliance date of the updated CFLK test 19 

### procedures. 20 

### For all compact fluorescent lamps, DOE 21 

### proposes to use DOE's test procedure for CFLs, 2261

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### which is located in Appendix W. If you were to 1 

### try to put a general service fluorescent lamp in 2 

### a CFLK or if you were to use a general service 3 

### incandescent lamp, you would again test lamp 4 

### efficacy, according to Appendix R, which is the 5 

### appendix for those products. 6 

### Any other fluorescent lamp other than a 7 

### CFL or GSFL—this would mostly be circlines—you 8 

### would also test lamp efficacy and this would be 9 

### tested according to LM-9. For integrated LED 10 

### lamps you would also measure lamp efficacy and 11 

### you would use DOE's test procedure for integrated 12 

### LED lamps, which is proposed to be in Appendix 13


### BB. 14 

### For all other solid state lighting lamps 15 

### you would use LM-79, and you would also use that 16 

### for integrated -- for CFLKs with integrated SSL 17 

### circuitry. Only you would be testing luminaire 18 

### efficacy in that case. 19 

### For CFLKs that use the multiple lamp 20 

### models, DOE proposes that each lamp model be 21 

### tested according to the appropriate lamp test 2262

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### procedure for that lamp type. Referencing 1 

### existing DOE lamp test procedures will minimize 2 

### the overall testing burden because lamps may have 3 

### already been tested to DOE test procedures and 4 

### would not require additional testing. 5


### For CFLKs that have both consumer 6 

### replaceable lamps and integrated SSL circuitry, 7 

### DOE proposes that lamp efficacy would be reported 8 

### for the consumer replaceable lamps and that 9 

### luminaire efficacy would be reported for the CFLK 10 

### with integrated SSL circuitry with the consumer 11 

### replaceable lamps removed. 12 

### And again, as we mentioned earlier, DOE 13 

### is not proposing to incorporate energy 14 

### consumption in standby mode or in off mode into 15 

### the CFLK metric. 16


### MR. BROOKMAN: Dave. 17 

### MR. GATTO: Dave Gatto, Westinghouse. 18 

### I'll throw you the bone. We agree with 19 

### that. Put it in with the fans where it makes 20



### sense. 21 

### MR. BROOKMAN: Thank you. 2263

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### MS. KANTNER: Okay. So now let's move on 1 

### to some clarifications to the energy conservation 2 

### standards. CFLK energy conservation standards 3 

### are codified in 10 CFR 430.32,Paragraph S. DOE 4 

### proposes to replace references to Energy Star 5 

### program requirements located there with tables 6 

### that contain the specific performance 7 

### requirements. The idea here is just to remove a 8 

### layer of documentation. 9 

### The performance requirements include for 10 

### CFLKs packaged with medium screw based CFLs: lamp 11 

### efficacy, lumen maintenance at 1,000 hours, lumen 12 

### maintenance at 40 percent of lifetime, rapid 13 

### cycle stress and lifetime. For CFLKs packaged 14 

### with medium screw base light sources other than 15 

### CFLs, it would just be lamp efficacy. For CFLKs 16 

### packaged with pin-based fluorescents, it would be 17 

### system efficacy, as well as a requirement to use 18 

### an electronic ballast. 19 

### And again, the current energy 20 

### conservation requirements remain unchanged. 21 

### We're just trying to clarify things. 2264

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### MR. BROOKMAN: Yes, Dave? 1 

### MR. GATTO: Dave Gatto, Westinghouse. I 2 

### just have a quick one because this is actually 3 

### how we interpreted it, so I believe I appreciate 4 

### the clarification. 5 

### So medium based dimmable or undimmable 6 

### LED screw base lamp that meets the efficacy 7 

### requirements of Energy Star 3.0 or what you're 8 

### referring to now would meet the standard. 9 

### I see nodding. Can I get the yes out 10


### loud? Come on. 11 

### MR. BROOKMAN: Ashley Armstrong. 12


### MS. ARMSTRONG: Yes. 13 

### MR. GATTO: Thank you. 14 

### MR. BROOKMAN: Okay. 15 

### MS. ARMSTRONG: As my enforcement 16 

### attorney back there is staring at me. 17 

### (Laughter.) 18 

### MR. BROOKMAN: Anything additional here? 19 

### (No audible response.) 20 

### MS. KANTNER: DOE is also updating the 21 

### guidance on accent lighting. DOE previously 2265

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### issued guidance on accent lighting used in CFLKs, 1 

### stating that DOE does not consider ceiling fan 2 

### accent lighting that is not a significant light 3 

### source to be part of the 190 watt limitation. 4 

### This was specifically in reference to Product 5 

### Class 3 CFLKs. Because it is difficult to 6 

### quantitatively define a significant light source 7 

### in a CFLK, and may result in inconsistency in the 8 

### application of CFLK standards, DOE proposes to 9 

### withdraw the current accent lighting 30 days 10 

### after the publication of the final rule, and 11 

### consider all lighting packaged with the CFLK to 12 

### be subject to energy conservation requirements. 13 

### And DOE requests comment on this. 14 

### (No comments.) 15 

### MS. ARMSTRONG: Okay. Moving right 16 

### along. 17 

### MR. UPTON: (Indiscernible). 18


### MR. BROOKMAN: No. No comments here. 19 

### Okay. 20 

### MS. ARMSTRONG: You okay with it? 21


### MR. UPTON: Yeah. 2266

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### MS. ARMSTRONG: Okay. 1 

### MS. KANTNER: All right. And then 2 

### finally we come to requirements for the 3 

### determination of representative values. 4 

### And these are the requirements for 5 

### determining representative values during Phase 1. 6 

### I first just want to note that the general 7 

### sampling requirements are applicable to all CFLKs 8 

### except for CFLKs that are subject to a design 9 

### standard to include a wattage limiter. 10 

### If a CFLK does have a test procedure, DOE 11 

### is trying to harmonize with existing DOE sampling 12 

### requirements for various lamp types. So if you 13 

### have a medium screw base CFL you would use the 14 

### requirements for represented values that exist in 15 

### 429.35. This is DOE's requirements for medium 16 

### screw based CFLs. For medium screw base 17 

### integrated LEDs you would use the requirements in 18 

### 429.56. Again, this is just where requirements 19 

### for integrated LED lamps exist for DOE. 20 

### If you were to use a general service 21 

### incandescent lamp you would use the requirements 2267

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### in 429.27. If you were to use a pin-based 1 

### fluorescents you would use the represented values 2 

### in 429.35, so you would use the requirements for 3 

### medium screw base CFLs for consistency between 4 

### those two types. And then this last line here is 5 

### not a sampling requirement. This is just 6 

### pointing to the place in the code where the 7 

### design requirement for a wattage limiter exists. 8 

### Okay. And then here are the requirements 9 

### for determining represented values during Phase 10 

### 2. This would be applicable for compliance with 11 

### amended energy conservation standards if 12 

### established. For all CFLs in that case you would 13 

### use the requirements in 429.35. Again, if you 14 

### were to put a general service fluorescent lamp in 15 

### a CFLK or an incandescent lamp, you would use the 16 

### requirements in 429.27. For integrated LED lamps 17 

### you would use DOE's requirements for integrated 18 

### LED lamps in 429.56. For all other fluorescent 19 

### lamps that are not CFLs or GSFLs—this would again 20 

### mostly be circlines— you would use the same 21 

### requirements as for CFLs. For all other SSL 2268

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### lamps that are not integrated LED lamps, you 1 

### would again use the requirements for integrated 2 

### LED lamps. And for CFLKs with integrated SSL 3 

### circuitry you would use the requirements that 4 

### currently exist in 429.33. These are the CFLK 5 

### specific requirements for representative values. 6 

### Note that in the future, since only lamp efficacy 7 

### will be measured, only the lower confidence 8 

### limit will continue to be there. 9 

### MS. ARMSTRONG: So I just want to point 10 

### out something on this slide. You know, it might 11 

### not be something that you guys are used to or 12 

### something that you're aware of currently, but for 13 

### CFLKs, you know, with the other base now that 14 

### doesn't have a test procedure but just is 15 

### required for a -- for the wattage limiter. So 16 

### we're proposing to move to either lamp efficacy 17 

### or luminaire efficacy. And this is where this 18 

### would matter. We've harmonized for the lamps to 19 

### the representative values and what representative 20 

### values are sampling sections. So the number of 21 

### units you will actually have to test. And then 2269

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### the confidence limits associated with how you 1 

### actually calculate the numbers that you can then 2 

### represent on your marketing literature and the 3 

### numbers you would have to certify to the 4 

### Department. 5 

### So if you haven't had a chance to look at 6 

### this, it's something that you do want to pay 7 

### attention to when you do make your comments 8 

### because it affects the number you would have to 9 

### test as well as how you can make representations 10 

### about your product's efficiency. 11 

### MR. BROOKMAN: David. 12 

### MR. TURNER: David with Hunter. When you 13 

### say "you" maybe that's a general you. 14


### MS. ARMSTRONG: Manufacturers of CFLKs. 15 

### MR. TURNER: Of the lamps or the CFLKs? 16 

### MS. ARMSTRONG: So the covered product is 17 

### a ceiling fan light kit. The requirement is on 18 

### the manufacturer of ceiling fan light kits. Now 19 

### that being said, what we have done is harmonize 20 

### with the lamp procedure. So if you're buying 21 

### otherwise, lamps that are compliant with the lamp 2270

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### regulations and you trust them, it's still your 1 

### responsibility but you trust them, you don't have 2 

### to retest them. You know, you need to maintain 3 

### documentation if DOE were to come and ask you for 4 

### the documentation, you should have a copy of that 5 

### lamp documentation. 6 

### MR. TURNER: Okay. So, besides they, 7 

### when you say you, that means the lamp 8 

### manufacturer tests and then we trust what they 9


### test. 10 

### MS. ARMSTRONG: It's up to you. That's 11 

### your decision. I say the CFLK manufacturer has 12 

### to comply with these regs. However you choose to 13 

### do that, yourself or relying upon the lamp 14 

### manufacturer in the room, that's up to you. 15 

### That's a business decision. But we've given you 16 

### that opportunity to not have to retest. 17


### MR. BROOKMAN: Yeah. Dave. 18 

### MR. GATTO: This is more for you, Dave 19 

### Turner. The challenge is that I'm assuming that 20 

### you would have requested third-party test results 21 

### that would back that up, which is what DOE would 2271

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### ask for -- 1 

### MR. TURNER: Right. 2


### MR. GATTO: -- based on whatever the 3 

### appropriate test procedure. But you're still 4 

### responsible if the lamps that actually make it 5 

### into your light kit don't test to the compliance 6 

### that you reported, then it would be you -- 7 

### MR. TURNER: Right. 8 

### MR. GATTO: -- that's in the dialog. 9 

### MR. TURNER: I understood there, I just - 10



### - 11


### MR. GATTO: Yeah. 12 

### MR. TURNER: We don't have planned 13 

### testing -- 14 

### MS. ARMSTRONG: So, and the reason I 15 

### point out the last one is, the ones with 16 

### integrated LEDs we're moving to this luminaire 17 

### efficacy. I would imagine that it's a whole 18 

### integrated type ceiling fan light kit thing. So 19 

### you know, that test, those number of units that 20 

### need to be tested, those calculations would be 21 

### something new from what you're doing; a departure 2272

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### from what you're doing today. At least that's 1 

### our proposal. So, I just wanted to point that 2 

### out because that is different and sometimes 3 

### people aren't aware that we actually have 4 

### sampling provisions in addition to just the test 5 

### procedure that govern how you make 6 

### representations. 7 

### MR. BROOKMAN: Okay. Additional 8 

### comments? Thanks for the clarification. That's 9 

### helpful. Final comments here before we move on? 10 

### (No audible response.) 11 

### MS. KANTNER: Okay. I think that's the 12 

### end for the presentation for the test procedures. 13


### MR. BROOKMAN: Yes. 14 

### MS. KANTNER: This is -- 15 

### MR. BROOKMAN: And so we promised you 16 

### another opportunity to comment here at the end 17 

### before we talk about how to submit written 18 

### comments. Final comments here, summary comments, 19 

### issues that haven't been fully described? Dave? 20 

### MR. GATTO: I don't know if it applies 21 

### here or if its -- because tomorrow when we talk 2273

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### about fans you're reinterpreting what a ceiling 1 

### fan is, which then in turn affects light kits. 2 

### So we haven't as much time with light kits to 3 

### review the documents. But as I read through this 4 

### and as I read through the TSD, it seems like DOE 5 

### is proposing that that reinterpretation would be 6 

### effective 30 days from the publication of the 7 

### test procedure, not in conjunction with the final 8


### rule. 9 

### So my question would be, 30 days is just 10 

### -- I mean, we can talk about it more tomorrow. 11 

### It applies to fans. But as we speak about light 12 

### kits it really does require an enormous amount of 13 

### time to review the product lines, to add or 14 

### change materials, build materials, add limiters 15 

### if applicable in some of what are currently 16 

### exempted fans which have a light kit, which you 17 

### know, had been exempted. 18 

### So I don't think we disagree with your 19 

### interpretation. I think we talked about that in 20 

### the last meeting, but maybe it's more for 21 

### tomorrow's conversation, but I just want to point 2274

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### out that it affects CFLKs and it affects ceiling 1 

### fans. And it just seemed like a very short -- I 2 

### think you guys know from prior meetings and from 3 

### what we've all fed Navigant, what the development 4 

### timeline is for a fan and light kit, especially 5 

### with the design elements that are included. 6 

### Thirty days just seems it's impossible. But I'm 7 

### not sure if you could help us understand the 8 

### thinking behind it. 9 

### MS. ARMSTRONG: So I'm going to -- this 10 

### is Ashley from DOE. I'm going to mostly wait 11 

### until tomorrow because it is teed up tomorrow. 12 

### You're right, though, if we were to -- we have 13 

### proposed to reinterpret the definition of a 14 

### ceiling fan as encompassing huggers so if we did 15 

### that it said CFLKs that are packaged with hugger 16


### fans would fall under the CFLK standards. The 17 

### proposed date is 30 days. 18 

### So when we talk about it tomorrow -- 19 

### you've got all your facts right so kudos to you 20 

### for reading the notice thoroughly. I would say 21 

### be prepared tomorrow to come with a discussion 2275

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### piece about what your ask would be for a 1 

### timeframe that's reasonable, and why. 2 

### MR. GATTO: Okay. 3 

### MS. ARMSTRONG: Okay? 4


### MR. BROOKMAN: Great. Thanks for that. 5 

### Final comments before we bring this meeting to a 6 

### closure? Your name, please? 7 

### MR. ROO: Allen Roo with Emerson 8 

### Electric. Going back to the accent lighting, 9 

### would existing inventory be -- what term? 10 

### Regulated by the new rule, 30 days? 11 

### MS. ARMSTRONG: Ms. Barhydt, you want to 12 

### answer that one? Existing inventory, would it 13 

### kick in 30 days, for accent lighting if we were 14 

### to reinterpret? 15


### MS. BARHYDT: I don't know the answer to 16 

### that off the top of my head. 17 

### MS. ARMSTRONG: So we'll get back to you. 18 

### MR. ROO: Well, previously before EPAC 19 

### 2005 I think the existing inventory was allowed 20 

### to be in the warehouse. 21 

### MS. ARMSTRONG: So let us get back to you 2276

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### with the specific answer. Will you be here 1


### tomorrow? 2


### MR. ROO: Yes. 3 

### MS. ARMSTRONG: Let us try to get back to 4 

### your tomorrow. 5 

### MR. ROO: And if it is, 30 days is not 6 

### enough time to requalify a product. 7 

### MS. ARMSTRONG: So 30 days is fine for 8 

### accent lighting as well as its inventory is 9 

### allowed to be sold through. Is that my 10 

### interpretation of your -- 11 

### MR. ROO: Yeah, and then, you know, new 12 

### imports. Thirty days is not enough time to 13 

### redesign the product and requalify it with the 14 

### safety agencies. You're probably looking at 120 15 

### days minimum. But I'd request about six months. 16 

### MS. ARMSTRONG: So let me actually -- I 17 

### guess I'm not understanding. I mean, DOE's 18 

### interpretation of accent lighting, how does that 19 

### impact your safety qualifications? 20 

### MR. ROO: Well, you're going to include a 21 

### new component, a breaker, a fuse, whatever it is. 2277

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### MS. ARMSTRONG: Okay. So that part of 1 

### it. 2 

### MR. ROO: You're going to have to go back 3


### to UL and -- 4 

### MS. ARMSTRONG: Thank you. 5 

### MR. ROO: -- and request they test them. 6 

### MS. ARMSTRONG: Fair enough. Okay. 7 

### Thanks for that clarification. 8 

### MR. BROOKMAN: Yes. Thank you, Allen. 9 

### Dick? 10 

### MR. UPTON: Ashley, the issue of 11 

### inventory on hand, what happens when you people 12 

### go through retailers to find out what they've got 13 

### and they've got products still on the shelf that 14 

### may be two years old and three years old, and 15


### that's not uncommon. 16 

### MS. ARMSTRONG: Right. 17 

### MR. UPTON: Is the manufacturer going to 18 

### have the problem of -- 19


### MS. ARMSTRONG: No. 20 

### MR. UPTON: -- having old product around? 21 

### MS. ARMSTRONG: So I'll limit this 2278

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### discussion to say we're talking about these 1 

### ceiling fan light kits here because there are 2 

### some nuances in some of our other products that 3 

### just are not relevant here at all. 4 

### But so typically our regs are at the 5 

### point of manufacturer. So once it leaves the 6 

### manufacturer's possession, or the point of 7 

### import, I will clarify that because that's a, you 8 

### know -- you know, but once it leaves the 9 

### manufacturer's possession, once it crosses the 10 

### border, once it goes out into the retail chain it 11 

### is otherwise in commerce. But we wouldn't go 12 

### back. We're looking for the date of manufacture, 13 

### the date of importation. Those are the key 14


### dates. 15 

### I will get a specific answer to 16 

### reinterpretation questions though, for tomorrow 17 

### from our legal staff. Just let me talk to them. 18 

### Yep, no problem. 19 

### MR. FLANNERY: It's also 30 days transit 20 

### from once it leaves the port to cross the border. 21 

### MS. ARMSTRONG: Okay. 2279

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### MR. BROOKMAN: Okay. Thank you, Tim. 1 

### Okay. 2 

### Final comments? Then back to Lucy. 3 

### MS. DEBUTTS: Well, this is -- I'm sorry. 4 

### I saw a hand? No? Okay. 5 

### This is Lucy again. So as a reminder in 6 

### closing for the test procedure in ceiling fan 7 

### light kits written comments, we are expecting 8 

### them by January 14th, 2015 and these are the ways 9


### to reach out to us. 10 

### Now I just want to point out that if you 11 

### accidentally send the comments not to the docket 12 

### e-mail address but either me or the general e13 

### mail address, we'll still consider them. I had 14 

### this question before so I just wanted to answer 15 

### that. But please use the docket e-mail address. 16 

### MR. BROOKMAN: Okay. So I think we are I 17 

### guess ending the test procedure portion of this 18 

### public hearing. We're going to take a break and 19 

### then we're going to move on from the break to 20 

### take up the energy conservation standards portion 21 

### of the meeting. 2280

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### It's now 10:45. I think 15 minutes ought 1 

### to be sufficient and so we'll resume here at 2 

### 11:00 and maybe, Emily, you can send out a 3 

### message for anybody that would be interested that 4 

### we're going to start early, the energy 5 

### conservation standards portion; earlier than was 6 

### reflected in the draft agenda. 7 

### So I think most of you are familiar with 8 

### the procedures around here. You must wear a 9 

### badge visible in the Department of Energy. There 10


### are restrooms on both ends of the hall. The 11 

### coffee shop is on the ground floor and we're 12 

### going to resume at 11:00. We'll see you back 13


### here then. 14 

### (Recess from 10:45 a.m. until 11:02 a.m.) 15


### MR. BROOKMAN: Let's resume. Good 16 

### morning again, everyone. This is the Energy 17 

### Conservation Standards Preliminary Analysis for 18 

### Ceiling Fan Light Kits segment of today's 19 

### meeting. 20 

### Today is Tuesday, November 18th, 2014. 21 

### We just finished this morning, first thing, a 2281

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### public meeting on test procedure notice of 1 

### proposed rulemaking. Now we're moving on to the 2 

### energy conservation standards segment. 3 

### Before we go much further all of you have 4 

### a detailed agenda in front of you. I won't 5 

### restate what I stated this morning, but we also, 6 

### the Department representatives have indicated 7 

### that they have a follow-on comment from the 8 

### morning meeting. Yes. 9 

### So apparently Dave has a comment. 10 

### MR. GATTO: So for the test procedure for 11 

### integrated solid state lighting we had a 12 

### discussion, Terry and I, offline, and we'd like 13 

### you to consider including system efficacy. So 14 

### the light engine. So which LM-79 would apply to. 15 

### So rather than luminaire efficacy, which 16 

### I know I said it was kind of fine with me, we 17 

### think LM-79 would provide a method that's less 18 

### expensive and less burdensome for manufacturers 19 

### to be able to give us the light engine efficacy, 20 

### the same as we would for lamps. So treat them 21 

### like lamps from the standpoint of the test 2282

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### procedure where applicable. I mean, if there's a 1 

### product that's not SSL where there isn't an 2 

### existing test procedure we know you'd have to do 3 

### luminaire efficacy. 4 

### MR. BROOKMAN: Okay. So thank you for 5 

### that. That's always helpful to get supplemental 6 

### comment, additional comment and also of course 7 

### the Department expects and hopes you will provide 8 

### extensive and detailed written comments. 9 

### MS. ARMSTRONG: So, Doug, can I ask one 10 

### clarifying question? 11 

### MR. BROOKMAN: Please, Ashley. 12 

### MS. ARMSTRONG: It's not going to you, 13 

### though, luckily. It's going to the corner. 14 

### MR. BROOKMAN: Tim. 15


### MS. ARMSTRONG: You made a comment at the 16 

### very end of this morning's proceeding regarding 17 

### something about the delta between 30 days from 18 

### leaving port maybe, until you bring in a product. 19 

### I just wanted to clarify, what was that 30 day 20 

### period you were referring to because I wasn't 21 

### sure that I captured it correctly. 2283

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### MR. FLANNERY: Okay. This is Tim 1 

### Flannery. 2 

### You had mentioned that the effective date 3 

### from when it actually crosses the border. So 4 

### products, when they leave from Asia, which is 5 

### predominantly where the proposed is coming and 6 

### going from, going from port to the States is 7 

### approximately 21 to 28 days. So realistically if 8 

### product is actually leaving Asia today it's not 9 

### going to be arriving here until 30 days from now. 10 

### And sometimes in excess of that with customs and 11 

### things of that nature. 12 

### MS. ARMSTRONG: All right. So I just ask 13 

### that you -- thank you for your clarification, and 14 

### I just ask that you consider, when you make your 15 

### comments, whether it be on the reinterpretation 16 

### of the accent light or the reinterpretation 17 

### tomorrow for the ceiling fans with respect to 18 

### huggers, and then the implications that would 19 

### have on ceiling fan light kits shipped with 20 

### huggers that when you provide comments that you 21 

### discuss what a reasonable time frame might be for 2284

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### those reinterpretations should we end up 1 

### finalizing them as proposed after comment. 2 

### MR. FLANNERY: Okay. Point noted. 3


### MS. ARMSTRONG: Thanks. 4 

### MR. BROOKMAN: Thank you. Any additional 5 

### clarifications, comments, related to this 6 

### morning's test procedure discussion? Sometimes 7 

### things bubble forward in the break. 8 

### Okay. Then we're going to proceed, we're 9 

### going to move on to the energy conservation 10 

### standards preliminary analysis segment of the 11 

### meeting, and Lucy deButts for opening remarks. 12 

### MS. DEBUTTS: All right. Lucy deButts 13 

### with DOE. So let's talk about submitting 14 

### comments now on the energy conservation standards 15 

### part of the ceiling fan light kits rulemaking. 16 

### And this slide shows the docket number and RIN 17 

### number that we are requesting to note when you 18 

### send written comments in. The e-mail address is 19 

### also listed, so as I stated earlier this morning, 20 

### the electronic submissions are preferred, however 21 

### if you can't accommodate that there is postal 2285

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### service and courier services allowed as well. 1 

### The comment period for energy 2 

### conservation standards rulemaking for ceiling fan 3 

### light kits ends on December 30th of 2014. So we 4 

### would like to have written comments submitted by 5


### that date. 6 

### And now to opening remarks. 7 

### MR. BROOKMAN: Opening remarks. Summary 8 

### statements here at the outset; issues that matter 9 

### to you. 10 

### Yes, please. Marianne. 11 

### MS. DIMASCIO: Hi. This is Marianne 12 

### Dimascio from the Appliance Standards Awareness 13 

### Project and just very brief comment saying that 14 

### first of all thank you for the analysis and 15 

### advancing the rulemaking to DOE. And at this 16 

### time we tentatively support the regrouping of 17 

### product classes, and also support the use of lamp 18 

### efficacy as the primary metric for the revised 19 

### standards. Thank you. 20 

### MR. BROOKMAN: Thank you. It's nice to 21 

### get comments that are supportive. That's 2286

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### helpful. 1 

### Additional comments here at the outset? 2 

### Then we'll proceed. 3 

### MS. DEBUTTS: Just like earlier today 4 

### with test procedures I'd like to share with 5 

### everyone our projected schedule and this is shown 6 

### on the slide that we're reviewing right now. 7 

### So the framework document was published 8 

### on March 11th of 2013. Then we followed up based 9 

### on the comments we received and data and 10 

### additional analysis, was the notice for the 11 

### preliminary analysis of technical support 12 

### documents availability on October 31st of 2014. 13 

### We are projecting to publish the notice 14 

### of proposed rulemaking for ceiling fan light 15 

### kits. The NOPR in third quarter of 2015, which 16 

### will be followed up by the final rule for ceiling 17 

### fan light kits in the second quarter of 2016. 18 

### And that would mean that the compliance dates for 19 

### ceiling fan light kits would be projected during 20 

### the second quarter of 2019. 21 

### Any questions? 2287

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### (No audible response.) 1 

### MS. DEBUTTS: No. Okay. Well, let's go 2 

### into regulatory history for energy conservation 3


### standards. 4 

### So, the test procedures and energy 5 

### conservation standards both came out with the 6 

### Energy Policy Act of 2005 and provided DOE with 7 

### ability to establish energy conservation 8 

### standards for ceiling fan light kits. 9


### So on October 18th of 2005 we also 10 

### published the final rule, technical amendment 11 

### that codified energy efficiency standards for two 12 

### product classes. And since we did not do the 13 

### codifying -- we didn't publish the final rule for 14 

### the third class, on January 11th of 2007 DOE 15 

### published the final rule technical amendment 16 

### which codified energy efficiency standards for 17 

### third product class as they were stated in the 18 

### legislation. 19 

### And the DOE's authority to conduct the 20 

### energy conservation standard lies in the U.S. 21 

### Code 42, part 6295(ff)(5). 2288

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### As to the scope of the coverage it's very 1 

### similar to what we saw earlier today in the test 2 

### procedure, and basically it's the same, not 3 

### similar. As I said, the CFLK is defined as 4 

### equipment designed to provide light from ceiling 5 

### fans. They can be integral or attachable, and 6 

### therefore any equipment designed to provide light 7 

### from the product that are defined as ceiling fans 8 

### under the ceiling fan rulemaking will be included 9 

### in the scope for ceiling fan light kits 10 

### rulemaking as well. 11 

### And if you don't have any further 12 

### questions on what was stated earlier, market and 13 

### technology assessment, Colleen is back at the 14 

### podium. 15 

### MS. KANTNER: Hi. I'm going to try to 16 

### adjust this mic a little bit. See if this helps 17 

### at all. Any better? 18


### MR. BROOKMAN: That's better. 19 

### MS. KANTNER: Okay. Alright. So now 20 

### let's talk about the market and technology 21 

### assessment. The purpose of the market and 2289

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### technology assessment is to characterize the 1 

### ceiling fan light kit market, to define product 2 

### classes, and to identify technology options. 3 

### The methodology used is, first, we 4 

### identify and characterize manufacturers of CFLKs. 5 

### Then DOE identifies existing regulatory and 6 

### voluntary efficiency programs, then gathers 7 

### historical and other relevant market data, 8 

### estimates market trends, and identifies measures 9 

### that could improve efficiency. 10 

### DOE first observed that CFLKs seem to be 11 

### almost exclusively paired with low-volume ceiling 12 

### fans, where volume refers to air flow. Low13 

### volume ceiling fans will be described and 14 

### discussed tomorrow, but the general idea is that 15 

### these are ceiling fans that are typically used in 16 

### residential and certain commercial applications, 17 

### but not industrial applications. 18 

### Even if manufacturers were to begin 19 

### producing CFLKs for high-volume ceiling fans in 20 

### large number, DOE does not anticipate that they 21 

### will have distinctive characteristics from 2290

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### ceiling fan light kits designed for low-volume 1 

### ceiling fans, and therefore DOE only analyzed 2 

### CFLKs designed for low-volume fans in its 3 

### analysis. 4 

### To obtain a better understanding of the 5 

### CFLK market, DOE examined the market distribution 6 

### of CFLKs broken down by product, class, and 7 

### socket type. This was based on comprehensive 8 

### store surveys at a number of stores for the three 9 

### largest retailers of ceiling fans and light kits, 10 

### as well as an examination of product offerings 11 

### available online. 12 

### These data were then weighted to get 13


### overall market shares. The breakdown of sales 14 

### online versus in-store came from a consumer 15 

### survey data from the market research firm, NPD, 16 

### and the data were also weighted by price. 17 

### Overall as you can see, candelabra based 18 

### CFLKs in Product Class 3 dominated the market 19 

### with some CFLKs with medium screw based CFLs and 20 

### a few using GU-24s, but not a significant number 21 

### of any other type, including pin-based 2291

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### fluorescent CFLKs. 1 

### DOE also looked into historical 2 

### shipments. DOE used data from NPD to estimate 3 

### historical shipments of ceiling fans and ceiling 4 

### fan light kits. Here are estimates from NPD of 5 

### the total U.S. shipments of ceiling fans sold 6 

### with and without CFLKs, along with shipments of 7 

### ceiling fans for which it was not specified if 8 

### the ceiling fan was sold with or without a light 9 

### kit. 10 

### DOE assumed that the ratio of ceiling 11 

### fans sold with and without light kits was 12 

### equivalent for consumers who did and did not 13 

### specify if they had one and came up with the 14 

### total estimates of sales with and without a 15 

### ceiling fan light kit shown in the bottom table. 16 

### Note that the fraction of ceiling fans 17 

### sold with the ceiling fan light kit appears to be 18 

### pretty constant over time. These numbers may not 19 

### capture stand-alone CFLKs that were sold at a 20 

### different time than the ceiling fan, but DOE does 21 

### not believe that this would be a significant 2292

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### fraction of ceiling fan light kits, since 1 

### consumers are likely to want to make sure that 2 

### the light kit matches the style of the ceiling 3


### fan. 4 

### This fraction is also consistent with the 5 

### total fraction of ceiling fans installed with 6 

### light kits from an LBNL study on ceiling fans and 7 

### light kits. 8 

### MR. BROOKMAN: Yes, David. 9 

### MR. TURNER: David with Hunter. Was 10 

### there an estimate for '12 and '13? 11 

### MS. KANTNER: No, there was not an 12 

### estimate available. 13 

### MR. TURNER: I mean, did DOE or LBNL come 14 

### up with one, I guess to -- as to the direction of 15 

### the trajectory. 16 

### MS. KANTNER: Mo, do you want to answer 17 

### this? 18 

### MR. GANESHALINGAM: We do a shipment 19 

### projection -- 20 

### MR. BROOKMAN: Let's get to a microphone. 21 

### MR. GANESHALINGAM: Sorry. 2293

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### MR. BROOKMAN: Thank you. David, I want 1 

### you to get that microphone closer to your face, 2 

### please. 3 

### MR. GANESHALINGAM: Hi, this is Mohan 4 

### Ganeshalingam from Lawrence Berkley National Lab. 5 

### Yes, we did a shipment trajection which 6 

### we'll talk about later this afternoon. 7 

### MR. BROOKMAN: Okay? 8 

### MS. ARMSTRONG: But you guys should feel 9 

### free to provide us data on shipments to help 10 

### inform the analysis too. 11 

### MR. TURNER: This is David with Hunter. 12 

### I think -- and we'll discuss this later, but 13 

### having some input from the two largest retailers 14 

### as well would be very helpful and that's 15 

### something that we're attempting, but also that we 16 

### hope that we can, you know, somehow unite. 17 

### MS. ARMSTRONG: That would be great. 18 

### We're happy to work on that with you. 19 

### MR. BROOKMAN: Thank you. Okay. 20 

### MS. ARMSTRONG: Okay. 21 

### MS. KANTNER: Then we have a couple of 2294

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### items for comment. DOE assumes that the majority 1 

### of ceiling fan light kits are sold with ceiling 2 

### fans and did not analyze ceiling fan light kits 3 

### sold separately in its analysis, and DOE requests 4 

### comments on this assumption and any available 5 

### data on CFLKs sold separately. 6 

### MR. BROOKMAN: David. 7 

### MR. GATTO: Dave Gatto, Westinghouse. 8 

### We, for the most part, agree with the 9 

### analysis in terms of the percentage in that it's 10 

### not meaningful. We looked at our own numbers. 11 

### We can't obviously provide that individually, 12 

### although I have provided some information to 13 

### Navigant and I think Aisha and Michael. But for 14 

### what it's worth we kind of agree with where 15 

### you're at. It's probably the closest to reality 16 

### that we're going to get. 17 

### MR. BROOKMAN: Okay. Thank you. 18


### MS. KANTNER: DOE also seeks answers to 19 

### the following questions related to ceiling fan 20 

### light kits designed for high-volume fans. Do 21 

### manufacturers anticipate that ceiling fan light 2295

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### kits designed for high-volume fans will 1 

### constitute a significant fraction of the CFLK 2 

### market in the next five to 10 years? What range 3 

### of lumen outputs would these products be designed 4 

### to achieve, and would these CFLKs be likely to 5 

### have any unique characteristics that are not 6


### common to the current market of CFLKs? 7 

### MR. BROOKMAN: Three rather specific 8 

### questions. Yes, Nathan. 9 

### MR. FRAMPTON: This is Nathan with 10 

### Fanimation, just a comment. I think on the high11 

### volume questions you're not going to get much 12 

### response today because I don't think there's any 13 

### high-volume manufacturers represented here. 14


### MS. KANTNER: Understood. 15 

### MR. BROOKMAN: Okay. Thank you. Dave? 16 

### MR. GATTO: So with -- and I've provided 17 

### this information to Navigant. With high 18 

### volume/small diameter, which is the one high19 

### volume fan that Westinghouse produces, we don't 20 

### include light kits. We don't really see that 21 

### changing, the applications, the industrial 2296

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### applications that are in are typically high 1 

### enough up that there wouldn't be a light source 2 

### capable of giving the light. Typically the space 3 

### is lit in some other manner and the fan is being 4 

### used because there is either no other HVAC system 5 

### in place or as a supplement to that. 6 

### MR. BROOKMAN: Can you say what the range 7 

### of lumens is approximately? 8 

### MR. GATTO: I think the short answer is, 9 

### we don't have a high-volume industrial fan with a 10 

### light kit, and we're not planning one. 11


### MR. BROOKMAN: Uh-huh. 12 

### MR. GATTO: I don't know what lumens you 13 

### would put on one. I mean, in minimum height 14 

### requirements it's going to be way up high in the 15 

### air. 16


### MR. BROOKMAN: Yeah. 17 

### MR. GATTO: Typically there is some other 18 

### light source. If it's an industrial application 19 

### it might be HID or LED now is taking center 20 

### stage. Or typically linear fluorescent is in 21 

### place. 2297

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### MR. BROOKMAN: Okay. 1 

### MR. GATTO: High Base. Something. 2 

### MR. BROOKMAN: Yeah. Okay. Thank you. 3 

### Nathan, you have a -- no? Nothing? Okay. 4 

### MS. KANTNER: Okay. So next is the 5 

### product classes that DOE considered. Pursuant to 6 

### EPCA, DOE establishes product classes based on 7 

### three criteria. First, by the type of energy 8 

### used, by the capacity of the product, and by any 9 

### other performance related features that require 10 

### different standard levels such as features 11 

### affecting consumer utility. 12 

### As far as energy used, DOE notes that all 13 

### CFLKs use electricity. In regards to capacity, 14 

### and by capacity we mean total light output, CFLKs 15 

### do not require different product classes to 16 

### account for a capacity. So the remaining 17 

### criterion is utility. The three original product 18 

### classes were defined in terms of socket type, 19 

### which DOE does not see as providing the unique 20 

### utility that would necessitate a different 21 

### efficiency standard. 2298

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### DOE believes that utilities such as 1 

### instant on, color quality, and dimming, which are 2 

### provided by incandescent lamps are also available 3 

### in more efficacious replacements such as LED 4 

### lamps and luminaires. 5 

### DOE did, however, find a unique utility 6 

### in CFLKs that use externally ballasted or driven 7 

### lamps, in that they allow consumers to replace 8 

### the lamp or the ballast separately if one fails 9 

### independently of the other. Additionally, 10 

### externally ballasted lamps may have different 11 

### cost efficiency relationships from internally 12 

### ballasted lamps, so they may require a different 13 

### efficiency standard. 14 

### As a result DOE is considering two 15 

### product classes: Externally Ballasted or Driven 16 

### lamps, and All Other CFLKs. Since there are not 17 

### externally driven CFLKs currently on the market, 18 

### with respect to the products currently on the 19 

### market, the new product class structure 20 

### essentially combines current product classes 1 21 

### and 3 into a new product class 2. 2299

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### Now we have some items for comment. 1 

### First, DOE is considering a new product class 2 

### structure that divides CFLKs into two product 3 

### classes that we just mentioned. DOE invites 4 

### comment on this structure. 5


### MR. BROOKMAN: Dave. 6 

### MR. GATTO: So, and this may come as a 7 

### surprise to DOE, but I think we agree with, or at 8 

### least Westinghouse, we agree with the fact that 9 

### LEDs will replace the utility of traditional 10 

### incandescent. 11 

### I think the challenge that it presents is 12 

### going to show up more in the LCC where I have 13 

### some questions about how you did the analysis. 14 

### What I would like DOE to consider is that the 15 

### utility that may get lost in there is going to be 16 

### on the design side because currently, and even if 17 

### you look three years out, while LEDs are moving 18 

### at a very fast pace, the majority of the 19 

### development or at least the fastest pace is A 20 

### lamp manufacturers, not necessarily fan 21 

### manufacturers who have to buy from a lamp 22100

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### manufacturer. So they're going to trail the 1 

### development and price learning. 2 

### The other thing that you're -- a little 3 

### bit of an issue, at least for the candelabra 4 

### based light kits that are out there is that, it's 5 

### tough to get the same lumen package in that small 6 

### of a space and maintain hours with an LED today. 7 

### You have heat issues. So it's going to get 8 

### there. It's going to get there very quickly, but 9 

### finalizing a rule with fans that requires the use 10 

### of products that aren't quite ready for primetime 11 

### is a concern, I think, for the fan industry. 12 

### MR. BROOKMAN: Okay. Thank you. 13 

### Additional comments on product classes, the 14 

### combination that's being proposed here? 15 

### Okay. 16 

### MS. KANTNER: Okay. DOE requests comment 17 

### on whether manufacturers are currently producing 18 

### or expecting to produce CFLKs that use externally 19 

### driven LED lamps. 20 

### MR. BROOKMAN: Okay. 21 

### MS. KANTNER: Okay. And DOE -- 22101

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### MS. ARMSTRONG: So can we interpret 1 

### silence as meaning no? 2 

### MR. BROOKMAN: Yes, Terry. 3 

### MS. KANTNER: I'll ask in a more direct 4


### way. 5 

### MR. MCGOWAN: Terry McGowan, American 6 

### Lighting Association. 7 

### When you mean externally driven LED lamps 8 

### what we're seeing is a circuit board with LEDs on 9 

### it and a driver in the middle. That's external 10 

### to the LEDs. It does not -- is that included in 11 

### your definition? 12


### MS. KANTNER: Are the LEDs consumer 13 

### replaceable? 14


### MR. MCGOWAN: No. 15 

### MS. KANTNER: Then, no. 16 

### MR. BROOKMAN: I didn't hear your answer. 17 

### MS. KANTNER: Oh. Then, no. 18 

### MR. BROOKMAN: Then, no. Okay. 19 

### MR. MCGOWAN: So you're defining this as 20 

### an LED assembly with an external driver, 21 

### physically separate from the LED assembly. 22102

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### MS. KANTNER: We're envisioning something 1 

### that's equivalent to a pin-based CFL, where 2 

### you've got a consumer replaceable lamp and then a 3 

### ballast or driver that's integral to the light 4 

### kit. 5 

### MR. MCGOWAN: Yeah, that's the problem 6 

### because the LED assembly is not consumer 7 

### replaceable. The LEDs are soldered in place, 8 

### can't be replaced, the assembly is custom built 9 

### to fit into the light -- 10 

### MS. KANTNER: Right. In that case it 11 

### would be in the all other product class. 12 

### MS. ARMSTRONG: So your answer to the 13 

### question then, would be no. 14 

### MR. MCGOWAN: Okay. Thank you. 15 

### MR. BROOKMAN: Nathan, please go ahead. 16 

### MS. ARMSTRONG: Yep, that's what I'm 17 

### talking about too. So the answer is you don't 18 

### see it going there. 19 

### MR. LINSTONE: This is Clark Linstone, 20 

### Lamps Plus. 21 

### Are you referring to basically an LED 22103

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### bulb that is, you know, the unit unto itself 1 

### irreplaceable, therefore that would fall into 2 

### this. Is there any contemplation of any fan 3 

### manufacturers including LED bulbs? Is that the 4 

### question? 5 

### MR. BOESENBERG: This is Alex Boesenberg, 6


### NEMA. 7 

### I think what -- since I don't work with 8 

### fan manufacturers, coming from the commercial 9 

### lighting side what this sounds like to me is 10 

### maybe the question -- Ashley, tell me if I get it 11 

### right. For the question for the fan 12 

### manufacturers is, do you plan in the future, or 13 

### are you currently offering ceiling fans with a 14 

### Zhaga socket base or some kind of connections 15 

### where you could snap in LED modules. You know, 16 

### so a consumer changeable LED light source that -- 17 

### I mean, I haven't really seen these on the store 18 

### shelves yet, but that is one of the goals of 19 

### organizations such as Zhaga, to come up with 20 

### something that is like a bayonet connect or 21 

### something. So, if anyone is thinking of that 22104

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### then I think that would be relevant to this item. 1


### MR. BROOKMAN: Nathan. 2 

### MR. FRAMPTON: I mean, my assumption 3 

### would be yes. The answer is yes. 4 

### MR. BROOKMAN: Uh-huh. Ali, do you want 5 

### to chime in here? Nothing. Okay. Nothing. 6 

### I get the sense that we haven't fully 7 

### covered this. And, Terry, you want to add some 8 

### more content here, please? 9 

### MR. MCGOWAN: Yes. Terry McGowan again. 10 

### MR. BROOKMAN: I don't think we've even 11 

### described the parameters on that LED fixture yet, 12 

### right? Keep going. 13 

### MR. MCGOWAN: No, we're very worried that 14 

### this is either not inclusive enough or too 15 

### inclusive and I'm not sure we know exactly which. 16 

### What we're seeing, of course, is a lot of changes 17 

### in the way LEDs are put into lighting products. 18 

### And Alex very properly brought up the fact that 19 

### Zhaga and other systems folks are making up new 20 

### sockets. And these sockets will impinge upon the 21 

### design of these light kits. They're not now, but 22105

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### they will. 1 

### And we're trying to look ahead five, 10 2 

### years here, and say okay, is this going to make 3 

### life worse or better? And we don’t know yet. We 4 

### have to think about this a little bit, but we're 5 

### glad you brought it up and you'll definitely get 6


### some comments. 7 

### But I guess right now what we need to do 8 

### is ask questions so we understand what it says. 9 

### And that's what I was trying to do and I think 10 

### Alex helped. 11 

### MS. KANTNER: If I could just clarify 12 

### further... The idea for this product class is that 13 

### there is a utility to being able to switch out 14 

### the lamp separate from the driver. So if it's a 15 

### consumer replaceable lamp that's separate from 16 

### the driver, that would be what would fall into 17 

### that category. 18


### MR. BROOKMAN: Allen. 19 

### MR. ROO: We do offer an LED array that's 20 

### AC driven with an integrated, you know, drivers 21 

### integrated into the actual LED array. And it is 22106

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### available as a repair part with the heat sink 1 

### integrated with it as an assembly. So that's on 2 

### the market today. 3 

### MR. BROOKMAN: Yeah. Thank you. David. 4 

### MR. GATTO: So I think this is one of 5 

### those things where we don't know where all the 6 

### places LED is going. And as Alex kind of 7 

### mentioned on an aside, we have seen in the 8 

### commercial marketplace, interest in replaceable 9 

### driver, replaceable module. But that's where the 10 

### maintenance issue is kind of more controllable. 11 

### I think the question might be, and I don't know 12 

### that we can answer -- I can't answer it as a fan 13 

### manufacturer so I don't know that these guys can 14 

### either. I think what you're asking is, are we 15 

### planning to, at some point, offer where the 16 

### driver and the module are replaceable by the 17 

### consumer, not necessarily as a repair part. 18 

### I'd like to get clarification on that, 19 

### Ashley. But as a product that's for sale in 20 

### commerce, in which case, you know, how do you 21 

### incorporate it into the rule, and I don't know 22107

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### that we can give you any kind of answer at all. 1 

### And honestly this is what we were talking about 2 

### earlier. This is where it gets scary that the 3 

### technology is moving so fast that the rule is 4 

### going to come out and then there's going to be 5 

### something that we can't do that everyone in the 6 

### room would want us to do because it's not -- the 7 

### scope doesn't allow it. 8 

### MS. ARMSTRONG: So I think you just hit 9 

### where I was going to go with the question. So if 10 

### you can't specifically answer the question it 11 

### seems like it's somewhere out there in the future 12 

### to be determined. The likelihood of it happening 13 

### is high, but how exactly it will happen and what 14 

### its impact will be is a little bit yet unknown. 15 

### I think about it on the other side. Is 16 

### what we're proposing here for product class 17 

### consolidation, would that have a negative impact 18 

### or would that in some reason inhibit your ability 19 

### to potentially do this in the future? That's 20 

### what I think we want to know. 21 

### And perhaps, you know, what we're 22108

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### proposing here, or the levels we may be analyzing 1 

### here because we haven't actually proposed 2 

### anything quite yet, but you know, it's not a 3 

### detrimental impact at this time. But I don't 4 

### think we're necessarily out to inhibit 5 

### innovation. We're not out to inhibit innovation 6 

### either. 7 

### So I think asked another way is, think 8 

### about it in what we are proposing to do, and is 9 

### there anything that you would see limiting your 10 

### future? Obviously, you know, standards increase 11 

### the efficiency, blah, blah, blah. But, you know, 12 

### limiting in the space at least. 13 

### MR. BROOKMAN: Right. So can we get a 14


### comment? 15 

### MS. ARMSTRONG: I don't think we need to 16 

### answer it now. 17 

### MR. BROOKMAN: Okay. 18 

### MS. ARMSTRONG: It's just, when you take 19 

### it back and think about this a little further, 20 

### you know, flipped around the other side, I think 21 

### that's what we're really searching for here. 22109

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### MR. BROOKMAN: Okay. Dick. 1 

### MR. UPTON: Actually, you're saying -- 2 

### MR. BROOKMAN: Dick, use the microphone. 3 

### MR. UPTON: You're saying in effect, you 4 

### may be ahead of the industry. And if that's -- 5 

### MS. ARMSTRONG: That would be a first. 6 

### MR. UPTON: Yeah. And if that's the 7 

### case, I compliment you on your concern about 8 

### inhibiting the marketplace and what might be able 9 

### to be developed, and we'll just have to do our 10 

### best to respond. 11 

### MS. ARMSTRONG: Just think about it, 12 

### yeah. I mean, I'm not sure that we are 13 

### necessarily and obviously we didn't aim to do 14 

### that, so -- but we wanted to make sure we at 15 

### least heat up the issue. 16


### MR. UPTON: Yeah. Well done. 17 

### MR. BROOKMAN: Okay. And then on to 18 

### dimming. 19 

### MS. KANTNER: Yes. So the last item for 20 

### comment on this slide is about dimming. DOE seeks 21 

### data on the dimming functionality of the current 22110

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### generation of CFL and LED lamps, and specifically 1 

### on the performance of those lamps with dimmers 2 

### designed for their control. DOE seeks data on 3 

### consumer satisfaction with the dimming 4 

### functionality of these systems. DOE also seeks 5 

### input from manufacturers as to whether they 6 

### anticipate accommodating dimming functionality 7 

### into LED CFLK modules they will offer for sale in 8 

### the next five years. And if so, what fraction of 9 

### LED CFLKs would include such functionality? 10


### MR. BROOKMAN: Dave? 11 

### MR. GATTO: I can weigh in on part of 12 

### this. So consumers hate -- Dave Gatto, 13 

### Westinghouse. See, this is what Alex is here 14


### for. 15 

### Dave Gatto, Westinghouse Lighting. 16 

### So CFLs don't dim well, and even the ones 17 

### that do, consumers don't like, and even when they 18 

### sort of like them the price is prohibitive and 19 

### there are other issues. LED does bring a lot 20 

### more functionality to the party. The two 21 

### challenges there are going to be cost, the 22111

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### initial cost to the consumer is a big impact 1 

### compared to current incandescent and halogen, 2 

### which in your own analysis represents somewhere 3 

### in the 80 percent of the current market range for 4


### CFLKs. 5 

### The other thing is that dimming is still 6 

### one of those things that sometimes it works and 7 

### sometimes it doesn't, and there's a lot of 8 

### factors at play. And so I don't know that LEDs 9 

### today or even in the short term future are going 10 

### to completely replace the kind of functionality 11 

### we have with incandescent light sources to the 12 

### consumer satisfaction. And I think that's the 13 

### challenge if we promulgate a rule that creates 14 

### consumer dissatisfaction its very disruptive to 15 

### the industry and to consumers, and their 16 

### alternative is less energy efficient products, 17 

### whether it be HVAC offset, or whether it be they 18 

### don't put a ceiling fan up and they put a, you 19 

### know, five light or a three light flush mount 20 

### that doesn't have currently any regulations on it 21 

### other than whatever is at the lamp level. 22112

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### MR. BROOKMAN: Okay. Thank you, Dave. 1 

### Additional thoughts on dimming? You can see the 2 

### question, the comment box. 3 

### Yes, Allen. 4 

### MR. FRAMPTON: Nathan with Fanimation. I 5 

### would say that a very high percentage will be 6 

### dimming; will be able to have that functionality. 7 

### MR. BROOKMAN: Thank you. Okay. Moving 8



### on. 9 

### MS. KANTNER: All right. Now moving on 10 

### to technology options. The technology assessment 11 

### identifies technology options that can improve 12 

### ceiling fan light kit efficiency. The assessment 13 

### provides a basis for the screening and 14 

### engineering analysis. 15 

### Lamps are the components that have the 16 

### greatest impact on CFLK active mode power 17 

### consumption. Light source technology is the 18 

### primary factor that affects lamp efficacy. DOE 19 

### is considering not including external ballasts as 20 

### a technology option for CFLKs. As discussed 21 

### earlier the test procedure proposes to rate the 22113

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### efficacy of CFLKs that use external ballasts 1 

### based on the performance of the lamp tested on a 2 

### reference ballast, so a more efficient ballast in 3 

### the CFLK would not change the rated performance. 4 

### DOE is also considering not including 5 

### lighting controls as a technology option in the 6 

### rulemaking. The energy savings from controls 7 

### cannot be measured by the methods specified in 8 

### the test procedure. In general, remote controls 9 

### are the only method of lighting control packaged 10 

### with the CFLK, but such controls are virtually 11 

### always incorporated into the fan housing and 12 

### control both the ceiling fan and the light kit. 13 

### Therefore DOE is considering only more 14 

### efficacious light sources as a technology option 15 

### for CFLKs. And then we have a couple of items 16


### for comment. 17 

### First, DOE requests comment on its 18 

### proposal not to include lighting controls as a 19 

### technology option in this rulemaking. 20


### MR. BROOKMAN: Dave. 21 

### MR. GATTO: Dave Gatto, Westinghouse 22114

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### Lighting. We agree with that proposal. 1 

### MR. BROOKMAN: Okay. Thank you. 2 

### Additional comments? 3 

### Okay. 4 

### MS. KANTNER: DOE requests comment on 5 

### lamps being considered as the technology option 6 

### for CFLKs and any additional options that should 7 

### be included. 8


### MR. BROOKMAN: Dave? 9 

### MR. GATTO: Dave Gatto, Westinghouse. 10 

### Just a question. Are you asking for feedback on 11 

### the specific lamps being considered as well as 12 

### other options? 13


### MS. KANTNER: Sure. 14 

### MR. GATTO: All right. So I'm just going 15 

### to kind of repeat the earlier comment, and I 16 

### don't know the solution to this so I'm just going 17 

### to throw it out there. I think more efficacious 18 

### light sources is the best play. My concern is if 19 

### they are for certain small profile lamps, 20 

### candelabra base in particular, there aren't any 21 

### really more efficacious that would meet 22115

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### anybody's, including my definition of energy 1 

### efficient. 2 

### So leaving them out, which is the 3 

### proposal to combine to a two class system, 4 

### potentially could create some headaches for the 5 

### consumer. I don't really have anything I would 6 

### recommend other than LED, though, as that 7 

### solution. So I can see the question on your 8 

### face, Ashley, I just don't know what it is. 9 

### MR. BROOKMAN: Ashley. 10 

### MS. ARMSTRONG: You can let Alex go 11 

### first. That's okay. 12 

### MR. BOESENBERG: Alex Boesenberg, NEMA. 13 

### Dave, you correct me if I miss the mark but I 14 

### think what you're saying or to maybe more 15 

### thoroughly or expand on that conversation, it's 16 

### you know, for ALA, NEMA submitted comments to 17 

### California Title 20 regarding some of their 18 

### proposals where there was a predilection towards 19 

### moving to LED only technology due to the efficacy 20


### levels. 21 

### And the point we made, to bring this back 22116

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### around to this meeting, is that in the case of 1 

### halogen technology, while LED might be 2 

### technically feasible there, the market is so 3 

### small that a few if any manufacturers have moved 4 

### to supply LED options. And so if this is also 5 

### true in the replacement lamps for the ceiling fan 6 

### industry, it could be that it's not that LED is 7 

### not capable, but no one bothers to make it 8 

### because it's such a small market. 9 

### MR. GATTO: So I think for a percentage, 10 

### and it might be in that four to eight percent 11 

### range from the earlier slide, there are some 12 

### noncandelabra or intermediate based light kits. 13 

### I think candelabra is something that, as a light 14 

### bulb manufacturer, yes, we're developing 15 

### candelabra based lamps. The challenge is getting 16 

### the lumen package and the lifetime in the 17 

### candelabra base that will fit inside the 18 

### traditional fan light kit, where you're not going 19 

### to have some other issues, or where you're going 20 

### to be able to meet the efficacy that's laid out. 21 

### I think my bigger concern is that by 22117

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### going to a two class system -- and I know you've 1 

### laid this out in the TSD or -- yeah, I think it's 2 

### in the TSD. Because of the no backsliding rule 3 

### your minimum efficacy requirement would be the 4 

### current Energy Star 3.0, which there is no 5 

### incandescent or halogen lamp that can hit, nor 6 

### are there any planned that can hit, particularly 7 

### in small profile. 8 

### So two classes from a lamp manufacturer 9 

### make sense to me. From the fan side it does 10 

### limit design options and it does create some 11 

### consumer cost issues that I don't -- when we get 12 

### there I'll comment, or maybe I'll ask some 13 

### questions, but I don't know that it was really 14 

### properly caught in the LCC because the way I read 15 

### it, because you made the assumption that there 16 

### wouldn't be any, because in a two class system 17 

### they can't exist, your baseline for pricing for 18


### the consumer cost starts at the current CFLK that 19 

### includes a medium based CFL. But that product is 20 

### more expensive to the consumer than an 21 

### incandescent base socketed light kit. 22118

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### Does that make sense? 1


### MS. ARMSTRONG: It makes sense. We'll 2 

### discuss. 3 

### MR. BROOKMAN: Terry. 4 

### MS. ARMSTRONG: Thank you. 5 

### MR. MCGOWAN: Terry McGowan, American 6 

### Lighting Association. I note that there are no 7 

### lighting control manufacturers here and I do hope 8 

### that they will comment on this because I am not 9 

### sure that this idea of not including the energy 10 

### saving potential of lighting controls is valid. 11 

### Lighting controls can be as powerful as 12 

### efficacy in energy savings. And the trick is to 13 

### consider how they might be used and would 14 

### contribute to that. That is a little more 15 

### complicated than efficacy, but it's nonetheless 16 

### powerful. And so I think the lighting controls 17 

### folks should comment, and also that we should be 18 

### open to some procedures, perhaps not in the test 19 

### procedures that we have so far, for incorporating 20 

### these energy savings. 21 

### If we're going to demand ever further 22119

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### energy savings, which has been the history of 1 

### these regulations, then we should look at all of 2 

### the options, not just efficacy. 3 

### MR. BROOKMAN: Okay. 4 

### MS. ARMSTRONG: So this is Ashley from 5 

### DOE. And in following to that, this gets a 6 

### little bit back to this morning's presentation on 7 

### our efforts to harmonize with lamp efficacy. 8 

### To the extent we start talking about 9 

### lighting controls, and I think the Department's 10 

### position is, we agree, they're an important tool 11 

### in the tool kit to reduce energy usage and 12 

### provide a potential for savings. But you're 13 

### right, we would have to go back and revisit the 14 

### test procedures. 15 

### And if we did revisit those test 16 

### procedures it could be a departure from lamp 17 

### based efficacy harmonization. So I would be 18 

### interested in hearing comments because, you know, 19 

### we want to make sure our analysis are consistent 20 

### internally so that's one of the reasons driving 21 

### this decision. 22120

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### You know, there was some support earlier 1 

### for this harmonization effort and lamp based 2 

### efficacy or system/luminaire efficacy. But in 3 

### order to fully implement controls, at least in my 4 

### opinion, the correct way, you would have to 5 

### recalculate the -- or you would have to revamp 6 

### the test procedures. And then they would become 7 

### more like luminaire, ceiling fan light kit type 8 

### test procedures rather than just lamp based. 9 

### So I would definitely like to hear from 10


### the fan manufacturers about that. 11 

### MR. BROOKMAN: No response at this time. 12


### Dave. 13 

### MR. TURNER: I think this is something 14 

### that we'll revisit in our written comment. You 15 

### know, we haven't had time to adequately dive into 16


### that. 17 

### MR. BROOKMAN: Okay. Thank you. Okay. 18 

### We're moving on then. 19 

### MS. KANTNER: I just wanted to quickly 20 

### follow up with a comment that Dave, that you 21 

### made. So in the preliminary analysis DOE stated 22121

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### that it didn't think that there was a utility 1 

### associated with different socket types. And 2 

### could you comment on the utility of candelabra 3 

### bases versus medium screw bases or other base 4 

### types? 5 

### MR. GATTO: It's really more on the 6 

### design side. So, you have different light kits 7 

### that you're meeting different design 8 

### considerations, and a medium base light kit is 9 

### going to be physically larger and it typically 10 

### has an A15 or an A19 shape lamp, an A-type. 11 

### Where candelabra typically is either a bullet, 12 

### kind of a torpedo shape, the chandelier look. So 13 

### there are applications, particularly in 14 

### candelabra where you've got some design elements 15 

### that have to do with more of the decorative 16 

### aspect of the light kit than with light output or 17 

### efficiency, or things like that. 18 

### You have the same thing in some of these 19 

### alternate specialty bases, whether it be you 20 

### know, E11 halogen or bi-pin or pin-based halogen 21 

### where you might have a particular design element 22122

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### where you want a lot of light in a very small 1 

### space. You can accomplish that with halogen. 2 

### You can't really accomplish that with LED today. 3 

### And to Alex's point, there is not a lot 4 

### of product development, and I'm including my own 5 

### product line in that, to fill those niches 6 

### because the volume associated with a 100 watt 7 

### double ended halogen is much, much, much smaller 8 

### and with the heat dissipation issues, I mean, LED 9 

### light source, if you want that much light in a 10 

### small space you're typically designing a whole 11 

### luminaire around it so that you have a place to 12 

### put the heat. So it's a design issue. 13 

### So that utility though, and I know DOE, 14 

### and I acknowledge you for it, John in particular 15 

### in the first meeting we had, DOE acknowledged 16 

### that there is a design element to this product. 17 

### It's not an appliance that's purely functional. 18 

### It has a style or a fashion appeal to the 19 

### consumer that it affects manufacturers because it 20 

### impacts the buying decision, but it also affects 21 

### consumers because they have a particular thing 22123

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### that they want the utility of, matching a décor 1 

### or a particular look that they're aiming for. 2 

### Does that help? 3 

### MS. KANTNER: Yes. Alright. Moving on. 4 

### So up next is the screening analysis which Julie 5 

### Pierce from Navigant will present. 6 

### MS. PIERCE: Hello. My name is Julie 7 

### Pierce and I'm with Navigant. I will first 8 

### discuss the screening analysis. 9 

### Technology options identified are 10 

### evaluated against four criteria, which are that 11 

### the option is technologically feasible, it is 12 

### practicable to manufacture, install, and service 13 

### on a commercial scale by the compliance date of 14 

### the standards, it does not have adverse impacts 15 

### on utility to consumers or availability, and that 16 

### it does not have adverse impacts on health or 17 

### safety. 18 

### Those technology options not screened out 19 

### are analyzed as design options in the engineering 20 

### analysis. For CFLKs the technology option under 21 

### consideration is more efficacious light sources. 22124

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### DOE did not screen out a more efficacious light 1 

### source as an option for improving efficacy of 2 

### CFLKs. DOE invites comment on the screening 3 

### analysis. 4 

### MR. TURNER: David with Hunter. I think 5 

### we would just continue to echo what Dave Gatto 6 

### has presented as far as adverse impacts with the 7 

### more efficacious light kits, or light lamps being 8 

### considered. 9 

### MS. PIERCE: Okay. 10 

### MR. BROOKMAN: Okay. 11 

### MS. ARMSTRONG: So I'm just going to 12 

### follow on to that just to kind of -- while those 13 

### general comments are helpful, we really need 14 

### details. And perhaps you've given them. I'm not 15 

### as, you know -- but as Julie goes on to the next 16 

### set of slides and presents the engineering and we 17 

### talk about how we actually develop these cost 18 

### curves for particular things, what I'm hearing, 19 

### I'm going to translate what Dave said to me, is 20 

### either two things. One is, you know, for all 21 

### different base types and/or designs or 22125

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### configurations you may offer right now to a 1 

### consumer, either more efficacious bulbs may not 2 

### be available across the board. It would be 3 

### helpful to know exactly which ones they are. Or 4 

### they come at a different cost, also would be 5 

### helpful to know what that delta cost would be 6 

### that is different. 7 

### That's the stuff, and those details, at 8 

### that level of detail is really what's most 9 

### helpful to drive the analysis. So think about 10 

### that. And if there are comments that they're 11 

### sensitive and you don't necessarily want to make 12 

### on the record, we have avenues for sharing that 13 

### type of information. But like I said, that's 14 

### really what is driving the foundation of the 15 

### analysis. 16 

### Sorry about that. 17 

### MR. BROOKMAN: No, that's good. That's 18 

### helpful. Dave, please. 19 

### MR. TURNER: Dave from Hunter. I think 20 

### you'll get a fair portion of the detail in the 21 

### written analysis. 22126

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### MS. ARMSTRONG: Okay. 1 

### MR. TURNER: Just because we didn't have 2 

### as much time with the CFLK portion of the TSD and 3 

### test procedures, so we'll be more thorough there. 4 

### And as far as cost deltas and whatnot, I think 5 

### if, you know, whatever those avenues are we 6 

### probably need to talk about them -- 7


### MS. ARMSTRONG: Sure. 8 

### MR. TURNER: -- because I think those do 9 

### need to be discussed by manufacturer. 10 

### MS. ARMSTRONG: That would be great. We 11 

### welcome all of it. So you're telling me I should 12 

### really prepare for tomorrow because you guys came 13 

### prepared for tomorrow? 14 

### MR. TURNER: Well, we had more time with 15 

### that, so -- but yeah. So I mean, right now we're 16 

### talking more about lamps which, you know, we 17


### don't have as -- 18 

### MS. ARMSTRONG: So I should get a really 19 

### good night's rest tonight. 20 

### MR. TURNER: Oh, yeah. Get to bed early. 21 

### MS. ARMSTRONG: Got it. 22127

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### MR. TURNER: That's fair. 1 

### MR. BROOKMAN: Okay. 2 

### MS. PIERCE: Okay. Thank you. Next I 3 

### will go over the engineering analysis. 4 

### DOE used the following general 5 

### methodology to develop the engineering analysis 6 

### for CFLKs. Of the product classes identified DOE 7 

### first selected certain representative product 8 

### classes to directly analyze. DOE then selected 9 

### baseline models for each representative product 10 

### class to use as reference points. After that for 11 

### each baseline model DOE identified more 12 

### efficacious substitutes based on design options 13 

### identified in the screening analysis. 14 

### DOE then developed candidate standards 15 

### levels, or CSLs that span the range of efficacy 16 

### from baseline to the maximum technologically 17 

### feasible level. 18 

### Finally DOE scaled its results to any 19 

### product classes not directly analyzed. 20 

### In general DOE chooses representative 21 

### product classes on which to focus its analytical 22128

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### effort. Of the two CFLK product classes which 1 

### are shown in this table, both were chosen as 2 

### representative. All Other CFLKs encompasses 3 

### self-ballasted lamps. This product class was 4 

### chosen as representative because it constitutes a 5 

### majority of CFLK sales. 6 

### Examples of lamps in the Externally 7 

### Ballasted product class include circline 8 

### fluorescents and pin-based CFLs. It was chosen 9 

### as representative because the CFLKs in this class 10 

### offer a unique utility in their ability to allow 11 

### the consumer to replace the lamp and ballast 12 

### separately in the event of failure. Additionally 13 

### the efficacies of externally ballasted/driven 14 

### lamps do not include losses from the ballasts. 15 

### Thus, lamps in the Externally Ballasted or Driven 16 

### product class have a different cost efficiency 17 

### relationship than lamps in the All Other CFLKs 18 

### product class. 19 

### DOE requests comment on the 20 

### representative product classes for CFLKs. 21


### MR. BROOKMAN: Dave? 22129

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### MR. GATTO: I'm just going to repeat, 1 

### it's already out there. I'm not going to say it 2 

### all again. But not having a third product class 3 

### really eliminates some design options. 4 

### MR. BROOKMAN: Okay. Thank you. 5 

### MS. ARMSTRONG: What third product class 6 

### are you asking for, just to be clear? 7 

### MR. GATTO: It's tough. You know, I 8 

### think I said this earlier actually. I don't 9


### know. 10 

### MS. ARMSTRONG: Oh, okay. 11 

### MR. GATTO: I think that as a lamp 12 

### manufacturer I'm on board with the move towards 13 

### LED. I think the challenge that this particular 14 

### rulemaking is coming early enough in the LED 15 

### development cycle that I don't know whether we'll 16 

### be where you're going to need us to be by 2019, 17 

### and because we're in the rulemaking timeframe 18 

### this is where just like we talked about, I'm 19 

### concerned that we're going to pass a rule that 20 

### then makes it very troublesome from that 2019 to 21 

### maybe 2022. There's a period of time where it 22130

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### could be very very disruptive for fan 1


### manufacturers. 2 

### So I don't know how to say it any better 3 

### than that. I don't really want incandescent and 4 

### halogen in the product class, but I don't know 5 

### how to get at the piece that -- I'm not sure if 6 

### we're going to get there in time. 7 

### I don't know that that helps you. I 8 

### mean, it's tough. I don't actually have an 9 

### alternate proposal where I'd say, oh, put them in 10 

### there and make it a 100 watt limiter. It's 11 

### pointless. I think if we were waiting long 12 

### enough it would be fine, but the rulemaking 13 

### timeline that you have out there doesn't make me 14 

### comfortable that we're going to have enough time 15 

### to get there from a fan light kit standpoint. 16 

### MR. BROOKMAN: Okay. Thank you. Okay. 17 

### MS. PIERCE: Now I will discuss the 18 

### general methodology for the engineering analysis 19 

### before discussing the details for each product 20


### class. 21 

### The baseline model typically represents 22131

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### the most common least efficacious lamp in a CFLK 1 

### that meets existing energy conservation 2 

### standards. DOE identifies a baseline model in 3 

### each representative product class. 4 

### In general, to identify more efficacious 5 

### replacement lamps, DOE considered lamps that save 6 

### energy compared to the baseline lamp, have system 7 

### lumen output within 10 percent of the baseline, 8 

### and have a rated life greater than or equal to 9 

### the baseline. 10 

### DOE also considered lamps with similar 11 

### characteristics, such as CRI, CCT, and bulb 12 

### shape. The base type was kept the same as the 13 

### baseline lamp. 14 

### DOE considered two scenarios, both of 15 

### which used the same baseline lamp: a lamp 16 

### replacement scenario and a fixture replacement 17 

### scenario. 18 

### In the lamp replacement scenario the more 19 

### efficacious substitute must have the same base 20 

### type as the baseline lamp and no changes to the 21 

### fixture are made. 22132

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### In the fixture replacement scenario the 1 

### fixture can change which allows for a more 2 

### efficacious lamp substitute with a different base 3 

### type than the baseline lamp and a change in the 4


### number of sockets. 5 

### DOE requests comment on the likelihood of 6 

### CFLK manufacturers selecting each substitute 7 

### scenario and information on any alternative 8 

### scenarios that manufacturers may choose. 9 

### MR. BROOKMAN: Dave. Thank you. 10 

### MR. GATTO: Sorry. So, I'm not going to 11 

### actually respond to this slide, but we kind of 12 

### skipped over the baseline lamp that was selected. 13 

### MS. PIERCE: So we'll go into the 14 

### specific details for each product class in a bit. 15 

### MR. GATTO: Okay. 16 

### MS. PIERCE: This is just the general 17 

### methodology. 18 

### MR. GATTO: Yeah, then from -- the only 19 

### thing I would say from a CFLK standpoint is that 20 

### the preferred method for us would be the lamp 21 

### replacement scenario because it's the least 22133

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### cumbersome in terms of change in design and 1 

### potentially product cost. 2 

### MR. BROOKMAN: Okay. Additional comments 3


### here? 4 

### MS. PIERCE: Okay. DOE developed 5 

### equations that are a function of wattage to 6 

### determine the CFLs. The equations specify a 7 

### minimum lamp efficacy requirement across wattages 8 

### and represent the efficacy a lamp achieves. 9 

### Because the equations account for variation in 10 

### efficacy due to wattage, they can account for 11 

### design options of new lamp wattages based on a 12 

### technology curve. DOE developed a different 13 

### equation for each representative product class. 14 

### Now we'll discuss the entire engineering 15 

### analysis, including the baseline lamp, more 16 

### efficacious substitutes, and CSLs for each 17 

### product class individually. We'll start with the 18 

### All Other CFLKs product class. 19 

### For this product class DOE found the most 20 

### common least efficacious lamp packaged with a 21 

### CFLK that meets existing standards to be a 14 22134

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### watt medium based spiral CFL. The baseline lamp 1 

### DOE selected for this product class has a light 2 

### output of 730 lumens, an efficacy of 52.1 lumens 3 

### per watt, and a lifetime of 10,000 hours. 4 

### For the fixture replacement analysis the 5 

### baseline fixture has two sockets, each containing 6 

### the baseline lamp. 7 

### DOE requests comment on the baseline unit 8 

### selected for the All Other CFLKs product class. 9


### MR. BROOKMAN: Dave. 10 

### MR. GATTO: Dave Gatto, Westinghouse. 11 

### So, if I understood the TSD correctly, you didn't 12 

### select the least efficacious lamp because the 13 

### Class 3 light kit doesn't have an efficiency 14 

### standard. But I would suggest that the least 15 

### efficacious lamp currently meeting the standard, 16 

### which includes a design standard for Class 3, is 17 

### actually an incandescent lamp. It's a 18 

### ridiculously low efficacy, candelabra based 19 

### incandescent. Maybe 10 or 15 -- well, maybe 20 

### eight to 10 lumens per watt, high side. 21 

### So I guess my question would be, why 22135

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### select this as the least efficacious when there 1 

### is a substantially less efficacious lamp 2 

### currently meeting the standard that's in the 3 

### marketplace? 4 

### MS. PIERCE: So with the new product 5 

### class structure we essentially combine classes 1 6 

### and 3 and we had to set the baseline level at a 7 

### level that would prevent backsliding. So since 8 

### the products in class 1 are subjected to what 9 

### would be a 45 lumen per watt standard, that was 10 

### where we started as our baseline. 11 

### MR. GATTO: Dave Gatto, Westinghouse. 12 

### So, I don't actually disagree with that other 13 

### than the fact that we're missing -- 14 

### MS. PIERCE: I got it. 15 

### MR. GATTO: -- the analysis, the consumer 16 

### impact that that represents because they're not 17 

### buying this product today. So when you get into 18 

### the consumer impact analysis we're showing no 19 

### consumer impact if you left EL0 in place, which 20 

### is this. But in fact I would suggest that they 21 

### have a quite high cost impact that they're going 22136

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### to experience. And while I don't actually think 1 

### that that's necessarily bad, I do think the 2 

### analysis should correctly account for what 3 

### they're paying today versus what we're proposing 4 

### they would pay in the future. 5 

### MS. PIERCE: Okay. 6 

### MR. BROOKMAN: Thank you. 7 

### MS. PIERCE: Thank you for the comment. 8 

### MR. BROOKMAN: Additional comments? 9 

### MS. PIERCE: Okay. For the lamp 10 

### replacement scenario DOE selected five 11 

### replacement lamps. DOE chose CFLs at CSLs 1 and 12 

### 2 and LEDs at CSLs 3 through 5. The wattage 13 

### decreases and the efficacy increases at each 14


### level. 15 

### The lifetimes of the CFL rep units are in 16 

### the 10,000 to 12,000 hour range and the LED rep 17 

### units have life times of 50,000 hours. 18 

### For the fixture replacement scenario DOE 19 

### selected five replacement fixtures. DOE used 20 

### CFLs at CSLs 1 and 2, and LEDs at CSLs 3 through 21


### 5. 22137

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### The number of sockets varies between one, 1 

### three, and four, and the total fixture wattage 2 

### decreases at each level. The lifetimes of the 3 

### CFL rep units are in the 10,000 to 12,000 hour 4 

### range. And the LED rep units have lifetimes of 5 

### 50,000 hours. 6 

### DOE requests comment on the criteria used 7 

### in selecting more efficacious substitute lamps as 8 

### well as the characteristics of the lamps 9 

### selected. So this slide or the previous. 10 

### MR. BROOKMAN: Yes, Dave. Thank you. 11 

### MR. GATTO: Sorry. Dave Gatto, 12 

### Westinghouse. Thank you, Alex. 13 

### The only thing I'd say here is that by 14 

### picking the medium based product, which I 15 

### acknowledge was the only thing you had in class 1 16 

### when you combined the classes, means that you're 17 

### picking lumen bins from the farthest along the 18 

### development path from the LED product side. So, 19 

### if you look at smaller base or alternate base, or 20 

### smaller, physically smaller than A-19 or you've 21 

### got an A-21 here which won't fit in most fan 22138

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### light kits, the challenge that you have is that 1 

### they tend to be less efficient. So not 2 

### necessarily a bad thing, but we'll bring it up 3 

### when we get there in the proposed standard. 4 

### If we stay with a two-class system then I 5 

### would suggest DOE needs to really leave enough 6 

### room in there for the less efficient candelabra 7 

### base and small profile solid state lighting 8 

### options to still be a viable option for 9 

### manufacturers and a cost that is acceptable to 10 

### consumers. Particularly with dimming. That adds 11 

### not only cost but there's some physical space 12 

### requirements. It's minimal, but you do need to 13 

### build in for that and consumers do want dimming. 14 

### MR. BROOKMAN: Okay. Thanks. 15 

### MS. PIERCE: Thank you. 16 

### MS. ARMSTRONG: So I'm going to ask you 17 

### as part of your comments, and you might not -- 18 

### what would this table look like with a base type 19 

### you feel that DOE should analyze that's one of 20 

### these that's the least furthest along? 21 

### MR. GATTO: Probably candelabra base -- a 22139

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### candelabra based torpedo or flame tip which you 1 

### can find. You know, we have a couple and we have 2 

### more coming and they're available on the 3 

### marketplace for a variety of manufacturers. 4 

### There are some Energy Star products. What I 5 

### would suggest is you look at two things. 6 

### One is, you look at size and you look at 7 

### cost, because if you look at the -- particularly 8 

### in Energy Star, it's a good reference, you'll see 9 

### that there's products with mid 60 efficiency and 10 

### then there's products with 100 lumens per watt. 11 

### But if you drill down into that you're going to 12 

### find that those higher efficacy models tend to be 13 

### the higher volume items, they're physically 14 

### larger. Or they're really aimed at the 15 

### commercial specification market, which can absorb 16 

### the higher price point. 17 

### So I would say that if you looked at the 18 

### candelabra base you'd find that -- I don't know 19 

### exactly off the top of my head, Ashley, but 20 

### you're probably running about 10 percent lower in 21 

### terms of the average efficacy. 22140

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### But physical size is important. I mean, 1 

### when you look at some of the ones that are the 2 

### best from a performance standpoint they wouldn't 3 

### fit in a lot of candelabra based light kits 4 

### today. Or they wouldn't fit in an aesthetically 5 

### pleasing manner. 6 

### MR. BROOKMAN: Yes, Tim. 7 

### MR. FLANNERY: I would also suggest that 8 

### you look at a G-9 format as well. 9 

### MR. BROOKMAN: Thank you. Thank you. 10


### MR. GATTO: And even smaller. 11 

### MR. BROOKMAN: Okay. Yes, Terry. 12


### Please. 13 

### MR. MCGOWAN: Terry McGowan, American 14 

### Lighting Association. 15 

### I'm looking at the lamp life column. 16


### MS. PIERCE: Yes. 17 

### MR. MCGOWAN: I believe that the 50,000 18 

### hour life ratings for LEDs are very very 19 

### optimistic in terms of service life. And we made 20 

### this mistake with CFLs and so we've had to 21 

### backtrack on that quite a bit. Because there are 22141

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### field conditions out there that more truly give 1 

### you the life that the consumer realizes and the 2 

### difference is, of course, very disruptive. 3 

### So I think again maybe Energy Star life 4 

### ratings would be a more appropriate number than 5


### the ones shown. 6 

### MS. PIERCE: Thank you. If you have any 7 

### specific data on typical lifetimes or test data 8 

### that would be really helpful as well. 9


### MR. BROOKMAN: Dave. 10 

### MR. GATTO: Yeah, one other thing I 11 

### wasn't thinking about there, and we can get that, 12 

### I mean EPA has it. And they probably have it in 13 

### the database. The other challenge with lifetime 14 

### is testing to certify to those lifetime hours 15 

### takes longer, substantially longer. Which again 16 

### means fan manufacturers who are not lamp 17 

### producers, other than me, they're going to be 18 

### trailing the product development of the lamp 19 

### manufacturers. So you really kind of double up 20 

### on the fact that this rule is going to go into 21 

### effect before some of these products are 22142

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### commercially available, which is going to force 1 

### fan manufacturers to either, I don't know, try 2 

### and develop their own light bulbs which won't 3 

### work. A lot of other people are getting out. Or 4 

### they're going to have to redesign products to 5 

### accommodate the products that they do have, you 6 

### know, access to. 7 

### MR. BROOKMAN: Yes, Tim. 8 

### MR. FLANNERY: Also what we're seeing 9 

### from a lamp manufacturer perspective is, although 10 

### 50,000 hours is what the expected life is going 11 

### to be, the warranty to the life on those bulbs is 12 

### really coming in at 25,000 and that's pretty much 13 

### an industry standard. 14 

### MR. BROOKMAN: Oh, thank you. Additional 15 

### thoughts on all of the content in this table and 16 

### responsive to the question itself? 17 

### (No audible response.) 18 

### MR. BROOKMAN: Okay. 19 

### MS. PIERCE: DOE developed equations that 20 

### are a function of wattage to determine the CSLs. 21 

### The equations specify a minimum lamp efficacy 22143

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### requirement across wattages and represent the 1 

### efficacy a lamp achieves. 2 

### Because the equations account for 3 

### variation in efficacy due to wattage, they can 4 

### account for design options of new lamp wattages 5 

### based on the technology curve. To determine the 6 

### coefficients of the CSL equations DOE reviewed 7 

### catalog data of commercially available lamps and 8 

### their associated catalog rated efficacies. 9 

### This table shows the CSLs that DOE is 10 

### considering for the All Other CFLKs product 11


### class. 12 

### This plot illustrates the five CSLs for 13 

### All Other CFLKs with the rep units for the lamp 14 

### and fixture replacement scenarios. The line at 15 

### 45 lumens per watt for wattages less than or 16 

### equal to 15 watts and 60 lumens per watt, for 17 

### wattages greater than 15 watts, denotes the 18 

### existing energy conservation standard. 19 

### The square box identifies the baseline 20 

### lamp. The plot also shows more efficacious 21 

### substitutes that DOE considered as replacements. 22144

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### These replacements were selected such that they 1 

### both have a lower lamp wattage and higher 2 

### efficacy than the previous level and maintain 3 

### lamplight output within 10 percent of the 4 

### baseline lamp. 5 

### Because proposed standards are based on 6 

### lamp efficacy, not fixture efficacy, for the 7 

### fixture replacement scenario the lamp wattage of 8 

### each rep unit is plotted. 9


### DOE ensured that CSL1 was set above the 10 

### existing standard to prevent backsliding. 11 

### DOE requests comment on the CSLs under 12 

### consideration, including the max tech level for 13 

### CFLKs. In particular DOE requests comment on the 14 

### equations used to define the efficacy 15 

### requirements at each CSL. 16


### MR. BROOKMAN: Dave. 17 

### MR. GATTO: Thanks, Doug. In general I 18 

### hate formulas when we're talking about fan stuff 19 

### just because it's a little bit more difficult for 20 

### them because they're not lamp producers. I'm a 21 

### little bit more familiar with it. But I think I 22145

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### recognize -- I'm going to ask this as a question, 1 

### maybe for Ashley or Lucy. You don't want to 2 

### propose an efficacy level by wattage. You don't 3 

### want to say five watts or lower this, 10 watts or 4 

### lower this, 15 watts or lower this. Is that the 5 

### reason for the formula? I recognize that at the 6 

### higher wattages you want to achieve a higher 7 

### efficacy, but the formula based scenario can get 8 

### very confusing from a compliance standpoint. 9 

### MS. PIERCE: I can answer it if you want 10


### too. So we found that the data showed that the 11 

### efficacy increases continuously with wattage, so 12 

### we're really trying to reflect what the lamp 13 

### performance actually is and if there's also a 14 

### chance that the lamps could get concentrated at 15 

### the higher wattages within a bin and save less 16 

### energy if you take that approach. 17 

### MR. GATTO: Yeah. And I guess my 18 

### response to that would be, in specifically in the 19 

### LED space, wattage is continuously going down and 20 

### efficacy is going up. But there's a tradeoff and 21 

### it's one that manufacturers have to make in, I 22146

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### can reduce wattage, I can increase efficacy, or I 1 

### can reduce cost. And really what you take away 2 

### with these formula based equations is you take 3 

### away the lamp manufacturer's ability to maximize 4 

### efficiency at the cost a consumer is willing to 5 

### pay in a physical lamp shape that will meet the 6 

### application need. 7 

### So when you start putting formulas in 8 

### what happens is that if we want to have a single 9 

### lamp instead of three lamps, which might save on 10 

### total cost to produce a fan light kit for the 11 

### light bulb, we now have to get -- we lose that 12 

### savings. And I appreciate that there's no CRI in 13 

### here because that's another kind of challenge. 14 

### But this balancing act, when you start to push 15 

### the envelope with the higher wattages, it's a 16 

### challenge. 17 

### What I don't know that you can take into 18 

### consideration, I understand that it's an 19 

### efficiency standard, is that you can make an 20 

### assumption. And DOE's own analysis and some of 21 

### the Caliper reports will show it, that the lumen 22147

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### bin per wattage is going to go down whether you 1 

### regulate or not. So if you're able to consider 2 

### that then I'd suggest setting a standard that the 3 

### smaller configuration, smaller base type options 4 

### can hit. 5 

### I know in your analysis you can't capture 6 

### the true energy savings, but I can tell you as a 7 

### lamp manufacturer, you're going to get more 8 

### efficient lower wattages anyway. The marketplace 9 

### is going that way. It's very market driven. So 10 

### it isn't like we're going to stop innovating at 11 

### some point and say, oh well now, it's all about 12 

### profit. There's not one lamp manufacturer. 13 

### There's, feels like hundreds of them these days. 14 

### MR. BROOKMAN: Thank you. Additional 15 

### thoughts on this? Yes, Ali. 16 

### MS. MCDONALD: I just wanted to, I guess 17 

### -- this is Ali McDonald. I just wanted to ask a 18 

### favor. If you prefer bins versus a continuous 19 

### equation, or another approach besides continuous 20 

### equations, if you could provide as much detail 21 

### about what your recommendation would be. You 22148

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### know, for example, if it were a bin approach 1 

### recommending actual wattage bin, divisions would 2 

### be helpful. 3 

### MR. GATTO: So Dave Gatto, Westinghouse. 4 

### Maybe. Believe it or not I'm glad Alex 5 

### is sitting here because this may be something 6 

### that we have to circle back and talk to the lamp 7 

### manufacturers. I think the biggest challenge is 8 

### we don't -- every analysis any of us do is off. 9 

### Typically by an order of magnitude. What we're 10 

### seeing now is that as prices drop for the lamp 11 

### side, now is when -- when you can find that price 12 

### point the consumers are actually at the highest 13 

### adoption rate, then you stop focusing on 14 

### efficacy, which has been kind of the race to 15 

### date, and you focus on lamp size, thermal 16 

### management, dimmability. All of the other things 17 

### that consumers want, and you maintain your price. 18 

### So I think if this was -- and it's an 19 

### efficiency standard so I understand that that's 20 

### the primary value to DOE. But the consumer 21 

### actually wants more than that and we have to 22149

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### accommodate that. The challenge for fan 1 

### manufacturers is that they're going to get 2 

### whatever the rest of us decide. And so if you 3 

### set a standard and then we all stop here because 4 

### we finally maximized the price picture for 5 

### consumers, we might be adding value that the 6 

### consumer wants, but we may not be reducing 7 

### wattage and now you're going to have fan 8 

### manufacturers in the, you know, unenviable 9 

### position of there's nothing available to fit the 10 

### socket. Does that help? 11 

### MR. BROOKMAN: Yeah. Thanks, Dave. 12


### Thanks. 13 

### Yes, Tim. 14 

### MR. FLANNERY: You know, looking at the 15 

### LED samples that you have here, I think one of 16 

### the problems that I think also needs to be 17 

### addressed is I'm familiar with some of these 18 

### products and I believe they're not omni 19 

### directional and I think what Dave is referring to 20 

### in some of the smaller packages are also omni21 

### directional. And I think, you know, moving 22150

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### forward in the future, I think that that's really 1 

### what we're all looking for from a decorative 2 

### perspective. 3 

### And the industry is, to Dave's point, 4 

### really isn't there yet. I mean, we hope that 5 

### it's going to get there and we're seeing more and 6 

### more products that are coming to that level. 7 

### But, you know, it's a real important part when 8 

### we're looking at putting in an LED replacement 9 

### bulb into a light kit. I mean, because of the 10 

### heat sink there's shadowing. There's other 11 

### things from a decorative perspective that really 12 

### need to be, you know, looked at from a design and 13 

### from an execution standpoint. 14 

### MR. BROOKMAN: Okay. 15 

### MS. PIERCE: Okay. Thank you. Now I 16 

### will discuss the engineering analysis for the 17 

### Externally Ballasted or Driven product class. 18 

### Because CFLKs with externally ballasted or driven 19 

### lamps utilize ballasts, DOE analyzed lamp-and20 

### ballast systems in order to capture real world 21 

### energy use and light output. 22151

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### DOE paired externally ballasted lamps 1 

### with electronic ballasts, since they are required 2 

### by existing CFLK standards and are the most 3


### common fluorescent ballasts on the market. 4 

### As noted previously the baseline lamp is 5 

### the most common, least efficacious lamp in a CFLK 6 

### for each representative product class. For the 7 

### Externally Ballasted product class DOE found the 8 

### most common efficacious lamp packaged with a CFLK 9 

### that meets existing standards to be a 22 watt T9 10 

### Circline fluorescent lamp. When paired with an 11 

### electronic ballast it has a system light output 12 

### of 855 lumens, a system efficacy of 50.3 lumens 13 

### per watt, and a lifetime of 12,000 hours. 14 

### DOE requests comment on the baseline lamp 15 

### selected for Externally Ballasted CFLKs. 16


### MR. BROOKMAN: No comments here? No 17 

### comments here. Okay. 18 

### MS. PIERCE: Okay. I'll move on. 19 

### For the lamp replacement scenario for the 20 

### Externally Ballasted product class DOE chose more 21 

### efficacious replacements that were compatible 22152

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### with the baseline ballast. Additionally system 1 

### lumens were kept within 10 percent of the 2 

### baseline fixture. DOE selected one replacement 3 

### lamp for the scenario which was a 20 watt T9 4 

### Circline lamp. The lamp has a light output of 5 

### 920 lumens, an efficacy of 48.4 lumens per watt, 6 

### and a lifetime of 12,000 hours. 7 

### For the fixture replacement scenario the 8 

### ballast, number of sockets, and base type were 9 

### all allowed to change. DOE ensured that the bulb 10 

### maximum dimension, i.e. length, was less than 11 

### that of the baseline and that as for the lamp 12 

### replacement scenario the systems lumens were kept 13 

### within 10 percent of the baseline fixture. 14 

### DOE selected one replacement lamp for 15 

### this scenario which was a 13 watt pin-based CFL. 16 

### The lamp has a light output of 900 lumens, an 17 

### efficacy of 69.2 lumens per watt, and a lifetime 18 

### of 17,000 hours. 19 

### DOE requests comment on the criteria used 20 

### in selecting more efficacious substitute lamps as 21 

### well as the characteristics of the lamps 22153

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### selected, particularly the lifetimes. And then 1 

### in issue 15, DOE requests comment on the lamp and 2 

### ballast system selected for the Externally 3 

### Ballasted or Driven product class. In particular 4 

### DOE requests comment on the selection of 5 

### electronic ballasts for the lamp and ballast 6 

### systems. 7 

### MR. BROOKMAN: Thoughts on these 8 

### questions? Okay. 9 

### MS. PIERCE: Okay. DOE developed 10 

### equations that are a function of wattage to 11 

### determine the CSLs. As mentioned, a different 12 

### equation was developed for each representative 13 

### product class. 14 

### To determine the coefficients of the CSL 15 

### equations DOE reviewed catalog data of 16 

### commercially available lamps and their associated 17 

### catalog rated efficacies. 18 

### This table shows the CSL that DOE is 19 

### considering for the Externally Ballasted or 20 

### Driven product class. 21 

### This plot illustrates the CSL for 22154

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### Externally Ballasted or Driven CFLKs with the 1 

### representative lamp units. The square box 2 

### identifies the baseline lamp. The plot also 3 

### shows the more efficacious substitutes that DOE 4 

### considered as replacements. 5 

### DOE requests comment on the CSLs under 6 

### consideration, including the max tech level for 7 

### Externally Ballasted or Driven CFLKs. In 8 

### particular DOE requests comment on the equations 9 

### used to define the efficacy requirements at each 10


### CSL. 11 

### MR. BROOKMAN: Any additional comments 12 

### here? Nothing. Okay. 13 

### MS. PIERCE: Okay. Moving on to scaling. 14 

### DOE typically scales CSLs to product classes not 15 

### directly analyzed, but since all product classes 16 

### were considered to be representative no scaling 17 

### was required. 18 

### So we have several requests for comment 19 

### in the next few slides, several of which are 20 

### related to LEDs and CFLKs. And in issue 17 DOE 21 

### requests comment on whether and what fraction of 22155

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### ballasts or pin-based fluorescent lamps are 1 

### designed to be replaceable by the consumer. 2 

### DOE also requests comment on whether 3 

### consumers generally replace the ballast in a CFLK 4 

### if it fails, or if consumers replace the entire 5 

### CFLK assuming it is no longer operable. 6 

### I'll stop there and -- 7


### MR. BROOKMAN: Comments on ballast 8 

### replacements? 9 

### Maybe we should rally. We're just about 10 

### to break for lunch. Let's try hard, here. Tim. 11 

### MR. FLANNERY: My understanding is it's 12 

### really replacement of the ceiling fan light kit, 13 

### versus the changing of the ballast. 14 

### MR. BROOKMAN: Tim, I didn't hear that. 15 

### Would you repeat that, please? 16 

### MR. FLANNERY: My feeling is, is that 17 

### they're changing the light kit versus the 18


### ballast. 19 

### MS. PIERCE: Thank you. 20 

### MR. BROOKMAN: Okay. Thank you. Yes. 21 

### Yes, Clark? 22156

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### MR. LINSTONE: This is Clark Linstone, 1 

### Lamps Plus. Our experience has been not just 2 

### changing the light kit but changing the whole 3 

### ceiling fan when that -- 4 

### MR. BROOKMAN: Okay. 5


### MR. LINSTONE: What we see consumers 6 

### doing. 7 

### MR. BROOKMAN: Thank you, Clark. Other 8 

### thoughts? Yes, please, Alan. 9 

### MR. ROO: The major problem that we've 10 

### come across is the replacement of the ballast 11 

### itself, it is no longer available from the 12 

### manufacturer, and the consumer then therefore has 13 

### to select a new light kit. 14 

### MR. BROOKMAN: Oh, okay. Replace the 15 

### entire kit. Okay. Yeah. Yes? 16 

### Is that it? Okay. 17 

### MS. PIERCE: Okay. And in issue 20 DOE 18 

### requests comment on the practicality of 19 

### externally driven LEDs. For example, LED module 20 

### and driver systems as replacements for externally 21 

### ballasted fluorescent or CFL lamps and CFLKs. 22157

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### Specifically DOE requests information on the 1 

### fixture changes necessary for such a replacement. 2 

### MR. BROOKMAN: Yes, Dave. 3 

### MR. GATTO: We can keep this one really 4 

### brief. The entire light kit would have to be 5 

### replaced. The consumer wouldn't be able to 6 

### retrofit to LED because no one would make a 7 

### retrofit LED for a pin base -- yeah, it just 8


### would be not done. 9 

### And I'd just maybe point out that this 10 

### product class in its current form represents I 11 

### think a whopping one percent or less. It's 12 

### possible that the fixture replacement scenario 13 

### with LED would ultimately change that. But as it 14 

### stands right now it's a very very small part of 15


### the market. 16 

### MR. BROOKMAN: Okay. 17 

### MS. PIERCE: Okay. In issue 21 DOE 18 

### requests information on the typical efficacy 19 

### ranges for externally driven LEDs used in CFLKs. 20 

### DOE requests information on what these efficacy 21 

### ranges represent, so these would be the LED 22158

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### modules. If anyone has data that would be really 1 

### helpful. 2 

### MR. BROOKMAN: Typical efficacy ranges? 3 

### MR. TURNER: This is David with Hunter. 4 

### I think this is where we spoke about, we're not 5 

### sure where it's going and so we can't really 6 

### provide too much commentary on it. 7 

### MR. BROOKMAN: Okay. 8 

### MR. TURNER: But there's potential for 9 

### it. 10 

### MR. BROOKMAN: In your written comments. 11


### MR. TURNER: Yes. 12 

### MR. BROOKMAN: Alex Boesenberg. 13 

### MR. BOESENBERG: Alex Boesenberg, NEMA. 14 

### I would add to that consideration. If, you know, 15 

### to sort of amplify my previous comment, if the 16 

### ceiling fan industry goes towards a uniform 17 

### socketed LED light modules and drivers consistent 18 

### with the emerging standards for interoperability, 19 

### i.e. Zhaga or other representatives, I would 20 

### estimate -- I'm not asking, but I'm saying it's 21 

### far likelier that those products will fall under 22159

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### regulation. And so then you -- it becomes more 1 

### like the previous class where the lamp being 2 

### supplied is covered by regulation and so you just 3 

### have to make sure that it is consistent with 4


### that. 5 

### So, you know, that might be where the 6 

### market heads if the market asks ceiling fan 7 

### manufacturers to go toward interoperable, one 8 

### module for multiple applications within the 9


### house. 10 

### MR. BROOKMAN: Okay. 11 

### MR. BOESENBERG: But it's only a guess. 12 

### MR. BROOKMAN: Thank you. Additional 13 

### thoughts on efficacy ranges? 14 

### Okay. 15 

### MS. PIERCE: Okay. Just one last 16 

### request. DOE requests comment on the overall 17 

### methodology and results of the CFLK engineering 18 

### analysis. 19 

### MR. BROOKMAN: Kind of a macro-comment. 20 

### If you wish, you can dwell on it over lunch 21


### because we're about to break. 22160

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### It's now 12:20. Let's break for lunch. 1 

### We've made a lot of progress here. There's still 2 

### more to take up. Make sure your visitor's badge 3 

### is visible. I think most of you are familiar 4 

### with the layout here. Down to the ground floor, 5 

### there's a Subway shop down there. About 100 6 

### yards in that direction there's a big cafeteria 7 

### up two escalators, and we'll see you back here at 8 

### 1:20 to finish off the day. 9 

### (Recess from 12:19 p.m. until 1:20 p.m.) 10 

### MR. BROOKMAN: Okay. Let's resume. How 11 

### many people are joining us online? 12


### EMILY: We have 20. 13 

### MR. BROOKMAN: Twenty individuals online. 14 

### That's good. 15 

### We are going to pick up where we left 16 

### off, and that's product price determination for 17 

### all of you that have got your packet of 18 

### information in front of you. And we're going to 19 

### hear from Aisha Husain. 20 

### MS. HUSAIN: Hi. My name is Aisha Husain 21 

### and I am with Navigant and I'll be going through 22161

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### the product price determination for ceiling fan 1 

### light kits. 2 

### Can everyone hear me okay? All right. 3 

### So as noted in this analysis ceiling fan 4 

### light kit efficiency is based on the efficacy of 5 

### the lamp with which it is packaged. Therefore 6 

### DOE developed consumer prices for lamps when they 7 

### are packaged with the light kits. To do so DOE 8 

### first determined how much a consumer would pay 9 

### for a ceiling fan light kit, and then what 10 

### portion of that was attributable to the lamp 11 

### component. 12 

### In its research DOE found a range of 13 

### ceiling fan light kit consumer prices that were 14 

### dependent on the distribution channel through 15 

### which the light kit was being purchased. To 16 

### represent this range DOE developed three premiums 17 

### and thereby three prices, using the 18 

### manufacturer's suggested distributor net prices, 19


### or DNPs. 20 

### The low ceiling fan light kit consumer 21 

### prices are representative of purchase through the 22162

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### electrical distributor channel which include 1 

### wholesalers and contractors. The medium prices 2 

### are representative of purchases through home 3 

### centers, and high prices are representative of 4 

### purchases through lighting showrooms. 5 

### DOE then developed a weighted price. So 6 

### based on estimated shipment volume through each 7 

### channel, DOE applied 12 percent to the electrical 8 

### distributor channel price, 80 percent to the home 9 

### center channel price, and eight percent to the 10 

### lighting showroom channel price, and developed a 11 

### weighted average consumer ceiling fan light kit 12 

### price. 13 

### So once we had the consumer ceiling fan 14 

### light kit price developed, the next step was to 15 

### determine what portion of that was attributable 16 

### to the lamp in the light kit. 17 

### From manufacturer feedback DOE determined 18 

### that for a light kit with a CFL or LED the lamp 19 

### component comprised an estimated 15 percent of 20 

### the ceiling fan light kit consumer price. So 21 

### this percentage was applied to the consumer price 22163

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### of the ceiling fan light kit to obtain the 1 

### consumer price of the lamp package with the light 2 

### kit. 3 

### In cases where DOE was unable to develop 4 

### a consumer price for a ceiling fan light kit with 5 

### the representative lamp, DOE applied a ratio 6 

### based on the expected incremental cost of the 7 

### representative lamp relative to the baseline lamp 8 

### in the light kit. 9 

### And we have a series of requests for 10 

### comment here. In issue 24 we're asking for 11 

### comments on DOE's determination that a basic 12 

### ceiling fan light kit package with a ceiling fan 13 

### comprises 20 percent of the consumer price of the 14 

### fan and light kit, and subsequently requests for 15 

### comment on the determination that a CFL or LED 16 

### package with a light kit comprises 15 percent of 17 

### the consumer price of the light kit. 18 

### MR. BROOKMAN: I see a few individuals 19 

### that are -- they're rolling their eyes as if 20 

### they're making a calculation in their head. 21


### Dave? 22164

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### MR. TURNER: I don't do calculations in 1 

### my head. 2 

### MR. BROOKMAN: You've got a calculator. 3 

### MR. TURNER: I have my calculator. 4 

### David with Hunter Fan. I would say the 5 

### percentage of the consumer price for LED light 6 

### kits is low, because we're talking about just the 7 

### light kit price, correct? If it's attached to a 8 

### fan the fan is not relevant in this? 9 

### MS. HUSAIN: So for the 15 percent it's 10 

### the LED component of the light kit consumer 11 

### price. 12 

### MR. TURNER: I would say it's, in my 13 

### estimation, it's probably closer to double that. 14 

### It's probably 30 percent. 15


### MS. HUSAIN: Double. And the CFL would - 16



### - 17 

### MR. TURNER: CFL is probably pretty 18


### accurate. 19 

### MR. BROOKMAN: Twenty percentish. 20 

### MR. TURNER: Well 15 percentish on the 21 

### CFLs portion -- 22165

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### MR. BROOKMAN: Oh, yeah, yeah, yeah. 1 

### MR. TURNER: -- of the light kit cost. 2 

### MR. BROOKMAN: Yeah. Thank you. Yes. 3 

### Okay. Any additional commentary? 4


### MR. FLANNERY: Concur. 5 

### MR. BROOKMAN: Yes, concur. Okay. Thank 6 

### you. Dave? 7 

### MR. GATTO: Yes, I basically agree with 8


### Dave Turner. 9 

### MR. BROOKMAN: Yeah. Okay. Thank you. 10 

### MR. GATTO: Dave Gatto, Westinghouse. 11 

### MR. BROOKMAN: That's helpful. Thank 12 

### you. Okay. On to 25. 13 

### MR. LINSTONE: I was just going to concur 14 

### as well with that. I think that's -- the LED is 15 

### going to be more expensive. 16 

### MR. UPTON: Do you concur with DOE or do 17 

### you concur with Dave? 18 

### MR. LINSTONE: With Dave. Both Daves, 19 

### actually. 20 

### MR. BROOKMAN: Thank you, Clark. Thank 21 

### you. Okay. 22166

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### MS. HUSAIN: Issue 25 is basically asking 1 

### for comment on the distribution channel weighting 2 

### that I went through earlier, so I can repeat 3 

### those again, what we used. It was 12 percent for 4 

### the electrical distributor channel, 80 percent 5 

### for the home center channel, and eight percent 6 

### for the lighting showroom. 7 

### And if you need to do calculations and 8 

### want to provide comment later on that would be 9 

### really helpful as well. 10 

### MR. BROOKMAN: Okay 11 

### MS. HUSAIN: Issue 27, we are requesting 12 

### comment on the assumption that the prices of the 13 

### different electronic ballasts presented in the 14 

### fixture replacement scenario are equal to each 15 

### others, so there's no difference in prices there 16 

### that we need to account for. And this is 17 

### specific to the Externally Ballasted product 18


### class. 19


### MR. BROOKMAN: No comment here. 20 

### MS. HUSAIN: Okay. So issue 26 is just a 21 

### general, any comments on the product price 22167

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### determination, results, methodology. 1


### MR. BROOKMAN: Dave. 2 

### MR. GATTO: This is going to be one of 3 

### those things where it's probably in the next 4 

### slide, but the price determination for the 5 

### consumer price for lamps for CFLs I think is 6 

### accurate. I think that what's going to be left 7 

### out is that there's no analysis of the price of 8 

### an incandescent lamp included with a CFLK. 9 

### MS. HUSAIN: Right. And that's based so 10 

### the product price determination is based on like 11 

### what's used in the engineering. So that would 12


### follow. Yes. 13 

### MR. BROOKMAN: Yeah. Okay. Okay? 14 

### MS. HUSAIN: Okay. So I am turning it 15 

### over to Colleen for energy use. 16 

### MS. KANTNER: Colleen Kantner, Lawrence 17 

### Berkley National Lab. 18 

### So next up is the energy use analysis. 19 

### The purpose of the energy use characterization is 20 

### to develop estimates of the actual energy use in 21 

### the field of CFLKs at each efficiency level. DOE 22168

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### derives annual energy use from the product of 1 

### annual operating hours and system input power. 2 

### To develop operating hours for CFLKs in the 3 

### residential sector, DOE combined data on the 4 

### rooms where CFLKs are located from an LBNL study 5 

### with data on operating hours for residential 6 

### ceiling light fixtures by room type from DOE's 7 

### Residential Lighting End-Use Consumption Survey. 8 

### To develop operating hours for the 9 

### commercial sector, DOE combined data on the hours 10 

### of use of lamp types typically used in CFLKs with 11 

### the fraction of lamps of each lighting technology 12 

### used in each commercial building type. And this 13 

### data came from DOE's U.S. Lighting Market 14 

### Characterization Report. 15 

### DOE estimated that the weighted average 16 

### over all building types was 10.6 hours per day in 17 

### the commercial sector, and 1.4 hours per day in 18 

### the residential sector. DOE assumed that CFLKs 19 

### were not used in the industrial sector. 20 

### DOE utilized the power consumption data 21 

### presented in the engineering analysis for 22169

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### representative lamps and lamp and ballast systems 1 

### to develop system input power. Since DOE's 2 

### analysis of energy use is intended to represent 3 

### the energy use of products in the field for the 4 

### All Other CFLK product class, DOE scaled the 5 

### lumen outputs of CFLKs from the engineering 6 

### analysis, which were constrained to be within a 7 

### certain percentage of the lumen output of the 8 

### least efficacious CFLKs under consideration, to 9 

### the typical lumen output of CFLKs on the market. 10 

### In recognition of stakeholders comments 11 

### on current product class 3, indicating that the 12 

### wattage limit constrains the light output of 13 

### CFLKs with low efficiency lamps to levels below 14 

### those preferred by consumers, DOE did not include 15 

### the lumen output of such CFLKs in developing its 16 

### estimate of typical CFLK lumen output. 17 

### And keep in mind that DOE is considering 18 

### removing the wattage limiter requirement under 19 

### the new product class structure, in which case 20 

### the constraint on lumen output would no longer 21 

### exist. 22170

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### To estimate the average lumen output of 1 

### All Other CFLKs, DOE used in-store shelf survey 2 

### data of ceiling fans with light kits and CFLKs 3 

### sold alone. This data included socket types, 4 

### socket numbers, light source technologies, lamp 5 

### wattages and retail prices, as well as lamp 6 

### efficacy data from online retailers on the 7 

### efficacy of the lamps found in All Other CFLKs. 8 

### For the Externally Ballasted or Driven 9 

### product class, because they occupy a very small 10 

### market share, DOE was unable to collect 11 

### sufficient data on their typical lumen output, so 12 

### DOE did not scale it. 13 

### It's also worth noting that, unlike All 14 

### Other CFLKs, where the market average number of 15 

### lamps in a CFLK might be fractional, all of the 16 

### CFLKs with circlines DOE found only contained one 17 

### lamp. 18


### So here we see the results of DOE's 19 

### analysis of the average lumen output of CFLKs. 20 

### Indeed it looks like the lumen output of CFLKs 21 

### with low efficiency lamps in the third product 22171

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### class, which are constrained by a wattage 1 

### limiter, had a lower average lumen output. And 2 

### the average lumen output for CFLKs that are not 3 

### constrained is close to 2,000 lumens. 4 

### The unconstrained lamps here include both 5 

### medium screw base lamps, which are not subject to 6 

### a wattage limit, as well as GU-24s that are in 7 

### Product Class 3, but have a high enough efficacy 8 

### that the wattage limiter does not constrain their 9 

### total lumen output. 10 

### All other types of CFLKs were rare enough 11 

### that DOE couldn't draw conclusions about their 12 

### typical lumen output. This analysis was used to 13 

### scale the lumen output at each CSL from the 14 

### engineering analysis by the ratio of the market 15 

### average CFLK lumen output to the lumen output of 16 

### CSL-0, for the All Other CFLK product class. 17 

### And here we see the results of the energy 18 

### use characterization. The top table is for 19 

### Externally Ballasted or Driven CFLKs, showing 20 

### both energy use at each CSL as well as the 21 

### savings, where the savings represent the 22172

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### difference between CSL-1 and the baseline. And 1 

### it's worth noting that for the energy use and 2 

### savings we assumed -- or DOE assumed that the two 3 

### engineering scenarios presented were equally 4 

### present in the market, so it just assumed equal 5 

### market shares for those two scenarios. And 6 

### that's also true for the bottom table which 7 

### presents the All Other CFLKs product class. 8 

### Again, the table displays the energy use and 9 

### savings at each CSL and also shows the 10 

### residential sector versus the commercial sector. 11 

### MR. TURNER: Can you repeat the part 12


### about market share? 13 

### MS. KANTNER: So there were two possible 14 

### engineering scenarios presented in the 15 

### engineering analysis. A lamp replacement 16 

### scenario and a fixture replacement scenario, and 17 

### since DOE doesn't have any market data to 18 

### indicate which one would be used, DOE assumed 19 

### that they would be used equally. And so this 20 

### data here represents just a 50 percent lamp 21 

### replacement scenario, 50 percent fixture 22173

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### replacement scenario. 1 

### MR. BROOKMAN: So, Dave, please follow on 2 

### if you have any thoughts on this. 3 

### MR. TURNER: Well, I don't know if this 4 

### affects anything but I think you made the point 5 

### earlier that we tend rather heavily towards lamp 6 

### replacement. At least in current state. 7


### MR. BROOKMAN: Dave. 8 

### MR. GATTO: Dave Gatto, Westinghouse. 9 

### Yeah, I'm not sure that it would have 10 

### done anything different for your analysis, just 11 

### because you're using similar efficacies. But I 12 

### think what Dave Turner is suggesting and I would 13 

### agree with is that in the current market place 14 

### lamp replacement is the primary method and while 15 

### it's possible that we'll see an increase, and we 16 

### talked about it earlier, an increase of 17 

### integrated LED or what you're calling fixture 18 

### replacement where the entire light kit is a 19 

### single integrated module, the odds of being 50/50 20 

### are probably fairly low, at least in the short 21


### term. 22174

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### MS. KANTNER: Just to clarify, fixture 1 

### replacement wasn't meant to imply only 2 

### replacement with integrated LEDs. It was just if 3 

### there were a different number of sockets, that 4 

### would be a fixture replacement. 5 

### MR. GATTO: Okay. So if it was a three6 

### light it might go to a two-light or a four-light. 7 

### MS. KANTNER: Exactly. 8 

### MR. GATTO: Okay. Then, I guess if you 9 

### have to pick a spot, I guess that spot is as good 10 

### as any other. So I don't really think we 11 

### disagree with the analysis on that piece. 12 

### The only thing I would not intentionally 13 

### disagree with, but I'd point out here and I think 14 

### it's a first for me, DOE is maybe intentionally 15 

### ignoring the huge energy savings that are 16 

### represented by moving from CSLs, minus one if you 17 

### will, to the new standard based on what you 18 

### proposed. I mean, I think that again, no 19 

### different than I think the LCC should capture 20 

### what the consumer cost impact is, I think that 21 

### there's a huge energy savings that DOE is 22175

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### proposing here and you're not really spelling 1 

### that out clearly and I'm not sure why. So I'd 2 

### ask Lucy maybe to expand on that. But, you know, 3 

### I definitely credit where it would be due and 4 

### this is one that would probably move the needle 5 

### if you calculated it right. 6 

### MR. BROOKMAN: Okay. Thanks, Dave. 7 

### MS. KANTNER: Okay. And there's an item 8 

### for comment. To improve its energy use estimates 9 

### DOE seeks comment on the typical total lumen 10 

### output of pin-based fluorescent CFLKs. 11 

### MR. BROOKMAN: Any comment here? Dave. 12 

### MR. GATTO: So I'm sorry. When you say 13 

### pin-based I'm assuming you're talking about 14 

### what's traditionally in a light kit now, which 15 

### would just be a circline four pin? 16 

### MS. KANTNER: Exactly. 17 

### MR. GATTO: So it's a very -- it's a one18 

### item market. So what you have is representative. 19 

### Does that help? 20 

### MS. KANTNER: Okay. Yes. 21 

### MR. BROOKMAN: Okay. Thank you. 22176

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### MS. KANTNER: Next is the life-cycle cost 1 

### analysis. 2 

### The purpose of the life-cycle cost 3 

### analysis is to provide an economic evaluation 4 

### from the end-user's perspective. Life-cycle cost 5 

### is the total purchaser cost over the life of a 6 

### product. Payback period is the time required to 7 

### recover the increased purchase price of a more 8 

### efficient and more energy efficient product 9 

### through reduced operating costs. The methodology 10 

### used to develop the lifecycle cost is to first 11 

### develop a Monte Carlo sample of 10,000 12 

### purchasers, then determine total installed cost 13 

### for each CSL, then operating costs are determined 14 

### for the first year and over the lifetime of the 15 

### product, which include lamp disposal costs, lamp 16 

### replacements throughout the lifetime of a CFLK, 17 

### and the residual value of lamps at the end of the 18 

### CFLK lifetime. 19 

### DOE also calculates the payback period by 20 

### dividing the average increase in installed costs 21 

### by the average decrease in first year operating 22177

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### costs. And the LCC is calculated by adding 1 

### installed costs and lifetime operating costs. 2 

### Then LCC savings are calculated with 3 

### respect to the distribution of efficiencies in 4


### the absence of standards. 5 

### To account for the variability in energy 6 

### consumption, energy price, or both, DOE developed 7 

### a sample of 10,000 CFLK purchasers. In the 8 

### residential sector households were randomly 9 

### selected from the subset of households with 10 

### ceiling fans in RECS 2009. DOE applied a 11 

### selection weight to each household based on the 12 

### number of ceiling fans in that household. 13 

### For the commercial sector buildings were 14 

### randomly selected from the 2003 Commercial 15 

### Buildings Energy Consumption Survey, CBECS. This 16 

### excluded vacant buildings, though. DOE applied a 17 

### selection weight to each building based on square 18 

### footage, the number of lamps per thousand square 19 

### feet, and the fraction of lamps using light 20 

### source technologies found in CFLKs. 21 

### To estimate the average LCC savings of a 22178

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### CSL, DOE first considers the expected market 1 

### distribution by efficiency level of CFLK 2 

### purchases that consumers would make in the 3 

### compliance here in the absence of an amended 4


### standard. For all other CFLKs DOE used LED 5 

### incursion in combination with a consumer choice 6 

### model to model the market distribution of 7 

### shipments from 2012 through 2019. And just as a 8 

### note, LED incursion and the consumer choice model 9 

### will be discussed in detail on the shipments 10 

### analysis later. 11 

### For Externally Ballasted or Driven CFLKs, 12 

### due to insufficient market data, DOE assumed an 13 

### even split in market share between CSL-0 and CSL14 

### 1 as previously mentioned. 15 

### And here we see the expected market 16 

### efficiency distribution for each product class. 17 

### Note that for the Externally Ballasted or Driven 18 

### product class, due to limited data, DOE assumed 19 

### an even split in market share between CSL-0 and 20 

### CSL-1, in addition to assuming an even split at 21 

### CSL-1 between the lamp replacement and the 22179

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### fixture replacement scenarios. 1 

### For both product classes, at each CSL, 2 

### DOE assumed -- this is also true for the all 3 

### others product class -- DOE assumed an even split 4 

### in market share between each CSL, between the 5 

### lamp replacement scenario and the fixture 6 

### replacement scenario. 7


### The lack of market share at CSL-3 and 4 8 

### in the -- this lack of market share reflects, in 9 

### part, the expected increase in LED efficacy by 10 

### the compliance year. By the compliance year the 11 

### LED market share is expected to be concentrated 12 

### to efficacies corresponding to CSL-5 and above. 13 

### MR. GATTO: Open for comment? 14 

### MR. BROOKMAN: Wherever you want, Dave. 15


### MS. KANTNER: Feel free to comment. 16 

### MR. BROOKMAN: Right here would be good. 17 

### MR. GATTO: So, I saw Doug looking at me. 18 

### So I wouldn't necessarily disagree that the 19 

### general service LED market would be close to what 20 

### you're proposing as CSL-5. In lower wattage 21 

### based on your scale. I don't know that you're 22180

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### going to see 20 and 25 watt LEDs that would be at 1 

### some 200 lumen per watt that wouldn't really 2 

### exist in the market place. 3 

### I don't know that I agree with making 4 

### that assumption here, only because you're basing 5 

### it on the lack of availability of product and 6 

### forward-looking forecast of general service LEDs. 7 

### But the products that go in the current CFLKs are 8 

### not general service, they're candelabra base and 9 

### decorative shape. 10 

### So, you know, I'm going to repeat my -- 11 

### it's not that I really have a problem with that 12 

### from a manufacturing and lamp standpoint, it's 13 

### just that the analysis should really be what is 14 

### the -- based on what we know today, not what we 15 

### think will happen. And that's where I get a 16 

### little concerned because these analysis are what 17 

### determine -- not only what DOE determines is the 18 

### new rule, but what consumers have to deal with 19 

### three years from when it publishes. 20


### So I don't know that I have an alternate 21 

### for you other than that if you don't know where 22181

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### it's going to go I would rather see you split it 1 

### evenly between CSL-3, 4, and 5. I understand 2 

### that CSLs are really CFL, and the other three are 3 

### LED. But in the absence of having a product to 4 

### analyze it just seems a little bit odd to shift 5 

### it all to the high end. 6 

### MS. KANTNER: Okay. 7 

### MR. BROOKMAN: Thank you. Additional 8 

### thoughts on this? Quite a bit of data here. 9 

### Okay. 10 

### MS. KANTNER: Okay. So next we have the 11 

### total installed cost. The total installed cost 12 

### is just the product price plus sales tax. 13 

### Product price is based on the output of the 14 

### product price determination, it includes the end15 

### user lamp and socket prices for each CFLK where 16 

### the number of lamps or sockets has been scaled by 17 

### the same factor as the total lumen output. This 18 

### also includes price learning for LEDs expected to 19 

### occur by the compliance date. And there will be 20 

### more detail on this provided in the shipments 21 

### section later. 22182

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### Sales tax, which includes both state and 1 

### local sales tax as determined by geographic 2 

### location, and installation cost was not included 3 

### because it was assumed not to vary with CSL. 4 

### Any comments on the total installed cost? 5


### MR. BROOKMAN: Dave. 6 

### MR. GATTO: Dave Gatto, Westinghouse. 7 

### I'll just repeat that the end-user lamp price and 8 

### socket prices is not being analyzed correctly 9 

### because we're leaving out the current cost to 10



### consumers. 11 

### MR. BROOKMAN: Okay. 12 

### MS. KANTNER: Average operating hours 13 

### were developed for each RECS reportable domain 14 

### using the approach described in the energy use 15 

### analysis to capture the variability for 16 

### individual purchasers, triangular distributions 17 

### of plus or minus 20 percent were applied to the 18 

### average hours of use. 19 

### As far as electricity prices, electricity 20 

### prices and trends were estimated using data from 21 

### EIA. DOE used EIA's Annual Energy Outlook for 22183

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### projections of future average energy prices for 1 

### reference, high, and low growth scenarios. For 2 

### all three scenarios. 3 

### Any comments? 4 

### (No audible response.) 5 

### MS. KANTNER: As far as discount rates, 6 

### DOE used discount rates to discount operating 7 

### cost to the year of purchase, and this year was 8 

### assumed to be 2019. And discount rates represent 9 

### the opportunity cost of funds used to purchase 10


### CFLKs. 11 

### In the residential sector, for 12 

### replacement CFLKs in existing homes, DOE used a 13 

### distribution of debt and asset classes for 14 

### purchasing appliances that include stocks, mutual 15 

### funds, savings accounts, bonds, loans. For CFLKs 16 

### installed in new construction, DOE used a 17 

### distribution of mortgage rates. 18 

### In the commercial sector, DOE used a 19 

### distribution of weighted average cost of capital. 20 

### Any comments on the discount rates? 21 

### (No audible response.) 22184

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### MS. KANTNER: Lifetime is the age at 1 

### which a CFLK is retired from service. DOE 2 

### assumed that the lifetime of a CFLK is the same 3 

### as a ceiling fan since CFLKs have fewer moving 4 

### parts than a ceiling fan and are unlikely to fail 5 

### earlier than the ceiling fan, but consumers will 6 

### likely retire them when they get a new fan 7 

### because they are typically sold together and 8 

### consumers generally want a matching ceiling fan 9 

### and light kit style. 10 

### While DOE considers the lifetime of a 11 

### CFLK to be equivalent to the lifetime of the 12 

### ceiling fan to which it is attached, DOE 13 

### recognizes that the lamps packaged with the 14 

### ceiling fan light kit may have a shorter 15 

### lifetime. 16 

### An amended CFLK standard would only 17 

### affect the efficacy of lamps packaged with the 18 

### CFLK. But the lifetime energy use of the light 19 

### kit is also affected by the efficacy of the 20 

### replacement lamps which are purchased at the end 21 

### of the lifetime of the lamps that are sold with 22185

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### the light kit. 1 

### DOE considers these replacement lamps to 2 

### be a repair and maintenance cost and considers 3 

### lamp replacement cost for failed lamps to be the 4 

### only repair or maintenance cost that varies with 5 

### product efficiency. 6


### MR. BROOKMAN: Dave. 7 

### MR. GATTO: Just I'll, you know, I'll go 8 

### on record that I kind of agree with that 9 

### analysis. I got a little confused in there when 10 

### you were talking about maintenance costs, where 11 

### the efficacy of the lamp that might replace the 12 

### original lamp might be maybe more efficacious 13 

### than the old lamp. Is that where you were going 14 

### with that? 15 

### MS. KANTNER: It could be either more or 16 

### less. This is just pointing out that the average 17 

### -- or excuse me, the energy use in each year 18 

### might change over the lifetime of a CFLK as you 19 

### replace it with different lamps than it was 20 

### originally packaged with. 21 

### MR. GATTO: Okay. Thank you. 22186

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### MS. KANTNER: Sure. As I just mentioned, 1 

### DOE included in the life-cycle cost the cost to 2 

### replace lamps that fail during the lifetime of a 3 

### CFLK. Lamp replacement costs are the purchase 4 

### costs of replacement lamps in the year that 5 

### failed lamps are replaced, discounted to the 6 

### analysis start year. 7 

### DOE assumes that CFLK lamps fail at the 8 

### end of their average service life, which is just 9 

### the lamp lifetime divided by the lamp’s operating 10 

### hours per year. It also assumed that replacement 11 

### lamps have the same base type as failed lamps, 12 

### provide an equivalent lumen output as failed 13 

### lamps, and just as a note, that the prices for 14 

### the replacement lamps do not include the CFLK 15 

### manufacturer markup. 16 

### DOE knows of no LED replacement options 17 

### for CFLKs with pin-based sockets. Since there 18 

### are limited data available to support any other 19 

### conclusion, DOE assumed that failed CFLK lamps 20 

### are replaced with the same lamp that was 21 

### originally packaged with the light kit for this 22187

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### product class. 1 

### For the All Other CFLKs product class, 2 

### consumers were again constrained to purchase 3 

### lamps of the same socket type and lumen range, 4 

### but DOE's model allowed them to choose lamps that 5 

### have a different light source technology from 6 

### those that were packaged with the CFLK. 7 

### DOE categorizes lamps as low, medium, or 8 

### high efficacy to characterize the lamp 9 

### replacement options. To determine lamp 10 

### characteristics, DOE used data on CFL and LED 11 

### lamps included in the engineering analysis for 12 

### the medium and high efficacy lamps, and market 13 

### research data for the low efficacy lamps. 14 

### Specifically the data used were 15 

### efficacies, watts, prices -- where price learning 16 

### was applied to LEDs -- and lifetimes for each 17 

### lamp replacement. 18 

### Note that the purchase cost of a 19 

### replacement lamp is the purchase price in the 20 

### year the replacement occurs, multiplied by sales 21 

### tax and then discounted back to the analysis 22188

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### start year. 1 

### Choice of replacement lamp in a given 2 

### year was determined by first estimating the 3 

### fraction of replacement lamps that would be high 4 

### efficacy based on the LED incursion into the 5 

### market for replacement lamps, which came from a 6 

### DOE SSL report. 7 

### The fraction of replacement lamps that 8 

### fell into the low versus medium efficacy lamp 9 

### categories was then determined by a consumer 10 

### choice model sensitive to price and operating 11 

### cost, using sector specific consumer choice 12 

### parameters. 13 

### And this graph here displays the 14 

### selection probability over time for the high 15 

### efficacy lamps in the greenish color, the medium 16 

### efficacy lamps in the red color, and the low 17 

### efficacy lamps in the blue color. 18 

### MR. CYMBALSKY: This is absent standards, 19


### correct? 20 

### MR. BROOKMAN: John Cymbalsky. 21 

### MS. KANTNER: This is for just lamps that 22189

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### are the replacement lamps. So this is not 1 

### subject to CFLK efficacy standards. 2 

### MR. CYMBALSKY: Right. So I think I 3 

### wanted to point out that this is just what we 4 

### predict to be purchased absent any standards for 5 

### the light kits. 6 

### MS. KANTNER: Well, regardless of the 7 

### standard for the light kit. 8 

### MR. CYMBALSKY: Right. Okay. I think 9 

### that's what I meant. So this is what we think is 10 

### going to happen, absent -- with or without 11


### standards. 12


### MR. BROOKMAN: Yeah. Dave. 13 

### MS. KANTNER: Exactly. 14 

### MR. GATTO: So I probably knew I was 15 

### going there, John. 16 

### So then I would ask the question -- Dave 17 

### Gatto, Westinghouse Lighting. You should just 18 

### turn your mic on and say it for me, Alex. 19 

### MR. BOESENBERG: I can't believe I didn’t 20 

### have to say it. 21 

### MR. GATTO: So my question would be, 22190

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### then, is a CFLK light kit rule necessary based on 1 

### the evidence, which I actually agree with and 2 

### we've seen it in the other SSL studies and it's 3 

### part of the GSL conversation we're about to have 4 

### in the other rulemaking. Is it necessary, 5 

### because in the absence of a standard, what I'm 6 

### seeing here is that everything is shifting in the 7 

### same direction we all agree, it's shifting which 8 

### is to higher efficacy. 9 

### So one of the things that I know that DOE 10 

### has to consider is sometimes staying out of our 11 

### own way, and I’m including industry in that. 12 

### That proposing a rule that actually slows down or 13 

### interferes with the adoption of the products that 14 

### we want everyone to move to. 15 

### MR. CYMBALSKY: So this is John from DOE. 16 

### So I think as we go further in and see what the 17 

### options are and the energy savings are, I think 18 

### we'll see some compelling economics for DOE to 19


### move forward. 20 

### MS. KANTNER: And it may be worth noting 21 

### that this trend exists in the analysis for no 22191

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### CFLK standard. So the results in the NIA, for 1 

### instance, are compared to -- there is a trend in 2 

### the background that is taken into account. 3 

### MR. GATTO: Dave Gatto, Westinghouse. So 4


### I'm not sure what that means. I understand that 5 

### this is in the absence of a rulemaking on CFLKs, 6 

### the lamp market is expected to move in this 7 

### direction. In the NIA and the shipping analysis 8 

### are you looking at both scenarios, with and 9 

### without a rulemaking? Or are you only looking at 10 

### with a rulemaking this is what will happen? 11 

### MS. KANTNER: We're looking at the 12 

### efficiency distribution in a standards case 13 

### versus the efficiency distribution when there is 14 

### no standard. But there's still this trend in the 15 

### efficiency distribution when there is no 16


### standard. 17 

### MR. GATTO: Okay. And I agree with that. 18 

### I think the only thing I would point out, and 19 

### this came up in the last public meeting, maybe 20 

### the one before that, is that fan manufacturers, 21 

### with exception of me, are not lamp manufacturers. 22192

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### So it becomes a little burdensome on the fan 1 

### manufacturer to be the leading edge of efficiency 2 

### on lamps instead of letting the lamp rulemaking 3 

### which is currently in progress, and any other 4 

### lamp rulemakings and the market itself kind of 5


### take us there. 6 

### And, John, for what it's worth, I agree 7 

### with you. I think that there may be some 8 

### additional savings you can capture. But capture 9 

### short-term until they get there by themselves, 10


### versus the burden on consumers and manufacturers 11 

### is something I think that at least DOE should 12 

### weigh. 13 

### MR. CYMBALSKY: Right. And this is John 14


### from DOE. 15 

### And we do that. And so, but you just 16 

### took the words -- you stole my thunder kind of by 17 

### looking at the graph. So, as with all the other 18 

### lighting rules that we seem to be working on, the 19 

### timing is the critical issue here. So if you 20 

### look at the graph, in my opinion you don't get 21 

### the phenomenon you're talking about until we get 22193

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### out at least, I'm thinking 15 years from where 1 

### we're sitting today. So I think, you know, there 2 

### is a good period of time where there is up front 3 

### energy and economics, and that's what's going to 4 

### drive, I think, the numbers you're going to see 5 

### here in a few minutes. 6 

### MR. GATTO: Dave Gatto, Westinghouse. I 7 

### appreciate that and I do agree with you that the 8 

### timeline will be shorter with a rulemaking. 9 

### MR. CYMBALSKY: Right. And I think what 10 

### you'll see in the analysis actually, you know, 11 

### comes -- it hits that head on. You'll see the 12


### numbers. 13 

### So this question is from Doug Smith on 14 

### the webinar. Are electricity prices based on 15 

### average or marginal. 16 

### So in all of our rulemakings it is the 17 

### marginal price of electricity that we do our 18 

### analysis on. 19 

### MS. KANTNER: I think these results were 20 

### done, at the preliminary analysis stage, with 21 

### average prices. So they could be done with the 22194

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### marginal prices at the NOPR stage. 1 

### MR. CYMBALSKY: Right. We will do 2 

### marginal electricity prices. 3 

### MR. BROOKMAN: Okay. 4 

### MS. KANTNER: Disposal cost is also an 5 

### input to the LCC analysis. The disposal cost 6 

### represents the cost of disposing, for example, 7 

### recycling, lamps at the end of the lamp lifetime. 8 

### DOE found that on average disposing of a CFL 9 

### costs about $1 per lamp. LED disposal costs were 10 

### assumed to be the same as CFLs due to limited 11 

### data to suggest otherwise. 12 

### In the residential sector DOE assumes 13 

### that consumers do not pay recycling cots, perhaps 14 

### recycling them for free at a home center. 15 

### In the commercial sector DOE assumed that 16 

### consumers paid recycling costs for 10 percent of 17 

### CFLs and LED lamp failures, and this was 18 

### implemented by applying an average cost of 10 19 

### cents to all lamps. 20 

### MR. GATTO: Dave Gatto, Westinghouse 21 

### Lighting. 22195

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### So, I'm not sure why you assume the same 1 

### disposal costs for LED as CFL. I would agree 2 

### with the dollar. I mean, that's really what 3 

### we've all landed on as the average recycling cost 4 

### for a spiral CFL. LEDs do not have that disposal 5 

### cost associated with them. They don't have 6 

### mercury. So I'm not sure what the -- 7 

### MS. KANTNER: What would you estimate is 8 

### the disposal cost for LEDs? 9 

### MR. GATTO: I would estimate -- I don't 10 

### know if you have a number that you apply to 11 

### throwing it in the trash, zero, I guess. You 12 

### know, there are some recycling values to some 13 

### LEDs because the aluminum content and the heat 14 

### sink, particularly in the commercial market, but 15



### -- 16 

### MS. KANTNER: A redemption value? 17 

### MR. GATTO: Yeah, that's more of a 18 

### redemption value. It's not a disposal cost. So 19 

### I would call it zero. 20 

### MS. KANTNER: Okay. Thank you. 21 

### MR. BROOKMAN: Thank you. 22196

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### MS. KANTNER: Okay. The residual value 1 

### is also an input to the LCC calculation. The 2 

### residual value represents the value, the 3 

### remaining dollar value of surviving lamps at the 4 

### end of the CFLK lifetime to account for the value 5 

### of lamps with the remaining life to the consumer. 6 

### The LCC model applies this residual value as a 7 

### credit at the end of the CFLK lifetime, and 8 

### discounts it back to the start of the analysis 9 

### period. 10 

### Note that for LEDs, the residual value of 11 

### these lamps is calculated based on the LED lamp 12 

### price in the year that the CFLK is retired, which 13 

### takes into account price learning. 14 

### Any comments? 15 

### (No audible response.) 16 

### MS. KANTNER: Okay. And here we see the 17 

### results for the LCC analysis. Specifically, here 18 

### are the results for the Externally Ballasted or 19 

### Driven CFLK product class. The results include 20 

### installed cost, first year operating cost, 21 

### lifetime operating cost, life-cycle cost, and 22197

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### simple payback period which can be compared to 1 

### the average lifetime of a CFLK. 2 

### All of the results presented for each CSL 3 

### here, except for the LCC savings at the end, 4 

### represent the average outcome if all 10,000 5 

### purchasers in the Monte Carlo sample bought at 6


### that CSL. 7 

### The LCC savings on the right-hand side on 8 

### the other hand, consider the distribution of 9 

### product efficiencies on the market in the absence 10 

### of an amended standard. So those savings are 11 

### relative to what a consumer would have purchased 12 

### without an amended standard and could include 13 

### lamps below the baseline proposed. Or baseline 14 

### considered, excuse me. 15 

### And I should note that the same sample is 16


### used for all CSLs. 17 

### The results are displayed separately for 18 

### the residential and commercial sectors. As 19 

### expected, the LCCs in the commercial sector are 20 

### higher at all CSLs due to the greater hours of 21 

### use in that sector. 22198

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### MR. BROOKMAN: Yes, Dave. 1 

### MR. TURNER: On installed costs for CSL - 2



### - 3 

### MR. BROOKMAN: Get closer to that, Dave. 4 

### MR. TURNER: On installed -- this is 5 

### David from Hunter Fans. 6 

### On installed costs for CFLKs was there an 7 

### installation figure put into that, because we 8 

### figured that 90 percent of them are attached to 9 

### fans. So how did that -- 10


### MS. KANTNER: We assumed that the 11 

### installation cost didn't vary by CSL, so we 12 

### didn't apply it in this case since the only thing 13 

### that matters to the LCC savings is the difference 14 

### between efficiency levels. 15 

### MR. TURNER: Okay. So just the cost of 16 

### the kit itself. 17 

### MS. KANTNER: Okay. And here are the 18 

### results for the All Other CFLKs product class. 19 

### And again, I want to note that the LCC savings 20 

### are calculated with respect to what consumers in 21 

### the sample would have purchased in the absence of 22199

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### an amended standard, which includes products with 1 

### efficacies below the baseline under product class 2 

### consolidation. 3


### I also want to note that there are bar 4 

### plots in the TSD which display the contributions 5 

### of installed cost, lifetime electricity costs, 6 

### relamping cost, and residual value to the overall 7 

### LCC. And those bar plots include bar plots for 8 

### lamps below the baseline considered in this 9 

### analysis. I know that there was some request for 10 

### data that showed what life-cycle costs looked 11 

### like for those lamps below the baseline 12 

### considered here. And those do exist in the TSD. 13


### MR. BROOKMAN: Dave. 14 

### MR. GATTO: Dave Gatto, Westinghouse. 15 

### So, I'm sorry. I just, I need your help. 16


### Walk me to the math. 17


### MS. KANTNER: Sure. 18 

### MR. GATTO: Where the installed cost of a 19 

### current class 3 incandescent light kit with a 20 

### limiter and say three or two, whatever you 21 

### considered your socket. I know you picked kind 22200

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### of one and then you modeled it. 1


### MS. KANTNER: Yes. 2 

### MR. GATTO: But I don't see any 3 

### difference in CSL-O, 1, or really a marginal to 4 

### 2, which makes sense to me if they're all compact 5 

### fluorescent, meeting the current Class 1 6 

### standard. So I just don't see where the consumer 7 

### installed cost of an incandescent light kit is up 8


### there. 9 

### MS. KANTNER: It's not represented by a 10 

### CSL here. When you look at the average LCC 11 

### savings in that column on the far right, that's 12 

### calculated with respect to what the efficiency 13 

### distribution would be without an amended 14 

### standard. And it includes the fraction of 15 

### consumers that would purchase CFLKs with 16 

### efficacies below the baseline. 17 

### There's also, as I was mentioning, 18 

### there's bar plots in the TSD chapter that show 19 

### the contributions to the various things I 20 

### mentioned, installed cost, electricity cost, 21


### whatever. 22201

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### MR. GATTO: No, that's okay. I think I 1 

### said it earlier, it wouldn't surprise me if the 2 

### payback period is reasonable to the consumer if 3 

### they understand that they're getting their money 4 

### back. I think the challenge that we as 5 

### manufacturers and the retailers who aren't 6 

### represented in the room here have is that the 7 

### consumer does not understand that. We tried to 8 

### explain it to them under the lamp FTC rule. It's 9 

### on the packaging. But it is unclear to them that 10 

### a $30 installed cost saves them money over the 11 

### lifetime versus a $10 installed cost. They don't 12 

### get it. 13 

### So I do think that that, depending on how 14 

### you apply that to the shipment analysis, which I 15 

### think if I remember correctly you show going up 16 

### year over year, I don't see how those two things 17 

### were taken into account. I don't know how you 18 

### could have the -- maybe what we need if you 19 

### didn't do it, is a price sensitivity analysis 20 

### because I think that's what's missing. It isn't 21 

### that I don't agree, and I do. For what it's 22202

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### worth to DOE, I do agree that the LED option will 1 

### take consumers where they want to go and then 2 

### over the lifetime of the product that they are 3 

### going to see a savings. I just don't think we've 4 

### really nailed down how that's going to impact 5 

### them on day one when they purchase the CFLK. 6 

### MS. KANTNER: I think we should hold off 7 

### on the shipments analysis because that will be 8 

### discussed in much more detail just shortly. 9 

### MR. BROOKMAN: David. 10 

### MR. TURNER: David from Hunter. Just to 11 

### circle back. 12 

### So, CSL-5 is LED, correct? Or is a lumen 13 

### per watt that only LED meets currently? 14


### MS. KANTNER: Yes. 15 

### MR. TURNER: And $27.50 is the consumer 16 

### purchase price. That's not like a manufacturer's 17 

### selling price? 18 

### MS. KANTNER: That's the fraction of the 19 

### consumer price to buy a light kit which is 20 

### represented by lamps and sockets. 21 

### MR. TURNER: Okay. From my end I would 22203

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### think that's low. 1 

### MR. BROOKMAN: Say it again? It's the 2 

### fraction of -- 3 

### MR. TURNER: That represents -- 4 

### MS. KANTNER: It's the fraction of the 5 

### light kit cost to a consumer that is represented 6 

### by the lamps and sockets. 7 

### MS. ARMSTRONG: Is it on a per lamp 8 

### basis, or is it cumulative? 9 

### MS. KANTNER: It's for, say on average 10 

### there was two and a half lamps, a market average 11 

### of two and a half lamps, then it would represent 12 

### that number of lamps and sockets. 13 

### MR. GATTO: So Dave Gatto with 14 

### Westinghouse Lighting. And, Dave, this may be 15 

### part -- 16 

### MS. KANTNER: Oh, I think also Mo has -- 17 

### MR. GANESHALINGAM: Oh, sorry just to 18 

### chime in. This is Mohan Ganeshalingam at 19 

### Lawrence Berkley, from Lawrence Berkley National 20 

### Labs. This also accounts for price learning, so 21 

### there is some drop in price between 2013 and 22204

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### 2019. 1 

### MR. BROOKMAN: Dave, keep going. 2 

### MR. GATTO: So, I’m sorry. Maybe it's a 3 

### question. So the installed cost is just a lamp 4 

### cost because that's the only thing different in 5 

### the light kit pre and post-standard? 6


### MS. KANTNER: Yes. 7


### MR. GATTO: And that -- 8 

### MS. KANTNER: DOE assumed that everything 9 

### besides the lamp and socket costs were the same. 10


### MR. GATTO: So then that would mean that 11 

### at the analysis, I think we suggested that 15 12 

### percent for LEDs is probably too low. It would 13 

### be more like 20. But for the 15 percent analysis 14 

### that you used, that would mean that a light kit - 15 

### - the cost of a light kit to the consumer would 16 

### be -- I do need my calculator for this. About 17 

### 100 and -- that can't be right. It looks way too 18 

### high. So 27.50 divided by .15 would be $183. 19 

### Does that sound like a light kit price that 20 

### anyone would pay? That's more than most fans. 21 

### So I'm not saying that that's what it 22205

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### would cost, I'm just trying to understand how we 1 

### got here and 15 percent of the light kit cost 2 

### being the lamp, $27.50, I’m just struggling with 3 

### it. 4 

### So I don't know if I'm reading that right 5 

### or if maybe I'm misunderstanding it. 6 

### MS. KANTNER: I'll let the folks who did 7 

### the engineering analysis answer that. 8


### MS. MCDONALD: Sure. We would welcome 9 

### any comments on prices. We have already 10 

### mentioned I guess that for the LEDs, you know, 11 

### this CSL-5 level would be an LED price. If that 12 

### were 20 or 30 percent of the light kit price, 13 

### then that wouldn't end up being $185. I see you 14 

### doing the calculation. It's probably going to 15 

### still turn out to be higher than you would want 16 

### it to be, or expect a consumer to pay. We would 17 

### welcome any comments on what, you know, the 18 

### prices that we're estimating for these lamps, you 19 

### know, including which, you know, which LEDs you'd 20 

### be most likely to include in a light kit that 21 

### would meet that level of efficacy. 22206

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### MR. GATTO: Dave. I would like one of 1 

### the other fan guys to get in here because this is 2 

### really just about light bulbs anymore. But thank 3 

### you. A., thank you. I think even at a 30 4 

### percent, if the LEDs represented 30 percent of 5 

### the light kit cost that's $100 light kit 6 

### ballpark. I don't know. I'm not saying that -- 7 

### I don't even know that that's accurate, that it 8 

### would be $100 light kit. So you know, whether 9 

### it's price learning or whether it's just the 10 

### percentage, LEDs are just moving so fast it's 11 

### really tough for me to give an opinion that isn't 12 

### a guess. And I hate to give an opinion that says 13 

### it's going to be less than that, but at the same 14 

### time -- 15 

### MS. MCDONALD: Comfortable saying the 16 

### prices are too -- 17 

### MR. GATTO: There has to be a price 18 

### sensitivity analysis done before we can move 19 

### forward with the rule if we're going to literally 20 

### quadruple the price of a CFLK, because I think if 21 

### you just, you know, with a medium based CFL in 22207

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### the box, at Home Depot right now, you're probably 1 

### $25, $30. Just, the consumers won't pay that. 2 

### And so I think that -- and again, if I sound a 3 

### little scared as a fan manufacturer, I'm a little 4 

### frightened that that type of impact would be 5 

### devastating to our industry. 6 

### I mean, it's not just that it would 7 

### impact the consumer. It could put us out of the 8 

### light kit business, which is a little scary. 9 

### MR. BROOKMAN: Okay. 10 

### MS. ARMSTRONG: So why don't you go ahead 11 

### and then I will. 12 

### MR. TURNER: Well, just like the last 13 

### comment that you said is what LEDs we might use. 14 

### And just to kind of echo Dave's comments, you 15 

### know, we're fan manufacturers. We're not lamp or 16 

### LED manufacturers and we follow where they go. 17 

### So if something becomes available that fits 18 

### within our, you know, our price points and we 19 

### think we can sell to consumers, and it's more 20 

### efficient and we can market it that way, that's 21


### what we'll use. 22208

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### But to look forward to 2019 and say that, 1 

### all right, well, we're going to use this 2 

### particular LED that has this particular 3 

### efficiency, that's not something we can -- we 4 

### don't guide that ship. It's going through other 5 

### regulations and everything else. So, we kind of 6


### follow that. 7 

### MS. ARMSTRONG: Okay. So my ask for you 8 

### is to talk to your lamp suppliers when you go 9 

### back and ask them what they have -- I mean, you 10 

### know, Dave's (indiscernible) is great but this 11 

### standards analysis is on you guys, not on the 12 

### lamps. I mean, yes, we've harmonized such that 13 

### it allows you to buy otherwise, you know, I will 14 

### say lamps that are tested pursuant to DOE 15 

### regulations, but the compliance cost is really 16 

### going to be born by the CFLK manufacturer that 17 

### has to purchase the lamps and then sell them to 18 

### consumers. Right? So -- 19 

### MR. TURNER: David Turner from Hunter 20 

### Fans. So I realize this standard is on us, but 21 

### if you were to set a level of efficiency that, 22209

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### like Dave said before, if LED manufacturers stop 1 

### going there, we would just have to take light 2 

### kits off of our fans because we're not going to 3 

### get into the lamp or LED business. It's, you 4


### know -- 5 

### MS. ARMSTRONG: Right. 6 

### MR. TURNER: I mean, we're not going to 7 

### start manufacturing those. 8 

### MS. ARMSTRONG: And obviously DOE is not 9 

### attempting to go there. So we really need the 10 

### feedback from you guys along with your lamp 11 

### suppliers, to the extent you can get them engaged 12 

### in this process with you, that would be most 13 

### helpful. 14 

### To circle back to you, though, regarding 15 

### your price sensitivity. I'm not following. And 16 

### maybe it's just me. I'm not following what it is 17 

### you're asking for exactly because if your 18 

### argument is that our prices are too high and 19 

### consumers won’t bear them, you know, the question 20 

### about whether consumers will bear that cost and 21 

### whether there's a reduction in shipments is a 22210

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### different question versus is this an accurate 1 

### price for getting that level of efficacy, which 2 

### is also a different question from the point you 3 

### made earlier whether it's technologically 4 

### feasible in all different design and shapes. 5 

### So what is it that -- I mean, if we ran a 6 

### sensitivity with lower numbers, guess what it's 7 

### going to come out as? I've never had anyone tell 8 

### me at a public meeting our numbers are too low, 9 

### though. 10 

### MR. GATTO: So, no, I appreciate that. 11 

### MS. ARMSTRONG: Especially a 12


### manufacturer. 13 

### MR. GATTO: No, no. And I think I said 14 

### at the beginning that this is a place -- and 15 

### we've been in this dialog all over the place on 16 

### the regulatory side and with EPA, it is moving in 17 

### the direction everyone wants. You won't get a 18 

### lamp manufacturer to really loudly disagree with 19


### that. 20 

### I think to answer your questions if I 21 

### understood them right, I think that that -- for 22211

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### CSL-5 I think that number might be high, or it 1 

### might be right about right. Price learning is 2 

### very tough in LED, especially because you're 3 

### going to start to hit a cap to that and I don't 4 

### know where it is. 5 

### I think on the price sensitivity what I 6 

### was aiming for was the consumer's willingness to 7 

### pay. To your point it's, would they pay 8 

### regardless of whether they're going to get their 9 

### money back or not. Would they pay that much? 10 

### And I think that's separate from -- 11 

### MS. ARMSTRONG: Right. 12 

### MR. GATTO: -- whether or not the product 13 

### price is accurate. 14 

### MS. ARMSTRONG: Right. 15 

### MR. GATTO: I just, I think my challenge 16 

### Ashley is, I don't know how to answer it. I 17 

### don't know what CSL really 4 and 5 are going to 18 

### be cost wise. 19 

### MS. ARMSTRONG: So let's just assume that 20 

### our -- I mean, maybe this is a bad assumption, 21 

### but for the purposes of this discussion let's 22212

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### assume these prices are somewhat accurate, or at 1 

### least the best guess that we can collectively 2 

### come up with, right? It would be helpful for the 3 

### department to know at these price levels, 4 

### especially once you back out the cost of the full 5 

### light kit, what percentage at each level do you 6 

### think consumers would actually turn away? 7 

### In other words, where would their 8 

### purchasing decision be different? And why? Is 9 

### it 25 percent? Is it 50 percent? Sure, we can 10 

### run that analysis. It's not in the LCC but we 11 

### can run that analysis. It's just a matter of 12 

### what is it that you want to see? 13 

### MR. GATTO: So, Dave Gatto, Westinghouse. 14 

### I think that we can probably provide some 15 

### feedback. But it's a challenge. We've been 16 

### talking about this with fans since the beginning, 17 

### that there is a price point within which the bulk 18 

### of the volume is going to either happen or not. 19 

### So I think on higher end products that price 20 

### sensitivity doesn't exist. But at the lower 21 

### price points, not necessarily lower efficacy, 22213

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### whether you're talking fan or light kit, there is 1 

### a price consumers expect to pay, and above that 2 

### they won't. And I don't know that we really have 3 

### a -- I'm looking around the room here. We might 4 

### have some ideas. We might be able to get some 5 

### feedback from some of our retail partners. I 6 

### don't know that we have that today. And we will 7 

### try to give that in the feedback because I agree 8 

### with you. If we can provide it, it will be good. 9 

### Just, your budget is bigger than ours. 10


### MR. BROOKMAN: Clark. 11 

### MR. LINSTONE: Clark Linstone from Lamps 12 

### Plus. I think there's basically, at least the 13 

### way we sell this product, is if it meets an 14 

### appropriate price that light kit kind of offsets 15 

### having a light fixture. And I think we kind of 16 

### know how ceiling fans and kind of the majority of 17 

### ceiling fans, the various bands in terms of 18 

### pricing, it's more towards the lower end. 19 

### So we're basically saying here is that if 20 

### we assume roughly about $100 price point on the 21 

### CSL-5 category, that's going to make it a higher 22214

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### end fan in terms of cost, and therefore you may 1 

### see some just going to buy a lower cost light 2 

### fixture in place of a ceiling fan with a light 3 

### kit. 4 

### But I mean, we don't have data to give 5 

### you at this point in time on that. 6 

### MR. BROOKMAN: Okay. Thank you. That's 7 

### helpful. Dick. 8 

### MR. UPTON: I don't know where it comes 9 

### in. But you might have a lifetime of saving on 10 

### energy cost that says to the consumer, this is a 11 

### good value. But at the lower end the opening 12 

### price becomes a significant factor, not the end 13 

### price of how much energy I'm saving. It's how 14 

### many dollars have I got in my pocket today or on 15 

### my credit card today that I can afford to pay. 16 

### And that's going to have a significant impact as 17 

### well, and I don't know if we can get arms around 18 

### that issue at all. But it's got to be taken into 19


### account. 20 

### MR. BROOKMAN: And Dave, you had an 21 

### additional comment? 22215

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### MR. GATTO: No, I just wanted -- 1 

### MS. ARMSTRONG: You got it. Go again. 2 

### MR. GATTO: Dave Gatto, Westinghouse. So 3


### I wanted to make sure that I answered all of 4 

### Ashley's points there. 5 

### MS. ARMSTRONG: And, Doug, to your point, 6 

### I mean, our model has the capability of analyzing 7 

### those issues. It's just a matter of what 8 

### assumptions do you make about -- or what 9 

### sensitivities you run about the impact of 10 

### different prices to consumer choices. And like I 11 

### said, we can guess all day, as could you guys. 12 

### If you have some sense about what's 13 

### acceptable we'd obviously be willing to -- 14 

### MS. KANTNER: And this is discussed in 15 

### the shipments analysis which is coming up, where 16 

### there was consumer sensitivity to price taken 17 

### into account. 18 

### MR. BROOKMAN: Tim? 19 

### MR. FLANNERY: So, I have a -- this is 20 

### Tim Flannery. I have a question here. The 27.50 21 

### that we're looking at here, looking at the 22216

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### equation for total cost is the product cost plus 1 

### sales tax. So am I assuming this correctly that 2 

### that's the retail price is 27.50 for a -- 3 

### MS. KANTNER: That's the retail price for 4 

### the fraction of the CFLK that the lamps and the 5 

### sockets represent. 6 

### MR. FLANNERY: So that's just the retail 7 

### price for what the module would be? 8 

### MS. ARMSTRONG: We assumed 15 percent, 9 

### right? So that's 15 percent, the retail price, 10 

### 15 percent of the retail price of the ceiling fan 11 

### light kit. Fair enough? 12 

### MS. KANTNER: Or it sounds like maybe 30 13 

### percent at some of the LED levels. 14 

### MR. FLANNERY: Yeah, there's likely some 15 

### lamps by -- 16 

### MS. ARMSTRONG: Something like that. 17 

### MR. BROOKMAN: Mark, please. 18 

### MS. ARMSTRONG: Multiply by four and get 19 

### your ceiling fan light kit. 20 

### MR. FLANNERY: Okay. 21 

### MS. ARMSTRONG: Close enough. Round 22217

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### numbers. 1 

### MR. FLANNERY: Well, that's -- if that's 2 

### not enough we'll be -- well. I don't know that I 3 

### agree with the equation. 4 

### MR. BROOKMAN: Clark, go ahead. 5 

### MS. ARMSTRONG: What would you change? 6 

### MR. LINSTONE: Well, no, I think the 7 

### point earlier this morning was the fact that the 8 

### 15 percent, I don't think the feeling was that 9 

### represented -- because we're just talking about 10 

### the light kit, how much the LED cost of the total 11 

### light kit. And that's where, throwing a number 12 

### around, we thought maybe 30 percent was a more 13 

### reasonable number. But if you get to as high as 14 

### 27 then obviously you're back down to $100, you 15 

### know, approximate cost of a light kit. And 16 

### that's where, you know, I think it could have a 17 

### very significant affect on sales. 18 

### But you know, that's how we kind of 19 

### backed up into this number. So. 20 

### MR. BROOKMAN: Okay. Thank you. Okay. 21 

### MS. KANTNER: Okay. So there's a couple 22218

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### of items for comment. For this preliminary 1 

### analysis DOE assumes that the lifetime of CFLKs 2 

### is equal to the lifetime of a ceiling fan. DOE 3 

### invites comment, input, and data on the lifetime 4


### of CFLKs. 5


### MR. BROOKMAN: Dave. 6 

### MR. GATTO: Dave Gatto, Westinghouse. 7 

### Yeah, we agree. The lifetime of the light kit is 8 

### going to be tied to the fan. If they replace the 9 

### fan they're not going to -- very unlikely that 10 

### they would keep the light kit and attach it to 11


### another fan. 12


### MR. BROOKMAN: Yeah. 13 

### MS. KANTNER: DOE also requests comment 14 

### on whether and which components and light kits 15 

### with solid state lighting components that are 16 

### inseparable from the CFLK are designed to be 17 

### replaceable by the consumer. Specifically DOE 18 

### requests information on which components may be 19 

### easily removable and replaceable by consumers and 20 

### how such replacements would be performed. 21 

### MR. GATTO: Dave Gatto, Westinghouse. I 22219

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### think long-term we don't know, is what came up 1 

### earlier. For today, and you guys may want to 2 

### weigh in, our limited assortment of LED SSL light 3 

### kits are integrated and not replaceable. 4 

### MR. BROOKMAN: Okay. Additional thoughts 5 

### on this, David? 6 

### MR. TURNER: David from Hunter. Ours has 7 

### a serviceable driver that can be replaced. I 8 

### don't know if that still means it's inseparable 9 

### or not, but -- 10 

### MR. BROOKMAN: But so does that mean it's 11 

### integrated? 12 

### MR. TURNER: It's integrated but if the 13 

### driver was to fail it can be replaced, but the 14 

### LEDs would stay. 15 

### MR. BROOKMAN: Oh, I see. Okay. 16


### MS. KANTNER: Thanks. DOE welcomes 17 

### comments on its approach to not including 18 

### installation costs on the LCC analysis. Again, 19 

### the reasoning for this is we assumed that it was 20


### the same at each CSL. 21


### MR. BROOKMAN: Dave. 22220

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### MR. GATTO: Yeah, Dave Gatto, 1 

### Westinghouse. Yeah, we agree with that. 2 

### MS. KANTNER: Okay. DOE requests comment 3 

### and any relevant data on the disposal cost 4 

### assumptions for different light source 5 

### technologies using CFLKs. We touched on this 6 

### earlier so there may -- unless there's any 7 

### additional. 8


### MR. BROOKMAN: We covered that. Yeah. 9 

### MS. KANTNER: Okay. 10 

### MR. BROOKMAN: Any additional comments on 11 

### disposal costs? We did cover that. Okay. 12 

### MS. KANTNER: DOE requests comment on the 13 

### overall methodology and assumptions, as well as 14 

### relevant data on the market distributions of 15 

### CFLKs by CSL for each product class. And we 16 

### discussed this a little bit as well, but I don't 17 

### know if there are any other comments on that. 18 

### MR. BROOKMAN: Yes, Marianne. 19 

### MS. DIMASCIO: This is Marianne Dimascio 20 

### from ASAP. I was just wondering what the 21 

### distribution was today for CSL-3, 4, and 5, for 22221

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### LEDs. Is that not -- 1 

### MR. GANESHALINGAM: Hello. This is Mohan 2 

### Ganeshalingam at LBNL. Yeah, I believe it's a 3 

### couple percent at CSL-3. 4 

### MS. DIMASCIO: And nothing at 4 and 5? 5 

### MR. GANESHALINGAM: And nothing at 4 and 6 

### 5. That's right. 7 

### MR. BROOKMAN: Okay. Thank you. 8 

### MR. TURNER: Is the last point, Issue 32, 9 

### is that referring back to the market efficiency 10 

### distribution in compliance year? 11


### MS. KANTNER: Yes. 12 

### MR. TURNER: And, Dave, you commented on 13 

### it when we hit that point, but was there 14 

### areasoning for skipping over -- well, three is a 15 

### 0.0 and four is .2 percent of the market share. 16


### Was there a reason those were left out almost 17 

### totally, or -- 18 

### MS. KANTNER: Well, this was based on the 19 

### projected efficiency of LEDs in the compliance 20 

### year, which was based on an SSL report. 21 

### MR. TURNER: Okay. All right. 22222

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### MR. BROOKMAN: Anything additional on 1 

### these three comment boxes? Okay. 2 

### MS. KANTNER: And up next, Mohan 3 

### Ganeshalingam will present the shipments and NIA 4 

### analysis. 5


### MR. GANESHALINGAM: Hello. Good 6 

### afternoon, everyone. I am Mohan Ganeshalingam 7 

### from LBNL and I'll be discussing the shipments 8 

### and NIA, or National Impact Analysis. 9 

### So, starting with the shipments, the 10 

### purpose of the shipments analysis is to project 11 

### future shipments of CFLKs over a 30 year analysis 12 

### period, which in this case was from 2019 to 2048. 13 

### DOE projects shipments in both the no 14 

### standards case, and under potential amended 15 

### energy efficiency standards. 16 

### The total CFLK shipments are 17 

### disaggregated into product classes and CSLs over 18 

### time. To estimate total shipments of CFLKs DOE 19 

### developed a model to estimate low volume ceiling 20 

### fan shipments and assumed 88 percent of those low 21 

### volume ceiling fans are then sold with a CFLK. 22223

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### So many of the inputs I'll be discussing in the 1 

### next few slides will actually be discussed 2


### tomorrow as well. 3 

### But then we take those total shipments 4 

### for low volume ceiling fans and scale by 88 5 

### percent. 6 

### So DOE's model uses a stock accounting 7 

### method, calibrated to historical shipments data. 8 

### DOE identifies market segments that drive 9 

### shipments over time and projects their 10 

### contributions to the total shipments. 11 

### In this analysis DOE accounted for 12 

### shipments due to product replacements. Those 13 

### being people who have ceiling fan light kits, and 14 

### that ceiling fan light kits dies and they go out 15 

### and buy, I guess in this case both a new ceiling 16 

### fan and ceiling fan light kit. 17 

### And we then also account for shipments 18 

### that go into new construction. And also 19 

### shipments to installations of existing buildings 20 

### that did not previously have a CFLK but now do. 21 

### So total shipments are then disaggregated 22224

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### by product class and CSL using a consumer choice 1 

### model to project purchasing decisions for each 2 

### year in the analysis period. 3 

### So this table here shows the inputs that 4 

### go into DOE's shipments models, and the data 5 

### sources associated with that input. So 6 

### replacements, DOE relied on historical shipments 7 

### of low volume ceiling fans from appliance 8 

### magazine, the NPD group, and estimates from 9 

### energy star. DOE then estimated the number of 10 

### units that fail in each year by applying a 11 

### retirement function based on the product lifetime 12 

### to develop the number of shipments in previous 13


### years. 14 

### And again, the lifetime that's being 15 

### assumed here is the lifetime of the ceiling fan, 16 

### which we assume is a good proxy for the lifetime 17


### of the CFLK. 18 

### For new construction DOE used estimates 19 

### for new housing starts from the annual energy 20 

### outlook, 2014, and assumed that 73 percent of new 21 

### houses were installed with ceiling fans with each 22225

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### average installation having about 3.1 fans per 1 

### home. These numbers come from an analysis of 2 

### RECS 2009. So that was the estimates for the 3 

### number of ceiling fans. 4 

### To get the number of CFLKs that go into 5 

### new construction we assumed 88 percent of those 6 

### installations would have a CFLK. 7 

### So for existing buildings we did an 8 

### analysis where we looked at the increasing 9 

### fraction of households that had ceiling fans from 10 

### RECS 1993 to RECS 2009, and noticed that there 11 

### was an increasing fraction of households with 12 

### ceiling fans. So we performed a fit to that and 13 

### found that the rate was increasing, but the rate 14 

### of increase was slowing. So we put a cap at a 15 

### total of -- at a market saturation of 75 percent 16 

### of households would have a ceiling fan. 17 

### And again, we assumed that 88 percent of 18 

### those installations would have a ceiling fan 19 

### light kit. 20 

### And for the market share, we used model 21 

### counts from in-store visits and online retailers 22226

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### to get an idea of what the current efficiency 1 

### distribution looks like and also the breakdown by 2 

### product class. 3 

### MR. GATTO: Dave Gatto, Westinghouse 4 

### Lighting. Just one quick question. 5 

### So you put a cap of 75 percent 6 

### saturation. Where is the market -- where is the 7 

### market today? So you've got an incremental 8 

### increase up to 75 percent -- 9


### MR. GANESHALINGAM: Yeah. 10 

### MR. GATTO: -- where you've capped it, 11 

### but where is it from the -- 12 

### MR. GANESHALINGAM: So in 2009 it was at 13 

### 73 percent. 14 

### MR. GATTO: Okay. So you're projecting 15 

### an increase in saturation, but then it's going to 16 

### whittle off? 17 

### MR. GANESHALINGAM: That remains. Yeah. 18 

### MR. GATTO: Okay. Thank you. 19


### MR. GANESHALINGAM: Yeah. Are there 20 

### other questions? 21 

### (No audible response.) 22227

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### MR. GANESHALINGAM: Okay. So, this is a 1 

### schematic of our shipments model showing the 2 

### market segments that feed into our total 3 

### shipments, so as I mentioned on the previous 4 

### slide, we have replacements, new construction, 5 

### and installations, and new installations. We 6 

### aggregate that to come up with the total 7 

### shipments, and then we use the consumer choice 8 

### model to disaggregate those into shipments by 9 

### product class and CSL. And we do this for each 10 

### year in our analysis period. 11 

### So a few more assumptions that go into 12 

### our model. As I previously mentioned, 88 percent 13 

### of low volume ceiling fans were packaged and sold 14 

### with CFLKs. Based on an analysis of market data 15 

### we are again assuming that CFLKs sold alone are a 16 

### negligible fraction of total shipments. We 17 

### assume that CFLKs were not purchased with high 18 

### volume ceiling fans. 19 

### The market share by product class for 20 

### 2012 was roughly .5 percent going to Externally 21 

### Ballasted/Driven and 99.5 percent going to the 22228

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### All Other CFLKs. And we estimated LED 1 

### penetration and also the pricing of LEDs using a 2 

### solid state lighting report that DOE put out in 3


### 2012. 4 

### So this brings us to an issue, Issue No. 5 

### 36, sector breakdown by CFLK usage by sector. 6 

### DOE requests comment on its assumed breakdown of 7 

### CFLK usage as 95 percent in the residential 8 

### sector and five percent commercial sector. So 9 

### these are fractions that get used in our 10 

### shipments model to keep track of which shipments 11 

### are staying in residential and which are in 12 

### commercial. 13


### MR. BROOKMAN: Dave. 14 

### MR. GATTO: Dave Gatto, Westinghouse. I 15 

### think from a percentage standpoint that's 16 

### probably accurate. I do think we talked about 17 

### this before. There is more commercial use in 18 

### like hospitality. But we still kind of, we 19 

### consider them residential applications, and they 20 

### would have similar hours of use to residential 21 

### because if it's in a hotel room it's not in a 22229

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### commercial space where it's on all the time. 1 

### The LED penetration estimate with the 2 

### incursion curve, you mentioned the DOE 2012 3 

### study, and I believe that focused on general 4 

### service medium base. So within the Caliper, more 5 

### recent Caliper, particularly now a lot of this 6 

### was MR-16 and pin-based, but you're also seeing 7 

### in the other product types, the same studies 8 

### suggest that the adoption rate and the 9 

### performance improvement and price learning are 10 

### slower for non-integral service lamp. 11 

### So it's not a huge difference, but when 12 

### you get into small profile the general service is 13 

### moving at a faster pace than any other lamp type 14 

### for a solid state. So I'm not sure if that's 15 

### built in or whether or not you use basically the 16 

### 2012 report as is. 17


### MR. GANESHALINGAM: Yeah. That's 18 

### actually our next slide. But I guess before we 19 

### move on, were there any other comments regarding 20 

### CFLK usage in different sectors? 21 

### MR. BROOKMAN: Ninety-five percent 22230

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### residential. No additional comments? Okay. 1 

### MR. GANESHALINGAM: Okay. And that leads 2 

### me perfectly into our next couple slides 3 

### regarding our treatment of LEDs using the SSL 4 

### report. 5 

### So, the price learning. So the retail 6 

### price associated with each CSL will impact 7 

### projected market shares over the course of our 8 

### shipments analysis and is accounted for in DOE's 9 

### consumer choice model. DOE accounts for price 10 

### learning in its estimate of lamp prices over the 11 

### analysis period. Price learning is the 12 

### systematic decrease in manufacturing cost due to 13 

### production experience. The idea here being that 14 

### as the cumulative number of units produced 15 

### increases manufacturers are able to reduce 16 

### manufacturing costs via optimized manufacturing 17 

### methods and economies of scale. 18 

### For this particular rulemaking we only 19 

### assumed that CFLKs that use solid state lighting 20 

### would undergo price learning. And so this is 21 

### adopted from the SSL report. So it actually uses 22231

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### the same rate as the SSL report. Here, in this 1 

### curve in red, it's normalized so on the Y axis is 2 

### the lamp price normalized to the 2019 price. And 3 

### on the X axis is just the time evolution of that 4 

### index. And the SSL report goes up to 2030 and 5 

### afterwards we just sort of cap it at the 2030 6 

### value. So between 2019 to 2030, it drops; the 7 

### price drops in half. 8


### MR. BROOKMAN: Dave. 9 

### MR. GATTO: Dave Gatto, Westinghouse 10 

### Lighting. First off, yes, I agree that only LEDs 11 

### will continue to undergo cost reduction. CFLs, 12 

### it's a mature product. There really isn't a 13 

### whole lot of development to improving or reducing 14 

### the cost. We're all shifting our R&D and our 15 

### development expense to LED. 16 

### I don't know that I could give you an 17 

### alternate curve to use, and I'm not sure that 18 

### this curve isn't appropriate because quite 19 

### honestly LED has been -- you know, it always 20 

### surprises us. I would just point out that, again 21 

### that curve is using an analysis on a medium base 22232

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### socket. I think 800 lumens, 60 watt equivalent, 1 

### which is not typically the lamp that goes into 70 2 

### what percent of the current light kits. 3


### MR. GANESHALINGAM: Thanks. 4 

### MR. BROOKMAN: Additional comments? What 5 

### about the scale of price decline? Dave. 6 

### MR. GATTO: Dave Gatto, Westinghouse. I 7 

### guess I have a question. So that 2.5 is just a 8 

### normalized -- you're just using that as a 9 

### baseline for -- that's not a specific lamp. 10 

### That's a, this is our baseline, then over this 11 

### time frame that this is what we expect the price 12 

### decline to look like. 13 

### MR. GANESHALINGAM: That's correct, yeah. 14


### MR. GATTO: Yeah. 15 

### MR. GANESHALINGAM: It's just an index. 16 

### MR. GATTO: I think that it's as good as 17 

### any other. You were using the six percent 18 

### learning -- 19 

### MR. GANESHALINGAM: Yeah, that's roughly, 20 

### right. 21 

### MR. GATTO: Honestly, it might be faster 22233

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### than that in general service. It might be 1 

### slightly slower than that with some of the 2 

### specialty sizes and shapes and bases, but it's as 3 

### good a number as any. I wouldn't argue it. 4 

### MR. BROOKMAN: Okay. 5


### MR. GANESHALINGAM: Great. 6 

### MR. BROOKMAN: Thanks for the bit of 7 

### validation. Okay. 8


### MR. GANESHALINGAM: So next we talk about 9 

### LED incursion. So this is how LEDs are actually 10 

### coming in to the market place for CFLKs. We 11 

### again use the projections, or we -- well, we 12 

### started with the projections from the SSL report. 13 

### There they have LEDs coming in at 2010. But from 14 

### our observations of the CFLK market we noticed 15 

### that there was a little bit of a time lag between 16 

### what was happening for general service lamps and 17 

### what was happening in CFLKs. So we actually 18 

### shifted the plot along the X axis to start in 19 

### 2012. But we kept the actual sort of the way it 20 

### diffuses into the market place the same as that 21 

### in the SSL report. 22234

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### And so by the beginning of our analysis 1 

### period in 2019 we're at about 26, 27 percent LED. 2 

### Which I guess I'll throw out there is that -- if 3 

### anyone has any comment on that. 4 

### MR. GATTO: Dave Gatto, Westinghouse. 5 

### Just that it's as good a guess as any. I do 6 

### appreciate, and it sounds like you recognized 7 

### that the CFLK adoption rate is going to trail the 8 

### general service lamp. It just, it's partly 9


### because of what Dave Turner and some of the other 10 

### guys said, that the fan manufacturers are really 11 

### relegated to what's available to them. But it's 12 

### also kind of a mature product category in and of 13 

### itself and it requires design changes to 14


### accommodate. 15 

### MR. BROOKMAN: Okay. Thanks. 16


### MR. GATTO: Thanks. 17 

### MR. BROOKMAN: David. 18 

### MR. TURNER: Is this in outside of fan 19 

### regulation outside of fan regulation, or light 20 

### kit regulation? I'm sorry. 21 

### MR. GANESHALINGAM: Well, this happens 22235

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### regardless. This is just sort of the expected 1


### rate. 2 

### MR. TURNER: Regardless of what this -- 3 

### outside of a performance standard being put into 4 

### place. 5 

### MR. GANESHALINGAM: That's correct. This 6 

### is just the projected rate at which LEDs will 7 

### come into CFLKs. 8 

### So a couple of issues for comment. CFLK 9 

### distributions by technology and sector. So DOE 10 

### assumed that the distribution of CFLKs by light 11 

### source technology in the commercial sector is the 12 

### same as the light source technology distribution 13 

### in the residential sector. DOE requests comment 14 

### and input regarding this assumption. 15


### MR. BROOKMAN: Dave. 16 

### MR. GATTO: Dave Gatto, Westinghouse. 17 

### Same thing I said earlier. I think the 18 

### commercial segment is small. So it's as good a 19


### guess as any. 20


### MR. GANESHALINGAM: And on to the next 21 

### issue, LED penetration in the CFLK market. I 22236

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### think we touched a little bit on this. But DOE 1 

### estimated that market penetration of LEDs into 2 

### the CFLK market has a bass diffusion curve. DOE 3 

### requests comment on this approach. 4 

### Okay. So that brings us to the consumer 5 

### choice model. DOE used a consumer choice model 6 

### projecting market shares for each product class 7 

### at each efficiency level. Typically the consumer 8 

### choice model estimates how consumers make a 9 

### choice based on their sensitivity to first cost 10 

### and operating cost of available options. 11 

### However, in the case of ceiling fan light 12 

### kits the consumers of the CFLKs aren't the ones 13 

### who are choosing the lamp. The lamp is actually 14 

### packaged by the manufacturer, so this has to be 15 

### taken into account in our modeling that it's the 16 

### manufacturer who is purchasing the lamp. 17 

### So the consumer choice model for CFLKs 18 

### works as followed. So first, market share is 19 

### apportioned to LED levels based on that incursion 20 

### curve which we saw on a previous slide. The 21 

### remaining market share is then split between the 22237

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### other CSLs, assuming manufacturers will choose 1 

### the lowest first cost lamp option for a given 2 

### socket type and lamp technology. 3 

### And then the market share for that given 4 

### CSL is divided evenly between those two scenarios 5 

### from the engineering data, with being the lamp 6 

### and the fixture replacement scenarios. 7 

### In a standards case, options that do not 8 

### meet the standard are eliminated and 9 

### probabilities are recalculated, sort of going 10 

### through this model in an iterative fashion. 11 

### So, DOE expects that a relative increase 12 

### in price for the average CFLK due to a standard 13 

### will have an impact on shipments. That being 14 

### that, an increase in price will decrease 15 

### shipments. DOE estimates this impact using a 16 

### price elasticity. So that's the impact of a 17 

### ceiling fan light kit standard on ceiling fan 18 

### light kit shipments. 19 

### Since CFLKs are packaged with ceiling 20 

### fans and a ceiling fan standard is also being 21 

### considered, we also took into account the impact 22238

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### of a ceiling fan standard on ceiling fan light 1 

### kit shipments and includes this in our analysis. 2 

### MR. BROOKMAN: David. 3 

### MR. TURNER: So regarding the relative 4 

### price elasticity, I know we're talking about a 5 

### price sensitivity analysis, and can you kind of 6 

### go into a little bit more about the price 7 

### elasticity and how it was determined how it would 8 

### affect shipments? 9 

### MR. GANESHALINGAM: Right. So the price 10 

### elasticity relates the fractional increase -- a 11 

### fractional increase in price will lead to a 12 

### fractional decrease in shipments. And so that's 13 

### related to another using an elasticity of demand. 14 

### That elasticity of demand in this case was 15 

### estimated from data from I believe it's 16 

### refrigerators and dishwashers. 17 

### And that elasticity is used in other 18 

### rulemakings as well. We didn't have any data 19 

### specific to ceiling fans in order to estimate 20 

### what the price elasticity would be in this case. 21 

### If manufacturers have that data it would be very 22239

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### useful to come up with a price of elasticity 1 

### specific to this product. 2 

### MR. LINSTONE: This is Clark Linstone, 3 

### Lamps Plus. I mean, I think my feeling in terms 4 

### of just looking at this product versus say 5 

### refrigerators, is there is probably more 6 

### variability I guess I would say, in terms of need 7 

### in a household. I mean, there are options, there 8 

### are different ways as I said, you know, some 9 

### people use these ceiling fans as a primary light 10 

### source in a room. So I think there would be a 11 

### higher elasticity than say refrigerator which 12 

### might be more of a, you know, required product in 13


### a home. 14 

### MR. BROOKMAN: Okay. Thank you. 15 

### MR. CYMBALSKY: This is John from DOE. 16 

### So I think tomorrow is where I think this 17 

### argument has been pretty vocal on the elasticity 18 

### with ceiling fans. And I know we're bringing it 19 

### up here because obviously these kind of go 20 

### together and, you know, I urge everyone to look 21 

### at -- when we get there tomorrow. Maybe a little 22240

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### homework for tonight. Look at the marginal cost 1 

### for the different efficiency levels considered 2 

### for ceiling fans, before we make statements about 3 

### what would happen to shipments. So I just throw 4


### that out there. 5 

### MR. BROOKMAN: Okay. 6 

### MR. GANESHALINGAM: Okay. Thank you. So 7 

### these are our results for the two product classes 8 

### being considered. On the left we have Externally 9 

### Ballasted/Driven, and on the right All Other 10


### CFLKs. 11 

### So these plots show both the shipments in 12 

### the no-standard case and with a given standard in 13 

### place. In cases where there's little difference 14 

### between shipments projections the results of the 15 

### higher standard overwrite the lower standard. 16 

### One thing to take note of is the decline 17 

### in Externally Ballasted/Driven over time, because 18 

### we actually expect LED incursion to happen and to 19 

### that product class as well, and to move market 20 

### share over to the All Other CFLK product class. 21 

### MR. BROOKMAN: Yes, Dave. 22241

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### MR. GATTO: So, on the All Other -- first 1 

### off, yeah, I agree with the Externally Ballasted 2 

### in the way that product class currently exists 3 

### with a pin-based fluorescent is going to 4 

### effectively go away. It's marginalized now and 5 

### LEDs will replace it. Whether that's as a 6 

### complete fixture or not it's, you know, still up 7 

### in the air. 8 

### But on All Other CFLKs you're projecting 9 

### ongoing increases in shipments at basically 10 

### evenly at all of the CSLs. But even if you 11 

### consider a fractional price elasticity you've got 12 

### some pretty nonfractional numbers in there. I'm 13 

### not sure how they didn't impact the shipment 14 

### analysis because it really looks like -- now I 15 

### know that this is looking out past 2025 and 16 

### you've got price learning in there. But you may 17 

### not have any ceiling fan light kits left in the 18 

### market place by that point if the price is too 19 

### high. So how did you account for that. 20 

### And I don't mean that facetiously, and 21 

### John, I agree with you, tomorrow is a good place 22242

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### to talk about it. I just, I'm having trouble 1 

### with the math. 2


### MR. GANESHALINGAM: Sure. So there are a 3 

### couple points. One, as you pointed out, price 4 

### learning is taken into account here. And so for 5 

### CSLs 3 through 5 there will be a drop in the 6 

### price which then -- the drop in price is lamp, 7 

### which then will not affect the shipments as much 8 

### in that case. 9 

### The other thing to keep in mind is I 10 

### mentioned that the price elasticity relates the 11 

### drop in shipment -- the fractional drop in 12 

### shipments to the fractional increase in price. 13 

### That price is the price of a ceiling fan plus the 14 

### ceiling fan light kit, because that's what a 15 

### consumer is purchasing. 16 

### MR. GATTO: So, Dave Gatto, Westinghouse. 17 

### John, I apologize. That's what you were saying a 18 

### minute ago and I missed it. This is the all-in 19 

### inclusive. So I'm sorry, I really had CFLKs in 20 

### my head. So that makes more sense in that what 21 

### you're saying is the total price might not change 22243

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### as much. I'm not sure if I agree with that, but 1 

### I can understand that that would drive this 2


### number. 3 

### MR. GANESHALINGAM: Okay. Okay. Now we 4 

### turn to the National Impact Analysis, or the NIA. 5 

### The purpose of the NIA is to estimate the 6 

### national energy savings and consumer net present 7 

### value of the potential standard. This is done by 8 

### developing an annual series of national energy 9 

### and economic impacts for the no standards case 10


### and standards cases. 11 

### Inputs to the NIA come from the LCC and 12 

### results from shipments. DOE reports the total 13 

### energy saved in a standards case with respect to 14 

### the base case and the economic impact as change 15 

### in consumer national net present value, which is 16 

### reported in constant year dollars. 17 

### The time value of money is accounted for 18 

### through defined discount rates when reporting the 19 

### net present value, or NPV for short. 20 

### So, here is a schematic of the NIA 21 

### process. As I mentioned, inputs from the 22244

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### shipments and LCC are used to calculate national 1 

### energy savings and economic impacts. Total 2 

### energy savings are aggregated over the analysis 3 

### period and reported in quads. Economic impacts 4 

### from a change installed cost and operating cost 5 

### due to a standard are discounted and then 6 

### aggregated to give the net present value. 7 

### All economic results are reported in 2013 8


### dollars. 9 

### The analysis computes NES and NPV for all 10 

### products shipped under the analysis period. It 11 

### includes the full energy savings realized over 12 

### the lifetime of those products. So the analysis 13 

### includes the impacts of shipments from 2019 to 14 

### 2048, but will include operating cost savings and 15 

### energy savings for CFLKs shipped over that period 16 

### that could live up to 2077. So that just means 17 

### you could have a product that's shipped in 2048, 18 

### but because it has a lifetime that could be as 19 

### long as 30 years, we're still accounting for any 20 

### energy savings that could happen in that 30 21


### years. 22245

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### So this is a slide just sort of showing 1 

### all of the inputs that go into the NIA. Total 2 

### installed cost is the per-unit annual weighted 3 

### average value as a function of CSL. That comes 4 

### from the LCC. Repair and maintenance costs. In 5 

### this case, we again took into account relamping, 6 

### similar to what was done in the LCC, except we do 7 

### it for each year, each of the CFLKs year's 8 

### shipments. 9 

### We have the annual energy use, which is 10 

### the per-unit annual weighted energy use as a 11 

### function of CSL, which comes from the energy use 12 

### analysis. 13


### We have the base case and standards case 14 

### efficiency distributions which are output from 15 

### our consumer choice model. 16 

### Energy prices are the average national 17 

### forecasted prices that come from AEO 2014. 18 

### Full fuel cycle, which is a multiplier 19 

### used on primary fuels to get a full accounting of 20 

### energy savings. Discount rates, we use seven 21 

### percent and three percent real, per OMB as 22246

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### regulatory analysis guideline. And the present 1 

### year used in this analysis is 2014. 2 

### MR. CYMBALSKY: So this is John from DOE. 3 

### So before we talk, Doug Smith had a question 4 

### about average versus marginal prices. And I 5 

### apologize, my head was stuck on a rule that we 6 

### used marginal prices on because it was a very 7 

### peaky end-use cooling in that case. 8 

### So in this case we did use the average 9 

### price because in our determination the lighting 10 

### use is not a peaky end-use, right? It's used 11 

### late at night when it's not peaking. So, we did 12 

### use average, and I think going forward we will 13 

### continue to use average. So I misspoke earlier 14 

### and I apologize. 15 

### MR. BROOKMAN: Okay. Thank you. 16 

### MR. GANESHALINGAM: So the national 17 

### energy savings are computed each year using this 18 

### equation. First we calculate the annual energy 19 

### consumption of stock for a given year in the base 20 

### case and compare that to the annual energy 21 

### consumption projected under a standard. We 22247

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### include a term to account for any rebound affect 1 

### that could happen due to a standard. And the 2 

### rebound affect accounts for increased usage after 3 

### moving to more efficient products. 4


### In our reference case we assumed a 5 

### rebound rate factor of one, which implies a 6 

### rebound rate of zero based on comments submitted 7 

### during the framework. 8 

### And finally we multiply by a full fuel 9 

### cycle multiplier to determine energy savings in 10 

### quads. 11 

### And this is just a little bit more 12 

### information on the full fuel cycle multiplier. 13 

### It's a measure of energy and greenhouse gases and 14 

### other omissions that is accounted for in the 15 

### standards rulemaking, and the methodology is 16 

### based on the calculation of an FSC multiplier or 17 

### conversion factor for the electricity used by 18 

### this product. And we have a TSD appendix which 19 

### goes into more detail. 20 

### This is our equation for calculating the 21 

### NPV, which is how we quantify economic impacts. 22248

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### The NPV is equal to the present value of savings 1 

### achieved under a standard, minus the present 2 

### value of added cost that that standard imposes. 3 

### Present values are computed for a three and seven 4 

### percent discount rate and reported in 2013 5 

### dollars. And again, we used 2014 as the year 6 

### that we discount to. 7 

### So these are some similar slides to what 8 

### we saw on the LCC. Just to reiterate that we 9 

### took into account lamp replacements. So we 10 

### included in the NIA, the cost to replace lamps 11 

### that failed during the lifetime of the CFLK. 12 

### Lamp replacement costs are the purchase cost of 13 

### replacement lamps in the year the lamps fail. 14 

### The CFLK lamps fail at the end of their average 15 

### service lifetime, which is the lamp lifetime 16 

### divided by the lamp's operating hours. Again, we 17 

### have the same criteria for those replacement 18 

### lamps. They must have the same base type as the 19 

### failed lamps, provide an equivalent lumen output 20 

### as the failed lamps, and the prices do not 21 

### include the CFLK manufacturer markup. And again 22249

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### we used that consumer choice model to determine 1 

### replacement lamps. 2 

### And again, I just wanted to reiterate 3 

### that not only does this come as a sort of cost 4 

### for actually having to replace the lamp, but it 5 

### could change the unit energy consumption 6 

### associated with that light kit as we move to a 7 

### different lamp. 8 

### Again, as similar to the LCC we take into 9 

### account residual value, which is the remaining 10 

### value of the surviving lamp at the end of the 11 

### CFLK lifetime. This is applied as a credit to 12 

### the NIA as it was in the LCC, and we calculate 13 

### the residual value for lamps based on the lamp 14 

### price and the year the CFLK is retired. 15 

### So, these are the results for the energy 16 

### savings reported in quads. And these are full 17 

### fuel cycle energy savings. Each of the different 18 

### columns are the different CSLs being considered 19 

### and the rows are the two product classes. 20 

### Couple things to point out. As you'd 21 

### expect, the values are mostly increasing as you 22250

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### go from CSL-1 to CSL-5, and the energy savings 1 

### between CSL-3 and CSL-5 are roughly the same 2 

### because of that evolution in LED efficacy that we 3 

### talked about earlier, that we actually expect 4 

### that by the beginning of the analysis period most 5 

### of the LED lamps have sort of moved to CSL-5. 6


### And these are the results for the net 7 

### present value. Again, the columns are the CSLs 8 

### and the rows are the product classes. And one 9 

### thing to keep in mind on this light is that the 10 

### results for the Externally Ballasted/Driven 11 

### product class are in millions of 2013 dollars, 12 

### and the results for All Other CFLKs are in 13 

### billions. 14 

### MR. BROOKMAN: Any comments on the 15 

### foregoing National Impact Analysis slides? 16


### Nathan? 17 

### MR. FRAMPTON: Is there any data that you 18 

### can give us on like total impact of national 19 

### energy consumption as a percentage? 20


### MR. GANESHALINGAM: Not off the -- can 21


### you -- 22251

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### MR. CYMBALSKY: So you mean, so how much 1 

### does 400 trills represent in -- yeah. So the 2 

### residential sector primary energy wise uses about 3 

### 18 quads. So, 400 trills and 18 quads in one 4 

### year. This is savings over 30 years, so. As far 5 

### as rules go, I mean, you know I'm looking more at 6 

### the NPV here. So it's over 2 billion of NPV to 7


### the consumer. 8 

### What you don't see here is manufacturer 9 

### impacts yet. So in the next phase of the 10 

### rulemaking you'll see some additional analysis 11 

### overlaid on top of this, and -- but you know, 2 12 

### billion is a pretty big number. 13 

### MR. BROOKMAN: Yes, Dave. 14 

### MR. GATTO: Dave Gatto, Westinghouse. 15 

### Yeah, thanks, John. And I was looking at these 16 

### the other night. And we haven't finished our 17 

### even discussion of comments yet. But in general, 18 

### if there's no additional savings but there's an 19 

### additional cost, that's something that DOE in the 20 

### past has been willing to look at when we're 21 

### talking about what the proposed rule establishes 22252

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### as the final CSL. I'm hoping/assuming, but I'm 1 

### kind of asking you since you and Lucy are here. 2 

### I would assume that DOE kind of sees it the same 3 

### way, that if we're going to -- we want to 4 

### maximize the savings with the least impact to 5 

### both consumers and manufacturing. 6 

### MR. CYMBALSKY: So what the statute says 7 

### is that we maximize energy efficiency that is 8 

### technologically feasible and economically 9 

### justified. So that is a little bit different 10 

### than what you just said, however there are 11 

### standards that maximize exactly what you said 12 

### because of other factors like manufacturer 13 

### impact. And so it could go either way. We're 14 

### not at that point yet. But the next rulemaking 15 

### document will get us to that point. 16 

### MR. BROOKMAN: Anthony Fryer has a 17 

### question. Anthony is joining us online. 18 

### Anthony, if you unmute your phone and speak 19 

### clearly we should be able to hear you in the 20



### room. 21 

### MR. FRYER: Thanks. Can you hear me 22253

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### okay? 1


### MR. BROOKMAN: Yes. 2 

### MR. FRYER: Okay. I've got a question on 3 

### the previous slide, the National Energy Savings 4 

### Estimate. 5 

### So in the TSD the .286 is listed out as 6 

### the impact of meeting CSL-0. And then there's an 7 

### additional column done measuring the impact from 8 

### CSL-0 to the other five CSLs. Based on that, 9 

### does that mean that these numbers do incorporate 10 

### savings associated with moving from the 11 

### incandescent technology that's now in that 12 

### product class? Or this purely savings from the 13 

### current product class standard level, the 45 14 

### lumens per watt level? 15 

### MR. GANESHALINGAM: So the energy savings 16 

### in this slide here represent going from no CFLK 17 

### standard to the standard listed in each of those 18


### columns. 19 

### MR. FRYER: Okay. So the savings from 20 

### the current product class 3 are incorporated in 21 

### this, they're just not used as a baseline? 22254

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### MR. GANESHALINGAM: So the way in which 1 

### it's broken out in the TSD of meeting CSL-0 would 2 

### be the impact of product class consolidation. 3 

### MS. KANTNER: This is Colleen Kantner. 4 

### To answer your question, yes, this does 5 

### incorporate the savings from going from no 6 

### standard to product class consolidation, as well 7 

### as the impact of going to the standard level 8 

### identified. 9 

### MR. BROOKMAN: Thank you, Colleen. 10


### MR. FRYER: Thanks. 11 

### MR. BROOKMAN: Anthony, do you have 12 

### additional questions? 13 

### MR. FRYER: That's it for now, thanks. 14 

### MR. BROOKMAN: Thank you. Okay. We are 15 

### finishing up on the net present value slides and 16 

### we're moving on. Any additional -- we're about 17 

### to move off preliminary -- or NIA. Any 18 

### additional questions, thoughts on NIA? 19 

### (No audible response.) 20 

### MR. BROOKMAN: Okay. On to preliminary 21 

### manufacturer impact analysis and to Aisha. 22255

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### MS. HUSAIN: This is Aisha from Navigant. 1 

### So I'll be talking about the methodology for the 2 

### manufacturer impact analysis, or the MIA. And I 3 

### just have one slide. 4 

### The main purpose of MIA is to 5 

### quantitatively assess the financial impact of 6 

### energy conservation standards on manufacturers of 7 

### ceiling fan light kits. This is done in three 8 

### phases. The first phase we do an industry 9 

### profile, and you probably will see that in the 10 

### preliminary TSD. The second and third phase 11 

### you'll see in the NOPR stage. 12 

### In the second phase DOE develops an 13 

### industry cash flow model called the Government 14 

### Regulatory Impact Model, or GRIM, to forecast 15 

### industry cash flows. In this phase DOE also 16 

### develops an interview guide for manufacturers to 17 

### facilitate discussions during manufacturer 18 

### interviews. 19 

### In the third phase manufacturers are 20 

### interviewed and information from the interviews 21


### and the GRIM model are used to conduct a 22256

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### quantitative assessment of impacts due to 1 

### potential standards. And manufacturer interviews 2 

### are also used to make qualitative assessments of 3 

### impacts. 4 

### The key output of the MIA is the change 5 

### in the industry net present value, or INPV, 6 

### resulting from potential standards. The MIA also 7 

### wanted to note attempts to identify any potential 8 

### manufacturer subgroups whose cost structure 9 

### differs significantly from industry average. 10 

### So an example would be a subgroup of a 11 

### subgroup would be small business manufacturers. 12 

### And finally, the MIA also attempts to 13 

### quantitatively and qualitatively examine other 14 

### nondirect financial impacts and these could 15 

### include a direct employment impact, a 16 

### manufacturing capacity impact, and a cumulative 17 

### regulatory burden impact on manufacturers of 18 

### ceiling fan light kits. 19 

### And so I do have another slide. So here 20 

### is the request for comments. So this basically 21 

### covers any comments you'd have on the methodology 22257

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### for the Manufacturer Impact Analysis. Also the 1 

### Regulatory Flexibility Act analysis which 2 

### basically evaluates the impact on small 3 

### businesses, any comments you might have on how 4 

### DOE proceeds with the manufacturer subgroup 5 

### analysis, and also if you have any comments on 6 

### the manufacturer markups that were used in this 7 

### preliminary analysis. 8 

### MR. BROOKMAN: Manufacturer markup being 9 

### 1.37 used in preliminary analysis, if that 10 

### interests you. Dave. 11 

### MR. GATTO: No, not that last one. I'm 12 

### not sure if I could even speak to that without 13 

### falling afoul of an antitrust violation. 14


### MR. BROOKMAN: Uh-huh. 15 

### MR. GATTO: But all I would say is that 16 

### Westinghouse is committed to participate in the 17 

### interview process again, and I'm encouraging my 18 

### counterparts who either did, to do it again or 19 

### who haven't, to do so, to make sure that you get 20 

### all the information you need for that analysis. 21 

### MR. BROOKMAN: Thank you. 22258

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### MS. HUSAIN: Thank you. 1


### MR. GATTO: Thanks. 2


### MR. CYMBALSKY: And on behalf of DOE I do 3 

### want to thank the manufacturers, and Dick stepped 4 

### out, I think. But I know Dick and others have 5 

### been, you know, very helpful in rounding up the 6 

### troops here, and you guys have been participating 7 

### very strongly in this rulemaking, and DOE really 8 

### appreciates it. I think without the good data 9 

### that you're supplying and information under the 10 

### NDAs, the rulemaking wouldn't be as strong as it 11 

### is. I know we've had issues in other rulemakings 12 

### and I think, you know, we don't have that here. 13 

### I think we have a good data set and I really 14 

### appreciate it. So, thanks. 15 

### MR. BROOKMAN: Thank you. There you see 16 

### the comment boxes related to general request for 17 

### comment on MIA and then Regulatory Flexibility 18 

### Act, and then manufacturer subgroup and once 19 

### gain, markups. Any additional comments on any of 20


### those four? 21 

### MR. TURNER: David Turner from Hunter 22259

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### Fan. Is the manufacturer markup, is that a 1 

### weighted across the three distribution channels 2


### of 1.37? 3 

### MS. HUSAIN: I don't think it was. Ali, 4 

### do you want to -- 5 

### MR. BROOKMAN: Ali. 6 

### MS. MCDONALD: I was just going to say 7 

### the production (indiscernible) -- 8 

### MR. BROOKMAN: We didn't hear that. The 9 

### mic did not pick that up. 10 

### MS. MCDONALD: Sure. This is Ali 11 

### McDonald. That's going from manufacturer 12 

### production costs to manufacturer selling price. 13 

### So it's prior to -- I guess it would be the same 14 

### across all three channels regardless of where it 15 

### was sold to. So that would vary based on the 16 

### channel it was sold at. 17 

### MR. TURNER: Say that again. It's going 18 

### from a manufacture production costs -- 19 

### MS. MCDONALD: From your cost to selling 20 

### price. 21 

### MR. TURNER: Okay. Okay. 22260

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### MR. BROOKMAN: Okay? Yes, Nathan. No? 1 

### You were just stretching. Okay. 2 

### Then we're moving on to the NOPR 3 

### analyses. 4 

### MS. KANTNER: So the NOPR analyses are 5 

### the analyses that will be conducted at the next 6 

### phase of the rulemaking. These include revising 7 

### the preliminary analysis, the life-cycle cost 8 

### subgroup analysis, the manufacturer impact 9 

### analysis, the employment impact analysis, the 10 

### utility impact analysis, the emissions impact 11 

### analysis, the monetization of emissions 12 

### reductions and benefits, and the regulatory 13 

### impact analysis. 14 

### This slide provides some details on what 15 

### each of these is supposed to represent. The 16 

### subgroup analysis looks at the effects on various 17 

### national consumer subgroups. The manufacturer 18 

### impact analysis continues work begun in the 19 

### preliminary MIA. The employment impact analysis 20 

### looks at indirect effects on national employment 21 

### as opposed to direct impacts which are looked at 22261

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### as part of the MIA. The utility impact analysis 1 

### looks at affects on generation capacity of 2 

### utilities. The emissions analysis looks at 3 

### affects on airborne pollutant emissions. The 4 

### monetization of emissions reduction benefits 5 

### looks at the monetary benefits of emissions 6 

### reductions. And the regulatory impact analysis 7 

### looks at the potential for nonregulatory 8 

### approaches. 9 

### MR. BROOKMAN: Comments on any of those, 10 

### what are called downstream analysis, should there 11 

### be any at this time? 12 

### Yes, Dave. 13 

### MR. GATTO: Dave Gatto, Westinghouse. In 14 

### the subgroup analysis for the LCC are you already 15 

### considering low income? Are there any -- I know 16 

### the spreadsheet came out like a week and a half 17 

### ago. I haven't had time to look at it yet, so 18 

### are there subgroups that you're already 19 

### considering? We might recommend some if it's 20 

### missing, but if you already have subgroups that 21 

### you're planning to analyze then -- 22262

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### MS. KANTNER: So there were no subgroups 1 

### analyzed at the preliminary analysis stage, but 2 

### we do intend to look at low income individuals -- 3 

### MR. GATTO: Okay. 4 

### MS. KANTNER: -- as one of the subgroups 5 

### (Multiple Speakers) -- 6 

### MR. BROOKMAN: So, Dave, if you have any 7 

### to suggest now -- 8 

### MR. GATTO: That was the main one and I 9 

### thought you had already -- I had talked to 10 

### somebody, it might have been you, John, offline 11 

### that I thought you were going that way. But I 12 

### didn't want to not ask the question and find out 13 

### that if we didn't include it in the comments it 14 

### wouldn't get done. So. 15 

### MR. CYMBALSKY: We do that in all the 16 

### rulemakings. 17 

### MR. GATTO: I thought so. 18 

### MR. CYMBALSKY: This one won't be any 19 

### different than the rest, so we -- 20 

### MR. GATTO: Yeah. Thank you. 21 

### MR. CYMBALSKY: The impact might be 22263

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Toll Free: 888-445-3376 

### different but the analysis -- 1


### MR. GATTO: Yes. 2 

### MR. CYMBALSKY: -- will be the same. 3 

### MR. GATTO: Thank you very much. 4 

### MR. BROOKMAN: Okay. So now an 5 

### invitation and opportunity for anybody that 6 

### wishes to, to make closing remarks. 7 

### (Discussion off the record.) 8 

### MR. BROOKMAN: No closing remarks, so 9 

### then back to Lucy deButts for a recitation on how 10 

### to submit comments. 11 

### MS. DEBUTTS: Well, first of all thanks 12 

### everyone for coming. We are looking for your 13 

### comments and it seems like we're going to have 14 

### quite a bit of information from you guys. And 15 

### again, this slide shows how to submit comments. 16 

### Hopefully we can get them all by December 30th of 17 

### this year. So next year is going to be very 18 

### productive for us. 19 

### And that's it. Thank you. 20


### MR. BROOKMAN: Thanks to all. Safe 21 

### travels. And we'll see many of you, most of you 22264

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Toll Free: 888-445-3376 

### tomorrow. Yes. 1 

### Dick, you have a comment? 2 

### MR. UPTON: May I have this room for 3 

### about three minutes after the meeting is 4 

### adjourned. I've got a subject I've got to raise 5 

### with him and this is the only time I can get him 6 

### to get it. 7


### MR. BROOKMAN: Sure. 8 

### MR. CYMBALSKY: There's also a back room, 9 

### a holding room in the back. You can close the 10 

### door and have privacy. 11


### MR. BROOKMAN: Yeah. 12 

### MR. UPTON: Thank you, John. 13 

### MR. CYMBALSKY: Yup. 14 

### MR. BROOKMAN: If you could help us clean 15 

### up this room, please remove your cups and other 16 

### paraphernalia. 17 

### (Meeting concluded at 3:08 p.m.) 18

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Toll Free: 888-445-3376 

### CERTIFICATE OF COURT REPORTER 1 

### I, Brian Knieser, the officer 2 

### before whom the foregoing proceedings were taken, 3 

### do hereby certify that the foregoing pages are a 4 

### correct and accurate transcription of the 5 

### proceedings that were recorded by me and 6 

### thereafter reduced to typewriting under my 7 

### direction; that I am neither counsel for, related 8 

### to, nor employed by any of the parties associated 9 

### with these proceedings. 10



### _______________________ 11


### BRIAN KNIESER 12

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22265

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### CERTIFICATE OF COURT REPORTER

2 

### I, Brian Knieser, the officer

3 

### before whom the foregoing proceedings were taken,

4 

### do hereby certify that the foregoing pages are a

5 

### correct and accurate transcription of the

6 

### proceedings that were recorded by me and

7 

### thereafter reduced to typewriting under my

8 

### direction; that I am neither counsel for, related

9 

### to, nor employed by any of the parties associated

10 

### with these proceedings.

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### BRIAN KNIESER

OLENDER REPORTING, INC. 1100 Connecticut Avenue NW, #810, Washington, DC 20036 Washington: 202-898-1108 • Baltimore: 410-752-3376 Toll Free: 888-445-3376