1 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 Department of Energy 

2 

3 

4 

5 

6 Ceiling Fan Light Kits 

7 

8 

9 

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

11 Tuesday, November 18, 2014 

12 

13 U.S. Department of Energy 

14 1000 Independence Avenue, SW 

15 Room 8E-089 

16 Washington, D.C. 20585 

17 

18 

19 

20 

21 

22 
2 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 PEOPLE AROUND THE TABLE: 

2 DOUG BROOKMAN - Facilitator 

3 JOHN CYMBALSKY - DOE 

4 ASHLEY ARMSTRONG - DOE 

5 LUCY DEBUTTS - DOE 

6 JENNIFER TIEDEMAN - DOE 

7 

8 From the Industry: 

9 RICHARD UPTON - American Lighting Association 

10 CLARK LINSTONE - Lamps Plus 

11 DAVID TURNER - Hunter Fan 

12 BILL WALKER - Hunter Fan 

13 ALLEN ROO – Emerson Electric 

14 NATHAN FRAMPTON - Fanimation 

15 TIM FLANNERY - The Minka Group 

16 MARIANNE DIMASCIO - Appliance Standards Awareness 

17 Project 

18 DAVID GATTO - Westinghouse Lighting 

19 ALEX BOESENBERG - NEMA 

20 VAN SMITH – Van Ness Feldman 

21 

22 
3 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 Consultants: 

2 AISHA HUSAIN - Navigant 

3 MOHAN GANESHALINGAM - LBNL 

4 COLLEEN KANTER - LBNL 

5 JULIE PIERCE - Navigant 

6 ALI MCDONALD - Navigant 

7 

8 Also present: 

9 TERRY MCGOWAN - American Lighting Association 

10 LOUIS-BENOIT DESROCHES - LBNL 

11 MICHAEL WEEMS - American Lighting Association 

12 KENT MATHIS - HKC 

13 CHUCK MATTHEWS - Matthews Lamp Company 

14 LAURA BARHYDT - DOE 

15 VICTOR TAYLOR - Navigant 

16 

17 On the Phone: 

18 ANTHONY FRYER 

19 DOUG SMITH 

20 

21 

22 
4 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

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

2 MR. BROOKMAN: Let's start. Good 

3 morning, everyone. 

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

5 public meeting on Test Procedure, Notice of 

6 Proposed Rulemaking and Energy Conservation 

7 Standards Preliminary Analysis for Ceiling Fan 

8 Light Kits. 

9 Today is Tuesday, November 18th, 2014, 

10 here in the Department of Energy in Washington, 

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

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

13 this morning with welcoming remarks from John 

14 Cymbalsky. 

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

16 John Cymbalsky. I'm the Program Manager for 

17 Appliance Standards here at DOE. I just want to 

18 welcome everyone to the public meeting for 

19 ceiling fan light kits. We have a lot of 

20 material to cover today. Hopefully we can get 

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

22 appreciate all of your verbal comments here at 
5 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 the meeting, but we also appreciate you following 

2 up with written comments for the record so that 

3 we can build our administrative record cleanly 

4 and move forward with the rulemaking. Thank you. 

5 MR. BROOKMAN: We always start with 

6 introductions and I'll start to my immediate 

7 left. You can get used to turning these 

8 microphones both on and off. Please say your 

9 name and organizational affiliation. 

10 If we could do this a little slowly so 

11 our court reporter can capture everyone's name 

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

13 and off, name and organizational affiliation. 

14 MR. SMITH: Van Smith. Van Ness Feldman 

15 LLP. 

16 MR. BOESENBERG: Alex Boesenberg, 

17 National Electrical Manufacturer's Association. 

18 MR. GATTO: David Gatto, Westinghouse 

19 Lighting. 

20 MS. DIMASCIO: Marianne Dimascio, 

21 Appliance Standards Awareness Project. 

22 MR. FLANNERY: Tim Flannery, the Minka 
6 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 Group. 

2 MR. FRAMPTON: Nathan Frampton, 

3 Fanimation. 

4 MR. WALKER: Bill Walker, Hunter Fan. 

5 MR. TURNER: David Turner, Hunter Fan. 

6 MR. LINDSTONE: Clark Linstone, Lamps 

7 Plus. 

8 MR. UPTON: Dick Upton, President of the 

9 American Lighting Association. 

10 MS. TIEDEMAN: Jennifer Tiedeman, DOE 

11 Office of General Counsel. 

12 MS. ARMSTRONG: Ashley Armstrong, DOE. 

13 MR. CYMBALSKY: John Cymbalsky, DOE. 

14 MR. BROOKMAN: That microphone ought to 

15 work. 

16 MS. HUSAIN: Aisha Husain, Navigant. 

17 MS. MCDONALD: Ali McDonald, Navigant. 

18 MS. PIERCE: Julie Pierce, Navigant. 

19 MS. KANTNER: Colleen Kantner, Lawrence 

20 Berkley National Lab. 

21 MR. GANESHALINGAM: Mohan Ganeshalingam, 

22 Lawrence Berkley National Lab. 
7 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 MR. BROOKMAN: Please introduce 

2 yourselves. 

3 MR. DESROCHES: Louis Desroches, Lawrence 

4 Berkley National Lab. 

5 MR. MCGOWAN: Terry McGowan, Director of 

6 Engineering for American Lighting Association. 

7 MR. BROOKMAN: It's probably sufficient 

8 if you just stand. Yes. 

9 MR. WEEMS: Michael Weems, American 

10 Lighting Association. 

11 MR. MATHIS: Kent Mathis, HKC. 

12 MR. MATTHEWS: Chuck Matthews, Matthews 

13 Lamp Company. 

14 MS. BARHYDT: Laura Barhydt, DOE. 

15 MR. GOERING: Steve Goering, DOE. 

16 MR. TAYLOR: Victor Taylor, Navigant. 

17 MS. DEBUTTS: Lucy deButts, DOE. 

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

19 Public Solutions, Baltimore. Nice to see you all 

20 here. Apologies for a slight delay getting going 

21 this morning. 

22 All of you received a packet of 
8 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 information, I hope, as you entered the building 

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

3 a very brief agenda review. 

4 Immediately following this agenda review 

5 there is an opportunity for anyone that wishes 

6 to, to make brief opening remarks; opening 

7 statements about matters that are of importance 

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

9 procedure regulatory history and rulemaking 

10 overview, and then moving on from there, existing 

11 product classes, metrics, and test procedures 

12 proposed amendments to current test procedures, 

13 proposed test procedures to support standards 

14 rulemaking. 

15 We'll take a break midmorning round about 

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

17 clarifications to the Energy Conservation 

18 Standards determination of represented values. 

19 And then closing remarks, an opportunity 

20 for anyone that wishes to, to make supplementary 

21 comments, closing comments on the test procedure 

22 notice of proposed rulemaking. 
9 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 We will pause for lunch around about 

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

3 return from lunch we'll take up the Energy 

4 Conservation Standards portion of today's 

5 meeting. We'll start with opening statements, 

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

7 from there to scope and market technology 

8 assessment, screening analysis, engineering 

9 analysis, product price determination. 

10 We'll take a break mid afternoon around 

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

12 break: energy use, life cycle cost analysis, 

13 shipments analysis, national impact analysis, 

14 preliminary manufacturing impact analysis, NOPR 

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

16 whenever we get there, having covered all this 

17 material, another opportunity for comment. 

18 Another opportunity for you to say things that 

19 haven't been covered fully during the course of 

20 this meeting today. Okay? 

21 Everybody with me on that? All of you 

22 have a packet of information that looks like 
10 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

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

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

3 record each time you speak. There will be a 

4 complete transcript of this meeting available. 

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

6 the focus here, turn your cell phones on silent 

7 mode, limit sidebar conversations. You already 

8 got used to turning the microphones on and off. 

9 Webinar participants, we welcome you. 

10 The Department of Energy wants very much to make 

11 these meetings totally accessible to all via the 

12 web. If you would keep your telephone on mute 

13 and raise your hand in the software provided to 

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

15 hear you in the room and you can join the 

16 conversation here. 

17 All the stakeholders who are present on 

18 the web are also reminded to join in submitting 

19 written comments to the Department after the 

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

21 that opportunity to provide your written 

22 comments. 
11 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 Do you want to do the purpose of the 

2 public? 

3 MS. DEBUTTS: Sure. 

4 MR. BROOKMAN: To Lucy deButts. 

5 MS. DEBUTTS: All right. So good 

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

7 about the purpose of the public meeting today. 

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

9 statute and the DOE actions for the ceiling fan 

10 light kits. 

11 We're proposing the test procedures so 

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

13 also review energy conservation standards that 

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

15 conducted already, so we'll be presenting the 

16 results. 

17 Again, we invite everyone to provide us 

18 with any additional data or any kind of 

19 information that will help DOE in establishing 

20 energy conservation standards, and this is going 

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

22 the materials we are inviting you to share your 
12 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 thoughts with us. 

2 And as I stated again, written comments 

3 are more than welcome because they will help us 

4 in the long run to establish the standard that is 

5 beneficial to the society and the manufacturers 

6 as well. 

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

8 meeting today. 

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

10 throughout the presentation we're going to have 

11 issues boxes. So these issues boxes are showing 

12 the -- they correspond to the issues that are 

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

14 And if you have any additional information on any 

15 of the issues we welcome that to be submitted 

16 through regulations.gov, via your written 

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

18 procedures we ask that you consider the docket 

19 number, and you can also find all the information 

20 related to the test procedure on the 

21 regulations.gov, following the link that is 

22 showed on this file -- slide. 
13 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 Just as a reminder, the deadline for 

2 submitting written comments on the test procedure 

3 NOPR is January 14th, 2015. 

4 I already kind of touched on this on how 

5 to submit to the written comments. But again, 

6 please mention the test procedures docket number 

7 and the RIN ID for rulemaking when you're 

8 submitting your comments. 

9 The e-mail address for submitting written 

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

11 don't have access to electronic sources you of 

12 course can send it via postal service or courier, 

13 although we encourage electronic submissions more 

14 than anything else. 

15 Once again, January 14th is the deadline 

16 for submission, comments on the test procedure. 

17 So now to opening remarks. 

18 MR. BROOKMAN: Thank you. One or two 

19 individuals told me they have some opening 

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

21 to start us off? 

22 MR. UPTON: I'm Dick Upton, the President 
14 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 and CEO of the American Lighting Association. 

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

3 States, Canada, and the Caribbean. They include 

4 retail showrooms, manufacturer's reps, and 

5 manufacturers of various lighting products, 

6 including ceiling fans and controls. 

7 Twenty-two ceiling fan members have come 

8 together to bring our comments and positions to 

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

10 I would point out that the ceiling fan industry 

11 is a highly competitive industry and I'm very 

12 proud of these people for being able to come 

13 together and being able to deliver the industry's 

14 response. 

15 We also have with us our Washington legal 

16 counsel who has been helping us significantly and 

17 we think a real asset to these discussions. 

18 For some comments, we have a number of 

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

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

21 areas where we strongly disagree. And we'll 

22 deliver factual responses during these two days 
15 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 to back up our positions, including data from a 

2 second survey that we just concluded last week, 

3 of consumers, that we think you'll find 

4 interesting and helpful to you in making your 

5 decisions. 

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

7 challenging to prepare for this session given the 

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

9 get ready. As it turns out this particular 

10 period is exceptionally challenging for the 

11 ceiling fan industry in their year of doing 

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

13 complete and effective in our written comments as 

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

15 comments, both today and tomorrow. 

16 Two specific comments and one call for 

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

18 first this morning, that a ceiling fan is an 

19 energy efficient device. And that gets lost 

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

21 the fact that hundreds of millions of these 

22 products have been sold to the American consumer 
16 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

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

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

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

4 then they're buying them for entertainment value 

5 for watching the blades go around. 

6 Lastly, we think there is an action that 

7 you can take now and we would recommend it to 

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

9 watt power limit on integrated light kits because 

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

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

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

13 industry, but certainly expensive for the 

14 consumer and unnecessary expense as well. 

15 Thank you very much. 

16 MR. BROOKMAN: Thank you, Dick. 

17 Additional comments here, or opening statements 

18 here at the outset? 

19 I'm looking around. Nothing additional 

20 at this time? 

21 (No audible response.) 

22 Okay. Then we will launch into the 
17 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 content in your packet. 

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

3 Lucy deButts here. 

4 This slide shows the rulemaking schedule 

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

6 can see, the test procedure NOPR published on 

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

8 day comment period. Comment period will expire 

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

10 We are projecting the final rule to 

11 establish any test procedures for the ceiling fan 

12 light kits to be published in the third quarter 

13 of 2015, and the test procedure will become 

14 effective for the Appendix V for the current test 

15 procedure 30 days after the final rule 

16 publication. 

17 Our test procedure compliance date, which 

18 projected for purposes of ceiling fan light kits 

19 test procedures and proposed in Appendix V1, 

20 which will support the ceiling fan light kit 

21 standards, will be effective in the second 

22 quarter of 2019. 
18 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 Okay. So we can go into the regulatory 

2 history for now. And this slide just shows the 

3 history of the test procedure. EPCA gave the DOE 

4 the authority to regulate certain consumer 

5 products. And in 2005 it was amended and 

6 published the conservation standards for ceiling 

7 fan light kits as well as it required the test 

8 procedure for ceiling fan light kits. 

9 On December 8th of 2006 DOE published the 

10 final rule which codified the test procedure for 

11 ceiling fan light kits. 

12 And the last bulletin here shows the 

13 authority that DOE has to conduct the test 

14 procedure rulemakings for ceiling fan light kits. 

15 With the establishment of the 

16 requirements during the EISA 2007, DOE got the 

17 authority to actually review test procedures 

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

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

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

21 accordance with that authority. 

22 The existing test procedure for ceiling 
19 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 fan light kits are specified in Appendix V, and 

2 it could be found in the Federal Register, Title 

3 10 of CFR part 430, Subtitle B. 

4 The scope of this rulemaking will cover 

5 the ceiling fan light kits as the equipment 

6 designed to provide light from a ceiling fan. 

7 And these can be either integral, which are 

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

9 or they can be attachable and sold separately 

10 next to the ceiling fan. So therefore, any 

11 equipment designed to provide light from the 

12 product that are defined as ceiling fans under 

13 the ceiling fan rulemaking will be included in 

14 the scope of the ceiling fan light kit 

15 rulemaking. 

16 Any questions? 

17 (No audible response.) 

18 MS. DEBUTTS: Okay. Well, that concludes 

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

20 with the existing product classes, metrics, and 

21 the test procedures I will ask Colleen Kantner 

22 for the Lawrence Berkley National Lab to assist 
20 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 me with her presentation. 

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

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

4 MR. BROOKMAN: Is your microphone on? 

5 MS. KANTNER: Oh. Is this better? 

6 UNIDENTIFIED SPEAKER: Louder. 

7 MS. KANTNER: Just talk louder? 

8 UNIDENTIFIED SPEAKER: Yes. 

9 MS. KANTNER: Okay. EPACT 2005 

10 established energy conservation standards for 

11 three groups of ceiling fan light kits, those 

12 with medium screw base sockets, those with pin13 based sockets for fluorescent lamps, and all 

14 other ceiling fan light kits. 

15 Of particular note is that the efficiency 

16 metric is different for each product class. For 

17 the first product class, CFLKs with the medium 

18 screw base sockets, the efficiency metric is lamp 

19 efficiency. For CFLKs with pin-based fluorescent 

20 sockets, the efficiency metric is system 

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

22 the ballast it was packaged with. And for the 
21 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 third product class the efficiency metric is 

2 essentially wattage, because unlike the other two 

3 product classes there is a design standard to 

4 include a wattage limiter rather than test 

5 procedures to determine efficacy. 

6 It's also worth noting that CFLKs with 

7 medium screw base sockets must be packaged with 

8 lamps to fill all those sockets, and medium screw 

9 base CFLs must meet additional specifications in 

10 Energy Star Program Requirements for Compact 

11 Fluorescent Lamps, version 3.0. 

12 CFLKs with pin base sockets must also use 

13 an electronic ballast and be packaged with lamps 

14 to fill all sockets. 

15 DOE's current test procedures are in 

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

17 of the Code of Federal Regulations. Test 

18 procedures for CFLKs with medium screw base 

19 sockets reference Energy Star Program 

20 Requirements for CFLs, version 3.0, which in turn 

21 references the 2000 version of LM-66. Test 

22 procedures for CFLKs with pin-based fluorescents 
22 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 reference Energy Star requirements for 

2 residential light fixtures, which in turn 

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

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

5 And again, there's no test procedure for 

6 the third product class because they are subject 

7 to a design requirement to use a wattage limiter 

8 instead. 

9 It's worth noting that both the Energy 

10 Star program procedures and the IES test 

11 procedures mentioned here are no longer current. 

12 DOE is planning to update these test 

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

14 when DOE amends a test procedure it must consider 

15 to what extent the proposed test procedure would 

16 alter the measured energy efficiency. DOE can 

17 only make a change to a test procedure that is 

18 not simultaneous with a change in the 

19 corresponding energy conservation standard if the 

20 energy efficiency measured will not change. DOE 

21 believes that there are some updates that can be 

22 made without altering the measured efficiency. 
23 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 So first DOE proposes to make minor 

2 clarifications in amendments to the current test 

3 procedures. This is just updating test procedure 

4 references. And because the amendments will not 

5 change the measured CFLK efficiency, DOE proposes 

6 that the test procedure will be effective 30 days 

7 after publication and that manufacturers must 

8 make any representations with respect to the 

9 energy efficiency of ceiling fan light kits 

10 beginning 180 days after publication of the final 

11 rule. 

12 Then, later, DOE proposes to add new test 

13 procedures that would revise the methods for 

14 measuring energy efficiency of ceiling fan light 

15 kit to support the concurrent energy conservation 

16 standards rulemaking. DOE proposes that these 

17 new test procedures would be required at the 

18 compliance date for a potential amended CFLK 

19 standard. 

20 And now we'll discuss the proposed 

21 amendments to the current test procedures. These 

22 are the proposed amendments DOE is planning to 
24 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 make during phase one. 

2 DOE's intention with the proposed changes 

3 to the current CFLK test procedure is to 

4 harmonize the represented values of lamp 

5 efficacy, wherever possible, with covered lamp 

6 regulations. DOE believes that this will reduce 

7 burden on CFLK manufacturers if they purchase 

8 covered lamps rated pursuant to DOE's regulations 

9 to be packaged with their CFLKs. 

10 DOE proposes to make amendments to the 

11 current test procedures for product classes one 

12 and two. 

13 DOE is proposing to replace the current 

14 reference to Energy Star requirements for CFLs 

15 with a reference to the DOE test procedures for 

16 medium screw based CFLs which are located in 

17 Appendix W. And this Appendix W in turn 

18 references the 2011 version of LM-66. 

19 DOE examined the methodologies in each 

20 version and doesn't believe that there are any 

21 differences between the 2000 and 2011 versions of 

22 LM-66 that would yield differences in the 
25 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 measured values of lamp efficacy. 

2 DOE is also proposing to replace Energy 

3 Star program requirements for residential light 

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

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

6 version of LM-9 for circlines. 

7 MR. BROOKMAN: David, please? 

8 MR. TURNER: Yeah, David Turner with 

9 Hunter. Without knowing the exact content of 

10 what the Product Class 1 would change to, would 

11 the requirement be that you would have to pack in 

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

13 just a lamp that met the efficiency of -- 

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

15 based CFL then there are certain additional 

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

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

18 efficacy. 

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

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

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

22 MR. BROOKMAN: Thank you, Ashley. Okay. 
26 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 Additional questions here on these changes? 

2 MS. KANTNER: I did just want to note 

3 that in order to maintain representations, the 

4 current representations of efficacy, DOE will 

5 continue to use system efficacy where the lamp is 

6 measured with the ballast it's packaged with. 

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

8 allow for testing with either a reference ballast 

9 or a commercial ballast. 

10 As with the update to medium screw base 

11 lamps DOE believes that the update to these more 

12 recent versions of the industry test procedures 

13 will not result in any changes in measured 

14 efficiency. 

15 Now we have a couple of items for 

16 comment. DOE requests comment on the proposed 

17 changes for existing test procedures for CFLKs 

18 packaged with medium screw base lamps. 

19 MR. BROOKMAN: Yes, David. 

20 MR. GATTO: Dave Gatto, Westinghouse 

21 Lighting. Just a question on CFLKs with medium 

22 screw base. 
27 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

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

2 packaged in that's already been tested to Energy 

3 Star current standard does DOE -- are you looking 

4 for additional testing, or when we recertify 

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

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

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

8 into the light kits? 

9 MR. BROOKMAN: Ashley Arm -- 

10 UNIDENTIFIED SPEAKER: Ready to answer. 

11 MR. BROOKMAN: Ashley Armstrong. 

12 MS. ARMSTRONG: I'm going to carefully 

13 answer this one. 

14 So, currently you should be testing to 

15 the version of the Energy Star document which 

16 incorporates by reference a certain industry 

17 standard and a specific version of that for 

18 federal minimums. 

19 To the extent EPA has gone past that and 

20 adopted different test procedures for their 

21 program they have diverged from what's required 

22 for federal minimums. Does that make sense? 
28 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

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

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

3 the clarifications in Phase 1 was to harmonize 

4 with the lamp procedures. When EPACT 05 came out 

5 it had different versions that we ultimately 

6 ended up adopting for lamp test procedures versus 

7 CFLKs that are packaged with those same lamps. 

8 So we are trying to eliminate that with 

9 this proposal by harmonizing the lamp procedures 

10 across the board where applicable to reduce 

11 burden. So if you buy an otherwise compliant 

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

13 the CFLKs responsibility -- manufacturer's 

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

15 CFLK that is a covered product. But the lamp 

16 manufacturer has to do this testing anyway and in 

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

18 harmonized the rated values. So as long as the 

19 rated values were developed in accordance with 

20 the lamp procedures, you know, you should be 

21 going forward. 

22 So the answer is, we're trying to reduce 
29 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 burden, not require retesting. The lamp 

2 manufacturer should already be doing this because 

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

4 MR. BROOKMAN: So back to Dave. 

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

6 MS. ARMSTRONG: Kind of answers your 

7 question in a roundabout way. 

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

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

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

11 typically we're not certifying to the old 3.0 

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

13 that. 

14 However, I'm not necessarily retesting 

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

16 have been only specific tests that had to be run 

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

18 full test procedure because we've taken an 

19 existing model that were already Energy Star 3.0, 

20 which is well above the minimum efficacy, which I 

21 know is what DOE is concerned with, and have 

22 recertified to 1.0, the new lamp specification 
30 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 that covers both solid state and CFL, would we 

2 need to go back and retest and then have that 

3 test data specific to the CFLK? 

4 I don't know if you can answer it 

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

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

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

8 test report -- 

9 MS. ARMSTRONG: Yes, you are required by 

10 federal -- you know, the DOE regulations require 

11 a certain version of a test procedure to be run 

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

13 one test procedure allowed to be used. Not 

14 different versions, not variations thereof, even 

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

16 measures of efficacy. 

17 That being said, in Lamps 1.0 what you 

18 will see is DOE worked closely with EPA for 

19 covered products referenced to CFR. So in 

20 theory, if you look at all the details they 

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

22 let's talk about it. 
31 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 MR. GATTO: Okay. 

2 MS. ARMSTRONG: So take a look because we 

3 did work pretty hard with EPA in the last version 

4 of the lamps that went out to harmonize for 

5 covered lamps. So CFLs would reference to CFR. 

6 Also there would be one test procedure, 

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

8 thing for ratings to reduce burden. 

9 MR. GATTO: So Dave Gatto, Westinghouse. 

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

11 devil is in the details. 

12 MS. ARMSTRONG: I know. 

13 MR. GATTO: And when we're referencing 

14 something that's referencing something else, and 

15 then references back to it -- 

16 MS. ARMSTRONG: So the key here is CFR 

17 matters. 

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

19 you. 

20 MR. BROOKMAN: Dick. 

21 MR. UPTON: Ashley, Westinghouse is 

22 unique to our manufacturing group in that they're 
32 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 a lamp manufacturer as well as a ceiling fan 

2 manufacturer. 

3 If I understood you correctly, if all the 

4 other manufacturers purchase a lamp that's been 

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

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

7 retest that lamp with the fixture? 

8 MS. ARMSTRONG: So there are some 

9 nuances. The answer is, mostly yes. 

10 MR. UPTON: Thank you. 

11 MS. ARMSTRONG: The responsibility is on 

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

13 retesting requirement per se, but you need to 

14 make sure that, you know, whoever is supplying 

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

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

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

18 data that's done in accordance with the DOE 

19 regulations there's nothing that makes you test 

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

21 MR. UPTON: Very well. 

22 MS. ARMSTRONG: Thank you. 
33 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

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

2 Additional comments? We have two comment boxes 

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

4 additional comments on these two? 

5 (No audible response.) 

6 MR. BROOKMAN: Nothing additional at this 

7 time. Okay, we're moving on. 

8 MS. KANTNER: Okay. Moving on to Phase 

9 2, the proposed test procedures to support the 

10 standards rulemaking. 

11 DOE is proposing to use efficacy as the 

12 efficiency metric for all CFLKs instead of using 

13 efficacy for some product classes and a wattage 

14 limit for others. The current variability in 

15 approach makes it difficult to compare the 

16 efficiency of different CFLKs. Moving to an 

17 efficacy-based approach allows DOE to move away 

18 from the problems associated with the wattage 

19 limiter approach, including the technical issues 

20 associated with the wattage limiter raised by 

21 stakeholders, and also the fact that wattage 

22 alone is not necessarily indicative of the 
34 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 lighting service provided by the CFLK. 

2 An efficacy metric is a universally 

3 accepted metric. It's used by lighting industry 

4 organizations and government bodies to 

5 characterize the efficiency of both lamps and 

6 luminaires. So DOE will be more closely 

7 harmonizing with this universally accepted 

8 approach. 

9 And again, this is the overall goal with 

10 these proposed test procedures, to harmonize with 

11 DOE and industry test procedures wherever 

12 possible. 

13 So DOE is proposing to update the active 

14 mode test procedures to reference DOE test 

15 procedures if they exist or will exist by the 

16 compliance date of the standards rulemaking and 

17 to reference current industry test procedures if 

18 DOE test procedures don't exist. 

19 As suggested in the framework document, 

20 DOE is not proposing to incorporate any energy 

21 consumption in standby or off mode into the CFLK 

22 efficiency metric. Energy consumption in standby 
35 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 mode for ceiling fan light kits packaged with 

2 ceiling fans will be measured as part of the 

3 proposed ceiling fan test procedure and will be 

4 discussed tomorrow. And DOE does not believe 

5 that CFLKs consume power in off mode. 

6 As mentioned in the previous slide, DOE 

7 proposes to use efficacy measured in lumens per 

8 watt to quantify the energy efficiency of all 

9 CFLKs. To the extent that it is technologically 

10 feasible, DOE proposes to use lamp efficacy as 

11 the measure of efficiency. 

12 For CFLKs with externally-ballasted 

13 lamps, DOE proposes shifting from the current 

14 approach, which uses system efficacy as measured 

15 on the ballast packaged with the CFLK, to one 

16 that uses lamp efficacy as measured on a 

17 reference ballast. 

18 Note that for CFLKs for which lamp 

19 efficacy is the metric, the same lamp model may 

20 be used in multiple CFLK models and lamp 

21 manufacturers may have already tested these lamps 

22 according to the required test procedures since 
36 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 the proposed test procedures harmonize with DOE 

2 and industry test procedures. Then, at least in 

3 theory, the lamp manufacturers could provide 

4 those test reports to the CFLK manufacturers. 

5 When it is not technically feasible to 

6 use lamp efficacy, DOE proposes to use luminaire 

7 efficacy. Some ceiling fan light kits with solid 

8 state lighting have designs for which it is not 

9 technically feasible to measure lamp efficacy 

10 without destructive disassembly of the CFLK 

11 circuitry, or even if it's possible to 

12 disassemble the light kit in a non destructive 

13 manner, the resulting measurements may not be 

14 accurate or consistent representations of the 

15 light source efficacy. 

16 Specifically, luminaire efficacy would be 

17 applicable to CFLKs with integral solid state 

18 lighting circuitry, which will be described on 

19 the next slide. 

20 The luminaire efficacy of each basic 

21 model of ceiling fan light kit with integral SSL 

22 circuitry would need to be tested, and the term 
37 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 “CFLKs with integral SSL circuitry” means either 

2 a ceiling fan light kit that has SSL drivers or 

3 light sources that are not consumer replaceable, 

4 or CFLKs that have SSL drivers and light sources 

5 that are consumer replaceable but the driver and 

6 the light source are separated by some additional 

7 intermediate circuitry. 

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

9 replaceable driver and a replaceable light 

10 source. 

11 So this is illustrated on the next slide. 

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

13 applicable to all consumer replaceable lamps. So 

14 these are lamps that can be removed from the 

15 light kit as a single integrated piece with a 

16 standard base. If either the light source or the 

17 driver are integrated into the CFLK and not 

18 consumer replaceable, then the CFLK is subject to 

19 luminaire efficacy testing. This is straight 

20 forward in the case of the light source, but 

21 since there aren't reference drivers for LEDs in 

22 the same way that there are reference ballasts 
38 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 for CFLs, then luminaire testing is required even 

2 if only the driver is not consumer replaceable. 

3 Testing this way is consistent with LM4 79, which applies to either integrated lamps or 

5 entire luminaires, but not to light sources by 

6 themselves. 

7 Luminaire testing is also required in 

8 this third case, that was described in the 

9 previous slide, where the light source and driver 

10 are both consumer replaceable but they are 

11 separated by some intermediate circuitry. And 

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

13 In general LM-79 applies to either 

14 integrated lamps or whole luminaires where the 

15 testing is done on the entire fixture, and that 

16 includes all components that could affect 

17 electrical, thermal, or optical properties. 

18 MS. ARMSTRONG: So if anybody has 

19 questions you guys can feel free to chime in, 

20 even though we're just kind of rolling through 

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

22 comments or questions, or tell us you agree with 
39 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

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

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

3 before lunch if we keep going like this. 

4 MR. BROOKMAN: Yes. Tim. 

5 MR. FLANNERY: So, would you consider a 

6 driver limiting device? 

7 MS. ARMSTRONG: Going back to my favorite 

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

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

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

11 requests that we reinterpret, you know, our 

12 requirement for the 190 watt on a limiter. I 

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

14 We believe in order to do something like that we 

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

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

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

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

19 with the data and the evidence, some of which 

20 you've already provided, that will give some 

21 background and some rationale as to why certain 

22 types of lamps, mainly LEDs, would never exceed 
40 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 the 190 watt requirement and do not need a 

2 limiter. 

3 So if you can help with that in your 

4 comments, if you would be willing to provide data 

5 for that, obviously the Department is open to 

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

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

8 presentation is going to be talking about 

9 standards in the future. We could reinterpret -- 

10 we could consider reinterpreting applying the 

11 limiter for the current standards as part of that 

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

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

14 Okay? 

15 MR. BROOKMAN: Please. And your name, 

16 and use the microphone, thank you. 

17 MR. MCGOWAN: Terry McGowan, Director of 

18 Engineering for the American Lighting 

19 Association. Actually, the situation we have 

20 here is very closely related to number 2, where 

21 you have pin-based fluorescent systems, and the 

22 regulation thereof. An LED manufactured to 
41 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 provide a certain light output and a fixed power 

2 input has all of the characteristics described 

3 there except the LEDs are not replaceable, 

4 they're fixed. So you could reinterpret that 

5 with fixed lamps and have exactly what we're 

6 trying to say, that the power input, and 

7 therefore the efficacy is rated according to the 

8 power input and the lumen output of the light 

9 sources. 

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

11 so I question whether that gets you to where you 

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

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

14 go for future standards, but the current 

15 standards right now we're dealing with are in 

16 terms of either for screw base sockets, efficacy, 

17 for pin bases sockets, system efficacy, as long 

18 as they have pin-based sockets. And for 

19 everything else we've interpreted that shall not 

20 be capable of operating as requiring a wattage 

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

22 we're dealing with, correct? 
42 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 MR. MCGOWAN: Yes. 

2 MS. ARMSTRONG: That the ask is for. 

3 That's my understanding. 

4 MR. MCGOWAN: Okay. Terry McGowan again. 

5 If you go then to the interpretation 3, 

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

7 because those devices by design cannot be changed 

8 once they are designed and installed because they 

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

10 current limiting device, the driver, which states 

11 and limits the power being drawn by that system. 

12 MS. ARMSTRONG: So, I think DOE is 

13 asking, while we understand by design, what does 

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

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

16 just because someone claims by design, what if 

17 they had one LED integrated with other bulb 

18 types? Does that exclude them by design? 

19 MR. MCGOWAN: There are no -- 

20 MS. ARMSTRONG: And what does that mean? 

21 MR. MCGOWAN: By design means there are 

22 no replaceable parts. 
43 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 MR. BROOKMAN: So, Terry, that was 

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

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

4 Ashley a question, please. 

5 MR. BROOKMAN: Microphone on. 

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

7 Dave Gatto, Westinghouse. Alex, you normally are 

8 right there with me, reminding me. 

9 MS. ARMSTRONG: Alex, you have coffee 

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

11 the quietest I've ever seen you. 

12 MR. GATTO: We come into this meeting 

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

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

15 name. I'm not Joe Howley. 

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

17 doing well. Keep going. 

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

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

20 our comments is the technical reasons why under 

21 class 3 integrated LED light sources, which 

22 wouldn't include these other light sources, would 
44 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

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

2 really what you're looking for is the technical 

3 reasons for -- 

4 MS. ARMSTRONG: Yes. 

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

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

7 like that's really what you want. 

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

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

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

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

12 is the data to support that integrated LEDs or 

13 LEDs that are not replaceable, you know, meet 

14 that definition. 

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

16 I think that's more than possible. 

17 MS. ARMSTRONG: And what are the bounds 

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

19 infinite number of them if somebody put thousands 

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

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

22 egregious with my comments here, but to show you 
45 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 the thought process that we have to go through 

2 because the language is fairly clear in the 

3 statute about shall not be capable of operating. 

4 MR. GATTO: Yes, so if we included 

5 something in the technical reasons that included 

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

7 190 watt or higher LED but I would actually say 

8 that in our comments we could probably agree that 

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

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

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

12 around and say, how would you know? 

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

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

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

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

17 for it to use 190. 

18 MS. ARMSTRONG: Sure. 

19 MR. GATTO: I will give you that. 

20 MS. ARMSTRONG: Great. 

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

22 useful restatement earlier. So thank you for 
46 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

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

2 you and your association to fulfill DOE's wishes 

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

4 that. 

5 Additional questions, comments at this 

6 stage? Dick. 

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

8 is there any other aspect of 190 watt power 

9 limiter that you want to address other than what 

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

11 product? 

12 MR. BROOKMAN: Tim. No? 

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

14 MR. BROOKMAN: Okay. 

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

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

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

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

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

20 think we've been fairly consistent in our 

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

22 rule. 
47 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 So this is the right time for this. This 

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

3 time to work together to figure out a way forward 

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

5 be -- 

6 MR. BROOKMAN: Back to Dave. 

7 MR. GATTO: Sorry. Dave Gatto, 

8 Westinghouse. 

9 So when you said earlier that you would 

10 consider reinterpreting, what we took that to 

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

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

13 that we would reinterpret the Class 3 design rule 

14 as currently written to allow solid-state 

15 lighting that met the statutory definition of not 

16 capable of operating, if we were able to provide 

17 you the technical details that that's true. 

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

19 predetermine the outcome of a rule, but we could 

20 consider such an outcome. 

21 MR. GATTO: Thank you. 

22 MR. BROOKMAN: Yes, Dick? 
48 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

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

2 time frame we're talking about when could you 

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

4 terminate the requirement of power limiter? 

5 Thirtieth of December? 

6 MS. ARMSTRONG: No. At the very least 

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

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

9 just have a preliminary analysis out. We would 

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

11 proposal out for comment, then we could finalize. 

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

13 unfortunately, this year. But we could work 

14 something -- we could understand the -- we 

15 understand the urgency, so. Okay. 

16 MR. UPTON: Ninety days? 

17 MR. CYMBALSKY: Didn't you have it 

18 scheduled? 

19 MS. ARMSTRONG: Are you going to ask for 

20 a comment period extension? 

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

22 MS. ARMSTRONG: Let's make a deal. 
49 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 MR. BROOKMAN: Either Bill or David. 

2 Bill, I think you. Yes. 

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

4 the statement about shall not be capable of 

5 operating. So, we had this discussion in the 

6 last meeting for like two light candelabras, 

7 where a light kit that just has two light socket 

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

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

10 Will that be in consideration too for this shall 

11 not be capable of operating? 

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

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

14 previously DOE made its original interpretation 

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

16 capable of operating." And for replaceable bulbs 

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

18 replace them with something with a higher 

19 wattage. Now, you know, without that limiting 

20 device in there. 

21 Now perhaps there are technical reasons, 

22 things that have changed over time. In your 
50 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 comments you are more than welcome to bring up 

2 any issues you would like to consider for the 

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

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

5 asking us to revisit that rationale you should 

6 point to anything that might have changed since 

7 then. 

8 If it hasn't, then -- 

9 MR. BROOKMAN: Dave. 

10 MR. GATTO: Dave Gatto, Westinghouse. So 

11 my question would be then, if the thing that 

12 changed was the EPACT effect on candelabra and 

13 intermediate based lamps, because I don't believe 

14 that was promulgated at the time that the limiter 

15 was discussed, would that represent -- the fact 

16 that there's no products available that would 

17 exceed those wattage limits, would that be 

18 something DOE would consider? It's really more 

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

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

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

22 but if you've got some concern that that would 
51 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 not actually prevent consumers from doing it, we 

2 won't waste our time. 

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

4 your -- your comments are not limited. We 

5 welcome any comments that you would like to make 

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

7 that. 

8 MR. BROOKMAN: Yes, please, Clark. 

9 MR. LINSTONE: Clark Linstone, Lamps 

10 Plus. 

11 So, it sounds like barring a test of the 

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

13 that if it's physically possible to create a 

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

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

16 test procedure to basically show that, you know, 

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

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

19 190 watts that we were trying to avoid. 

20 MS. ARMSTRONG: So this is Ashley from 

21 DOE. 

22 So I was a little bit trying to play, for 
52 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

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

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

3 you do consider making your comments and asking 

4 the department to do this reinterpretation and 

5 why, are there any reasonable bounds you would 

6 think to put around it? 

7 I'm not necessarily advocating a test for 

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

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

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

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

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

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

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

15 operating. 

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

17 the Department, when I come up with this 

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

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

20 technical proposals my lawyers are going to ask 

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

22 capable of operating language? So put yourself 
53 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

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

2 That's the ask. 

3 MR. BROOKMAN: Okay. Terry, please. 

4 MR. MCGOWAN: Terry McGowan, American 

5 Lighting Association. 

6 All ceiling fan light kits have a label 

7 or a specification sheet that says maximum 

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

9 that that maximum wattage not be over 190 watts. 

10 Is that sufficient when you state maximum wattage 

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

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

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

14 something that was brought up in the original 

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

16 originally the department rejected based on the 

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

18 could be capable of operating above that rated 

19 wattage, even though it may not have been 

20 originally intended for that. 

21 So, I will say that was something we 

22 considered before and ultimately ended up at our 
54 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 wattage limiter decision. However, if we are 

2 reinterpreting if there are reasons or facts that 

3 have changed as to why that rated wattage is 

4 different now on the label than it was 

5 previously, obviously we're open to considering 

6 all the facts. 

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

8 guess because what we're talking about is a 

9 device that has no replaceable parts. So the 

10 rated wattage on the box and the specification is 

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

12 MS. ARMSTRONG: Right. So I think the 

13 answer is different for replaceable versus not 

14 replaceable, perhaps, and maybe you can make 

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

16 kind of gone back and forth of, will you consider 

17 something as broadly as reinterpreting the whole 

18 thing for replaceable lamps. And, you know, I'm 

19 not an expert in CFLKs or lamps by any means, but 

20 you would have to show -- we came to that 

21 decision for a variety of facts; based on a 

22 variety of facts at that time. You would have to 
55 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 show something has changed. 

2 Now, obviously for LEDs, especially 

3 nonreplaceable LEDs, things have changed. The 

4 market has changed a little bit and maybe the 

5 facts have changed, and that is something you 

6 have been asking for a long time and we are 

7 willing to open to considering that. 

8 MR. MCGOWAN: That's useful. Thank you. 

9 MS. ARMSTRONG: Yep. 

10 MR. BROOKMAN: Thank you, Terry. Tim. 

11 MR. FLANNERY: And I hate to circle back 

12 here. This is Tim Flannery. 

13 But if in fact a limiter is not capable 

14 of going over 190 watts, okay, would that be 

15 considered a limiting device? 

16 UNIDENTIFIED SPEAKER: So you mean an LED 

17 light? 

18 MR. FLANNERY: An LED. 

19 UNIDENTIFIED SPEAKER: LED driver. 

20 MS. ARMSTRONG: Yeah, driver? 

21 MR. FLANNERY: I'm sorry. With the 

22 driver. 
56 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 MS. ARMSTRONG: I don't know. I mean, 

2 that's not something I think -- like I said -- 

3 MR. FLANNERY: But if a driver -- if 

4 we're able to provide information that the driver 

5 cannot exceed 190 watts would we need an 

6 additional ruling because it falls within the 

7 current ruling of a limiter. 

8 MS. ARMSTRONG: So we haven't had an 

9 opinion on that. If you want to make the case to 

10 me, happy to consider it separately as a 

11 different -- that's something I'm not going to be 

12 able to answer on the spot. But we could talk 

13 about it, definitely. 

14 MR. FLANNERY: Okay. 

15 MS. ARMSTRONG: Yep. If it's simply that 

16 we need -- you know, it could be that -- I don't 

17 know if we could do it through guidance, or 

18 something like that, something quicker, if that's 

19 what you're asking. 

20 MR. FLANNERY: Okay. I guess my point 

21 is, is if the driver is not capable of exceeding 

22 -- 
57 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 MS. ARMSTRONG: Right. 

2 MR. FLANNERY: -- 190 watts it should 

3 fall within the existing rule. 

4 MS. ARMSTRONG: You're asking us to 

5 interpret the driver as the equivalent of a 

6 limiter. I get it. 

7 MR. FLANNERY: Well, it is a limiting 

8 device. 

9 MS. ARMSTRONG: I get your ask. 

10 MR. FLANNERY: Thank you. 

11 MS. ARMSTRONG: The answer is, I don't 

12 know. 

13 MR. BROOKMAN: So this has been 

14 productive. Now additional comments or questions 

15 in this stream of content before we move on? Any 

16 additional clarifications from anyone? 

17 Okay, yes. Colleen. 

18 MS. KANTNER: I don't know if there -- we 

19 talked about the wattage limiter for a while. 

20 Are there any questions or comments on the 

21 proposed efficacy metrics? 

22 MS. ARMSTRONG: So just to kind of get 
58 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 back to where we are, for the future rule, not 

2 the standards today but for standards we're 

3 considering in this afternoon's presentation, 

4 we're proposing to move everything to efficacy. 

5 So there would be no more wattage limit, there 

6 would be no more limiter. Moving everything to 

7 efficacy, either lamp based efficacy or some type 

8 of luminaire type efficacy depending on the type. 

9 But that's what the proposals are. We 

10 have a -- you can say you agree with us. That 

11 would be helpful. 

12 The court reporter can't actually write 

13 down that. 

14 MR. BROOKMAN: Yeah. Dave. 

15 MR. GATTO: Dave Gatto, Westinghouse. 

16 I think that this is something when we 

17 get to the proposed standards that we'll probably 

18 talk about a little bit. I think the only 

19 concern I would have is an efficacy measurement 

20 is fine as long as the standard potentially, and 

21 I'm not sure that we even need this, but it may 

22 need to allow for more flexibility than what the 
59 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 standards that are being proposed are because of 

2 the way you combine classes. 

3 But from an efficacy standpoint I think 

4 that just for Westinghouse's standpoint, we agree 

5 with, I do agree with you that lamp efficacy is 

6 the best method. For now I think CFLKs with 

7 integral SSL luminaire efficacy is acceptable. 

8 MS. ARMSTRONG: Because it's what we're 

9 going to get? 

10 MR. GATTO: Yeah, it's kind of -- it's 

11 what we're doing now and I know you needed test 

12 procedure to change that. So unless something 

13 happens further down the line on luminaires with 

14 Energy Star that gives you something you could 

15 tie your cart to, I think that that's fine. 

16 MR. BROOKMAN: As Ashley said, it's 

17 useful for stakeholders, for interested parties 

18 to comment if DOE is getting it right. If you 

19 like what they're doing it's nice to have that 

20 acknowledged, so that that's clear. 

21 Okay. Any final comments, additional 

22 comments on these two issue boxes, issue box 5 
60 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 and 7 as listed here because we're about to move 

2 on? 

3 (No audible response.) 

4 MR. BROOKMAN: Okay, Colleen. 

5 MS. KANTNER: Okay. So here are the 

6 proposed test procedures in active mode. This is 

7 again in Phase 2, to support the Energy 

8 Conservation Standards rulemaking. 

9 MR. UPTON: It's hard to hear. 

10 MS. KANTNER: Okay. Sorry about that. 

11 Again, DOE wants to harmonize with 

12 existing DOE test procedures whenever possible, 

13 and with industry test procedures otherwise. 

14 It's worth noting that DOE is currently engaged 

15 in two test procedure rulemakings for lamp types 

16 that are currently used in CFLKs. These are test 

17 procedures for CFLs and for integrated LED lamps 

18 which DOE expects to be in force prior to the 

19 compliance date of the updated CFLK test 

20 procedures. 

21 For all compact fluorescent lamps, DOE 

22 proposes to use DOE's test procedure for CFLs, 
61 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 which is located in Appendix W. If you were to 

2 try to put a general service fluorescent lamp in 

3 a CFLK or if you were to use a general service 

4 incandescent lamp, you would again test lamp 

5 efficacy, according to Appendix R, which is the 

6 appendix for those products. 

7 Any other fluorescent lamp other than a 

8 CFL or GSFL—this would mostly be circlines—you 

9 would also test lamp efficacy and this would be 

10 tested according to LM-9. For integrated LED 

11 lamps you would also measure lamp efficacy and 

12 you would use DOE's test procedure for integrated 

13 LED lamps, which is proposed to be in Appendix 

14 BB. 

15 For all other solid state lighting lamps 

16 you would use LM-79, and you would also use that 

17 for integrated -- for CFLKs with integrated SSL 

18 circuitry. Only you would be testing luminaire 

19 efficacy in that case. 

20 For CFLKs that use the multiple lamp 

21 models, DOE proposes that each lamp model be 

22 tested according to the appropriate lamp test 
62 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 procedure for that lamp type. Referencing 

2 existing DOE lamp test procedures will minimize 

3 the overall testing burden because lamps may have 

4 already been tested to DOE test procedures and 

5 would not require additional testing. 

6 For CFLKs that have both consumer 

7 replaceable lamps and integrated SSL circuitry, 

8 DOE proposes that lamp efficacy would be reported 

9 for the consumer replaceable lamps and that 

10 luminaire efficacy would be reported for the CFLK 

11 with integrated SSL circuitry with the consumer 

12 replaceable lamps removed. 

13 And again, as we mentioned earlier, DOE 

14 is not proposing to incorporate energy 

15 consumption in standby mode or in off mode into 

16 the CFLK metric. 

17 MR. BROOKMAN: Dave. 

18 MR. GATTO: Dave Gatto, Westinghouse. 

19 I'll throw you the bone. We agree with 

20 that. Put it in with the fans where it makes 

21 sense. 

22 MR. BROOKMAN: Thank you. 
63 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 MS. KANTNER: Okay. So now let's move on 

2 to some clarifications to the energy conservation 

3 standards. CFLK energy conservation standards 

4 are codified in 10 CFR 430.32,Paragraph S. DOE 

5 proposes to replace references to Energy Star 

6 program requirements located there with tables 

7 that contain the specific performance 

8 requirements. The idea here is just to remove a 

9 layer of documentation. 

10 The performance requirements include for 

11 CFLKs packaged with medium screw based CFLs: lamp 

12 efficacy, lumen maintenance at 1,000 hours, lumen 

13 maintenance at 40 percent of lifetime, rapid 

14 cycle stress and lifetime. For CFLKs packaged 

15 with medium screw base light sources other than 

16 CFLs, it would just be lamp efficacy. For CFLKs 

17 packaged with pin-based fluorescents, it would be 

18 system efficacy, as well as a requirement to use 

19 an electronic ballast. 

20 And again, the current energy 

21 conservation requirements remain unchanged. 

22 We're just trying to clarify things. 
64 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 MR. BROOKMAN: Yes, Dave? 

2 MR. GATTO: Dave Gatto, Westinghouse. I 

3 just have a quick one because this is actually 

4 how we interpreted it, so I believe I appreciate 

5 the clarification. 

6 So medium based dimmable or undimmable 

7 LED screw base lamp that meets the efficacy 

8 requirements of Energy Star 3.0 or what you're 

9 referring to now would meet the standard. 

10 I see nodding. Can I get the yes out 

11 loud? Come on. 

12 MR. BROOKMAN: Ashley Armstrong. 

13 MS. ARMSTRONG: Yes. 

14 MR. GATTO: Thank you. 

15 MR. BROOKMAN: Okay. 

16 MS. ARMSTRONG: As my enforcement 

17 attorney back there is staring at me. 

18 (Laughter.) 

19 MR. BROOKMAN: Anything additional here? 

20 (No audible response.) 

21 MS. KANTNER: DOE is also updating the 

22 guidance on accent lighting. DOE previously 
65 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 issued guidance on accent lighting used in CFLKs, 

2 stating that DOE does not consider ceiling fan 

3 accent lighting that is not a significant light 

4 source to be part of the 190 watt limitation. 

5 This was specifically in reference to Product 

6 Class 3 CFLKs. Because it is difficult to 

7 quantitatively define a significant light source 

8 in a CFLK, and may result in inconsistency in the 

9 application of CFLK standards, DOE proposes to 

10 withdraw the current accent lighting 30 days 

11 after the publication of the final rule, and 

12 consider all lighting packaged with the CFLK to 

13 be subject to energy conservation requirements. 

14 And DOE requests comment on this. 

15 (No comments.) 

16 MS. ARMSTRONG: Okay. Moving right 

17 along. 

18 MR. UPTON: (Indiscernible). 

19 MR. BROOKMAN: No. No comments here. 

20 Okay. 

21 MS. ARMSTRONG: You okay with it? 

22 MR. UPTON: Yeah. 
66 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 MS. ARMSTRONG: Okay. 

2 MS. KANTNER: All right. And then 

3 finally we come to requirements for the 

4 determination of representative values. 

5 And these are the requirements for 

6 determining representative values during Phase 1. 

7 I first just want to note that the general 

8 sampling requirements are applicable to all CFLKs 

9 except for CFLKs that are subject to a design 

10 standard to include a wattage limiter. 

11 If a CFLK does have a test procedure, DOE 

12 is trying to harmonize with existing DOE sampling 

13 requirements for various lamp types. So if you 

14 have a medium screw base CFL you would use the 

15 requirements for represented values that exist in 

16 429.35. This is DOE's requirements for medium 

17 screw based CFLs. For medium screw base 

18 integrated LEDs you would use the requirements in 

19 429.56. Again, this is just where requirements 

20 for integrated LED lamps exist for DOE. 

21 If you were to use a general service 

22 incandescent lamp you would use the requirements 
67 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 in 429.27. If you were to use a pin-based 

2 fluorescents you would use the represented values 

3 in 429.35, so you would use the requirements for 

4 medium screw base CFLs for consistency between 

5 those two types. And then this last line here is 

6 not a sampling requirement. This is just 

7 pointing to the place in the code where the 

8 design requirement for a wattage limiter exists. 

9 Okay. And then here are the requirements 

10 for determining represented values during Phase 

11 2. This would be applicable for compliance with 

12 amended energy conservation standards if 

13 established. For all CFLs in that case you would 

14 use the requirements in 429.35. Again, if you 

15 were to put a general service fluorescent lamp in 

16 a CFLK or an incandescent lamp, you would use the 

17 requirements in 429.27. For integrated LED lamps 

18 you would use DOE's requirements for integrated 

19 LED lamps in 429.56. For all other fluorescent 

20 lamps that are not CFLs or GSFLs—this would again 

21 mostly be circlines— you would use the same 

22 requirements as for CFLs. For all other SSL 
68 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 lamps that are not integrated LED lamps, you 

2 would again use the requirements for integrated 

3 LED lamps. And for CFLKs with integrated SSL 

4 circuitry you would use the requirements that 

5 currently exist in 429.33. These are the CFLK 

6 specific requirements for representative values. 

7 Note that in the future, since only lamp efficacy 

8 will be measured, only the lower confidence 

9 limit will continue to be there. 

10 MS. ARMSTRONG: So I just want to point 

11 out something on this slide. You know, it might 

12 not be something that you guys are used to or 

13 something that you're aware of currently, but for 

14 CFLKs, you know, with the other base now that 

15 doesn't have a test procedure but just is 

16 required for a -- for the wattage limiter. So 

17 we're proposing to move to either lamp efficacy 

18 or luminaire efficacy. And this is where this 

19 would matter. We've harmonized for the lamps to 

20 the representative values and what representative 

21 values are sampling sections. So the number of 

22 units you will actually have to test. And then 
69 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 the confidence limits associated with how you 

2 actually calculate the numbers that you can then 

3 represent on your marketing literature and the 

4 numbers you would have to certify to the 

5 Department. 

6 So if you haven't had a chance to look at 

7 this, it's something that you do want to pay 

8 attention to when you do make your comments 

9 because it affects the number you would have to 

10 test as well as how you can make representations 

11 about your product's efficiency. 

12 MR. BROOKMAN: David. 

13 MR. TURNER: David with Hunter. When you 

14 say "you" maybe that's a general you. 

15 MS. ARMSTRONG: Manufacturers of CFLKs. 

16 MR. TURNER: Of the lamps or the CFLKs? 

17 MS. ARMSTRONG: So the covered product is 

18 a ceiling fan light kit. The requirement is on 

19 the manufacturer of ceiling fan light kits. Now 

20 that being said, what we have done is harmonize 

21 with the lamp procedure. So if you're buying 

22 otherwise, lamps that are compliant with the lamp 
70 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 regulations and you trust them, it's still your 

2 responsibility but you trust them, you don't have 

3 to retest them. You know, you need to maintain 

4 documentation if DOE were to come and ask you for 

5 the documentation, you should have a copy of that 

6 lamp documentation. 

7 MR. TURNER: Okay. So, besides they, 

8 when you say you, that means the lamp 

9 manufacturer tests and then we trust what they 

10 test. 

11 MS. ARMSTRONG: It's up to you. That's 

12 your decision. I say the CFLK manufacturer has 

13 to comply with these regs. However you choose to 

14 do that, yourself or relying upon the lamp 

15 manufacturer in the room, that's up to you. 

16 That's a business decision. But we've given you 

17 that opportunity to not have to retest. 

18 MR. BROOKMAN: Yeah. Dave. 

19 MR. GATTO: This is more for you, Dave 

20 Turner. The challenge is that I'm assuming that 

21 you would have requested third-party test results 

22 that would back that up, which is what DOE would 
71 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 ask for -- 

2 MR. TURNER: Right. 

3 MR. GATTO: -- based on whatever the 

4 appropriate test procedure. But you're still 

5 responsible if the lamps that actually make it 

6 into your light kit don't test to the compliance 

7 that you reported, then it would be you -- 

8 MR. TURNER: Right. 

9 MR. GATTO: -- that's in the dialog. 

10 MR. TURNER: I understood there, I just -

11 - 

12 MR. GATTO: Yeah. 

13 MR. TURNER: We don't have planned 

14 testing -- 

15 MS. ARMSTRONG: So, and the reason I 

16 point out the last one is, the ones with 

17 integrated LEDs we're moving to this luminaire 

18 efficacy. I would imagine that it's a whole 

19 integrated type ceiling fan light kit thing. So 

20 you know, that test, those number of units that 

21 need to be tested, those calculations would be 

22 something new from what you're doing; a departure 
72 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 from what you're doing today. At least that's 

2 our proposal. So, I just wanted to point that 

3 out because that is different and sometimes 

4 people aren't aware that we actually have 

5 sampling provisions in addition to just the test 

6 procedure that govern how you make 

7 representations. 

8 MR. BROOKMAN: Okay. Additional 

9 comments? Thanks for the clarification. That's 

10 helpful. Final comments here before we move on? 

11 (No audible response.) 

12 MS. KANTNER: Okay. I think that's the 

13 end for the presentation for the test procedures. 

14 MR. BROOKMAN: Yes. 

15 MS. KANTNER: This is -- 

16 MR. BROOKMAN: And so we promised you 

17 another opportunity to comment here at the end 

18 before we talk about how to submit written 

19 comments. Final comments here, summary comments, 

20 issues that haven't been fully described? Dave? 

21 MR. GATTO: I don't know if it applies 

22 here or if its -- because tomorrow when we talk 
73 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 about fans you're reinterpreting what a ceiling 

2 fan is, which then in turn affects light kits. 

3 So we haven't as much time with light kits to 

4 review the documents. But as I read through this 

5 and as I read through the TSD, it seems like DOE 

6 is proposing that that reinterpretation would be 

7 effective 30 days from the publication of the 

8 test procedure, not in conjunction with the final 

9 rule. 

10 So my question would be, 30 days is just 

11 -- I mean, we can talk about it more tomorrow. 

12 It applies to fans. But as we speak about light 

13 kits it really does require an enormous amount of 

14 time to review the product lines, to add or 

15 change materials, build materials, add limiters 

16 if applicable in some of what are currently 

17 exempted fans which have a light kit, which you 

18 know, had been exempted. 

19 So I don't think we disagree with your 

20 interpretation. I think we talked about that in 

21 the last meeting, but maybe it's more for 

22 tomorrow's conversation, but I just want to point 
74 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 out that it affects CFLKs and it affects ceiling 

2 fans. And it just seemed like a very short -- I 

3 think you guys know from prior meetings and from 

4 what we've all fed Navigant, what the development 

5 timeline is for a fan and light kit, especially 

6 with the design elements that are included. 

7 Thirty days just seems it's impossible. But I'm 

8 not sure if you could help us understand the 

9 thinking behind it. 

10 MS. ARMSTRONG: So I'm going to -- this 

11 is Ashley from DOE. I'm going to mostly wait 

12 until tomorrow because it is teed up tomorrow. 

13 You're right, though, if we were to -- we have 

14 proposed to reinterpret the definition of a 

15 ceiling fan as encompassing huggers so if we did 

16 that it said CFLKs that are packaged with hugger 

17 fans would fall under the CFLK standards. The 

18 proposed date is 30 days. 

19 So when we talk about it tomorrow -- 

20 you've got all your facts right so kudos to you 

21 for reading the notice thoroughly. I would say 

22 be prepared tomorrow to come with a discussion 
75 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 piece about what your ask would be for a 

2 timeframe that's reasonable, and why. 

3 MR. GATTO: Okay. 

4 MS. ARMSTRONG: Okay? 

5 MR. BROOKMAN: Great. Thanks for that. 

6 Final comments before we bring this meeting to a 

7 closure? Your name, please? 

8 MR. ROO: Allen Roo with Emerson 

9 Electric. Going back to the accent lighting, 

10 would existing inventory be -- what term? 

11 Regulated by the new rule, 30 days? 

12 MS. ARMSTRONG: Ms. Barhydt, you want to 

13 answer that one? Existing inventory, would it 

14 kick in 30 days, for accent lighting if we were 

15 to reinterpret? 

16 MS. BARHYDT: I don't know the answer to 

17 that off the top of my head. 

18 MS. ARMSTRONG: So we'll get back to you. 

19 MR. ROO: Well, previously before EPAC 

20 2005 I think the existing inventory was allowed 

21 to be in the warehouse. 

22 MS. ARMSTRONG: So let us get back to you 
76 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 with the specific answer. Will you be here 

2 tomorrow? 

3 MR. ROO: Yes. 

4 MS. ARMSTRONG: Let us try to get back to 

5 your tomorrow. 

6 MR. ROO: And if it is, 30 days is not 

7 enough time to requalify a product. 

8 MS. ARMSTRONG: So 30 days is fine for 

9 accent lighting as well as its inventory is 

10 allowed to be sold through. Is that my 

11 interpretation of your -- 

12 MR. ROO: Yeah, and then, you know, new 

13 imports. Thirty days is not enough time to 

14 redesign the product and requalify it with the 

15 safety agencies. You're probably looking at 120 

16 days minimum. But I'd request about six months. 

17 MS. ARMSTRONG: So let me actually -- I 

18 guess I'm not understanding. I mean, DOE's 

19 interpretation of accent lighting, how does that 

20 impact your safety qualifications? 

21 MR. ROO: Well, you're going to include a 

22 new component, a breaker, a fuse, whatever it is. 
77 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 MS. ARMSTRONG: Okay. So that part of 

2 it. 

3 MR. ROO: You're going to have to go back 

4 to UL and -- 

5 MS. ARMSTRONG: Thank you. 

6 MR. ROO: -- and request they test them. 

7 MS. ARMSTRONG: Fair enough. Okay. 

8 Thanks for that clarification. 

9 MR. BROOKMAN: Yes. Thank you, Allen. 

10 Dick? 

11 MR. UPTON: Ashley, the issue of 

12 inventory on hand, what happens when you people 

13 go through retailers to find out what they've got 

14 and they've got products still on the shelf that 

15 may be two years old and three years old, and 

16 that's not uncommon. 

17 MS. ARMSTRONG: Right. 

18 MR. UPTON: Is the manufacturer going to 

19 have the problem of -- 

20 MS. ARMSTRONG: No. 

21 MR. UPTON: -- having old product around? 

22 MS. ARMSTRONG: So I'll limit this 
78 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 discussion to say we're talking about these 

2 ceiling fan light kits here because there are 

3 some nuances in some of our other products that 

4 just are not relevant here at all. 

5 But so typically our regs are at the 

6 point of manufacturer. So once it leaves the 

7 manufacturer's possession, or the point of 

8 import, I will clarify that because that's a, you 

9 know -- you know, but once it leaves the 

10 manufacturer's possession, once it crosses the 

11 border, once it goes out into the retail chain it 

12 is otherwise in commerce. But we wouldn't go 

13 back. We're looking for the date of manufacture, 

14 the date of importation. Those are the key 

15 dates. 

16 I will get a specific answer to 

17 reinterpretation questions though, for tomorrow 

18 from our legal staff. Just let me talk to them. 

19 Yep, no problem. 

20 MR. FLANNERY: It's also 30 days transit 

21 from once it leaves the port to cross the border. 

22 MS. ARMSTRONG: Okay. 
79 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 MR. BROOKMAN: Okay. Thank you, Tim. 

2 Okay. 

3 Final comments? Then back to Lucy. 

4 MS. DEBUTTS: Well, this is -- I'm sorry. 

5 I saw a hand? No? Okay. 

6 This is Lucy again. So as a reminder in 

7 closing for the test procedure in ceiling fan 

8 light kits written comments, we are expecting 

9 them by January 14th, 2015 and these are the ways 

10 to reach out to us. 

11 Now I just want to point out that if you 

12 accidentally send the comments not to the docket 

13 e-mail address but either me or the general e14 mail address, we'll still consider them. I had 

15 this question before so I just wanted to answer 

16 that. But please use the docket e-mail address. 

17 MR. BROOKMAN: Okay. So I think we are I 

18 guess ending the test procedure portion of this 

19 public hearing. We're going to take a break and 

20 then we're going to move on from the break to 

21 take up the energy conservation standards portion 

22 of the meeting. 
80 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 It's now 10:45. I think 15 minutes ought 

2 to be sufficient and so we'll resume here at 

3 11:00 and maybe, Emily, you can send out a 

4 message for anybody that would be interested that 

5 we're going to start early, the energy 

6 conservation standards portion; earlier than was 

7 reflected in the draft agenda. 

8 So I think most of you are familiar with 

9 the procedures around here. You must wear a 

10 badge visible in the Department of Energy. There 

11 are restrooms on both ends of the hall. The 

12 coffee shop is on the ground floor and we're 

13 going to resume at 11:00. We'll see you back 

14 here then. 

15 (Recess from 10:45 a.m. until 11:02 a.m.) 

16 MR. BROOKMAN: Let's resume. Good 

17 morning again, everyone. This is the Energy 

18 Conservation Standards Preliminary Analysis for 

19 Ceiling Fan Light Kits segment of today's 

20 meeting. 

21 Today is Tuesday, November 18th, 2014. 

22 We just finished this morning, first thing, a 
81 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 public meeting on test procedure notice of 

2 proposed rulemaking. Now we're moving on to the 

3 energy conservation standards segment. 

4 Before we go much further all of you have 

5 a detailed agenda in front of you. I won't 

6 restate what I stated this morning, but we also, 

7 the Department representatives have indicated 

8 that they have a follow-on comment from the 

9 morning meeting. Yes. 

10 So apparently Dave has a comment. 

11 MR. GATTO: So for the test procedure for 

12 integrated solid state lighting we had a 

13 discussion, Terry and I, offline, and we'd like 

14 you to consider including system efficacy. So 

15 the light engine. So which LM-79 would apply to. 

16 So rather than luminaire efficacy, which 

17 I know I said it was kind of fine with me, we 

18 think LM-79 would provide a method that's less 

19 expensive and less burdensome for manufacturers 

20 to be able to give us the light engine efficacy, 

21 the same as we would for lamps. So treat them 

22 like lamps from the standpoint of the test 
82 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 procedure where applicable. I mean, if there's a 

2 product that's not SSL where there isn't an 

3 existing test procedure we know you'd have to do 

4 luminaire efficacy. 

5 MR. BROOKMAN: Okay. So thank you for 

6 that. That's always helpful to get supplemental 

7 comment, additional comment and also of course 

8 the Department expects and hopes you will provide 

9 extensive and detailed written comments. 

10 MS. ARMSTRONG: So, Doug, can I ask one 

11 clarifying question? 

12 MR. BROOKMAN: Please, Ashley. 

13 MS. ARMSTRONG: It's not going to you, 

14 though, luckily. It's going to the corner. 

15 MR. BROOKMAN: Tim. 

16 MS. ARMSTRONG: You made a comment at the 

17 very end of this morning's proceeding regarding 

18 something about the delta between 30 days from 

19 leaving port maybe, until you bring in a product. 

20 I just wanted to clarify, what was that 30 day 

21 period you were referring to because I wasn't 

22 sure that I captured it correctly. 
83 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 MR. FLANNERY: Okay. This is Tim 

2 Flannery. 

3 You had mentioned that the effective date 

4 from when it actually crosses the border. So 

5 products, when they leave from Asia, which is 

6 predominantly where the proposed is coming and 

7 going from, going from port to the States is 

8 approximately 21 to 28 days. So realistically if 

9 product is actually leaving Asia today it's not 

10 going to be arriving here until 30 days from now. 

11 And sometimes in excess of that with customs and 

12 things of that nature. 

13 MS. ARMSTRONG: All right. So I just ask 

14 that you -- thank you for your clarification, and 

15 I just ask that you consider, when you make your 

16 comments, whether it be on the reinterpretation 

17 of the accent light or the reinterpretation 

18 tomorrow for the ceiling fans with respect to 

19 huggers, and then the implications that would 

20 have on ceiling fan light kits shipped with 

21 huggers that when you provide comments that you 

22 discuss what a reasonable time frame might be for 
84 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 those reinterpretations should we end up 

2 finalizing them as proposed after comment. 

3 MR. FLANNERY: Okay. Point noted. 

4 MS. ARMSTRONG: Thanks. 

5 MR. BROOKMAN: Thank you. Any additional 

6 clarifications, comments, related to this 

7 morning's test procedure discussion? Sometimes 

8 things bubble forward in the break. 

9 Okay. Then we're going to proceed, we're 

10 going to move on to the energy conservation 

11 standards preliminary analysis segment of the 

12 meeting, and Lucy deButts for opening remarks. 

13 MS. DEBUTTS: All right. Lucy deButts 

14 with DOE. So let's talk about submitting 

15 comments now on the energy conservation standards 

16 part of the ceiling fan light kits rulemaking. 

17 And this slide shows the docket number and RIN 

18 number that we are requesting to note when you 

19 send written comments in. The e-mail address is 

20 also listed, so as I stated earlier this morning, 

21 the electronic submissions are preferred, however 

22 if you can't accommodate that there is postal 
85 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 service and courier services allowed as well. 

2 The comment period for energy 

3 conservation standards rulemaking for ceiling fan 

4 light kits ends on December 30th of 2014. So we 

5 would like to have written comments submitted by 

6 that date. 

7 And now to opening remarks. 

8 MR. BROOKMAN: Opening remarks. Summary 

9 statements here at the outset; issues that matter 

10 to you. 

11 Yes, please. Marianne. 

12 MS. DIMASCIO: Hi. This is Marianne 

13 Dimascio from the Appliance Standards Awareness 

14 Project and just very brief comment saying that 

15 first of all thank you for the analysis and 

16 advancing the rulemaking to DOE. And at this 

17 time we tentatively support the regrouping of 

18 product classes, and also support the use of lamp 

19 efficacy as the primary metric for the revised 

20 standards. Thank you. 

21 MR. BROOKMAN: Thank you. It's nice to 

22 get comments that are supportive. That's 
86 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 helpful. 

2 Additional comments here at the outset? 

3 Then we'll proceed. 

4 MS. DEBUTTS: Just like earlier today 

5 with test procedures I'd like to share with 

6 everyone our projected schedule and this is shown 

7 on the slide that we're reviewing right now. 

8 So the framework document was published 

9 on March 11th of 2013. Then we followed up based 

10 on the comments we received and data and 

11 additional analysis, was the notice for the 

12 preliminary analysis of technical support 

13 documents availability on October 31st of 2014. 

14 We are projecting to publish the notice 

15 of proposed rulemaking for ceiling fan light 

16 kits. The NOPR in third quarter of 2015, which 

17 will be followed up by the final rule for ceiling 

18 fan light kits in the second quarter of 2016. 

19 And that would mean that the compliance dates for 

20 ceiling fan light kits would be projected during 

21 the second quarter of 2019. 

22 Any questions? 
87 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 (No audible response.) 

2 MS. DEBUTTS: No. Okay. Well, let's go 

3 into regulatory history for energy conservation 

4 standards. 

5 So, the test procedures and energy 

6 conservation standards both came out with the 

7 Energy Policy Act of 2005 and provided DOE with 

8 ability to establish energy conservation 

9 standards for ceiling fan light kits. 

10 So on October 18th of 2005 we also 

11 published the final rule, technical amendment 

12 that codified energy efficiency standards for two 

13 product classes. And since we did not do the 

14 codifying -- we didn't publish the final rule for 

15 the third class, on January 11th of 2007 DOE 

16 published the final rule technical amendment 

17 which codified energy efficiency standards for 

18 third product class as they were stated in the 

19 legislation. 

20 And the DOE's authority to conduct the 

21 energy conservation standard lies in the U.S. 

22 Code 42, part 6295(ff)(5). 
88 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 As to the scope of the coverage it's very 

2 similar to what we saw earlier today in the test 

3 procedure, and basically it's the same, not 

4 similar. As I said, the CFLK is defined as 

5 equipment designed to provide light from ceiling 

6 fans. They can be integral or attachable, and 

7 therefore any equipment designed to provide light 

8 from the product that are defined as ceiling fans 

9 under the ceiling fan rulemaking will be included 

10 in the scope for ceiling fan light kits 

11 rulemaking as well. 

12 And if you don't have any further 

13 questions on what was stated earlier, market and 

14 technology assessment, Colleen is back at the 

15 podium. 

16 MS. KANTNER: Hi. I'm going to try to 

17 adjust this mic a little bit. See if this helps 

18 at all. Any better? 

19 MR. BROOKMAN: That's better. 

20 MS. KANTNER: Okay. Alright. So now 

21 let's talk about the market and technology 

22 assessment. The purpose of the market and 
89 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 technology assessment is to characterize the 

2 ceiling fan light kit market, to define product 

3 classes, and to identify technology options. 

4 The methodology used is, first, we 

5 identify and characterize manufacturers of CFLKs. 

6 Then DOE identifies existing regulatory and 

7 voluntary efficiency programs, then gathers 

8 historical and other relevant market data, 

9 estimates market trends, and identifies measures 

10 that could improve efficiency. 

11 DOE first observed that CFLKs seem to be 

12 almost exclusively paired with low-volume ceiling 

13 fans, where volume refers to air flow. Low14 volume ceiling fans will be described and 

15 discussed tomorrow, but the general idea is that 

16 these are ceiling fans that are typically used in 

17 residential and certain commercial applications, 

18 but not industrial applications. 

19 Even if manufacturers were to begin 

20 producing CFLKs for high-volume ceiling fans in 

21 large number, DOE does not anticipate that they 

22 will have distinctive characteristics from 
90 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 ceiling fan light kits designed for low-volume 

2 ceiling fans, and therefore DOE only analyzed 

3 CFLKs designed for low-volume fans in its 

4 analysis. 

5 To obtain a better understanding of the 

6 CFLK market, DOE examined the market distribution 

7 of CFLKs broken down by product, class, and 

8 socket type. This was based on comprehensive 

9 store surveys at a number of stores for the three 

10 largest retailers of ceiling fans and light kits, 

11 as well as an examination of product offerings 

12 available online. 

13 These data were then weighted to get 

14 overall market shares. The breakdown of sales 

15 online versus in-store came from a consumer 

16 survey data from the market research firm, NPD, 

17 and the data were also weighted by price. 

18 Overall as you can see, candelabra based 

19 CFLKs in Product Class 3 dominated the market 

20 with some CFLKs with medium screw based CFLs and 

21 a few using GU-24s, but not a significant number 

22 of any other type, including pin-based 
91 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 fluorescent CFLKs. 

2 DOE also looked into historical 

3 shipments. DOE used data from NPD to estimate 

4 historical shipments of ceiling fans and ceiling 

5 fan light kits. Here are estimates from NPD of 

6 the total U.S. shipments of ceiling fans sold 

7 with and without CFLKs, along with shipments of 

8 ceiling fans for which it was not specified if 

9 the ceiling fan was sold with or without a light 

10 kit. 

11 DOE assumed that the ratio of ceiling 

12 fans sold with and without light kits was 

13 equivalent for consumers who did and did not 

14 specify if they had one and came up with the 

15 total estimates of sales with and without a 

16 ceiling fan light kit shown in the bottom table. 

17 Note that the fraction of ceiling fans 

18 sold with the ceiling fan light kit appears to be 

19 pretty constant over time. These numbers may not 

20 capture stand-alone CFLKs that were sold at a 

21 different time than the ceiling fan, but DOE does 

22 not believe that this would be a significant 
92 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 fraction of ceiling fan light kits, since 

2 consumers are likely to want to make sure that 

3 the light kit matches the style of the ceiling 

4 fan. 

5 This fraction is also consistent with the 

6 total fraction of ceiling fans installed with 

7 light kits from an LBNL study on ceiling fans and 

8 light kits. 

9 MR. BROOKMAN: Yes, David. 

10 MR. TURNER: David with Hunter. Was 

11 there an estimate for '12 and '13? 

12 MS. KANTNER: No, there was not an 

13 estimate available. 

14 MR. TURNER: I mean, did DOE or LBNL come 

15 up with one, I guess to -- as to the direction of 

16 the trajectory. 

17 MS. KANTNER: Mo, do you want to answer 

18 this? 

19 MR. GANESHALINGAM: We do a shipment 

20 projection -- 

21 MR. BROOKMAN: Let's get to a microphone. 

22 MR. GANESHALINGAM: Sorry. 
93 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 MR. BROOKMAN: Thank you. David, I want 

2 you to get that microphone closer to your face, 

3 please. 

4 MR. GANESHALINGAM: Hi, this is Mohan 

5 Ganeshalingam from Lawrence Berkley National Lab. 

6 Yes, we did a shipment trajection which 

7 we'll talk about later this afternoon. 

8 MR. BROOKMAN: Okay? 

9 MS. ARMSTRONG: But you guys should feel 

10 free to provide us data on shipments to help 

11 inform the analysis too. 

12 MR. TURNER: This is David with Hunter. 

13 I think -- and we'll discuss this later, but 

14 having some input from the two largest retailers 

15 as well would be very helpful and that's 

16 something that we're attempting, but also that we 

17 hope that we can, you know, somehow unite. 

18 MS. ARMSTRONG: That would be great. 

19 We're happy to work on that with you. 

20 MR. BROOKMAN: Thank you. Okay. 

21 MS. ARMSTRONG: Okay. 

22 MS. KANTNER: Then we have a couple of 
94 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 items for comment. DOE assumes that the majority 

2 of ceiling fan light kits are sold with ceiling 

3 fans and did not analyze ceiling fan light kits 

4 sold separately in its analysis, and DOE requests 

5 comments on this assumption and any available 

6 data on CFLKs sold separately. 

7 MR. BROOKMAN: David. 

8 MR. GATTO: Dave Gatto, Westinghouse. 

9 We, for the most part, agree with the 

10 analysis in terms of the percentage in that it's 

11 not meaningful. We looked at our own numbers. 

12 We can't obviously provide that individually, 

13 although I have provided some information to 

14 Navigant and I think Aisha and Michael. But for 

15 what it's worth we kind of agree with where 

16 you're at. It's probably the closest to reality 

17 that we're going to get. 

18 MR. BROOKMAN: Okay. Thank you. 

19 MS. KANTNER: DOE also seeks answers to 

20 the following questions related to ceiling fan 

21 light kits designed for high-volume fans. Do 

22 manufacturers anticipate that ceiling fan light 
95 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 kits designed for high-volume fans will 

2 constitute a significant fraction of the CFLK 

3 market in the next five to 10 years? What range 

4 of lumen outputs would these products be designed 

5 to achieve, and would these CFLKs be likely to 

6 have any unique characteristics that are not 

7 common to the current market of CFLKs? 

8 MR. BROOKMAN: Three rather specific 

9 questions. Yes, Nathan. 

10 MR. FRAMPTON: This is Nathan with 

11 Fanimation, just a comment. I think on the high12 volume questions you're not going to get much 

13 response today because I don't think there's any 

14 high-volume manufacturers represented here. 

15 MS. KANTNER: Understood. 

16 MR. BROOKMAN: Okay. Thank you. Dave? 

17 MR. GATTO: So with -- and I've provided 

18 this information to Navigant. With high 

19 volume/small diameter, which is the one high20 volume fan that Westinghouse produces, we don't 

21 include light kits. We don't really see that 

22 changing, the applications, the industrial 
96 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 applications that are in are typically high 

2 enough up that there wouldn't be a light source 

3 capable of giving the light. Typically the space 

4 is lit in some other manner and the fan is being 

5 used because there is either no other HVAC system 

6 in place or as a supplement to that. 

7 MR. BROOKMAN: Can you say what the range 

8 of lumens is approximately? 

9 MR. GATTO: I think the short answer is, 

10 we don't have a high-volume industrial fan with a 

11 light kit, and we're not planning one. 

12 MR. BROOKMAN: Uh-huh. 

13 MR. GATTO: I don't know what lumens you 

14 would put on one. I mean, in minimum height 

15 requirements it's going to be way up high in the 

16 air. 

17 MR. BROOKMAN: Yeah. 

18 MR. GATTO: Typically there is some other 

19 light source. If it's an industrial application 

20 it might be HID or LED now is taking center 

21 stage. Or typically linear fluorescent is in 

22 place. 
97 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 MR. BROOKMAN: Okay. 

2 MR. GATTO: High Base. Something. 

3 MR. BROOKMAN: Yeah. Okay. Thank you. 

4 Nathan, you have a -- no? Nothing? Okay. 

5 MS. KANTNER: Okay. So next is the 

6 product classes that DOE considered. Pursuant to 

7 EPCA, DOE establishes product classes based on 

8 three criteria. First, by the type of energy 

9 used, by the capacity of the product, and by any 

10 other performance related features that require 

11 different standard levels such as features 

12 affecting consumer utility. 

13 As far as energy used, DOE notes that all 

14 CFLKs use electricity. In regards to capacity, 

15 and by capacity we mean total light output, CFLKs 

16 do not require different product classes to 

17 account for a capacity. So the remaining 

18 criterion is utility. The three original product 

19 classes were defined in terms of socket type, 

20 which DOE does not see as providing the unique 

21 utility that would necessitate a different 

22 efficiency standard. 
98 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 DOE believes that utilities such as 

2 instant on, color quality, and dimming, which are 

3 provided by incandescent lamps are also available 

4 in more efficacious replacements such as LED 

5 lamps and luminaires. 

6 DOE did, however, find a unique utility 

7 in CFLKs that use externally ballasted or driven 

8 lamps, in that they allow consumers to replace 

9 the lamp or the ballast separately if one fails 

10 independently of the other. Additionally, 

11 externally ballasted lamps may have different 

12 cost efficiency relationships from internally 

13 ballasted lamps, so they may require a different 

14 efficiency standard. 

15 As a result DOE is considering two 

16 product classes: Externally Ballasted or Driven 

17 lamps, and All Other CFLKs. Since there are not 

18 externally driven CFLKs currently on the market, 

19 with respect to the products currently on the 

20 market, the new product class structure 

21 essentially combines current product classes 1 

22 and 3 into a new product class 2. 
99 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 Now we have some items for comment. 

2 First, DOE is considering a new product class 

3 structure that divides CFLKs into two product 

4 classes that we just mentioned. DOE invites 

5 comment on this structure. 

6 MR. BROOKMAN: Dave. 

7 MR. GATTO: So, and this may come as a 

8 surprise to DOE, but I think we agree with, or at 

9 least Westinghouse, we agree with the fact that 

10 LEDs will replace the utility of traditional 

11 incandescent. 

12 I think the challenge that it presents is 

13 going to show up more in the LCC where I have 

14 some questions about how you did the analysis. 

15 What I would like DOE to consider is that the 

16 utility that may get lost in there is going to be 

17 on the design side because currently, and even if 

18 you look three years out, while LEDs are moving 

19 at a very fast pace, the majority of the 

20 development or at least the fastest pace is A 

21 lamp manufacturers, not necessarily fan 

22 manufacturers who have to buy from a lamp 
100 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 manufacturer. So they're going to trail the 

2 development and price learning. 

3 The other thing that you're -- a little 

4 bit of an issue, at least for the candelabra 

5 based light kits that are out there is that, it's 

6 tough to get the same lumen package in that small 

7 of a space and maintain hours with an LED today. 

8 You have heat issues. So it's going to get 

9 there. It's going to get there very quickly, but 

10 finalizing a rule with fans that requires the use 

11 of products that aren't quite ready for primetime 

12 is a concern, I think, for the fan industry. 

13 MR. BROOKMAN: Okay. Thank you. 

14 Additional comments on product classes, the 

15 combination that's being proposed here? 

16 Okay. 

17 MS. KANTNER: Okay. DOE requests comment 

18 on whether manufacturers are currently producing 

19 or expecting to produce CFLKs that use externally 

20 driven LED lamps. 

21 MR. BROOKMAN: Okay. 

22 MS. KANTNER: Okay. And DOE -- 
101 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 MS. ARMSTRONG: So can we interpret 

2 silence as meaning no? 

3 MR. BROOKMAN: Yes, Terry. 

4 MS. KANTNER: I'll ask in a more direct 

5 way. 

6 MR. MCGOWAN: Terry McGowan, American 

7 Lighting Association. 

8 When you mean externally driven LED lamps 

9 what we're seeing is a circuit board with LEDs on 

10 it and a driver in the middle. That's external 

11 to the LEDs. It does not -- is that included in 

12 your definition? 

13 MS. KANTNER: Are the LEDs consumer 

14 replaceable? 

15 MR. MCGOWAN: No. 

16 MS. KANTNER: Then, no. 

17 MR. BROOKMAN: I didn't hear your answer. 

18 MS. KANTNER: Oh. Then, no. 

19 MR. BROOKMAN: Then, no. Okay. 

20 MR. MCGOWAN: So you're defining this as 

21 an LED assembly with an external driver, 

22 physically separate from the LED assembly. 
102 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 MS. KANTNER: We're envisioning something 

2 that's equivalent to a pin-based CFL, where 

3 you've got a consumer replaceable lamp and then a 

4 ballast or driver that's integral to the light 

5 kit. 

6 MR. MCGOWAN: Yeah, that's the problem 

7 because the LED assembly is not consumer 

8 replaceable. The LEDs are soldered in place, 

9 can't be replaced, the assembly is custom built 

10 to fit into the light -- 

11 MS. KANTNER: Right. In that case it 

12 would be in the all other product class. 

13 MS. ARMSTRONG: So your answer to the 

14 question then, would be no. 

15 MR. MCGOWAN: Okay. Thank you. 

16 MR. BROOKMAN: Nathan, please go ahead. 

17 MS. ARMSTRONG: Yep, that's what I'm 

18 talking about too. So the answer is you don't 

19 see it going there. 

20 MR. LINSTONE: This is Clark Linstone, 

21 Lamps Plus. 

22 Are you referring to basically an LED 
103 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 bulb that is, you know, the unit unto itself 

2 irreplaceable, therefore that would fall into 

3 this. Is there any contemplation of any fan 

4 manufacturers including LED bulbs? Is that the 

5 question? 

6 MR. BOESENBERG: This is Alex Boesenberg, 

7 NEMA. 

8 I think what -- since I don't work with 

9 fan manufacturers, coming from the commercial 

10 lighting side what this sounds like to me is 

11 maybe the question -- Ashley, tell me if I get it 

12 right. For the question for the fan 

13 manufacturers is, do you plan in the future, or 

14 are you currently offering ceiling fans with a 

15 Zhaga socket base or some kind of connections 

16 where you could snap in LED modules. You know, 

17 so a consumer changeable LED light source that -- 

18 I mean, I haven't really seen these on the store 

19 shelves yet, but that is one of the goals of 

20 organizations such as Zhaga, to come up with 

21 something that is like a bayonet connect or 

22 something. So, if anyone is thinking of that 
104 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 then I think that would be relevant to this item. 

2 MR. BROOKMAN: Nathan. 

3 MR. FRAMPTON: I mean, my assumption 

4 would be yes. The answer is yes. 

5 MR. BROOKMAN: Uh-huh. Ali, do you want 

6 to chime in here? Nothing. Okay. Nothing. 

7 I get the sense that we haven't fully 

8 covered this. And, Terry, you want to add some 

9 more content here, please? 

10 MR. MCGOWAN: Yes. Terry McGowan again. 

11 MR. BROOKMAN: I don't think we've even 

12 described the parameters on that LED fixture yet, 

13 right? Keep going. 

14 MR. MCGOWAN: No, we're very worried that 

15 this is either not inclusive enough or too 

16 inclusive and I'm not sure we know exactly which. 

17 What we're seeing, of course, is a lot of changes 

18 in the way LEDs are put into lighting products. 

19 And Alex very properly brought up the fact that 

20 Zhaga and other systems folks are making up new 

21 sockets. And these sockets will impinge upon the 

22 design of these light kits. They're not now, but 
105 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 they will. 

2 And we're trying to look ahead five, 10 

3 years here, and say okay, is this going to make 

4 life worse or better? And we don’t know yet. We 

5 have to think about this a little bit, but we're 

6 glad you brought it up and you'll definitely get 

7 some comments. 

8 But I guess right now what we need to do 

9 is ask questions so we understand what it says. 

10 And that's what I was trying to do and I think 

11 Alex helped. 

12 MS. KANTNER: If I could just clarify 

13 further... The idea for this product class is that 

14 there is a utility to being able to switch out 

15 the lamp separate from the driver. So if it's a 

16 consumer replaceable lamp that's separate from 

17 the driver, that would be what would fall into 

18 that category. 

19 MR. BROOKMAN: Allen. 

20 MR. ROO: We do offer an LED array that's 

21 AC driven with an integrated, you know, drivers 

22 integrated into the actual LED array. And it is 
106 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 available as a repair part with the heat sink 

2 integrated with it as an assembly. So that's on 

3 the market today. 

4 MR. BROOKMAN: Yeah. Thank you. David. 

5 MR. GATTO: So I think this is one of 

6 those things where we don't know where all the 

7 places LED is going. And as Alex kind of 

8 mentioned on an aside, we have seen in the 

9 commercial marketplace, interest in replaceable 

10 driver, replaceable module. But that's where the 

11 maintenance issue is kind of more controllable. 

12 I think the question might be, and I don't know 

13 that we can answer -- I can't answer it as a fan 

14 manufacturer so I don't know that these guys can 

15 either. I think what you're asking is, are we 

16 planning to, at some point, offer where the 

17 driver and the module are replaceable by the 

18 consumer, not necessarily as a repair part. 

19 I'd like to get clarification on that, 

20 Ashley. But as a product that's for sale in 

21 commerce, in which case, you know, how do you 

22 incorporate it into the rule, and I don't know 
107 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 that we can give you any kind of answer at all. 

2 And honestly this is what we were talking about 

3 earlier. This is where it gets scary that the 

4 technology is moving so fast that the rule is 

5 going to come out and then there's going to be 

6 something that we can't do that everyone in the 

7 room would want us to do because it's not -- the 

8 scope doesn't allow it. 

9 MS. ARMSTRONG: So I think you just hit 

10 where I was going to go with the question. So if 

11 you can't specifically answer the question it 

12 seems like it's somewhere out there in the future 

13 to be determined. The likelihood of it happening 

14 is high, but how exactly it will happen and what 

15 its impact will be is a little bit yet unknown. 

16 I think about it on the other side. Is 

17 what we're proposing here for product class 

18 consolidation, would that have a negative impact 

19 or would that in some reason inhibit your ability 

20 to potentially do this in the future? That's 

21 what I think we want to know. 

22 And perhaps, you know, what we're 
108 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 proposing here, or the levels we may be analyzing 

2 here because we haven't actually proposed 

3 anything quite yet, but you know, it's not a 

4 detrimental impact at this time. But I don't 

5 think we're necessarily out to inhibit 

6 innovation. We're not out to inhibit innovation 

7 either. 

8 So I think asked another way is, think 

9 about it in what we are proposing to do, and is 

10 there anything that you would see limiting your 

11 future? Obviously, you know, standards increase 

12 the efficiency, blah, blah, blah. But, you know, 

13 limiting in the space at least. 

14 MR. BROOKMAN: Right. So can we get a 

15 comment? 

16 MS. ARMSTRONG: I don't think we need to 

17 answer it now. 

18 MR. BROOKMAN: Okay. 

19 MS. ARMSTRONG: It's just, when you take 

20 it back and think about this a little further, 

21 you know, flipped around the other side, I think 

22 that's what we're really searching for here. 
109 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 MR. BROOKMAN: Okay. Dick. 

2 MR. UPTON: Actually, you're saying -- 

3 MR. BROOKMAN: Dick, use the microphone. 

4 MR. UPTON: You're saying in effect, you 

5 may be ahead of the industry. And if that's -- 

6 MS. ARMSTRONG: That would be a first. 

7 MR. UPTON: Yeah. And if that's the 

8 case, I compliment you on your concern about 

9 inhibiting the marketplace and what might be able 

10 to be developed, and we'll just have to do our 

11 best to respond. 

12 MS. ARMSTRONG: Just think about it, 

13 yeah. I mean, I'm not sure that we are 

14 necessarily and obviously we didn't aim to do 

15 that, so -- but we wanted to make sure we at 

16 least heat up the issue. 

17 MR. UPTON: Yeah. Well done. 

18 MR. BROOKMAN: Okay. And then on to 

19 dimming. 

20 MS. KANTNER: Yes. So the last item for 

21 comment on this slide is about dimming. DOE seeks 

22 data on the dimming functionality of the current 
110 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 generation of CFL and LED lamps, and specifically 

2 on the performance of those lamps with dimmers 

3 designed for their control. DOE seeks data on 

4 consumer satisfaction with the dimming 

5 functionality of these systems. DOE also seeks 

6 input from manufacturers as to whether they 

7 anticipate accommodating dimming functionality 

8 into LED CFLK modules they will offer for sale in 

9 the next five years. And if so, what fraction of 

10 LED CFLKs would include such functionality? 

11 MR. BROOKMAN: Dave? 

12 MR. GATTO: I can weigh in on part of 

13 this. So consumers hate -- Dave Gatto, 

14 Westinghouse. See, this is what Alex is here 

15 for. 

16 Dave Gatto, Westinghouse Lighting. 

17 So CFLs don't dim well, and even the ones 

18 that do, consumers don't like, and even when they 

19 sort of like them the price is prohibitive and 

20 there are other issues. LED does bring a lot 

21 more functionality to the party. The two 

22 challenges there are going to be cost, the 
111 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 initial cost to the consumer is a big impact 

2 compared to current incandescent and halogen, 

3 which in your own analysis represents somewhere 

4 in the 80 percent of the current market range for 

5 CFLKs. 

6 The other thing is that dimming is still 

7 one of those things that sometimes it works and 

8 sometimes it doesn't, and there's a lot of 

9 factors at play. And so I don't know that LEDs 

10 today or even in the short term future are going 

11 to completely replace the kind of functionality 

12 we have with incandescent light sources to the 

13 consumer satisfaction. And I think that's the 

14 challenge if we promulgate a rule that creates 

15 consumer dissatisfaction its very disruptive to 

16 the industry and to consumers, and their 

17 alternative is less energy efficient products, 

18 whether it be HVAC offset, or whether it be they 

19 don't put a ceiling fan up and they put a, you 

20 know, five light or a three light flush mount 

21 that doesn't have currently any regulations on it 

22 other than whatever is at the lamp level. 
112 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 MR. BROOKMAN: Okay. Thank you, Dave. 

2 Additional thoughts on dimming? You can see the 

3 question, the comment box. 

4 Yes, Allen. 

5 MR. FRAMPTON: Nathan with Fanimation. I 

6 would say that a very high percentage will be 

7 dimming; will be able to have that functionality. 

8 MR. BROOKMAN: Thank you. Okay. Moving 

9 on. 

10 MS. KANTNER: All right. Now moving on 

11 to technology options. The technology assessment 

12 identifies technology options that can improve 

13 ceiling fan light kit efficiency. The assessment 

14 provides a basis for the screening and 

15 engineering analysis. 

16 Lamps are the components that have the 

17 greatest impact on CFLK active mode power 

18 consumption. Light source technology is the 

19 primary factor that affects lamp efficacy. DOE 

20 is considering not including external ballasts as 

21 a technology option for CFLKs. As discussed 

22 earlier the test procedure proposes to rate the 
113 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 efficacy of CFLKs that use external ballasts 

2 based on the performance of the lamp tested on a 

3 reference ballast, so a more efficient ballast in 

4 the CFLK would not change the rated performance. 

5 DOE is also considering not including 

6 lighting controls as a technology option in the 

7 rulemaking. The energy savings from controls 

8 cannot be measured by the methods specified in 

9 the test procedure. In general, remote controls 

10 are the only method of lighting control packaged 

11 with the CFLK, but such controls are virtually 

12 always incorporated into the fan housing and 

13 control both the ceiling fan and the light kit. 

14 Therefore DOE is considering only more 

15 efficacious light sources as a technology option 

16 for CFLKs. And then we have a couple of items 

17 for comment. 

18 First, DOE requests comment on its 

19 proposal not to include lighting controls as a 

20 technology option in this rulemaking. 

21 MR. BROOKMAN: Dave. 

22 MR. GATTO: Dave Gatto, Westinghouse 
114 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 Lighting. We agree with that proposal. 

2 MR. BROOKMAN: Okay. Thank you. 

3 Additional comments? 

4 Okay. 

5 MS. KANTNER: DOE requests comment on 

6 lamps being considered as the technology option 

7 for CFLKs and any additional options that should 

8 be included. 

9 MR. BROOKMAN: Dave? 

10 MR. GATTO: Dave Gatto, Westinghouse. 

11 Just a question. Are you asking for feedback on 

12 the specific lamps being considered as well as 

13 other options? 

14 MS. KANTNER: Sure. 

15 MR. GATTO: All right. So I'm just going 

16 to kind of repeat the earlier comment, and I 

17 don't know the solution to this so I'm just going 

18 to throw it out there. I think more efficacious 

19 light sources is the best play. My concern is if 

20 they are for certain small profile lamps, 

21 candelabra base in particular, there aren't any 

22 really more efficacious that would meet 
115 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 anybody's, including my definition of energy 

2 efficient. 

3 So leaving them out, which is the 

4 proposal to combine to a two class system, 

5 potentially could create some headaches for the 

6 consumer. I don't really have anything I would 

7 recommend other than LED, though, as that 

8 solution. So I can see the question on your 

9 face, Ashley, I just don't know what it is. 

10 MR. BROOKMAN: Ashley. 

11 MS. ARMSTRONG: You can let Alex go 

12 first. That's okay. 

13 MR. BOESENBERG: Alex Boesenberg, NEMA. 

14 Dave, you correct me if I miss the mark but I 

15 think what you're saying or to maybe more 

16 thoroughly or expand on that conversation, it's 

17 you know, for ALA, NEMA submitted comments to 

18 California Title 20 regarding some of their 

19 proposals where there was a predilection towards 

20 moving to LED only technology due to the efficacy 

21 levels. 

22 And the point we made, to bring this back 
116 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 around to this meeting, is that in the case of 

2 halogen technology, while LED might be 

3 technically feasible there, the market is so 

4 small that a few if any manufacturers have moved 

5 to supply LED options. And so if this is also 

6 true in the replacement lamps for the ceiling fan 

7 industry, it could be that it's not that LED is 

8 not capable, but no one bothers to make it 

9 because it's such a small market. 

10 MR. GATTO: So I think for a percentage, 

11 and it might be in that four to eight percent 

12 range from the earlier slide, there are some 

13 noncandelabra or intermediate based light kits. 

14 I think candelabra is something that, as a light 

15 bulb manufacturer, yes, we're developing 

16 candelabra based lamps. The challenge is getting 

17 the lumen package and the lifetime in the 

18 candelabra base that will fit inside the 

19 traditional fan light kit, where you're not going 

20 to have some other issues, or where you're going 

21 to be able to meet the efficacy that's laid out. 

22 I think my bigger concern is that by 
117 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 going to a two class system -- and I know you've 

2 laid this out in the TSD or -- yeah, I think it's 

3 in the TSD. Because of the no backsliding rule 

4 your minimum efficacy requirement would be the 

5 current Energy Star 3.0, which there is no 

6 incandescent or halogen lamp that can hit, nor 

7 are there any planned that can hit, particularly 

8 in small profile. 

9 So two classes from a lamp manufacturer 

10 make sense to me. From the fan side it does 

11 limit design options and it does create some 

12 consumer cost issues that I don't -- when we get 

13 there I'll comment, or maybe I'll ask some 

14 questions, but I don't know that it was really 

15 properly caught in the LCC because the way I read 

16 it, because you made the assumption that there 

17 wouldn't be any, because in a two class system 

18 they can't exist, your baseline for pricing for 

19 the consumer cost starts at the current CFLK that 

20 includes a medium based CFL. But that product is 

21 more expensive to the consumer than an 

22 incandescent base socketed light kit. 
118 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 Does that make sense? 

2 MS. ARMSTRONG: It makes sense. We'll 

3 discuss. 

4 MR. BROOKMAN: Terry. 

5 MS. ARMSTRONG: Thank you. 

6 MR. MCGOWAN: Terry McGowan, American 

7 Lighting Association. I note that there are no 

8 lighting control manufacturers here and I do hope 

9 that they will comment on this because I am not 

10 sure that this idea of not including the energy 

11 saving potential of lighting controls is valid. 

12 Lighting controls can be as powerful as 

13 efficacy in energy savings. And the trick is to 

14 consider how they might be used and would 

15 contribute to that. That is a little more 

16 complicated than efficacy, but it's nonetheless 

17 powerful. And so I think the lighting controls 

18 folks should comment, and also that we should be 

19 open to some procedures, perhaps not in the test 

20 procedures that we have so far, for incorporating 

21 these energy savings. 

22 If we're going to demand ever further 
119 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 energy savings, which has been the history of 

2 these regulations, then we should look at all of 

3 the options, not just efficacy. 

4 MR. BROOKMAN: Okay. 

5 MS. ARMSTRONG: So this is Ashley from 

6 DOE. And in following to that, this gets a 

7 little bit back to this morning's presentation on 

8 our efforts to harmonize with lamp efficacy. 

9 To the extent we start talking about 

10 lighting controls, and I think the Department's 

11 position is, we agree, they're an important tool 

12 in the tool kit to reduce energy usage and 

13 provide a potential for savings. But you're 

14 right, we would have to go back and revisit the 

15 test procedures. 

16 And if we did revisit those test 

17 procedures it could be a departure from lamp 

18 based efficacy harmonization. So I would be 

19 interested in hearing comments because, you know, 

20 we want to make sure our analysis are consistent 

21 internally so that's one of the reasons driving 

22 this decision. 
120 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 You know, there was some support earlier 

2 for this harmonization effort and lamp based 

3 efficacy or system/luminaire efficacy. But in 

4 order to fully implement controls, at least in my 

5 opinion, the correct way, you would have to 

6 recalculate the -- or you would have to revamp 

7 the test procedures. And then they would become 

8 more like luminaire, ceiling fan light kit type 

9 test procedures rather than just lamp based. 

10 So I would definitely like to hear from 

11 the fan manufacturers about that. 

12 MR. BROOKMAN: No response at this time. 

13 Dave. 

14 MR. TURNER: I think this is something 

15 that we'll revisit in our written comment. You 

16 know, we haven't had time to adequately dive into 

17 that. 

18 MR. BROOKMAN: Okay. Thank you. Okay. 

19 We're moving on then. 

20 MS. KANTNER: I just wanted to quickly 

21 follow up with a comment that Dave, that you 

22 made. So in the preliminary analysis DOE stated 
121 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 that it didn't think that there was a utility 

2 associated with different socket types. And 

3 could you comment on the utility of candelabra 

4 bases versus medium screw bases or other base 

5 types? 

6 MR. GATTO: It's really more on the 

7 design side. So, you have different light kits 

8 that you're meeting different design 

9 considerations, and a medium base light kit is 

10 going to be physically larger and it typically 

11 has an A15 or an A19 shape lamp, an A-type. 

12 Where candelabra typically is either a bullet, 

13 kind of a torpedo shape, the chandelier look. So 

14 there are applications, particularly in 

15 candelabra where you've got some design elements 

16 that have to do with more of the decorative 

17 aspect of the light kit than with light output or 

18 efficiency, or things like that. 

19 You have the same thing in some of these 

20 alternate specialty bases, whether it be you 

21 know, E11 halogen or bi-pin or pin-based halogen 

22 where you might have a particular design element 
122 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 where you want a lot of light in a very small 

2 space. You can accomplish that with halogen. 

3 You can't really accomplish that with LED today. 

4 And to Alex's point, there is not a lot 

5 of product development, and I'm including my own 

6 product line in that, to fill those niches 

7 because the volume associated with a 100 watt 

8 double ended halogen is much, much, much smaller 

9 and with the heat dissipation issues, I mean, LED 

10 light source, if you want that much light in a 

11 small space you're typically designing a whole 

12 luminaire around it so that you have a place to 

13 put the heat. So it's a design issue. 

14 So that utility though, and I know DOE, 

15 and I acknowledge you for it, John in particular 

16 in the first meeting we had, DOE acknowledged 

17 that there is a design element to this product. 

18 It's not an appliance that's purely functional. 

19 It has a style or a fashion appeal to the 

20 consumer that it affects manufacturers because it 

21 impacts the buying decision, but it also affects 

22 consumers because they have a particular thing 
123 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 that they want the utility of, matching a décor 

2 or a particular look that they're aiming for. 

3 Does that help? 

4 MS. KANTNER: Yes. Alright. Moving on. 

5 So up next is the screening analysis which Julie 

6 Pierce from Navigant will present. 

7 MS. PIERCE: Hello. My name is Julie 

8 Pierce and I'm with Navigant. I will first 

9 discuss the screening analysis. 

10 Technology options identified are 

11 evaluated against four criteria, which are that 

12 the option is technologically feasible, it is 

13 practicable to manufacture, install, and service 

14 on a commercial scale by the compliance date of 

15 the standards, it does not have adverse impacts 

16 on utility to consumers or availability, and that 

17 it does not have adverse impacts on health or 

18 safety. 

19 Those technology options not screened out 

20 are analyzed as design options in the engineering 

21 analysis. For CFLKs the technology option under 

22 consideration is more efficacious light sources. 
124 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 DOE did not screen out a more efficacious light 

2 source as an option for improving efficacy of 

3 CFLKs. DOE invites comment on the screening 

4 analysis. 

5 MR. TURNER: David with Hunter. I think 

6 we would just continue to echo what Dave Gatto 

7 has presented as far as adverse impacts with the 

8 more efficacious light kits, or light lamps being 

9 considered. 

10 MS. PIERCE: Okay. 

11 MR. BROOKMAN: Okay. 

12 MS. ARMSTRONG: So I'm just going to 

13 follow on to that just to kind of -- while those 

14 general comments are helpful, we really need 

15 details. And perhaps you've given them. I'm not 

16 as, you know -- but as Julie goes on to the next 

17 set of slides and presents the engineering and we 

18 talk about how we actually develop these cost 

19 curves for particular things, what I'm hearing, 

20 I'm going to translate what Dave said to me, is 

21 either two things. One is, you know, for all 

22 different base types and/or designs or 
125 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 configurations you may offer right now to a 

2 consumer, either more efficacious bulbs may not 

3 be available across the board. It would be 

4 helpful to know exactly which ones they are. Or 

5 they come at a different cost, also would be 

6 helpful to know what that delta cost would be 

7 that is different. 

8 That's the stuff, and those details, at 

9 that level of detail is really what's most 

10 helpful to drive the analysis. So think about 

11 that. And if there are comments that they're 

12 sensitive and you don't necessarily want to make 

13 on the record, we have avenues for sharing that 

14 type of information. But like I said, that's 

15 really what is driving the foundation of the 

16 analysis. 

17 Sorry about that. 

18 MR. BROOKMAN: No, that's good. That's 

19 helpful. Dave, please. 

20 MR. TURNER: Dave from Hunter. I think 

21 you'll get a fair portion of the detail in the 

22 written analysis. 
126 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 MS. ARMSTRONG: Okay. 

2 MR. TURNER: Just because we didn't have 

3 as much time with the CFLK portion of the TSD and 

4 test procedures, so we'll be more thorough there. 

5 And as far as cost deltas and whatnot, I think 

6 if, you know, whatever those avenues are we 

7 probably need to talk about them -- 

8 MS. ARMSTRONG: Sure. 

9 MR. TURNER: -- because I think those do 

10 need to be discussed by manufacturer. 

11 MS. ARMSTRONG: That would be great. We 

12 welcome all of it. So you're telling me I should 

13 really prepare for tomorrow because you guys came 

14 prepared for tomorrow? 

15 MR. TURNER: Well, we had more time with 

16 that, so -- but yeah. So I mean, right now we're 

17 talking more about lamps which, you know, we 

18 don't have as -- 

19 MS. ARMSTRONG: So I should get a really 

20 good night's rest tonight. 

21 MR. TURNER: Oh, yeah. Get to bed early. 

22 MS. ARMSTRONG: Got it. 
127 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 MR. TURNER: That's fair. 

2 MR. BROOKMAN: Okay. 

3 MS. PIERCE: Okay. Thank you. Next I 

4 will go over the engineering analysis. 

5 DOE used the following general 

6 methodology to develop the engineering analysis 

7 for CFLKs. Of the product classes identified DOE 

8 first selected certain representative product 

9 classes to directly analyze. DOE then selected 

10 baseline models for each representative product 

11 class to use as reference points. After that for 

12 each baseline model DOE identified more 

13 efficacious substitutes based on design options 

14 identified in the screening analysis. 

15 DOE then developed candidate standards 

16 levels, or CSLs that span the range of efficacy 

17 from baseline to the maximum technologically 

18 feasible level. 

19 Finally DOE scaled its results to any 

20 product classes not directly analyzed. 

21 In general DOE chooses representative 

22 product classes on which to focus its analytical 
128 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 effort. Of the two CFLK product classes which 

2 are shown in this table, both were chosen as 

3 representative. All Other CFLKs encompasses 

4 self-ballasted lamps. This product class was 

5 chosen as representative because it constitutes a 

6 majority of CFLK sales. 

7 Examples of lamps in the Externally 

8 Ballasted product class include circline 

9 fluorescents and pin-based CFLs. It was chosen 

10 as representative because the CFLKs in this class 

11 offer a unique utility in their ability to allow 

12 the consumer to replace the lamp and ballast 

13 separately in the event of failure. Additionally 

14 the efficacies of externally ballasted/driven 

15 lamps do not include losses from the ballasts. 

16 Thus, lamps in the Externally Ballasted or Driven 

17 product class have a different cost efficiency 

18 relationship than lamps in the All Other CFLKs 

19 product class. 

20 DOE requests comment on the 

21 representative product classes for CFLKs. 

22 MR. BROOKMAN: Dave? 
129 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 MR. GATTO: I'm just going to repeat, 

2 it's already out there. I'm not going to say it 

3 all again. But not having a third product class 

4 really eliminates some design options. 

5 MR. BROOKMAN: Okay. Thank you. 

6 MS. ARMSTRONG: What third product class 

7 are you asking for, just to be clear? 

8 MR. GATTO: It's tough. You know, I 

9 think I said this earlier actually. I don't 

10 know. 

11 MS. ARMSTRONG: Oh, okay. 

12 MR. GATTO: I think that as a lamp 

13 manufacturer I'm on board with the move towards 

14 LED. I think the challenge that this particular 

15 rulemaking is coming early enough in the LED 

16 development cycle that I don't know whether we'll 

17 be where you're going to need us to be by 2019, 

18 and because we're in the rulemaking timeframe 

19 this is where just like we talked about, I'm 

20 concerned that we're going to pass a rule that 

21 then makes it very troublesome from that 2019 to 

22 maybe 2022. There's a period of time where it 
130 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 could be very very disruptive for fan 

2 manufacturers. 

3 So I don't know how to say it any better 

4 than that. I don't really want incandescent and 

5 halogen in the product class, but I don't know 

6 how to get at the piece that -- I'm not sure if 

7 we're going to get there in time. 

8 I don't know that that helps you. I 

9 mean, it's tough. I don't actually have an 

10 alternate proposal where I'd say, oh, put them in 

11 there and make it a 100 watt limiter. It's 

12 pointless. I think if we were waiting long 

13 enough it would be fine, but the rulemaking 

14 timeline that you have out there doesn't make me 

15 comfortable that we're going to have enough time 

16 to get there from a fan light kit standpoint. 

17 MR. BROOKMAN: Okay. Thank you. Okay. 

18 MS. PIERCE: Now I will discuss the 

19 general methodology for the engineering analysis 

20 before discussing the details for each product 

21 class. 

22 The baseline model typically represents 
131 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 the most common least efficacious lamp in a CFLK 

2 that meets existing energy conservation 

3 standards. DOE identifies a baseline model in 

4 each representative product class. 

5 In general, to identify more efficacious 

6 replacement lamps, DOE considered lamps that save 

7 energy compared to the baseline lamp, have system 

8 lumen output within 10 percent of the baseline, 

9 and have a rated life greater than or equal to 

10 the baseline. 

11 DOE also considered lamps with similar 

12 characteristics, such as CRI, CCT, and bulb 

13 shape. The base type was kept the same as the 

14 baseline lamp. 

15 DOE considered two scenarios, both of 

16 which used the same baseline lamp: a lamp 

17 replacement scenario and a fixture replacement 

18 scenario. 

19 In the lamp replacement scenario the more 

20 efficacious substitute must have the same base 

21 type as the baseline lamp and no changes to the 

22 fixture are made. 
132 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 In the fixture replacement scenario the 

2 fixture can change which allows for a more 

3 efficacious lamp substitute with a different base 

4 type than the baseline lamp and a change in the 

5 number of sockets. 

6 DOE requests comment on the likelihood of 

7 CFLK manufacturers selecting each substitute 

8 scenario and information on any alternative 

9 scenarios that manufacturers may choose. 

10 MR. BROOKMAN: Dave. Thank you. 

11 MR. GATTO: Sorry. So, I'm not going to 

12 actually respond to this slide, but we kind of 

13 skipped over the baseline lamp that was selected. 

14 MS. PIERCE: So we'll go into the 

15 specific details for each product class in a bit. 

16 MR. GATTO: Okay. 

17 MS. PIERCE: This is just the general 

18 methodology. 

19 MR. GATTO: Yeah, then from -- the only 

20 thing I would say from a CFLK standpoint is that 

21 the preferred method for us would be the lamp 

22 replacement scenario because it's the least 
133 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 cumbersome in terms of change in design and 

2 potentially product cost. 

3 MR. BROOKMAN: Okay. Additional comments 

4 here? 

5 MS. PIERCE: Okay. DOE developed 

6 equations that are a function of wattage to 

7 determine the CFLs. The equations specify a 

8 minimum lamp efficacy requirement across wattages 

9 and represent the efficacy a lamp achieves. 

10 Because the equations account for variation in 

11 efficacy due to wattage, they can account for 

12 design options of new lamp wattages based on a 

13 technology curve. DOE developed a different 

14 equation for each representative product class. 

15 Now we'll discuss the entire engineering 

16 analysis, including the baseline lamp, more 

17 efficacious substitutes, and CSLs for each 

18 product class individually. We'll start with the 

19 All Other CFLKs product class. 

20 For this product class DOE found the most 

21 common least efficacious lamp packaged with a 

22 CFLK that meets existing standards to be a 14 
134 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 watt medium based spiral CFL. The baseline lamp 

2 DOE selected for this product class has a light 

3 output of 730 lumens, an efficacy of 52.1 lumens 

4 per watt, and a lifetime of 10,000 hours. 

5 For the fixture replacement analysis the 

6 baseline fixture has two sockets, each containing 

7 the baseline lamp. 

8 DOE requests comment on the baseline unit 

9 selected for the All Other CFLKs product class. 

10 MR. BROOKMAN: Dave. 

11 MR. GATTO: Dave Gatto, Westinghouse. 

12 So, if I understood the TSD correctly, you didn't 

13 select the least efficacious lamp because the 

14 Class 3 light kit doesn't have an efficiency 

15 standard. But I would suggest that the least 

16 efficacious lamp currently meeting the standard, 

17 which includes a design standard for Class 3, is 

18 actually an incandescent lamp. It's a 

19 ridiculously low efficacy, candelabra based 

20 incandescent. Maybe 10 or 15 -- well, maybe 

21 eight to 10 lumens per watt, high side. 

22 So I guess my question would be, why 
135 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 select this as the least efficacious when there 

2 is a substantially less efficacious lamp 

3 currently meeting the standard that's in the 

4 marketplace? 

5 MS. PIERCE: So with the new product 

6 class structure we essentially combine classes 1 

7 and 3 and we had to set the baseline level at a 

8 level that would prevent backsliding. So since 

9 the products in class 1 are subjected to what 

10 would be a 45 lumen per watt standard, that was 

11 where we started as our baseline. 

12 MR. GATTO: Dave Gatto, Westinghouse. 

13 So, I don't actually disagree with that other 

14 than the fact that we're missing -- 

15 MS. PIERCE: I got it. 

16 MR. GATTO: -- the analysis, the consumer 

17 impact that that represents because they're not 

18 buying this product today. So when you get into 

19 the consumer impact analysis we're showing no 

20 consumer impact if you left EL0 in place, which 

21 is this. But in fact I would suggest that they 

22 have a quite high cost impact that they're going 
136 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 to experience. And while I don't actually think 

2 that that's necessarily bad, I do think the 

3 analysis should correctly account for what 

4 they're paying today versus what we're proposing 

5 they would pay in the future. 

6 MS. PIERCE: Okay. 

7 MR. BROOKMAN: Thank you. 

8 MS. PIERCE: Thank you for the comment. 

9 MR. BROOKMAN: Additional comments? 

10 MS. PIERCE: Okay. For the lamp 

11 replacement scenario DOE selected five 

12 replacement lamps. DOE chose CFLs at CSLs 1 and 

13 2 and LEDs at CSLs 3 through 5. The wattage 

14 decreases and the efficacy increases at each 

15 level. 

16 The lifetimes of the CFL rep units are in 

17 the 10,000 to 12,000 hour range and the LED rep 

18 units have life times of 50,000 hours. 

19 For the fixture replacement scenario DOE 

20 selected five replacement fixtures. DOE used 

21 CFLs at CSLs 1 and 2, and LEDs at CSLs 3 through 

22 5. 
137 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 The number of sockets varies between one, 

2 three, and four, and the total fixture wattage 

3 decreases at each level. The lifetimes of the 

4 CFL rep units are in the 10,000 to 12,000 hour 

5 range. And the LED rep units have lifetimes of 

6 50,000 hours. 

7 DOE requests comment on the criteria used 

8 in selecting more efficacious substitute lamps as 

9 well as the characteristics of the lamps 

10 selected. So this slide or the previous. 

11 MR. BROOKMAN: Yes, Dave. Thank you. 

12 MR. GATTO: Sorry. Dave Gatto, 

13 Westinghouse. Thank you, Alex. 

14 The only thing I'd say here is that by 

15 picking the medium based product, which I 

16 acknowledge was the only thing you had in class 1 

17 when you combined the classes, means that you're 

18 picking lumen bins from the farthest along the 

19 development path from the LED product side. So, 

20 if you look at smaller base or alternate base, or 

21 smaller, physically smaller than A-19 or you've 

22 got an A-21 here which won't fit in most fan 
138 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 light kits, the challenge that you have is that 

2 they tend to be less efficient. So not 

3 necessarily a bad thing, but we'll bring it up 

4 when we get there in the proposed standard. 

5 If we stay with a two-class system then I 

6 would suggest DOE needs to really leave enough 

7 room in there for the less efficient candelabra 

8 base and small profile solid state lighting 

9 options to still be a viable option for 

10 manufacturers and a cost that is acceptable to 

11 consumers. Particularly with dimming. That adds 

12 not only cost but there's some physical space 

13 requirements. It's minimal, but you do need to 

14 build in for that and consumers do want dimming. 

15 MR. BROOKMAN: Okay. Thanks. 

16 MS. PIERCE: Thank you. 

17 MS. ARMSTRONG: So I'm going to ask you 

18 as part of your comments, and you might not -- 

19 what would this table look like with a base type 

20 you feel that DOE should analyze that's one of 

21 these that's the least furthest along? 

22 MR. GATTO: Probably candelabra base -- a 
139 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 candelabra based torpedo or flame tip which you 

2 can find. You know, we have a couple and we have 

3 more coming and they're available on the 

4 marketplace for a variety of manufacturers. 

5 There are some Energy Star products. What I 

6 would suggest is you look at two things. 

7 One is, you look at size and you look at 

8 cost, because if you look at the -- particularly 

9 in Energy Star, it's a good reference, you'll see 

10 that there's products with mid 60 efficiency and 

11 then there's products with 100 lumens per watt. 

12 But if you drill down into that you're going to 

13 find that those higher efficacy models tend to be 

14 the higher volume items, they're physically 

15 larger. Or they're really aimed at the 

16 commercial specification market, which can absorb 

17 the higher price point. 

18 So I would say that if you looked at the 

19 candelabra base you'd find that -- I don't know 

20 exactly off the top of my head, Ashley, but 

21 you're probably running about 10 percent lower in 

22 terms of the average efficacy. 
140 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 But physical size is important. I mean, 

2 when you look at some of the ones that are the 

3 best from a performance standpoint they wouldn't 

4 fit in a lot of candelabra based light kits 

5 today. Or they wouldn't fit in an aesthetically 

6 pleasing manner. 

7 MR. BROOKMAN: Yes, Tim. 

8 MR. FLANNERY: I would also suggest that 

9 you look at a G-9 format as well. 

10 MR. BROOKMAN: Thank you. Thank you. 

11 MR. GATTO: And even smaller. 

12 MR. BROOKMAN: Okay. Yes, Terry. 

13 Please. 

14 MR. MCGOWAN: Terry McGowan, American 

15 Lighting Association. 

16 I'm looking at the lamp life column. 

17 MS. PIERCE: Yes. 

18 MR. MCGOWAN: I believe that the 50,000 

19 hour life ratings for LEDs are very very 

20 optimistic in terms of service life. And we made 

21 this mistake with CFLs and so we've had to 

22 backtrack on that quite a bit. Because there are 
141 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 field conditions out there that more truly give 

2 you the life that the consumer realizes and the 

3 difference is, of course, very disruptive. 

4 So I think again maybe Energy Star life 

5 ratings would be a more appropriate number than 

6 the ones shown. 

7 MS. PIERCE: Thank you. If you have any 

8 specific data on typical lifetimes or test data 

9 that would be really helpful as well. 

10 MR. BROOKMAN: Dave. 

11 MR. GATTO: Yeah, one other thing I 

12 wasn't thinking about there, and we can get that, 

13 I mean EPA has it. And they probably have it in 

14 the database. The other challenge with lifetime 

15 is testing to certify to those lifetime hours 

16 takes longer, substantially longer. Which again 

17 means fan manufacturers who are not lamp 

18 producers, other than me, they're going to be 

19 trailing the product development of the lamp 

20 manufacturers. So you really kind of double up 

21 on the fact that this rule is going to go into 

22 effect before some of these products are 
142 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 commercially available, which is going to force 

2 fan manufacturers to either, I don't know, try 

3 and develop their own light bulbs which won't 

4 work. A lot of other people are getting out. Or 

5 they're going to have to redesign products to 

6 accommodate the products that they do have, you 

7 know, access to. 

8 MR. BROOKMAN: Yes, Tim. 

9 MR. FLANNERY: Also what we're seeing 

10 from a lamp manufacturer perspective is, although 

11 50,000 hours is what the expected life is going 

12 to be, the warranty to the life on those bulbs is 

13 really coming in at 25,000 and that's pretty much 

14 an industry standard. 

15 MR. BROOKMAN: Oh, thank you. Additional 

16 thoughts on all of the content in this table and 

17 responsive to the question itself? 

18 (No audible response.) 

19 MR. BROOKMAN: Okay. 

20 MS. PIERCE: DOE developed equations that 

21 are a function of wattage to determine the CSLs. 

22 The equations specify a minimum lamp efficacy 
143 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 requirement across wattages and represent the 

2 efficacy a lamp achieves. 

3 Because the equations account for 

4 variation in efficacy due to wattage, they can 

5 account for design options of new lamp wattages 

6 based on the technology curve. To determine the 

7 coefficients of the CSL equations DOE reviewed 

8 catalog data of commercially available lamps and 

9 their associated catalog rated efficacies. 

10 This table shows the CSLs that DOE is 

11 considering for the All Other CFLKs product 

12 class. 

13 This plot illustrates the five CSLs for 

14 All Other CFLKs with the rep units for the lamp 

15 and fixture replacement scenarios. The line at 

16 45 lumens per watt for wattages less than or 

17 equal to 15 watts and 60 lumens per watt, for 

18 wattages greater than 15 watts, denotes the 

19 existing energy conservation standard. 

20 The square box identifies the baseline 

21 lamp. The plot also shows more efficacious 

22 substitutes that DOE considered as replacements. 
144 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 These replacements were selected such that they 

2 both have a lower lamp wattage and higher 

3 efficacy than the previous level and maintain 

4 lamplight output within 10 percent of the 

5 baseline lamp. 

6 Because proposed standards are based on 

7 lamp efficacy, not fixture efficacy, for the 

8 fixture replacement scenario the lamp wattage of 

9 each rep unit is plotted. 

10 DOE ensured that CSL1 was set above the 

11 existing standard to prevent backsliding. 

12 DOE requests comment on the CSLs under 

13 consideration, including the max tech level for 

14 CFLKs. In particular DOE requests comment on the 

15 equations used to define the efficacy 

16 requirements at each CSL. 

17 MR. BROOKMAN: Dave. 

18 MR. GATTO: Thanks, Doug. In general I 

19 hate formulas when we're talking about fan stuff 

20 just because it's a little bit more difficult for 

21 them because they're not lamp producers. I'm a 

22 little bit more familiar with it. But I think I 
145 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 recognize -- I'm going to ask this as a question, 

2 maybe for Ashley or Lucy. You don't want to 

3 propose an efficacy level by wattage. You don't 

4 want to say five watts or lower this, 10 watts or 

5 lower this, 15 watts or lower this. Is that the 

6 reason for the formula? I recognize that at the 

7 higher wattages you want to achieve a higher 

8 efficacy, but the formula based scenario can get 

9 very confusing from a compliance standpoint. 

10 MS. PIERCE: I can answer it if you want 

11 too. So we found that the data showed that the 

12 efficacy increases continuously with wattage, so 

13 we're really trying to reflect what the lamp 

14 performance actually is and if there's also a 

15 chance that the lamps could get concentrated at 

16 the higher wattages within a bin and save less 

17 energy if you take that approach. 

18 MR. GATTO: Yeah. And I guess my 

19 response to that would be, in specifically in the 

20 LED space, wattage is continuously going down and 

21 efficacy is going up. But there's a tradeoff and 

22 it's one that manufacturers have to make in, I 
146 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 can reduce wattage, I can increase efficacy, or I 

2 can reduce cost. And really what you take away 

3 with these formula based equations is you take 

4 away the lamp manufacturer's ability to maximize 

5 efficiency at the cost a consumer is willing to 

6 pay in a physical lamp shape that will meet the 

7 application need. 

8 So when you start putting formulas in 

9 what happens is that if we want to have a single 

10 lamp instead of three lamps, which might save on 

11 total cost to produce a fan light kit for the 

12 light bulb, we now have to get -- we lose that 

13 savings. And I appreciate that there's no CRI in 

14 here because that's another kind of challenge. 

15 But this balancing act, when you start to push 

16 the envelope with the higher wattages, it's a 

17 challenge. 

18 What I don't know that you can take into 

19 consideration, I understand that it's an 

20 efficiency standard, is that you can make an 

21 assumption. And DOE's own analysis and some of 

22 the Caliper reports will show it, that the lumen 
147 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 bin per wattage is going to go down whether you 

2 regulate or not. So if you're able to consider 

3 that then I'd suggest setting a standard that the 

4 smaller configuration, smaller base type options 

5 can hit. 

6 I know in your analysis you can't capture 

7 the true energy savings, but I can tell you as a 

8 lamp manufacturer, you're going to get more 

9 efficient lower wattages anyway. The marketplace 

10 is going that way. It's very market driven. So 

11 it isn't like we're going to stop innovating at 

12 some point and say, oh well now, it's all about 

13 profit. There's not one lamp manufacturer. 

14 There's, feels like hundreds of them these days. 

15 MR. BROOKMAN: Thank you. Additional 

16 thoughts on this? Yes, Ali. 

17 MS. MCDONALD: I just wanted to, I guess 

18 -- this is Ali McDonald. I just wanted to ask a 

19 favor. If you prefer bins versus a continuous 

20 equation, or another approach besides continuous 

21 equations, if you could provide as much detail 

22 about what your recommendation would be. You 
148 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 know, for example, if it were a bin approach 

2 recommending actual wattage bin, divisions would 

3 be helpful. 

4 MR. GATTO: So Dave Gatto, Westinghouse. 

5 Maybe. Believe it or not I'm glad Alex 

6 is sitting here because this may be something 

7 that we have to circle back and talk to the lamp 

8 manufacturers. I think the biggest challenge is 

9 we don't -- every analysis any of us do is off. 

10 Typically by an order of magnitude. What we're 

11 seeing now is that as prices drop for the lamp 

12 side, now is when -- when you can find that price 

13 point the consumers are actually at the highest 

14 adoption rate, then you stop focusing on 

15 efficacy, which has been kind of the race to 

16 date, and you focus on lamp size, thermal 

17 management, dimmability. All of the other things 

18 that consumers want, and you maintain your price. 

19 So I think if this was -- and it's an 

20 efficiency standard so I understand that that's 

21 the primary value to DOE. But the consumer 

22 actually wants more than that and we have to 
149 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 accommodate that. The challenge for fan 

2 manufacturers is that they're going to get 

3 whatever the rest of us decide. And so if you 

4 set a standard and then we all stop here because 

5 we finally maximized the price picture for 

6 consumers, we might be adding value that the 

7 consumer wants, but we may not be reducing 

8 wattage and now you're going to have fan 

9 manufacturers in the, you know, unenviable 

10 position of there's nothing available to fit the 

11 socket. Does that help? 

12 MR. BROOKMAN: Yeah. Thanks, Dave. 

13 Thanks. 

14 Yes, Tim. 

15 MR. FLANNERY: You know, looking at the 

16 LED samples that you have here, I think one of 

17 the problems that I think also needs to be 

18 addressed is I'm familiar with some of these 

19 products and I believe they're not omni 

20 directional and I think what Dave is referring to 

21 in some of the smaller packages are also omni22 directional. And I think, you know, moving 
150 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 forward in the future, I think that that's really 

2 what we're all looking for from a decorative 

3 perspective. 

4 And the industry is, to Dave's point, 

5 really isn't there yet. I mean, we hope that 

6 it's going to get there and we're seeing more and 

7 more products that are coming to that level. 

8 But, you know, it's a real important part when 

9 we're looking at putting in an LED replacement 

10 bulb into a light kit. I mean, because of the 

11 heat sink there's shadowing. There's other 

12 things from a decorative perspective that really 

13 need to be, you know, looked at from a design and 

14 from an execution standpoint. 

15 MR. BROOKMAN: Okay. 

16 MS. PIERCE: Okay. Thank you. Now I 

17 will discuss the engineering analysis for the 

18 Externally Ballasted or Driven product class. 

19 Because CFLKs with externally ballasted or driven 

20 lamps utilize ballasts, DOE analyzed lamp-and21 ballast systems in order to capture real world 

22 energy use and light output. 
151 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 DOE paired externally ballasted lamps 

2 with electronic ballasts, since they are required 

3 by existing CFLK standards and are the most 

4 common fluorescent ballasts on the market. 

5 As noted previously the baseline lamp is 

6 the most common, least efficacious lamp in a CFLK 

7 for each representative product class. For the 

8 Externally Ballasted product class DOE found the 

9 most common efficacious lamp packaged with a CFLK 

10 that meets existing standards to be a 22 watt T9 

11 Circline fluorescent lamp. When paired with an 

12 electronic ballast it has a system light output 

13 of 855 lumens, a system efficacy of 50.3 lumens 

14 per watt, and a lifetime of 12,000 hours. 

15 DOE requests comment on the baseline lamp 

16 selected for Externally Ballasted CFLKs. 

17 MR. BROOKMAN: No comments here? No 

18 comments here. Okay. 

19 MS. PIERCE: Okay. I'll move on. 

20 For the lamp replacement scenario for the 

21 Externally Ballasted product class DOE chose more 

22 efficacious replacements that were compatible 
152 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 with the baseline ballast. Additionally system 

2 lumens were kept within 10 percent of the 

3 baseline fixture. DOE selected one replacement 

4 lamp for the scenario which was a 20 watt T9 

5 Circline lamp. The lamp has a light output of 

6 920 lumens, an efficacy of 48.4 lumens per watt, 

7 and a lifetime of 12,000 hours. 

8 For the fixture replacement scenario the 

9 ballast, number of sockets, and base type were 

10 all allowed to change. DOE ensured that the bulb 

11 maximum dimension, i.e. length, was less than 

12 that of the baseline and that as for the lamp 

13 replacement scenario the systems lumens were kept 

14 within 10 percent of the baseline fixture. 

15 DOE selected one replacement lamp for 

16 this scenario which was a 13 watt pin-based CFL. 

17 The lamp has a light output of 900 lumens, an 

18 efficacy of 69.2 lumens per watt, and a lifetime 

19 of 17,000 hours. 

20 DOE requests comment on the criteria used 

21 in selecting more efficacious substitute lamps as 

22 well as the characteristics of the lamps 
153 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 selected, particularly the lifetimes. And then 

2 in issue 15, DOE requests comment on the lamp and 

3 ballast system selected for the Externally 

4 Ballasted or Driven product class. In particular 

5 DOE requests comment on the selection of 

6 electronic ballasts for the lamp and ballast 

7 systems. 

8 MR. BROOKMAN: Thoughts on these 

9 questions? Okay. 

10 MS. PIERCE: Okay. DOE developed 

11 equations that are a function of wattage to 

12 determine the CSLs. As mentioned, a different 

13 equation was developed for each representative 

14 product class. 

15 To determine the coefficients of the CSL 

16 equations DOE reviewed catalog data of 

17 commercially available lamps and their associated 

18 catalog rated efficacies. 

19 This table shows the CSL that DOE is 

20 considering for the Externally Ballasted or 

21 Driven product class. 

22 This plot illustrates the CSL for 
154 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 Externally Ballasted or Driven CFLKs with the 

2 representative lamp units. The square box 

3 identifies the baseline lamp. The plot also 

4 shows the more efficacious substitutes that DOE 

5 considered as replacements. 

6 DOE requests comment on the CSLs under 

7 consideration, including the max tech level for 

8 Externally Ballasted or Driven CFLKs. In 

9 particular DOE requests comment on the equations 

10 used to define the efficacy requirements at each 

11 CSL. 

12 MR. BROOKMAN: Any additional comments 

13 here? Nothing. Okay. 

14 MS. PIERCE: Okay. Moving on to scaling. 

15 DOE typically scales CSLs to product classes not 

16 directly analyzed, but since all product classes 

17 were considered to be representative no scaling 

18 was required. 

19 So we have several requests for comment 

20 in the next few slides, several of which are 

21 related to LEDs and CFLKs. And in issue 17 DOE 

22 requests comment on whether and what fraction of 
155 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 ballasts or pin-based fluorescent lamps are 

2 designed to be replaceable by the consumer. 

3 DOE also requests comment on whether 

4 consumers generally replace the ballast in a CFLK 

5 if it fails, or if consumers replace the entire 

6 CFLK assuming it is no longer operable. 

7 I'll stop there and -- 

8 MR. BROOKMAN: Comments on ballast 

9 replacements? 

10 Maybe we should rally. We're just about 

11 to break for lunch. Let's try hard, here. Tim. 

12 MR. FLANNERY: My understanding is it's 

13 really replacement of the ceiling fan light kit, 

14 versus the changing of the ballast. 

15 MR. BROOKMAN: Tim, I didn't hear that. 

16 Would you repeat that, please? 

17 MR. FLANNERY: My feeling is, is that 

18 they're changing the light kit versus the 

19 ballast. 

20 MS. PIERCE: Thank you. 

21 MR. BROOKMAN: Okay. Thank you. Yes. 

22 Yes, Clark? 
156 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 MR. LINSTONE: This is Clark Linstone, 

2 Lamps Plus. Our experience has been not just 

3 changing the light kit but changing the whole 

4 ceiling fan when that -- 

5 MR. BROOKMAN: Okay. 

6 MR. LINSTONE: What we see consumers 

7 doing. 

8 MR. BROOKMAN: Thank you, Clark. Other 

9 thoughts? Yes, please, Alan. 

10 MR. ROO: The major problem that we've 

11 come across is the replacement of the ballast 

12 itself, it is no longer available from the 

13 manufacturer, and the consumer then therefore has 

14 to select a new light kit. 

15 MR. BROOKMAN: Oh, okay. Replace the 

16 entire kit. Okay. Yeah. Yes? 

17 Is that it? Okay. 

18 MS. PIERCE: Okay. And in issue 20 DOE 

19 requests comment on the practicality of 

20 externally driven LEDs. For example, LED module 

21 and driver systems as replacements for externally 

22 ballasted fluorescent or CFL lamps and CFLKs. 
157 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 Specifically DOE requests information on the 

2 fixture changes necessary for such a replacement. 

3 MR. BROOKMAN: Yes, Dave. 

4 MR. GATTO: We can keep this one really 

5 brief. The entire light kit would have to be 

6 replaced. The consumer wouldn't be able to 

7 retrofit to LED because no one would make a 

8 retrofit LED for a pin base -- yeah, it just 

9 would be not done. 

10 And I'd just maybe point out that this 

11 product class in its current form represents I 

12 think a whopping one percent or less. It's 

13 possible that the fixture replacement scenario 

14 with LED would ultimately change that. But as it 

15 stands right now it's a very very small part of 

16 the market. 

17 MR. BROOKMAN: Okay. 

18 MS. PIERCE: Okay. In issue 21 DOE 

19 requests information on the typical efficacy 

20 ranges for externally driven LEDs used in CFLKs. 

21 DOE requests information on what these efficacy 

22 ranges represent, so these would be the LED 
158 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 modules. If anyone has data that would be really 

2 helpful. 

3 MR. BROOKMAN: Typical efficacy ranges? 

4 MR. TURNER: This is David with Hunter. 

5 I think this is where we spoke about, we're not 

6 sure where it's going and so we can't really 

7 provide too much commentary on it. 

8 MR. BROOKMAN: Okay. 

9 MR. TURNER: But there's potential for 

10 it. 

11 MR. BROOKMAN: In your written comments. 

12 MR. TURNER: Yes. 

13 MR. BROOKMAN: Alex Boesenberg. 

14 MR. BOESENBERG: Alex Boesenberg, NEMA. 

15 I would add to that consideration. If, you know, 

16 to sort of amplify my previous comment, if the 

17 ceiling fan industry goes towards a uniform 

18 socketed LED light modules and drivers consistent 

19 with the emerging standards for interoperability, 

20 i.e. Zhaga or other representatives, I would 

21 estimate -- I'm not asking, but I'm saying it's 

22 far likelier that those products will fall under 
159 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 regulation. And so then you -- it becomes more 

2 like the previous class where the lamp being 

3 supplied is covered by regulation and so you just 

4 have to make sure that it is consistent with 

5 that. 

6 So, you know, that might be where the 

7 market heads if the market asks ceiling fan 

8 manufacturers to go toward interoperable, one 

9 module for multiple applications within the 

10 house. 

11 MR. BROOKMAN: Okay. 

12 MR. BOESENBERG: But it's only a guess. 

13 MR. BROOKMAN: Thank you. Additional 

14 thoughts on efficacy ranges? 

15 Okay. 

16 MS. PIERCE: Okay. Just one last 

17 request. DOE requests comment on the overall 

18 methodology and results of the CFLK engineering 

19 analysis. 

20 MR. BROOKMAN: Kind of a macro-comment. 

21 If you wish, you can dwell on it over lunch 

22 because we're about to break. 
160 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 It's now 12:20. Let's break for lunch. 

2 We've made a lot of progress here. There's still 

3 more to take up. Make sure your visitor's badge 

4 is visible. I think most of you are familiar 

5 with the layout here. Down to the ground floor, 

6 there's a Subway shop down there. About 100 

7 yards in that direction there's a big cafeteria 

8 up two escalators, and we'll see you back here at 

9 1:20 to finish off the day. 

10 (Recess from 12:19 p.m. until 1:20 p.m.) 

11 MR. BROOKMAN: Okay. Let's resume. How 

12 many people are joining us online? 

13 EMILY: We have 20. 

14 MR. BROOKMAN: Twenty individuals online. 

15 That's good. 

16 We are going to pick up where we left 

17 off, and that's product price determination for 

18 all of you that have got your packet of 

19 information in front of you. And we're going to 

20 hear from Aisha Husain. 

21 MS. HUSAIN: Hi. My name is Aisha Husain 

22 and I am with Navigant and I'll be going through 
161 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 the product price determination for ceiling fan 

2 light kits. 

3 Can everyone hear me okay? All right. 

4 So as noted in this analysis ceiling fan 

5 light kit efficiency is based on the efficacy of 

6 the lamp with which it is packaged. Therefore 

7 DOE developed consumer prices for lamps when they 

8 are packaged with the light kits. To do so DOE 

9 first determined how much a consumer would pay 

10 for a ceiling fan light kit, and then what 

11 portion of that was attributable to the lamp 

12 component. 

13 In its research DOE found a range of 

14 ceiling fan light kit consumer prices that were 

15 dependent on the distribution channel through 

16 which the light kit was being purchased. To 

17 represent this range DOE developed three premiums 

18 and thereby three prices, using the 

19 manufacturer's suggested distributor net prices, 

20 or DNPs. 

21 The low ceiling fan light kit consumer 

22 prices are representative of purchase through the 
162 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 electrical distributor channel which include 

2 wholesalers and contractors. The medium prices 

3 are representative of purchases through home 

4 centers, and high prices are representative of 

5 purchases through lighting showrooms. 

6 DOE then developed a weighted price. So 

7 based on estimated shipment volume through each 

8 channel, DOE applied 12 percent to the electrical 

9 distributor channel price, 80 percent to the home 

10 center channel price, and eight percent to the 

11 lighting showroom channel price, and developed a 

12 weighted average consumer ceiling fan light kit 

13 price. 

14 So once we had the consumer ceiling fan 

15 light kit price developed, the next step was to 

16 determine what portion of that was attributable 

17 to the lamp in the light kit. 

18 From manufacturer feedback DOE determined 

19 that for a light kit with a CFL or LED the lamp 

20 component comprised an estimated 15 percent of 

21 the ceiling fan light kit consumer price. So 

22 this percentage was applied to the consumer price 
163 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 of the ceiling fan light kit to obtain the 

2 consumer price of the lamp package with the light 

3 kit. 

4 In cases where DOE was unable to develop 

5 a consumer price for a ceiling fan light kit with 

6 the representative lamp, DOE applied a ratio 

7 based on the expected incremental cost of the 

8 representative lamp relative to the baseline lamp 

9 in the light kit. 

10 And we have a series of requests for 

11 comment here. In issue 24 we're asking for 

12 comments on DOE's determination that a basic 

13 ceiling fan light kit package with a ceiling fan 

14 comprises 20 percent of the consumer price of the 

15 fan and light kit, and subsequently requests for 

16 comment on the determination that a CFL or LED 

17 package with a light kit comprises 15 percent of 

18 the consumer price of the light kit. 

19 MR. BROOKMAN: I see a few individuals 

20 that are -- they're rolling their eyes as if 

21 they're making a calculation in their head. 

22 Dave? 
164 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 MR. TURNER: I don't do calculations in 

2 my head. 

3 MR. BROOKMAN: You've got a calculator. 

4 MR. TURNER: I have my calculator. 

5 David with Hunter Fan. I would say the 

6 percentage of the consumer price for LED light 

7 kits is low, because we're talking about just the 

8 light kit price, correct? If it's attached to a 

9 fan the fan is not relevant in this? 

10 MS. HUSAIN: So for the 15 percent it's 

11 the LED component of the light kit consumer 

12 price. 

13 MR. TURNER: I would say it's, in my 

14 estimation, it's probably closer to double that. 

15 It's probably 30 percent. 

16 MS. HUSAIN: Double. And the CFL would -

17 - 

18 MR. TURNER: CFL is probably pretty 

19 accurate. 

20 MR. BROOKMAN: Twenty percentish. 

21 MR. TURNER: Well 15 percentish on the 

22 CFLs portion -- 
165 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 MR. BROOKMAN: Oh, yeah, yeah, yeah. 

2 MR. TURNER: -- of the light kit cost. 

3 MR. BROOKMAN: Yeah. Thank you. Yes. 

4 Okay. Any additional commentary? 

5 MR. FLANNERY: Concur. 

6 MR. BROOKMAN: Yes, concur. Okay. Thank 

7 you. Dave? 

8 MR. GATTO: Yes, I basically agree with 

9 Dave Turner. 

10 MR. BROOKMAN: Yeah. Okay. Thank you. 

11 MR. GATTO: Dave Gatto, Westinghouse. 

12 MR. BROOKMAN: That's helpful. Thank 

13 you. Okay. On to 25. 

14 MR. LINSTONE: I was just going to concur 

15 as well with that. I think that's -- the LED is 

16 going to be more expensive. 

17 MR. UPTON: Do you concur with DOE or do 

18 you concur with Dave? 

19 MR. LINSTONE: With Dave. Both Daves, 

20 actually. 

21 MR. BROOKMAN: Thank you, Clark. Thank 

22 you. Okay. 
166 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 MS. HUSAIN: Issue 25 is basically asking 

2 for comment on the distribution channel weighting 

3 that I went through earlier, so I can repeat 

4 those again, what we used. It was 12 percent for 

5 the electrical distributor channel, 80 percent 

6 for the home center channel, and eight percent 

7 for the lighting showroom. 

8 And if you need to do calculations and 

9 want to provide comment later on that would be 

10 really helpful as well. 

11 MR. BROOKMAN: Okay 

12 MS. HUSAIN: Issue 27, we are requesting 

13 comment on the assumption that the prices of the 

14 different electronic ballasts presented in the 

15 fixture replacement scenario are equal to each 

16 others, so there's no difference in prices there 

17 that we need to account for. And this is 

18 specific to the Externally Ballasted product 

19 class. 

20 MR. BROOKMAN: No comment here. 

21 MS. HUSAIN: Okay. So issue 26 is just a 

22 general, any comments on the product price 
167 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 determination, results, methodology. 

2 MR. BROOKMAN: Dave. 

3 MR. GATTO: This is going to be one of 

4 those things where it's probably in the next 

5 slide, but the price determination for the 

6 consumer price for lamps for CFLs I think is 

7 accurate. I think that what's going to be left 

8 out is that there's no analysis of the price of 

9 an incandescent lamp included with a CFLK. 

10 MS. HUSAIN: Right. And that's based so 

11 the product price determination is based on like 

12 what's used in the engineering. So that would 

13 follow. Yes. 

14 MR. BROOKMAN: Yeah. Okay. Okay? 

15 MS. HUSAIN: Okay. So I am turning it 

16 over to Colleen for energy use. 

17 MS. KANTNER: Colleen Kantner, Lawrence 

18 Berkley National Lab. 

19 So next up is the energy use analysis. 

20 The purpose of the energy use characterization is 

21 to develop estimates of the actual energy use in 

22 the field of CFLKs at each efficiency level. DOE 
168 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 derives annual energy use from the product of 

2 annual operating hours and system input power. 

3 To develop operating hours for CFLKs in the 

4 residential sector, DOE combined data on the 

5 rooms where CFLKs are located from an LBNL study 

6 with data on operating hours for residential 

7 ceiling light fixtures by room type from DOE's 

8 Residential Lighting End-Use Consumption Survey. 

9 To develop operating hours for the 

10 commercial sector, DOE combined data on the hours 

11 of use of lamp types typically used in CFLKs with 

12 the fraction of lamps of each lighting technology 

13 used in each commercial building type. And this 

14 data came from DOE's U.S. Lighting Market 

15 Characterization Report. 

16 DOE estimated that the weighted average 

17 over all building types was 10.6 hours per day in 

18 the commercial sector, and 1.4 hours per day in 

19 the residential sector. DOE assumed that CFLKs 

20 were not used in the industrial sector. 

21 DOE utilized the power consumption data 

22 presented in the engineering analysis for 
169 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 representative lamps and lamp and ballast systems 

2 to develop system input power. Since DOE's 

3 analysis of energy use is intended to represent 

4 the energy use of products in the field for the 

5 All Other CFLK product class, DOE scaled the 

6 lumen outputs of CFLKs from the engineering 

7 analysis, which were constrained to be within a 

8 certain percentage of the lumen output of the 

9 least efficacious CFLKs under consideration, to 

10 the typical lumen output of CFLKs on the market. 

11 In recognition of stakeholders comments 

12 on current product class 3, indicating that the 

13 wattage limit constrains the light output of 

14 CFLKs with low efficiency lamps to levels below 

15 those preferred by consumers, DOE did not include 

16 the lumen output of such CFLKs in developing its 

17 estimate of typical CFLK lumen output. 

18 And keep in mind that DOE is considering 

19 removing the wattage limiter requirement under 

20 the new product class structure, in which case 

21 the constraint on lumen output would no longer 

22 exist. 
170 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 To estimate the average lumen output of 

2 All Other CFLKs, DOE used in-store shelf survey 

3 data of ceiling fans with light kits and CFLKs 

4 sold alone. This data included socket types, 

5 socket numbers, light source technologies, lamp 

6 wattages and retail prices, as well as lamp 

7 efficacy data from online retailers on the 

8 efficacy of the lamps found in All Other CFLKs. 

9 For the Externally Ballasted or Driven 

10 product class, because they occupy a very small 

11 market share, DOE was unable to collect 

12 sufficient data on their typical lumen output, so 

13 DOE did not scale it. 

14 It's also worth noting that, unlike All 

15 Other CFLKs, where the market average number of 

16 lamps in a CFLK might be fractional, all of the 

17 CFLKs with circlines DOE found only contained one 

18 lamp. 

19 So here we see the results of DOE's 

20 analysis of the average lumen output of CFLKs. 

21 Indeed it looks like the lumen output of CFLKs 

22 with low efficiency lamps in the third product 
171 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 class, which are constrained by a wattage 

2 limiter, had a lower average lumen output. And 

3 the average lumen output for CFLKs that are not 

4 constrained is close to 2,000 lumens. 

5 The unconstrained lamps here include both 

6 medium screw base lamps, which are not subject to 

7 a wattage limit, as well as GU-24s that are in 

8 Product Class 3, but have a high enough efficacy 

9 that the wattage limiter does not constrain their 

10 total lumen output. 

11 All other types of CFLKs were rare enough 

12 that DOE couldn't draw conclusions about their 

13 typical lumen output. This analysis was used to 

14 scale the lumen output at each CSL from the 

15 engineering analysis by the ratio of the market 

16 average CFLK lumen output to the lumen output of 

17 CSL-0, for the All Other CFLK product class. 

18 And here we see the results of the energy 

19 use characterization. The top table is for 

20 Externally Ballasted or Driven CFLKs, showing 

21 both energy use at each CSL as well as the 

22 savings, where the savings represent the 
172 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 difference between CSL-1 and the baseline. And 

2 it's worth noting that for the energy use and 

3 savings we assumed -- or DOE assumed that the two 

4 engineering scenarios presented were equally 

5 present in the market, so it just assumed equal 

6 market shares for those two scenarios. And 

7 that's also true for the bottom table which 

8 presents the All Other CFLKs product class. 

9 Again, the table displays the energy use and 

10 savings at each CSL and also shows the 

11 residential sector versus the commercial sector. 

12 MR. TURNER: Can you repeat the part 

13 about market share? 

14 MS. KANTNER: So there were two possible 

15 engineering scenarios presented in the 

16 engineering analysis. A lamp replacement 

17 scenario and a fixture replacement scenario, and 

18 since DOE doesn't have any market data to 

19 indicate which one would be used, DOE assumed 

20 that they would be used equally. And so this 

21 data here represents just a 50 percent lamp 

22 replacement scenario, 50 percent fixture 
173 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 replacement scenario. 

2 MR. BROOKMAN: So, Dave, please follow on 

3 if you have any thoughts on this. 

4 MR. TURNER: Well, I don't know if this 

5 affects anything but I think you made the point 

6 earlier that we tend rather heavily towards lamp 

7 replacement. At least in current state. 

8 MR. BROOKMAN: Dave. 

9 MR. GATTO: Dave Gatto, Westinghouse. 

10 Yeah, I'm not sure that it would have 

11 done anything different for your analysis, just 

12 because you're using similar efficacies. But I 

13 think what Dave Turner is suggesting and I would 

14 agree with is that in the current market place 

15 lamp replacement is the primary method and while 

16 it's possible that we'll see an increase, and we 

17 talked about it earlier, an increase of 

18 integrated LED or what you're calling fixture 

19 replacement where the entire light kit is a 

20 single integrated module, the odds of being 50/50 

21 are probably fairly low, at least in the short 

22 term. 
174 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 MS. KANTNER: Just to clarify, fixture 

2 replacement wasn't meant to imply only 

3 replacement with integrated LEDs. It was just if 

4 there were a different number of sockets, that 

5 would be a fixture replacement. 

6 MR. GATTO: Okay. So if it was a three7 light it might go to a two-light or a four-light. 

8 MS. KANTNER: Exactly. 

9 MR. GATTO: Okay. Then, I guess if you 

10 have to pick a spot, I guess that spot is as good 

11 as any other. So I don't really think we 

12 disagree with the analysis on that piece. 

13 The only thing I would not intentionally 

14 disagree with, but I'd point out here and I think 

15 it's a first for me, DOE is maybe intentionally 

16 ignoring the huge energy savings that are 

17 represented by moving from CSLs, minus one if you 

18 will, to the new standard based on what you 

19 proposed. I mean, I think that again, no 

20 different than I think the LCC should capture 

21 what the consumer cost impact is, I think that 

22 there's a huge energy savings that DOE is 
175 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 proposing here and you're not really spelling 

2 that out clearly and I'm not sure why. So I'd 

3 ask Lucy maybe to expand on that. But, you know, 

4 I definitely credit where it would be due and 

5 this is one that would probably move the needle 

6 if you calculated it right. 

7 MR. BROOKMAN: Okay. Thanks, Dave. 

8 MS. KANTNER: Okay. And there's an item 

9 for comment. To improve its energy use estimates 

10 DOE seeks comment on the typical total lumen 

11 output of pin-based fluorescent CFLKs. 

12 MR. BROOKMAN: Any comment here? Dave. 

13 MR. GATTO: So I'm sorry. When you say 

14 pin-based I'm assuming you're talking about 

15 what's traditionally in a light kit now, which 

16 would just be a circline four pin? 

17 MS. KANTNER: Exactly. 

18 MR. GATTO: So it's a very -- it's a one19 item market. So what you have is representative. 

20 Does that help? 

21 MS. KANTNER: Okay. Yes. 

22 MR. BROOKMAN: Okay. Thank you. 
176 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 MS. KANTNER: Next is the life-cycle cost 

2 analysis. 

3 The purpose of the life-cycle cost 

4 analysis is to provide an economic evaluation 

5 from the end-user's perspective. Life-cycle cost 

6 is the total purchaser cost over the life of a 

7 product. Payback period is the time required to 

8 recover the increased purchase price of a more 

9 efficient and more energy efficient product 

10 through reduced operating costs. The methodology 

11 used to develop the lifecycle cost is to first 

12 develop a Monte Carlo sample of 10,000 

13 purchasers, then determine total installed cost 

14 for each CSL, then operating costs are determined 

15 for the first year and over the lifetime of the 

16 product, which include lamp disposal costs, lamp 

17 replacements throughout the lifetime of a CFLK, 

18 and the residual value of lamps at the end of the 

19 CFLK lifetime. 

20 DOE also calculates the payback period by 

21 dividing the average increase in installed costs 

22 by the average decrease in first year operating 
177 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 costs. And the LCC is calculated by adding 

2 installed costs and lifetime operating costs. 

3 Then LCC savings are calculated with 

4 respect to the distribution of efficiencies in 

5 the absence of standards. 

6 To account for the variability in energy 

7 consumption, energy price, or both, DOE developed 

8 a sample of 10,000 CFLK purchasers. In the 

9 residential sector households were randomly 

10 selected from the subset of households with 

11 ceiling fans in RECS 2009. DOE applied a 

12 selection weight to each household based on the 

13 number of ceiling fans in that household. 

14 For the commercial sector buildings were 

15 randomly selected from the 2003 Commercial 

16 Buildings Energy Consumption Survey, CBECS. This 

17 excluded vacant buildings, though. DOE applied a 

18 selection weight to each building based on square 

19 footage, the number of lamps per thousand square 

20 feet, and the fraction of lamps using light 

21 source technologies found in CFLKs. 

22 To estimate the average LCC savings of a 
178 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 CSL, DOE first considers the expected market 

2 distribution by efficiency level of CFLK 

3 purchases that consumers would make in the 

4 compliance here in the absence of an amended 

5 standard. For all other CFLKs DOE used LED 

6 incursion in combination with a consumer choice 

7 model to model the market distribution of 

8 shipments from 2012 through 2019. And just as a 

9 note, LED incursion and the consumer choice model 

10 will be discussed in detail on the shipments 

11 analysis later. 

12 For Externally Ballasted or Driven CFLKs, 

13 due to insufficient market data, DOE assumed an 

14 even split in market share between CSL-0 and CSL15 1 as previously mentioned. 

16 And here we see the expected market 

17 efficiency distribution for each product class. 

18 Note that for the Externally Ballasted or Driven 

19 product class, due to limited data, DOE assumed 

20 an even split in market share between CSL-0 and 

21 CSL-1, in addition to assuming an even split at 

22 CSL-1 between the lamp replacement and the 
179 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 fixture replacement scenarios. 

2 For both product classes, at each CSL, 

3 DOE assumed -- this is also true for the all 

4 others product class -- DOE assumed an even split 

5 in market share between each CSL, between the 

6 lamp replacement scenario and the fixture 

7 replacement scenario. 

8 The lack of market share at CSL-3 and 4 

9 in the -- this lack of market share reflects, in 

10 part, the expected increase in LED efficacy by 

11 the compliance year. By the compliance year the 

12 LED market share is expected to be concentrated 

13 to efficacies corresponding to CSL-5 and above. 

14 MR. GATTO: Open for comment? 

15 MR. BROOKMAN: Wherever you want, Dave. 

16 MS. KANTNER: Feel free to comment. 

17 MR. BROOKMAN: Right here would be good. 

18 MR. GATTO: So, I saw Doug looking at me. 

19 So I wouldn't necessarily disagree that the 

20 general service LED market would be close to what 

21 you're proposing as CSL-5. In lower wattage 

22 based on your scale. I don't know that you're 
180 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 going to see 20 and 25 watt LEDs that would be at 

2 some 200 lumen per watt that wouldn't really 

3 exist in the market place. 

4 I don't know that I agree with making 

5 that assumption here, only because you're basing 

6 it on the lack of availability of product and 

7 forward-looking forecast of general service LEDs. 

8 But the products that go in the current CFLKs are 

9 not general service, they're candelabra base and 

10 decorative shape. 

11 So, you know, I'm going to repeat my -- 

12 it's not that I really have a problem with that 

13 from a manufacturing and lamp standpoint, it's 

14 just that the analysis should really be what is 

15 the -- based on what we know today, not what we 

16 think will happen. And that's where I get a 

17 little concerned because these analysis are what 

18 determine -- not only what DOE determines is the 

19 new rule, but what consumers have to deal with 

20 three years from when it publishes. 

21 So I don't know that I have an alternate 

22 for you other than that if you don't know where 
181 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 it's going to go I would rather see you split it 

2 evenly between CSL-3, 4, and 5. I understand 

3 that CSLs are really CFL, and the other three are 

4 LED. But in the absence of having a product to 

5 analyze it just seems a little bit odd to shift 

6 it all to the high end. 

7 MS. KANTNER: Okay. 

8 MR. BROOKMAN: Thank you. Additional 

9 thoughts on this? Quite a bit of data here. 

10 Okay. 

11 MS. KANTNER: Okay. So next we have the 

12 total installed cost. The total installed cost 

13 is just the product price plus sales tax. 

14 Product price is based on the output of the 

15 product price determination, it includes the end16 user lamp and socket prices for each CFLK where 

17 the number of lamps or sockets has been scaled by 

18 the same factor as the total lumen output. This 

19 also includes price learning for LEDs expected to 

20 occur by the compliance date. And there will be 

21 more detail on this provided in the shipments 

22 section later. 
182 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 Sales tax, which includes both state and 

2 local sales tax as determined by geographic 

3 location, and installation cost was not included 

4 because it was assumed not to vary with CSL. 

5 Any comments on the total installed cost? 

6 MR. BROOKMAN: Dave. 

7 MR. GATTO: Dave Gatto, Westinghouse. 

8 I'll just repeat that the end-user lamp price and 

9 socket prices is not being analyzed correctly 

10 because we're leaving out the current cost to 

11 consumers. 

12 MR. BROOKMAN: Okay. 

13 MS. KANTNER: Average operating hours 

14 were developed for each RECS reportable domain 

15 using the approach described in the energy use 

16 analysis to capture the variability for 

17 individual purchasers, triangular distributions 

18 of plus or minus 20 percent were applied to the 

19 average hours of use. 

20 As far as electricity prices, electricity 

21 prices and trends were estimated using data from 

22 EIA. DOE used EIA's Annual Energy Outlook for 
183 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 projections of future average energy prices for 

2 reference, high, and low growth scenarios. For 

3 all three scenarios. 

4 Any comments? 

5 (No audible response.) 

6 MS. KANTNER: As far as discount rates, 

7 DOE used discount rates to discount operating 

8 cost to the year of purchase, and this year was 

9 assumed to be 2019. And discount rates represent 

10 the opportunity cost of funds used to purchase 

11 CFLKs. 

12 In the residential sector, for 

13 replacement CFLKs in existing homes, DOE used a 

14 distribution of debt and asset classes for 

15 purchasing appliances that include stocks, mutual 

16 funds, savings accounts, bonds, loans. For CFLKs 

17 installed in new construction, DOE used a 

18 distribution of mortgage rates. 

19 In the commercial sector, DOE used a 

20 distribution of weighted average cost of capital. 

21 Any comments on the discount rates? 

22 (No audible response.) 
184 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 MS. KANTNER: Lifetime is the age at 

2 which a CFLK is retired from service. DOE 

3 assumed that the lifetime of a CFLK is the same 

4 as a ceiling fan since CFLKs have fewer moving 

5 parts than a ceiling fan and are unlikely to fail 

6 earlier than the ceiling fan, but consumers will 

7 likely retire them when they get a new fan 

8 because they are typically sold together and 

9 consumers generally want a matching ceiling fan 

10 and light kit style. 

11 While DOE considers the lifetime of a 

12 CFLK to be equivalent to the lifetime of the 

13 ceiling fan to which it is attached, DOE 

14 recognizes that the lamps packaged with the 

15 ceiling fan light kit may have a shorter 

16 lifetime. 

17 An amended CFLK standard would only 

18 affect the efficacy of lamps packaged with the 

19 CFLK. But the lifetime energy use of the light 

20 kit is also affected by the efficacy of the 

21 replacement lamps which are purchased at the end 

22 of the lifetime of the lamps that are sold with 
185 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 the light kit. 

2 DOE considers these replacement lamps to 

3 be a repair and maintenance cost and considers 

4 lamp replacement cost for failed lamps to be the 

5 only repair or maintenance cost that varies with 

6 product efficiency. 

7 MR. BROOKMAN: Dave. 

8 MR. GATTO: Just I'll, you know, I'll go 

9 on record that I kind of agree with that 

10 analysis. I got a little confused in there when 

11 you were talking about maintenance costs, where 

12 the efficacy of the lamp that might replace the 

13 original lamp might be maybe more efficacious 

14 than the old lamp. Is that where you were going 

15 with that? 

16 MS. KANTNER: It could be either more or 

17 less. This is just pointing out that the average 

18 -- or excuse me, the energy use in each year 

19 might change over the lifetime of a CFLK as you 

20 replace it with different lamps than it was 

21 originally packaged with. 

22 MR. GATTO: Okay. Thank you. 
186 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 MS. KANTNER: Sure. As I just mentioned, 

2 DOE included in the life-cycle cost the cost to 

3 replace lamps that fail during the lifetime of a 

4 CFLK. Lamp replacement costs are the purchase 

5 costs of replacement lamps in the year that 

6 failed lamps are replaced, discounted to the 

7 analysis start year. 

8 DOE assumes that CFLK lamps fail at the 

9 end of their average service life, which is just 

10 the lamp lifetime divided by the lamp’s operating 

11 hours per year. It also assumed that replacement 

12 lamps have the same base type as failed lamps, 

13 provide an equivalent lumen output as failed 

14 lamps, and just as a note, that the prices for 

15 the replacement lamps do not include the CFLK 

16 manufacturer markup. 

17 DOE knows of no LED replacement options 

18 for CFLKs with pin-based sockets. Since there 

19 are limited data available to support any other 

20 conclusion, DOE assumed that failed CFLK lamps 

21 are replaced with the same lamp that was 

22 originally packaged with the light kit for this 
187 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 product class. 

2 For the All Other CFLKs product class, 

3 consumers were again constrained to purchase 

4 lamps of the same socket type and lumen range, 

5 but DOE's model allowed them to choose lamps that 

6 have a different light source technology from 

7 those that were packaged with the CFLK. 

8 DOE categorizes lamps as low, medium, or 

9 high efficacy to characterize the lamp 

10 replacement options. To determine lamp 

11 characteristics, DOE used data on CFL and LED 

12 lamps included in the engineering analysis for 

13 the medium and high efficacy lamps, and market 

14 research data for the low efficacy lamps. 

15 Specifically the data used were 

16 efficacies, watts, prices -- where price learning 

17 was applied to LEDs -- and lifetimes for each 

18 lamp replacement. 

19 Note that the purchase cost of a 

20 replacement lamp is the purchase price in the 

21 year the replacement occurs, multiplied by sales 

22 tax and then discounted back to the analysis 
188 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 start year. 

2 Choice of replacement lamp in a given 

3 year was determined by first estimating the 

4 fraction of replacement lamps that would be high 

5 efficacy based on the LED incursion into the 

6 market for replacement lamps, which came from a 

7 DOE SSL report. 

8 The fraction of replacement lamps that 

9 fell into the low versus medium efficacy lamp 

10 categories was then determined by a consumer 

11 choice model sensitive to price and operating 

12 cost, using sector specific consumer choice 

13 parameters. 

14 And this graph here displays the 

15 selection probability over time for the high 

16 efficacy lamps in the greenish color, the medium 

17 efficacy lamps in the red color, and the low 

18 efficacy lamps in the blue color. 

19 MR. CYMBALSKY: This is absent standards, 

20 correct? 

21 MR. BROOKMAN: John Cymbalsky. 

22 MS. KANTNER: This is for just lamps that 
189 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 are the replacement lamps. So this is not 

2 subject to CFLK efficacy standards. 

3 MR. CYMBALSKY: Right. So I think I 

4 wanted to point out that this is just what we 

5 predict to be purchased absent any standards for 

6 the light kits. 

7 MS. KANTNER: Well, regardless of the 

8 standard for the light kit. 

9 MR. CYMBALSKY: Right. Okay. I think 

10 that's what I meant. So this is what we think is 

11 going to happen, absent -- with or without 

12 standards. 

13 MR. BROOKMAN: Yeah. Dave. 

14 MS. KANTNER: Exactly. 

15 MR. GATTO: So I probably knew I was 

16 going there, John. 

17 So then I would ask the question -- Dave 

18 Gatto, Westinghouse Lighting. You should just 

19 turn your mic on and say it for me, Alex. 

20 MR. BOESENBERG: I can't believe I didn’t 

21 have to say it. 

22 MR. GATTO: So my question would be, 
190 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 then, is a CFLK light kit rule necessary based on 

2 the evidence, which I actually agree with and 

3 we've seen it in the other SSL studies and it's 

4 part of the GSL conversation we're about to have 

5 in the other rulemaking. Is it necessary, 

6 because in the absence of a standard, what I'm 

7 seeing here is that everything is shifting in the 

8 same direction we all agree, it's shifting which 

9 is to higher efficacy. 

10 So one of the things that I know that DOE 

11 has to consider is sometimes staying out of our 

12 own way, and I’m including industry in that. 

13 That proposing a rule that actually slows down or 

14 interferes with the adoption of the products that 

15 we want everyone to move to. 

16 MR. CYMBALSKY: So this is John from DOE. 

17 So I think as we go further in and see what the 

18 options are and the energy savings are, I think 

19 we'll see some compelling economics for DOE to 

20 move forward. 

21 MS. KANTNER: And it may be worth noting 

22 that this trend exists in the analysis for no 
191 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 CFLK standard. So the results in the NIA, for 

2 instance, are compared to -- there is a trend in 

3 the background that is taken into account. 

4 MR. GATTO: Dave Gatto, Westinghouse. So 

5 I'm not sure what that means. I understand that 

6 this is in the absence of a rulemaking on CFLKs, 

7 the lamp market is expected to move in this 

8 direction. In the NIA and the shipping analysis 

9 are you looking at both scenarios, with and 

10 without a rulemaking? Or are you only looking at 

11 with a rulemaking this is what will happen? 

12 MS. KANTNER: We're looking at the 

13 efficiency distribution in a standards case 

14 versus the efficiency distribution when there is 

15 no standard. But there's still this trend in the 

16 efficiency distribution when there is no 

17 standard. 

18 MR. GATTO: Okay. And I agree with that. 

19 I think the only thing I would point out, and 

20 this came up in the last public meeting, maybe 

21 the one before that, is that fan manufacturers, 

22 with exception of me, are not lamp manufacturers. 
192 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 So it becomes a little burdensome on the fan 

2 manufacturer to be the leading edge of efficiency 

3 on lamps instead of letting the lamp rulemaking 

4 which is currently in progress, and any other 

5 lamp rulemakings and the market itself kind of 

6 take us there. 

7 And, John, for what it's worth, I agree 

8 with you. I think that there may be some 

9 additional savings you can capture. But capture 

10 short-term until they get there by themselves, 

11 versus the burden on consumers and manufacturers 

12 is something I think that at least DOE should 

13 weigh. 

14 MR. CYMBALSKY: Right. And this is John 

15 from DOE. 

16 And we do that. And so, but you just 

17 took the words -- you stole my thunder kind of by 

18 looking at the graph. So, as with all the other 

19 lighting rules that we seem to be working on, the 

20 timing is the critical issue here. So if you 

21 look at the graph, in my opinion you don't get 

22 the phenomenon you're talking about until we get 
193 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 out at least, I'm thinking 15 years from where 

2 we're sitting today. So I think, you know, there 

3 is a good period of time where there is up front 

4 energy and economics, and that's what's going to 

5 drive, I think, the numbers you're going to see 

6 here in a few minutes. 

7 MR. GATTO: Dave Gatto, Westinghouse. I 

8 appreciate that and I do agree with you that the 

9 timeline will be shorter with a rulemaking. 

10 MR. CYMBALSKY: Right. And I think what 

11 you'll see in the analysis actually, you know, 

12 comes -- it hits that head on. You'll see the 

13 numbers. 

14 So this question is from Doug Smith on 

15 the webinar. Are electricity prices based on 

16 average or marginal. 

17 So in all of our rulemakings it is the 

18 marginal price of electricity that we do our 

19 analysis on. 

20 MS. KANTNER: I think these results were 

21 done, at the preliminary analysis stage, with 

22 average prices. So they could be done with the 
194 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 marginal prices at the NOPR stage. 

2 MR. CYMBALSKY: Right. We will do 

3 marginal electricity prices. 

4 MR. BROOKMAN: Okay. 

5 MS. KANTNER: Disposal cost is also an 

6 input to the LCC analysis. The disposal cost 

7 represents the cost of disposing, for example, 

8 recycling, lamps at the end of the lamp lifetime. 

9 DOE found that on average disposing of a CFL 

10 costs about $1 per lamp. LED disposal costs were 

11 assumed to be the same as CFLs due to limited 

12 data to suggest otherwise. 

13 In the residential sector DOE assumes 

14 that consumers do not pay recycling cots, perhaps 

15 recycling them for free at a home center. 

16 In the commercial sector DOE assumed that 

17 consumers paid recycling costs for 10 percent of 

18 CFLs and LED lamp failures, and this was 

19 implemented by applying an average cost of 10 

20 cents to all lamps. 

21 MR. GATTO: Dave Gatto, Westinghouse 

22 Lighting. 
195 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 So, I'm not sure why you assume the same 

2 disposal costs for LED as CFL. I would agree 

3 with the dollar. I mean, that's really what 

4 we've all landed on as the average recycling cost 

5 for a spiral CFL. LEDs do not have that disposal 

6 cost associated with them. They don't have 

7 mercury. So I'm not sure what the -- 

8 MS. KANTNER: What would you estimate is 

9 the disposal cost for LEDs? 

10 MR. GATTO: I would estimate -- I don't 

11 know if you have a number that you apply to 

12 throwing it in the trash, zero, I guess. You 

13 know, there are some recycling values to some 

14 LEDs because the aluminum content and the heat 

15 sink, particularly in the commercial market, but 

16 -- 

17 MS. KANTNER: A redemption value? 

18 MR. GATTO: Yeah, that's more of a 

19 redemption value. It's not a disposal cost. So 

20 I would call it zero. 

21 MS. KANTNER: Okay. Thank you. 

22 MR. BROOKMAN: Thank you. 
196 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 MS. KANTNER: Okay. The residual value 

2 is also an input to the LCC calculation. The 

3 residual value represents the value, the 

4 remaining dollar value of surviving lamps at the 

5 end of the CFLK lifetime to account for the value 

6 of lamps with the remaining life to the consumer. 

7 The LCC model applies this residual value as a 

8 credit at the end of the CFLK lifetime, and 

9 discounts it back to the start of the analysis 

10 period. 

11 Note that for LEDs, the residual value of 

12 these lamps is calculated based on the LED lamp 

13 price in the year that the CFLK is retired, which 

14 takes into account price learning. 

15 Any comments? 

16 (No audible response.) 

17 MS. KANTNER: Okay. And here we see the 

18 results for the LCC analysis. Specifically, here 

19 are the results for the Externally Ballasted or 

20 Driven CFLK product class. The results include 

21 installed cost, first year operating cost, 

22 lifetime operating cost, life-cycle cost, and 
197 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 simple payback period which can be compared to 

2 the average lifetime of a CFLK. 

3 All of the results presented for each CSL 

4 here, except for the LCC savings at the end, 

5 represent the average outcome if all 10,000 

6 purchasers in the Monte Carlo sample bought at 

7 that CSL. 

8 The LCC savings on the right-hand side on 

9 the other hand, consider the distribution of 

10 product efficiencies on the market in the absence 

11 of an amended standard. So those savings are 

12 relative to what a consumer would have purchased 

13 without an amended standard and could include 

14 lamps below the baseline proposed. Or baseline 

15 considered, excuse me. 

16 And I should note that the same sample is 

17 used for all CSLs. 

18 The results are displayed separately for 

19 the residential and commercial sectors. As 

20 expected, the LCCs in the commercial sector are 

21 higher at all CSLs due to the greater hours of 

22 use in that sector. 
198 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 MR. BROOKMAN: Yes, Dave. 

2 MR. TURNER: On installed costs for CSL -

3 - 

4 MR. BROOKMAN: Get closer to that, Dave. 

5 MR. TURNER: On installed -- this is 

6 David from Hunter Fans. 

7 On installed costs for CFLKs was there an 

8 installation figure put into that, because we 

9 figured that 90 percent of them are attached to 

10 fans. So how did that -- 

11 MS. KANTNER: We assumed that the 

12 installation cost didn't vary by CSL, so we 

13 didn't apply it in this case since the only thing 

14 that matters to the LCC savings is the difference 

15 between efficiency levels. 

16 MR. TURNER: Okay. So just the cost of 

17 the kit itself. 

18 MS. KANTNER: Okay. And here are the 

19 results for the All Other CFLKs product class. 

20 And again, I want to note that the LCC savings 

21 are calculated with respect to what consumers in 

22 the sample would have purchased in the absence of 
199 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 an amended standard, which includes products with 

2 efficacies below the baseline under product class 

3 consolidation. 

4 I also want to note that there are bar 

5 plots in the TSD which display the contributions 

6 of installed cost, lifetime electricity costs, 

7 relamping cost, and residual value to the overall 

8 LCC. And those bar plots include bar plots for 

9 lamps below the baseline considered in this 

10 analysis. I know that there was some request for 

11 data that showed what life-cycle costs looked 

12 like for those lamps below the baseline 

13 considered here. And those do exist in the TSD. 

14 MR. BROOKMAN: Dave. 

15 MR. GATTO: Dave Gatto, Westinghouse. 

16 So, I'm sorry. I just, I need your help. 

17 Walk me to the math. 

18 MS. KANTNER: Sure. 

19 MR. GATTO: Where the installed cost of a 

20 current class 3 incandescent light kit with a 

21 limiter and say three or two, whatever you 

22 considered your socket. I know you picked kind 
200 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 of one and then you modeled it. 

2 MS. KANTNER: Yes. 

3 MR. GATTO: But I don't see any 

4 difference in CSL-O, 1, or really a marginal to 

5 2, which makes sense to me if they're all compact 

6 fluorescent, meeting the current Class 1 

7 standard. So I just don't see where the consumer 

8 installed cost of an incandescent light kit is up 

9 there. 

10 MS. KANTNER: It's not represented by a 

11 CSL here. When you look at the average LCC 

12 savings in that column on the far right, that's 

13 calculated with respect to what the efficiency 

14 distribution would be without an amended 

15 standard. And it includes the fraction of 

16 consumers that would purchase CFLKs with 

17 efficacies below the baseline. 

18 There's also, as I was mentioning, 

19 there's bar plots in the TSD chapter that show 

20 the contributions to the various things I 

21 mentioned, installed cost, electricity cost, 

22 whatever. 
201 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 MR. GATTO: No, that's okay. I think I 

2 said it earlier, it wouldn't surprise me if the 

3 payback period is reasonable to the consumer if 

4 they understand that they're getting their money 

5 back. I think the challenge that we as 

6 manufacturers and the retailers who aren't 

7 represented in the room here have is that the 

8 consumer does not understand that. We tried to 

9 explain it to them under the lamp FTC rule. It's 

10 on the packaging. But it is unclear to them that 

11 a $30 installed cost saves them money over the 

12 lifetime versus a $10 installed cost. They don't 

13 get it. 

14 So I do think that that, depending on how 

15 you apply that to the shipment analysis, which I 

16 think if I remember correctly you show going up 

17 year over year, I don't see how those two things 

18 were taken into account. I don't know how you 

19 could have the -- maybe what we need if you 

20 didn't do it, is a price sensitivity analysis 

21 because I think that's what's missing. It isn't 

22 that I don't agree, and I do. For what it's 
202 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 worth to DOE, I do agree that the LED option will 

2 take consumers where they want to go and then 

3 over the lifetime of the product that they are 

4 going to see a savings. I just don't think we've 

5 really nailed down how that's going to impact 

6 them on day one when they purchase the CFLK. 

7 MS. KANTNER: I think we should hold off 

8 on the shipments analysis because that will be 

9 discussed in much more detail just shortly. 

10 MR. BROOKMAN: David. 

11 MR. TURNER: David from Hunter. Just to 

12 circle back. 

13 So, CSL-5 is LED, correct? Or is a lumen 

14 per watt that only LED meets currently? 

15 MS. KANTNER: Yes. 

16 MR. TURNER: And $27.50 is the consumer 

17 purchase price. That's not like a manufacturer's 

18 selling price? 

19 MS. KANTNER: That's the fraction of the 

20 consumer price to buy a light kit which is 

21 represented by lamps and sockets. 

22 MR. TURNER: Okay. From my end I would 
203 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 think that's low. 

2 MR. BROOKMAN: Say it again? It's the 

3 fraction of -- 

4 MR. TURNER: That represents -- 

5 MS. KANTNER: It's the fraction of the 

6 light kit cost to a consumer that is represented 

7 by the lamps and sockets. 

8 MS. ARMSTRONG: Is it on a per lamp 

9 basis, or is it cumulative? 

10 MS. KANTNER: It's for, say on average 

11 there was two and a half lamps, a market average 

12 of two and a half lamps, then it would represent 

13 that number of lamps and sockets. 

14 MR. GATTO: So Dave Gatto with 

15 Westinghouse Lighting. And, Dave, this may be 

16 part -- 

17 MS. KANTNER: Oh, I think also Mo has -- 

18 MR. GANESHALINGAM: Oh, sorry just to 

19 chime in. This is Mohan Ganeshalingam at 

20 Lawrence Berkley, from Lawrence Berkley National 

21 Labs. This also accounts for price learning, so 

22 there is some drop in price between 2013 and 
204 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 2019. 

2 MR. BROOKMAN: Dave, keep going. 

3 MR. GATTO: So, I’m sorry. Maybe it's a 

4 question. So the installed cost is just a lamp 

5 cost because that's the only thing different in 

6 the light kit pre and post-standard? 

7 MS. KANTNER: Yes. 

8 MR. GATTO: And that -- 

9 MS. KANTNER: DOE assumed that everything 

10 besides the lamp and socket costs were the same. 

11 MR. GATTO: So then that would mean that 

12 at the analysis, I think we suggested that 15 

13 percent for LEDs is probably too low. It would 

14 be more like 20. But for the 15 percent analysis 

15 that you used, that would mean that a light kit -

16 - the cost of a light kit to the consumer would 

17 be -- I do need my calculator for this. About 

18 100 and -- that can't be right. It looks way too 

19 high. So 27.50 divided by .15 would be $183. 

20 Does that sound like a light kit price that 

21 anyone would pay? That's more than most fans. 

22 So I'm not saying that that's what it 
205 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 would cost, I'm just trying to understand how we 

2 got here and 15 percent of the light kit cost 

3 being the lamp, $27.50, I’m just struggling with 

4 it. 

5 So I don't know if I'm reading that right 

6 or if maybe I'm misunderstanding it. 

7 MS. KANTNER: I'll let the folks who did 

8 the engineering analysis answer that. 

9 MS. MCDONALD: Sure. We would welcome 

10 any comments on prices. We have already 

11 mentioned I guess that for the LEDs, you know, 

12 this CSL-5 level would be an LED price. If that 

13 were 20 or 30 percent of the light kit price, 

14 then that wouldn't end up being $185. I see you 

15 doing the calculation. It's probably going to 

16 still turn out to be higher than you would want 

17 it to be, or expect a consumer to pay. We would 

18 welcome any comments on what, you know, the 

19 prices that we're estimating for these lamps, you 

20 know, including which, you know, which LEDs you'd 

21 be most likely to include in a light kit that 

22 would meet that level of efficacy. 
206 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 MR. GATTO: Dave. I would like one of 

2 the other fan guys to get in here because this is 

3 really just about light bulbs anymore. But thank 

4 you. A., thank you. I think even at a 30 

5 percent, if the LEDs represented 30 percent of 

6 the light kit cost that's $100 light kit 

7 ballpark. I don't know. I'm not saying that -- 

8 I don't even know that that's accurate, that it 

9 would be $100 light kit. So you know, whether 

10 it's price learning or whether it's just the 

11 percentage, LEDs are just moving so fast it's 

12 really tough for me to give an opinion that isn't 

13 a guess. And I hate to give an opinion that says 

14 it's going to be less than that, but at the same 

15 time -- 

16 MS. MCDONALD: Comfortable saying the 

17 prices are too -- 

18 MR. GATTO: There has to be a price 

19 sensitivity analysis done before we can move 

20 forward with the rule if we're going to literally 

21 quadruple the price of a CFLK, because I think if 

22 you just, you know, with a medium based CFL in 
207 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 the box, at Home Depot right now, you're probably 

2 $25, $30. Just, the consumers won't pay that. 

3 And so I think that -- and again, if I sound a 

4 little scared as a fan manufacturer, I'm a little 

5 frightened that that type of impact would be 

6 devastating to our industry. 

7 I mean, it's not just that it would 

8 impact the consumer. It could put us out of the 

9 light kit business, which is a little scary. 

10 MR. BROOKMAN: Okay. 

11 MS. ARMSTRONG: So why don't you go ahead 

12 and then I will. 

13 MR. TURNER: Well, just like the last 

14 comment that you said is what LEDs we might use. 

15 And just to kind of echo Dave's comments, you 

16 know, we're fan manufacturers. We're not lamp or 

17 LED manufacturers and we follow where they go. 

18 So if something becomes available that fits 

19 within our, you know, our price points and we 

20 think we can sell to consumers, and it's more 

21 efficient and we can market it that way, that's 

22 what we'll use. 
208 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 But to look forward to 2019 and say that, 

2 all right, well, we're going to use this 

3 particular LED that has this particular 

4 efficiency, that's not something we can -- we 

5 don't guide that ship. It's going through other 

6 regulations and everything else. So, we kind of 

7 follow that. 

8 MS. ARMSTRONG: Okay. So my ask for you 

9 is to talk to your lamp suppliers when you go 

10 back and ask them what they have -- I mean, you 

11 know, Dave's (indiscernible) is great but this 

12 standards analysis is on you guys, not on the 

13 lamps. I mean, yes, we've harmonized such that 

14 it allows you to buy otherwise, you know, I will 

15 say lamps that are tested pursuant to DOE 

16 regulations, but the compliance cost is really 

17 going to be born by the CFLK manufacturer that 

18 has to purchase the lamps and then sell them to 

19 consumers. Right? So -- 

20 MR. TURNER: David Turner from Hunter 

21 Fans. So I realize this standard is on us, but 

22 if you were to set a level of efficiency that, 
209 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 like Dave said before, if LED manufacturers stop 

2 going there, we would just have to take light 

3 kits off of our fans because we're not going to 

4 get into the lamp or LED business. It's, you 

5 know -- 

6 MS. ARMSTRONG: Right. 

7 MR. TURNER: I mean, we're not going to 

8 start manufacturing those. 

9 MS. ARMSTRONG: And obviously DOE is not 

10 attempting to go there. So we really need the 

11 feedback from you guys along with your lamp 

12 suppliers, to the extent you can get them engaged 

13 in this process with you, that would be most 

14 helpful. 

15 To circle back to you, though, regarding 

16 your price sensitivity. I'm not following. And 

17 maybe it's just me. I'm not following what it is 

18 you're asking for exactly because if your 

19 argument is that our prices are too high and 

20 consumers won’t bear them, you know, the question 

21 about whether consumers will bear that cost and 

22 whether there's a reduction in shipments is a 
210 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 different question versus is this an accurate 

2 price for getting that level of efficacy, which 

3 is also a different question from the point you 

4 made earlier whether it's technologically 

5 feasible in all different design and shapes. 

6 So what is it that -- I mean, if we ran a 

7 sensitivity with lower numbers, guess what it's 

8 going to come out as? I've never had anyone tell 

9 me at a public meeting our numbers are too low, 

10 though. 

11 MR. GATTO: So, no, I appreciate that. 

12 MS. ARMSTRONG: Especially a 

13 manufacturer. 

14 MR. GATTO: No, no. And I think I said 

15 at the beginning that this is a place -- and 

16 we've been in this dialog all over the place on 

17 the regulatory side and with EPA, it is moving in 

18 the direction everyone wants. You won't get a 

19 lamp manufacturer to really loudly disagree with 

20 that. 

21 I think to answer your questions if I 

22 understood them right, I think that that -- for 
211 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 CSL-5 I think that number might be high, or it 

2 might be right about right. Price learning is 

3 very tough in LED, especially because you're 

4 going to start to hit a cap to that and I don't 

5 know where it is. 

6 I think on the price sensitivity what I 

7 was aiming for was the consumer's willingness to 

8 pay. To your point it's, would they pay 

9 regardless of whether they're going to get their 

10 money back or not. Would they pay that much? 

11 And I think that's separate from -- 

12 MS. ARMSTRONG: Right. 

13 MR. GATTO: -- whether or not the product 

14 price is accurate. 

15 MS. ARMSTRONG: Right. 

16 MR. GATTO: I just, I think my challenge 

17 Ashley is, I don't know how to answer it. I 

18 don't know what CSL really 4 and 5 are going to 

19 be cost wise. 

20 MS. ARMSTRONG: So let's just assume that 

21 our -- I mean, maybe this is a bad assumption, 

22 but for the purposes of this discussion let's 
212 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 assume these prices are somewhat accurate, or at 

2 least the best guess that we can collectively 

3 come up with, right? It would be helpful for the 

4 department to know at these price levels, 

5 especially once you back out the cost of the full 

6 light kit, what percentage at each level do you 

7 think consumers would actually turn away? 

8 In other words, where would their 

9 purchasing decision be different? And why? Is 

10 it 25 percent? Is it 50 percent? Sure, we can 

11 run that analysis. It's not in the LCC but we 

12 can run that analysis. It's just a matter of 

13 what is it that you want to see? 

14 MR. GATTO: So, Dave Gatto, Westinghouse. 

15 I think that we can probably provide some 

16 feedback. But it's a challenge. We've been 

17 talking about this with fans since the beginning, 

18 that there is a price point within which the bulk 

19 of the volume is going to either happen or not. 

20 So I think on higher end products that price 

21 sensitivity doesn't exist. But at the lower 

22 price points, not necessarily lower efficacy, 
213 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 whether you're talking fan or light kit, there is 

2 a price consumers expect to pay, and above that 

3 they won't. And I don't know that we really have 

4 a -- I'm looking around the room here. We might 

5 have some ideas. We might be able to get some 

6 feedback from some of our retail partners. I 

7 don't know that we have that today. And we will 

8 try to give that in the feedback because I agree 

9 with you. If we can provide it, it will be good. 

10 Just, your budget is bigger than ours. 

11 MR. BROOKMAN: Clark. 

12 MR. LINSTONE: Clark Linstone from Lamps 

13 Plus. I think there's basically, at least the 

14 way we sell this product, is if it meets an 

15 appropriate price that light kit kind of offsets 

16 having a light fixture. And I think we kind of 

17 know how ceiling fans and kind of the majority of 

18 ceiling fans, the various bands in terms of 

19 pricing, it's more towards the lower end. 

20 So we're basically saying here is that if 

21 we assume roughly about $100 price point on the 

22 CSL-5 category, that's going to make it a higher 
214 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 end fan in terms of cost, and therefore you may 

2 see some just going to buy a lower cost light 

3 fixture in place of a ceiling fan with a light 

4 kit. 

5 But I mean, we don't have data to give 

6 you at this point in time on that. 

7 MR. BROOKMAN: Okay. Thank you. That's 

8 helpful. Dick. 

9 MR. UPTON: I don't know where it comes 

10 in. But you might have a lifetime of saving on 

11 energy cost that says to the consumer, this is a 

12 good value. But at the lower end the opening 

13 price becomes a significant factor, not the end 

14 price of how much energy I'm saving. It's how 

15 many dollars have I got in my pocket today or on 

16 my credit card today that I can afford to pay. 

17 And that's going to have a significant impact as 

18 well, and I don't know if we can get arms around 

19 that issue at all. But it's got to be taken into 

20 account. 

21 MR. BROOKMAN: And Dave, you had an 

22 additional comment? 
215 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 MR. GATTO: No, I just wanted -- 

2 MS. ARMSTRONG: You got it. Go again. 

3 MR. GATTO: Dave Gatto, Westinghouse. So 

4 I wanted to make sure that I answered all of 

5 Ashley's points there. 

6 MS. ARMSTRONG: And, Doug, to your point, 

7 I mean, our model has the capability of analyzing 

8 those issues. It's just a matter of what 

9 assumptions do you make about -- or what 

10 sensitivities you run about the impact of 

11 different prices to consumer choices. And like I 

12 said, we can guess all day, as could you guys. 

13 If you have some sense about what's 

14 acceptable we'd obviously be willing to -- 

15 MS. KANTNER: And this is discussed in 

16 the shipments analysis which is coming up, where 

17 there was consumer sensitivity to price taken 

18 into account. 

19 MR. BROOKMAN: Tim? 

20 MR. FLANNERY: So, I have a -- this is 

21 Tim Flannery. I have a question here. The 27.50 

22 that we're looking at here, looking at the 
216 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 equation for total cost is the product cost plus 

2 sales tax. So am I assuming this correctly that 

3 that's the retail price is 27.50 for a -- 

4 MS. KANTNER: That's the retail price for 

5 the fraction of the CFLK that the lamps and the 

6 sockets represent. 

7 MR. FLANNERY: So that's just the retail 

8 price for what the module would be? 

9 MS. ARMSTRONG: We assumed 15 percent, 

10 right? So that's 15 percent, the retail price, 

11 15 percent of the retail price of the ceiling fan 

12 light kit. Fair enough? 

13 MS. KANTNER: Or it sounds like maybe 30 

14 percent at some of the LED levels. 

15 MR. FLANNERY: Yeah, there's likely some 

16 lamps by -- 

17 MS. ARMSTRONG: Something like that. 

18 MR. BROOKMAN: Mark, please. 

19 MS. ARMSTRONG: Multiply by four and get 

20 your ceiling fan light kit. 

21 MR. FLANNERY: Okay. 

22 MS. ARMSTRONG: Close enough. Round 
217 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 numbers. 

2 MR. FLANNERY: Well, that's -- if that's 

3 not enough we'll be -- well. I don't know that I 

4 agree with the equation. 

5 MR. BROOKMAN: Clark, go ahead. 

6 MS. ARMSTRONG: What would you change? 

7 MR. LINSTONE: Well, no, I think the 

8 point earlier this morning was the fact that the 

9 15 percent, I don't think the feeling was that 

10 represented -- because we're just talking about 

11 the light kit, how much the LED cost of the total 

12 light kit. And that's where, throwing a number 

13 around, we thought maybe 30 percent was a more 

14 reasonable number. But if you get to as high as 

15 27 then obviously you're back down to $100, you 

16 know, approximate cost of a light kit. And 

17 that's where, you know, I think it could have a 

18 very significant affect on sales. 

19 But you know, that's how we kind of 

20 backed up into this number. So. 

21 MR. BROOKMAN: Okay. Thank you. Okay. 

22 MS. KANTNER: Okay. So there's a couple 
218 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 of items for comment. For this preliminary 

2 analysis DOE assumes that the lifetime of CFLKs 

3 is equal to the lifetime of a ceiling fan. DOE 

4 invites comment, input, and data on the lifetime 

5 of CFLKs. 

6 MR. BROOKMAN: Dave. 

7 MR. GATTO: Dave Gatto, Westinghouse. 

8 Yeah, we agree. The lifetime of the light kit is 

9 going to be tied to the fan. If they replace the 

10 fan they're not going to -- very unlikely that 

11 they would keep the light kit and attach it to 

12 another fan. 

13 MR. BROOKMAN: Yeah. 

14 MS. KANTNER: DOE also requests comment 

15 on whether and which components and light kits 

16 with solid state lighting components that are 

17 inseparable from the CFLK are designed to be 

18 replaceable by the consumer. Specifically DOE 

19 requests information on which components may be 

20 easily removable and replaceable by consumers and 

21 how such replacements would be performed. 

22 MR. GATTO: Dave Gatto, Westinghouse. I 
219 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 think long-term we don't know, is what came up 

2 earlier. For today, and you guys may want to 

3 weigh in, our limited assortment of LED SSL light 

4 kits are integrated and not replaceable. 

5 MR. BROOKMAN: Okay. Additional thoughts 

6 on this, David? 

7 MR. TURNER: David from Hunter. Ours has 

8 a serviceable driver that can be replaced. I 

9 don't know if that still means it's inseparable 

10 or not, but -- 

11 MR. BROOKMAN: But so does that mean it's 

12 integrated? 

13 MR. TURNER: It's integrated but if the 

14 driver was to fail it can be replaced, but the 

15 LEDs would stay. 

16 MR. BROOKMAN: Oh, I see. Okay. 

17 MS. KANTNER: Thanks. DOE welcomes 

18 comments on its approach to not including 

19 installation costs on the LCC analysis. Again, 

20 the reasoning for this is we assumed that it was 

21 the same at each CSL. 

22 MR. BROOKMAN: Dave. 
220 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 MR. GATTO: Yeah, Dave Gatto, 

2 Westinghouse. Yeah, we agree with that. 

3 MS. KANTNER: Okay. DOE requests comment 

4 and any relevant data on the disposal cost 

5 assumptions for different light source 

6 technologies using CFLKs. We touched on this 

7 earlier so there may -- unless there's any 

8 additional. 

9 MR. BROOKMAN: We covered that. Yeah. 

10 MS. KANTNER: Okay. 

11 MR. BROOKMAN: Any additional comments on 

12 disposal costs? We did cover that. Okay. 

13 MS. KANTNER: DOE requests comment on the 

14 overall methodology and assumptions, as well as 

15 relevant data on the market distributions of 

16 CFLKs by CSL for each product class. And we 

17 discussed this a little bit as well, but I don't 

18 know if there are any other comments on that. 

19 MR. BROOKMAN: Yes, Marianne. 

20 MS. DIMASCIO: This is Marianne Dimascio 

21 from ASAP. I was just wondering what the 

22 distribution was today for CSL-3, 4, and 5, for 
221 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 LEDs. Is that not -- 

2 MR. GANESHALINGAM: Hello. This is Mohan 

3 Ganeshalingam at LBNL. Yeah, I believe it's a 

4 couple percent at CSL-3. 

5 MS. DIMASCIO: And nothing at 4 and 5? 

6 MR. GANESHALINGAM: And nothing at 4 and 

7 5. That's right. 

8 MR. BROOKMAN: Okay. Thank you. 

9 MR. TURNER: Is the last point, Issue 32, 

10 is that referring back to the market efficiency 

11 distribution in compliance year? 

12 MS. KANTNER: Yes. 

13 MR. TURNER: And, Dave, you commented on 

14 it when we hit that point, but was there 

15 areasoning for skipping over -- well, three is a 

16 0.0 and four is .2 percent of the market share. 

17 Was there a reason those were left out almost 

18 totally, or -- 

19 MS. KANTNER: Well, this was based on the 

20 projected efficiency of LEDs in the compliance 

21 year, which was based on an SSL report. 

22 MR. TURNER: Okay. All right. 
222 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 MR. BROOKMAN: Anything additional on 

2 these three comment boxes? Okay. 

3 MS. KANTNER: And up next, Mohan 

4 Ganeshalingam will present the shipments and NIA 

5 analysis. 

6 MR. GANESHALINGAM: Hello. Good 

7 afternoon, everyone. I am Mohan Ganeshalingam 

8 from LBNL and I'll be discussing the shipments 

9 and NIA, or National Impact Analysis. 

10 So, starting with the shipments, the 

11 purpose of the shipments analysis is to project 

12 future shipments of CFLKs over a 30 year analysis 

13 period, which in this case was from 2019 to 2048. 

14 DOE projects shipments in both the no 

15 standards case, and under potential amended 

16 energy efficiency standards. 

17 The total CFLK shipments are 

18 disaggregated into product classes and CSLs over 

19 time. To estimate total shipments of CFLKs DOE 

20 developed a model to estimate low volume ceiling 

21 fan shipments and assumed 88 percent of those low 

22 volume ceiling fans are then sold with a CFLK. 
223 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 So many of the inputs I'll be discussing in the 

2 next few slides will actually be discussed 

3 tomorrow as well. 

4 But then we take those total shipments 

5 for low volume ceiling fans and scale by 88 

6 percent. 

7 So DOE's model uses a stock accounting 

8 method, calibrated to historical shipments data. 

9 DOE identifies market segments that drive 

10 shipments over time and projects their 

11 contributions to the total shipments. 

12 In this analysis DOE accounted for 

13 shipments due to product replacements. Those 

14 being people who have ceiling fan light kits, and 

15 that ceiling fan light kits dies and they go out 

16 and buy, I guess in this case both a new ceiling 

17 fan and ceiling fan light kit. 

18 And we then also account for shipments 

19 that go into new construction. And also 

20 shipments to installations of existing buildings 

21 that did not previously have a CFLK but now do. 

22 So total shipments are then disaggregated 
224 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 by product class and CSL using a consumer choice 

2 model to project purchasing decisions for each 

3 year in the analysis period. 

4 So this table here shows the inputs that 

5 go into DOE's shipments models, and the data 

6 sources associated with that input. So 

7 replacements, DOE relied on historical shipments 

8 of low volume ceiling fans from appliance 

9 magazine, the NPD group, and estimates from 

10 energy star. DOE then estimated the number of 

11 units that fail in each year by applying a 

12 retirement function based on the product lifetime 

13 to develop the number of shipments in previous 

14 years. 

15 And again, the lifetime that's being 

16 assumed here is the lifetime of the ceiling fan, 

17 which we assume is a good proxy for the lifetime 

18 of the CFLK. 

19 For new construction DOE used estimates 

20 for new housing starts from the annual energy 

21 outlook, 2014, and assumed that 73 percent of new 

22 houses were installed with ceiling fans with each 
225 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 average installation having about 3.1 fans per 

2 home. These numbers come from an analysis of 

3 RECS 2009. So that was the estimates for the 

4 number of ceiling fans. 

5 To get the number of CFLKs that go into 

6 new construction we assumed 88 percent of those 

7 installations would have a CFLK. 

8 So for existing buildings we did an 

9 analysis where we looked at the increasing 

10 fraction of households that had ceiling fans from 

11 RECS 1993 to RECS 2009, and noticed that there 

12 was an increasing fraction of households with 

13 ceiling fans. So we performed a fit to that and 

14 found that the rate was increasing, but the rate 

15 of increase was slowing. So we put a cap at a 

16 total of -- at a market saturation of 75 percent 

17 of households would have a ceiling fan. 

18 And again, we assumed that 88 percent of 

19 those installations would have a ceiling fan 

20 light kit. 

21 And for the market share, we used model 

22 counts from in-store visits and online retailers 
226 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 to get an idea of what the current efficiency 

2 distribution looks like and also the breakdown by 

3 product class. 

4 MR. GATTO: Dave Gatto, Westinghouse 

5 Lighting. Just one quick question. 

6 So you put a cap of 75 percent 

7 saturation. Where is the market -- where is the 

8 market today? So you've got an incremental 

9 increase up to 75 percent -- 

10 MR. GANESHALINGAM: Yeah. 

11 MR. GATTO: -- where you've capped it, 

12 but where is it from the -- 

13 MR. GANESHALINGAM: So in 2009 it was at 

14 73 percent. 

15 MR. GATTO: Okay. So you're projecting 

16 an increase in saturation, but then it's going to 

17 whittle off? 

18 MR. GANESHALINGAM: That remains. Yeah. 

19 MR. GATTO: Okay. Thank you. 

20 MR. GANESHALINGAM: Yeah. Are there 

21 other questions? 

22 (No audible response.) 
227 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 MR. GANESHALINGAM: Okay. So, this is a 

2 schematic of our shipments model showing the 

3 market segments that feed into our total 

4 shipments, so as I mentioned on the previous 

5 slide, we have replacements, new construction, 

6 and installations, and new installations. We 

7 aggregate that to come up with the total 

8 shipments, and then we use the consumer choice 

9 model to disaggregate those into shipments by 

10 product class and CSL. And we do this for each 

11 year in our analysis period. 

12 So a few more assumptions that go into 

13 our model. As I previously mentioned, 88 percent 

14 of low volume ceiling fans were packaged and sold 

15 with CFLKs. Based on an analysis of market data 

16 we are again assuming that CFLKs sold alone are a 

17 negligible fraction of total shipments. We 

18 assume that CFLKs were not purchased with high 

19 volume ceiling fans. 

20 The market share by product class for 

21 2012 was roughly .5 percent going to Externally 

22 Ballasted/Driven and 99.5 percent going to the 
228 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 All Other CFLKs. And we estimated LED 

2 penetration and also the pricing of LEDs using a 

3 solid state lighting report that DOE put out in 

4 2012. 

5 So this brings us to an issue, Issue No. 

6 36, sector breakdown by CFLK usage by sector. 

7 DOE requests comment on its assumed breakdown of 

8 CFLK usage as 95 percent in the residential 

9 sector and five percent commercial sector. So 

10 these are fractions that get used in our 

11 shipments model to keep track of which shipments 

12 are staying in residential and which are in 

13 commercial. 

14 MR. BROOKMAN: Dave. 

15 MR. GATTO: Dave Gatto, Westinghouse. I 

16 think from a percentage standpoint that's 

17 probably accurate. I do think we talked about 

18 this before. There is more commercial use in 

19 like hospitality. But we still kind of, we 

20 consider them residential applications, and they 

21 would have similar hours of use to residential 

22 because if it's in a hotel room it's not in a 
229 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 commercial space where it's on all the time. 

2 The LED penetration estimate with the 

3 incursion curve, you mentioned the DOE 2012 

4 study, and I believe that focused on general 

5 service medium base. So within the Caliper, more 

6 recent Caliper, particularly now a lot of this 

7 was MR-16 and pin-based, but you're also seeing 

8 in the other product types, the same studies 

9 suggest that the adoption rate and the 

10 performance improvement and price learning are 

11 slower for non-integral service lamp. 

12 So it's not a huge difference, but when 

13 you get into small profile the general service is 

14 moving at a faster pace than any other lamp type 

15 for a solid state. So I'm not sure if that's 

16 built in or whether or not you use basically the 

17 2012 report as is. 

18 MR. GANESHALINGAM: Yeah. That's 

19 actually our next slide. But I guess before we 

20 move on, were there any other comments regarding 

21 CFLK usage in different sectors? 

22 MR. BROOKMAN: Ninety-five percent 
230 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 residential. No additional comments? Okay. 

2 MR. GANESHALINGAM: Okay. And that leads 

3 me perfectly into our next couple slides 

4 regarding our treatment of LEDs using the SSL 

5 report. 

6 So, the price learning. So the retail 

7 price associated with each CSL will impact 

8 projected market shares over the course of our 

9 shipments analysis and is accounted for in DOE's 

10 consumer choice model. DOE accounts for price 

11 learning in its estimate of lamp prices over the 

12 analysis period. Price learning is the 

13 systematic decrease in manufacturing cost due to 

14 production experience. The idea here being that 

15 as the cumulative number of units produced 

16 increases manufacturers are able to reduce 

17 manufacturing costs via optimized manufacturing 

18 methods and economies of scale. 

19 For this particular rulemaking we only 

20 assumed that CFLKs that use solid state lighting 

21 would undergo price learning. And so this is 

22 adopted from the SSL report. So it actually uses 
231 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 the same rate as the SSL report. Here, in this 

2 curve in red, it's normalized so on the Y axis is 

3 the lamp price normalized to the 2019 price. And 

4 on the X axis is just the time evolution of that 

5 index. And the SSL report goes up to 2030 and 

6 afterwards we just sort of cap it at the 2030 

7 value. So between 2019 to 2030, it drops; the 

8 price drops in half. 

9 MR. BROOKMAN: Dave. 

10 MR. GATTO: Dave Gatto, Westinghouse 

11 Lighting. First off, yes, I agree that only LEDs 

12 will continue to undergo cost reduction. CFLs, 

13 it's a mature product. There really isn't a 

14 whole lot of development to improving or reducing 

15 the cost. We're all shifting our R&D and our 

16 development expense to LED. 

17 I don't know that I could give you an 

18 alternate curve to use, and I'm not sure that 

19 this curve isn't appropriate because quite 

20 honestly LED has been -- you know, it always 

21 surprises us. I would just point out that, again 

22 that curve is using an analysis on a medium base 
232 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 socket. I think 800 lumens, 60 watt equivalent, 

2 which is not typically the lamp that goes into 70 

3 what percent of the current light kits. 

4 MR. GANESHALINGAM: Thanks. 

5 MR. BROOKMAN: Additional comments? What 

6 about the scale of price decline? Dave. 

7 MR. GATTO: Dave Gatto, Westinghouse. I 

8 guess I have a question. So that 2.5 is just a 

9 normalized -- you're just using that as a 

10 baseline for -- that's not a specific lamp. 

11 That's a, this is our baseline, then over this 

12 time frame that this is what we expect the price 

13 decline to look like. 

14 MR. GANESHALINGAM: That's correct, yeah. 

15 MR. GATTO: Yeah. 

16 MR. GANESHALINGAM: It's just an index. 

17 MR. GATTO: I think that it's as good as 

18 any other. You were using the six percent 

19 learning -- 

20 MR. GANESHALINGAM: Yeah, that's roughly, 

21 right. 

22 MR. GATTO: Honestly, it might be faster 
233 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 than that in general service. It might be 

2 slightly slower than that with some of the 

3 specialty sizes and shapes and bases, but it's as 

4 good a number as any. I wouldn't argue it. 

5 MR. BROOKMAN: Okay. 

6 MR. GANESHALINGAM: Great. 

7 MR. BROOKMAN: Thanks for the bit of 

8 validation. Okay. 

9 MR. GANESHALINGAM: So next we talk about 

10 LED incursion. So this is how LEDs are actually 

11 coming in to the market place for CFLKs. We 

12 again use the projections, or we -- well, we 

13 started with the projections from the SSL report. 

14 There they have LEDs coming in at 2010. But from 

15 our observations of the CFLK market we noticed 

16 that there was a little bit of a time lag between 

17 what was happening for general service lamps and 

18 what was happening in CFLKs. So we actually 

19 shifted the plot along the X axis to start in 

20 2012. But we kept the actual sort of the way it 

21 diffuses into the market place the same as that 

22 in the SSL report. 
234 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 And so by the beginning of our analysis 

2 period in 2019 we're at about 26, 27 percent LED. 

3 Which I guess I'll throw out there is that -- if 

4 anyone has any comment on that. 

5 MR. GATTO: Dave Gatto, Westinghouse. 

6 Just that it's as good a guess as any. I do 

7 appreciate, and it sounds like you recognized 

8 that the CFLK adoption rate is going to trail the 

9 general service lamp. It just, it's partly 

10 because of what Dave Turner and some of the other 

11 guys said, that the fan manufacturers are really 

12 relegated to what's available to them. But it's 

13 also kind of a mature product category in and of 

14 itself and it requires design changes to 

15 accommodate. 

16 MR. BROOKMAN: Okay. Thanks. 

17 MR. GATTO: Thanks. 

18 MR. BROOKMAN: David. 

19 MR. TURNER: Is this in outside of fan 

20 regulation outside of fan regulation, or light 

21 kit regulation? I'm sorry. 

22 MR. GANESHALINGAM: Well, this happens 
235 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 regardless. This is just sort of the expected 

2 rate. 

3 MR. TURNER: Regardless of what this -- 

4 outside of a performance standard being put into 

5 place. 

6 MR. GANESHALINGAM: That's correct. This 

7 is just the projected rate at which LEDs will 

8 come into CFLKs. 

9 So a couple of issues for comment. CFLK 

10 distributions by technology and sector. So DOE 

11 assumed that the distribution of CFLKs by light 

12 source technology in the commercial sector is the 

13 same as the light source technology distribution 

14 in the residential sector. DOE requests comment 

15 and input regarding this assumption. 

16 MR. BROOKMAN: Dave. 

17 MR. GATTO: Dave Gatto, Westinghouse. 

18 Same thing I said earlier. I think the 

19 commercial segment is small. So it's as good a 

20 guess as any. 

21 MR. GANESHALINGAM: And on to the next 

22 issue, LED penetration in the CFLK market. I 
236 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 think we touched a little bit on this. But DOE 

2 estimated that market penetration of LEDs into 

3 the CFLK market has a bass diffusion curve. DOE 

4 requests comment on this approach. 

5 Okay. So that brings us to the consumer 

6 choice model. DOE used a consumer choice model 

7 projecting market shares for each product class 

8 at each efficiency level. Typically the consumer 

9 choice model estimates how consumers make a 

10 choice based on their sensitivity to first cost 

11 and operating cost of available options. 

12 However, in the case of ceiling fan light 

13 kits the consumers of the CFLKs aren't the ones 

14 who are choosing the lamp. The lamp is actually 

15 packaged by the manufacturer, so this has to be 

16 taken into account in our modeling that it's the 

17 manufacturer who is purchasing the lamp. 

18 So the consumer choice model for CFLKs 

19 works as followed. So first, market share is 

20 apportioned to LED levels based on that incursion 

21 curve which we saw on a previous slide. The 

22 remaining market share is then split between the 
237 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 other CSLs, assuming manufacturers will choose 

2 the lowest first cost lamp option for a given 

3 socket type and lamp technology. 

4 And then the market share for that given 

5 CSL is divided evenly between those two scenarios 

6 from the engineering data, with being the lamp 

7 and the fixture replacement scenarios. 

8 In a standards case, options that do not 

9 meet the standard are eliminated and 

10 probabilities are recalculated, sort of going 

11 through this model in an iterative fashion. 

12 So, DOE expects that a relative increase 

13 in price for the average CFLK due to a standard 

14 will have an impact on shipments. That being 

15 that, an increase in price will decrease 

16 shipments. DOE estimates this impact using a 

17 price elasticity. So that's the impact of a 

18 ceiling fan light kit standard on ceiling fan 

19 light kit shipments. 

20 Since CFLKs are packaged with ceiling 

21 fans and a ceiling fan standard is also being 

22 considered, we also took into account the impact 
238 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 of a ceiling fan standard on ceiling fan light 

2 kit shipments and includes this in our analysis. 

3 MR. BROOKMAN: David. 

4 MR. TURNER: So regarding the relative 

5 price elasticity, I know we're talking about a 

6 price sensitivity analysis, and can you kind of 

7 go into a little bit more about the price 

8 elasticity and how it was determined how it would 

9 affect shipments? 

10 MR. GANESHALINGAM: Right. So the price 

11 elasticity relates the fractional increase -- a 

12 fractional increase in price will lead to a 

13 fractional decrease in shipments. And so that's 

14 related to another using an elasticity of demand. 

15 That elasticity of demand in this case was 

16 estimated from data from I believe it's 

17 refrigerators and dishwashers. 

18 And that elasticity is used in other 

19 rulemakings as well. We didn't have any data 

20 specific to ceiling fans in order to estimate 

21 what the price elasticity would be in this case. 

22 If manufacturers have that data it would be very 
239 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 useful to come up with a price of elasticity 

2 specific to this product. 

3 MR. LINSTONE: This is Clark Linstone, 

4 Lamps Plus. I mean, I think my feeling in terms 

5 of just looking at this product versus say 

6 refrigerators, is there is probably more 

7 variability I guess I would say, in terms of need 

8 in a household. I mean, there are options, there 

9 are different ways as I said, you know, some 

10 people use these ceiling fans as a primary light 

11 source in a room. So I think there would be a 

12 higher elasticity than say refrigerator which 

13 might be more of a, you know, required product in 

14 a home. 

15 MR. BROOKMAN: Okay. Thank you. 

16 MR. CYMBALSKY: This is John from DOE. 

17 So I think tomorrow is where I think this 

18 argument has been pretty vocal on the elasticity 

19 with ceiling fans. And I know we're bringing it 

20 up here because obviously these kind of go 

21 together and, you know, I urge everyone to look 

22 at -- when we get there tomorrow. Maybe a little 
240 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 homework for tonight. Look at the marginal cost 

2 for the different efficiency levels considered 

3 for ceiling fans, before we make statements about 

4 what would happen to shipments. So I just throw 

5 that out there. 

6 MR. BROOKMAN: Okay. 

7 MR. GANESHALINGAM: Okay. Thank you. So 

8 these are our results for the two product classes 

9 being considered. On the left we have Externally 

10 Ballasted/Driven, and on the right All Other 

11 CFLKs. 

12 So these plots show both the shipments in 

13 the no-standard case and with a given standard in 

14 place. In cases where there's little difference 

15 between shipments projections the results of the 

16 higher standard overwrite the lower standard. 

17 One thing to take note of is the decline 

18 in Externally Ballasted/Driven over time, because 

19 we actually expect LED incursion to happen and to 

20 that product class as well, and to move market 

21 share over to the All Other CFLK product class. 

22 MR. BROOKMAN: Yes, Dave. 
241 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 MR. GATTO: So, on the All Other -- first 

2 off, yeah, I agree with the Externally Ballasted 

3 in the way that product class currently exists 

4 with a pin-based fluorescent is going to 

5 effectively go away. It's marginalized now and 

6 LEDs will replace it. Whether that's as a 

7 complete fixture or not it's, you know, still up 

8 in the air. 

9 But on All Other CFLKs you're projecting 

10 ongoing increases in shipments at basically 

11 evenly at all of the CSLs. But even if you 

12 consider a fractional price elasticity you've got 

13 some pretty nonfractional numbers in there. I'm 

14 not sure how they didn't impact the shipment 

15 analysis because it really looks like -- now I 

16 know that this is looking out past 2025 and 

17 you've got price learning in there. But you may 

18 not have any ceiling fan light kits left in the 

19 market place by that point if the price is too 

20 high. So how did you account for that. 

21 And I don't mean that facetiously, and 

22 John, I agree with you, tomorrow is a good place 
242 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 to talk about it. I just, I'm having trouble 

2 with the math. 

3 MR. GANESHALINGAM: Sure. So there are a 

4 couple points. One, as you pointed out, price 

5 learning is taken into account here. And so for 

6 CSLs 3 through 5 there will be a drop in the 

7 price which then -- the drop in price is lamp, 

8 which then will not affect the shipments as much 

9 in that case. 

10 The other thing to keep in mind is I 

11 mentioned that the price elasticity relates the 

12 drop in shipment -- the fractional drop in 

13 shipments to the fractional increase in price. 

14 That price is the price of a ceiling fan plus the 

15 ceiling fan light kit, because that's what a 

16 consumer is purchasing. 

17 MR. GATTO: So, Dave Gatto, Westinghouse. 

18 John, I apologize. That's what you were saying a 

19 minute ago and I missed it. This is the all-in 

20 inclusive. So I'm sorry, I really had CFLKs in 

21 my head. So that makes more sense in that what 

22 you're saying is the total price might not change 
243 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 as much. I'm not sure if I agree with that, but 

2 I can understand that that would drive this 

3 number. 

4 MR. GANESHALINGAM: Okay. Okay. Now we 

5 turn to the National Impact Analysis, or the NIA. 

6 The purpose of the NIA is to estimate the 

7 national energy savings and consumer net present 

8 value of the potential standard. This is done by 

9 developing an annual series of national energy 

10 and economic impacts for the no standards case 

11 and standards cases. 

12 Inputs to the NIA come from the LCC and 

13 results from shipments. DOE reports the total 

14 energy saved in a standards case with respect to 

15 the base case and the economic impact as change 

16 in consumer national net present value, which is 

17 reported in constant year dollars. 

18 The time value of money is accounted for 

19 through defined discount rates when reporting the 

20 net present value, or NPV for short. 

21 So, here is a schematic of the NIA 

22 process. As I mentioned, inputs from the 
244 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 shipments and LCC are used to calculate national 

2 energy savings and economic impacts. Total 

3 energy savings are aggregated over the analysis 

4 period and reported in quads. Economic impacts 

5 from a change installed cost and operating cost 

6 due to a standard are discounted and then 

7 aggregated to give the net present value. 

8 All economic results are reported in 2013 

9 dollars. 

10 The analysis computes NES and NPV for all 

11 products shipped under the analysis period. It 

12 includes the full energy savings realized over 

13 the lifetime of those products. So the analysis 

14 includes the impacts of shipments from 2019 to 

15 2048, but will include operating cost savings and 

16 energy savings for CFLKs shipped over that period 

17 that could live up to 2077. So that just means 

18 you could have a product that's shipped in 2048, 

19 but because it has a lifetime that could be as 

20 long as 30 years, we're still accounting for any 

21 energy savings that could happen in that 30 

22 years. 
245 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 So this is a slide just sort of showing 

2 all of the inputs that go into the NIA. Total 

3 installed cost is the per-unit annual weighted 

4 average value as a function of CSL. That comes 

5 from the LCC. Repair and maintenance costs. In 

6 this case, we again took into account relamping, 

7 similar to what was done in the LCC, except we do 

8 it for each year, each of the CFLKs year's 

9 shipments. 

10 We have the annual energy use, which is 

11 the per-unit annual weighted energy use as a 

12 function of CSL, which comes from the energy use 

13 analysis. 

14 We have the base case and standards case 

15 efficiency distributions which are output from 

16 our consumer choice model. 

17 Energy prices are the average national 

18 forecasted prices that come from AEO 2014. 

19 Full fuel cycle, which is a multiplier 

20 used on primary fuels to get a full accounting of 

21 energy savings. Discount rates, we use seven 

22 percent and three percent real, per OMB as 
246 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 regulatory analysis guideline. And the present 

2 year used in this analysis is 2014. 

3 MR. CYMBALSKY: So this is John from DOE. 

4 So before we talk, Doug Smith had a question 

5 about average versus marginal prices. And I 

6 apologize, my head was stuck on a rule that we 

7 used marginal prices on because it was a very 

8 peaky end-use cooling in that case. 

9 So in this case we did use the average 

10 price because in our determination the lighting 

11 use is not a peaky end-use, right? It's used 

12 late at night when it's not peaking. So, we did 

13 use average, and I think going forward we will 

14 continue to use average. So I misspoke earlier 

15 and I apologize. 

16 MR. BROOKMAN: Okay. Thank you. 

17 MR. GANESHALINGAM: So the national 

18 energy savings are computed each year using this 

19 equation. First we calculate the annual energy 

20 consumption of stock for a given year in the base 

21 case and compare that to the annual energy 

22 consumption projected under a standard. We 
247 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 include a term to account for any rebound affect 

2 that could happen due to a standard. And the 

3 rebound affect accounts for increased usage after 

4 moving to more efficient products. 

5 In our reference case we assumed a 

6 rebound rate factor of one, which implies a 

7 rebound rate of zero based on comments submitted 

8 during the framework. 

9 And finally we multiply by a full fuel 

10 cycle multiplier to determine energy savings in 

11 quads. 

12 And this is just a little bit more 

13 information on the full fuel cycle multiplier. 

14 It's a measure of energy and greenhouse gases and 

15 other omissions that is accounted for in the 

16 standards rulemaking, and the methodology is 

17 based on the calculation of an FSC multiplier or 

18 conversion factor for the electricity used by 

19 this product. And we have a TSD appendix which 

20 goes into more detail. 

21 This is our equation for calculating the 

22 NPV, which is how we quantify economic impacts. 
248 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 The NPV is equal to the present value of savings 

2 achieved under a standard, minus the present 

3 value of added cost that that standard imposes. 

4 Present values are computed for a three and seven 

5 percent discount rate and reported in 2013 

6 dollars. And again, we used 2014 as the year 

7 that we discount to. 

8 So these are some similar slides to what 

9 we saw on the LCC. Just to reiterate that we 

10 took into account lamp replacements. So we 

11 included in the NIA, the cost to replace lamps 

12 that failed during the lifetime of the CFLK. 

13 Lamp replacement costs are the purchase cost of 

14 replacement lamps in the year the lamps fail. 

15 The CFLK lamps fail at the end of their average 

16 service lifetime, which is the lamp lifetime 

17 divided by the lamp's operating hours. Again, we 

18 have the same criteria for those replacement 

19 lamps. They must have the same base type as the 

20 failed lamps, provide an equivalent lumen output 

21 as the failed lamps, and the prices do not 

22 include the CFLK manufacturer markup. And again 
249 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 we used that consumer choice model to determine 

2 replacement lamps. 

3 And again, I just wanted to reiterate 

4 that not only does this come as a sort of cost 

5 for actually having to replace the lamp, but it 

6 could change the unit energy consumption 

7 associated with that light kit as we move to a 

8 different lamp. 

9 Again, as similar to the LCC we take into 

10 account residual value, which is the remaining 

11 value of the surviving lamp at the end of the 

12 CFLK lifetime. This is applied as a credit to 

13 the NIA as it was in the LCC, and we calculate 

14 the residual value for lamps based on the lamp 

15 price and the year the CFLK is retired. 

16 So, these are the results for the energy 

17 savings reported in quads. And these are full 

18 fuel cycle energy savings. Each of the different 

19 columns are the different CSLs being considered 

20 and the rows are the two product classes. 

21 Couple things to point out. As you'd 

22 expect, the values are mostly increasing as you 
250 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 go from CSL-1 to CSL-5, and the energy savings 

2 between CSL-3 and CSL-5 are roughly the same 

3 because of that evolution in LED efficacy that we 

4 talked about earlier, that we actually expect 

5 that by the beginning of the analysis period most 

6 of the LED lamps have sort of moved to CSL-5. 

7 And these are the results for the net 

8 present value. Again, the columns are the CSLs 

9 and the rows are the product classes. And one 

10 thing to keep in mind on this light is that the 

11 results for the Externally Ballasted/Driven 

12 product class are in millions of 2013 dollars, 

13 and the results for All Other CFLKs are in 

14 billions. 

15 MR. BROOKMAN: Any comments on the 

16 foregoing National Impact Analysis slides? 

17 Nathan? 

18 MR. FRAMPTON: Is there any data that you 

19 can give us on like total impact of national 

20 energy consumption as a percentage? 

21 MR. GANESHALINGAM: Not off the -- can 

22 you -- 
251 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 MR. CYMBALSKY: So you mean, so how much 

2 does 400 trills represent in -- yeah. So the 

3 residential sector primary energy wise uses about 

4 18 quads. So, 400 trills and 18 quads in one 

5 year. This is savings over 30 years, so. As far 

6 as rules go, I mean, you know I'm looking more at 

7 the NPV here. So it's over 2 billion of NPV to 

8 the consumer. 

9 What you don't see here is manufacturer 

10 impacts yet. So in the next phase of the 

11 rulemaking you'll see some additional analysis 

12 overlaid on top of this, and -- but you know, 2 

13 billion is a pretty big number. 

14 MR. BROOKMAN: Yes, Dave. 

15 MR. GATTO: Dave Gatto, Westinghouse. 

16 Yeah, thanks, John. And I was looking at these 

17 the other night. And we haven't finished our 

18 even discussion of comments yet. But in general, 

19 if there's no additional savings but there's an 

20 additional cost, that's something that DOE in the 

21 past has been willing to look at when we're 

22 talking about what the proposed rule establishes 
252 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 as the final CSL. I'm hoping/assuming, but I'm 

2 kind of asking you since you and Lucy are here. 

3 I would assume that DOE kind of sees it the same 

4 way, that if we're going to -- we want to 

5 maximize the savings with the least impact to 

6 both consumers and manufacturing. 

7 MR. CYMBALSKY: So what the statute says 

8 is that we maximize energy efficiency that is 

9 technologically feasible and economically 

10 justified. So that is a little bit different 

11 than what you just said, however there are 

12 standards that maximize exactly what you said 

13 because of other factors like manufacturer 

14 impact. And so it could go either way. We're 

15 not at that point yet. But the next rulemaking 

16 document will get us to that point. 

17 MR. BROOKMAN: Anthony Fryer has a 

18 question. Anthony is joining us online. 

19 Anthony, if you unmute your phone and speak 

20 clearly we should be able to hear you in the 

21 room. 

22 MR. FRYER: Thanks. Can you hear me 
253 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 okay? 

2 MR. BROOKMAN: Yes. 

3 MR. FRYER: Okay. I've got a question on 

4 the previous slide, the National Energy Savings 

5 Estimate. 

6 So in the TSD the .286 is listed out as 

7 the impact of meeting CSL-0. And then there's an 

8 additional column done measuring the impact from 

9 CSL-0 to the other five CSLs. Based on that, 

10 does that mean that these numbers do incorporate 

11 savings associated with moving from the 

12 incandescent technology that's now in that 

13 product class? Or this purely savings from the 

14 current product class standard level, the 45 

15 lumens per watt level? 

16 MR. GANESHALINGAM: So the energy savings 

17 in this slide here represent going from no CFLK 

18 standard to the standard listed in each of those 

19 columns. 

20 MR. FRYER: Okay. So the savings from 

21 the current product class 3 are incorporated in 

22 this, they're just not used as a baseline? 
254 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 MR. GANESHALINGAM: So the way in which 

2 it's broken out in the TSD of meeting CSL-0 would 

3 be the impact of product class consolidation. 

4 MS. KANTNER: This is Colleen Kantner. 

5 To answer your question, yes, this does 

6 incorporate the savings from going from no 

7 standard to product class consolidation, as well 

8 as the impact of going to the standard level 

9 identified. 

10 MR. BROOKMAN: Thank you, Colleen. 

11 MR. FRYER: Thanks. 

12 MR. BROOKMAN: Anthony, do you have 

13 additional questions? 

14 MR. FRYER: That's it for now, thanks. 

15 MR. BROOKMAN: Thank you. Okay. We are 

16 finishing up on the net present value slides and 

17 we're moving on. Any additional -- we're about 

18 to move off preliminary -- or NIA. Any 

19 additional questions, thoughts on NIA? 

20 (No audible response.) 

21 MR. BROOKMAN: Okay. On to preliminary 

22 manufacturer impact analysis and to Aisha. 
255 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 MS. HUSAIN: This is Aisha from Navigant. 

2 So I'll be talking about the methodology for the 

3 manufacturer impact analysis, or the MIA. And I 

4 just have one slide. 

5 The main purpose of MIA is to 

6 quantitatively assess the financial impact of 

7 energy conservation standards on manufacturers of 

8 ceiling fan light kits. This is done in three 

9 phases. The first phase we do an industry 

10 profile, and you probably will see that in the 

11 preliminary TSD. The second and third phase 

12 you'll see in the NOPR stage. 

13 In the second phase DOE develops an 

14 industry cash flow model called the Government 

15 Regulatory Impact Model, or GRIM, to forecast 

16 industry cash flows. In this phase DOE also 

17 develops an interview guide for manufacturers to 

18 facilitate discussions during manufacturer 

19 interviews. 

20 In the third phase manufacturers are 

21 interviewed and information from the interviews 

22 and the GRIM model are used to conduct a 
256 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 quantitative assessment of impacts due to 

2 potential standards. And manufacturer interviews 

3 are also used to make qualitative assessments of 

4 impacts. 

5 The key output of the MIA is the change 

6 in the industry net present value, or INPV, 

7 resulting from potential standards. The MIA also 

8 wanted to note attempts to identify any potential 

9 manufacturer subgroups whose cost structure 

10 differs significantly from industry average. 

11 So an example would be a subgroup of a 

12 subgroup would be small business manufacturers. 

13 And finally, the MIA also attempts to 

14 quantitatively and qualitatively examine other 

15 nondirect financial impacts and these could 

16 include a direct employment impact, a 

17 manufacturing capacity impact, and a cumulative 

18 regulatory burden impact on manufacturers of 

19 ceiling fan light kits. 

20 And so I do have another slide. So here 

21 is the request for comments. So this basically 

22 covers any comments you'd have on the methodology 
257 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 for the Manufacturer Impact Analysis. Also the 

2 Regulatory Flexibility Act analysis which 

3 basically evaluates the impact on small 

4 businesses, any comments you might have on how 

5 DOE proceeds with the manufacturer subgroup 

6 analysis, and also if you have any comments on 

7 the manufacturer markups that were used in this 

8 preliminary analysis. 

9 MR. BROOKMAN: Manufacturer markup being 

10 1.37 used in preliminary analysis, if that 

11 interests you. Dave. 

12 MR. GATTO: No, not that last one. I'm 

13 not sure if I could even speak to that without 

14 falling afoul of an antitrust violation. 

15 MR. BROOKMAN: Uh-huh. 

16 MR. GATTO: But all I would say is that 

17 Westinghouse is committed to participate in the 

18 interview process again, and I'm encouraging my 

19 counterparts who either did, to do it again or 

20 who haven't, to do so, to make sure that you get 

21 all the information you need for that analysis. 

22 MR. BROOKMAN: Thank you. 
258 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 MS. HUSAIN: Thank you. 

2 MR. GATTO: Thanks. 

3 MR. CYMBALSKY: And on behalf of DOE I do 

4 want to thank the manufacturers, and Dick stepped 

5 out, I think. But I know Dick and others have 

6 been, you know, very helpful in rounding up the 

7 troops here, and you guys have been participating 

8 very strongly in this rulemaking, and DOE really 

9 appreciates it. I think without the good data 

10 that you're supplying and information under the 

11 NDAs, the rulemaking wouldn't be as strong as it 

12 is. I know we've had issues in other rulemakings 

13 and I think, you know, we don't have that here. 

14 I think we have a good data set and I really 

15 appreciate it. So, thanks. 

16 MR. BROOKMAN: Thank you. There you see 

17 the comment boxes related to general request for 

18 comment on MIA and then Regulatory Flexibility 

19 Act, and then manufacturer subgroup and once 

20 gain, markups. Any additional comments on any of 

21 those four? 

22 MR. TURNER: David Turner from Hunter 
259 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 Fan. Is the manufacturer markup, is that a 

2 weighted across the three distribution channels 

3 of 1.37? 

4 MS. HUSAIN: I don't think it was. Ali, 

5 do you want to -- 

6 MR. BROOKMAN: Ali. 

7 MS. MCDONALD: I was just going to say 

8 the production (indiscernible) -- 

9 MR. BROOKMAN: We didn't hear that. The 

10 mic did not pick that up. 

11 MS. MCDONALD: Sure. This is Ali 

12 McDonald. That's going from manufacturer 

13 production costs to manufacturer selling price. 

14 So it's prior to -- I guess it would be the same 

15 across all three channels regardless of where it 

16 was sold to. So that would vary based on the 

17 channel it was sold at. 

18 MR. TURNER: Say that again. It's going 

19 from a manufacture production costs -- 

20 MS. MCDONALD: From your cost to selling 

21 price. 

22 MR. TURNER: Okay. Okay. 
260 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 MR. BROOKMAN: Okay? Yes, Nathan. No? 

2 You were just stretching. Okay. 

3 Then we're moving on to the NOPR 

4 analyses. 

5 MS. KANTNER: So the NOPR analyses are 

6 the analyses that will be conducted at the next 

7 phase of the rulemaking. These include revising 

8 the preliminary analysis, the life-cycle cost 

9 subgroup analysis, the manufacturer impact 

10 analysis, the employment impact analysis, the 

11 utility impact analysis, the emissions impact 

12 analysis, the monetization of emissions 

13 reductions and benefits, and the regulatory 

14 impact analysis. 

15 This slide provides some details on what 

16 each of these is supposed to represent. The 

17 subgroup analysis looks at the effects on various 

18 national consumer subgroups. The manufacturer 

19 impact analysis continues work begun in the 

20 preliminary MIA. The employment impact analysis 

21 looks at indirect effects on national employment 

22 as opposed to direct impacts which are looked at 
261 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 as part of the MIA. The utility impact analysis 

2 looks at affects on generation capacity of 

3 utilities. The emissions analysis looks at 

4 affects on airborne pollutant emissions. The 

5 monetization of emissions reduction benefits 

6 looks at the monetary benefits of emissions 

7 reductions. And the regulatory impact analysis 

8 looks at the potential for nonregulatory 

9 approaches. 

10 MR. BROOKMAN: Comments on any of those, 

11 what are called downstream analysis, should there 

12 be any at this time? 

13 Yes, Dave. 

14 MR. GATTO: Dave Gatto, Westinghouse. In 

15 the subgroup analysis for the LCC are you already 

16 considering low income? Are there any -- I know 

17 the spreadsheet came out like a week and a half 

18 ago. I haven't had time to look at it yet, so 

19 are there subgroups that you're already 

20 considering? We might recommend some if it's 

21 missing, but if you already have subgroups that 

22 you're planning to analyze then -- 
262 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 MS. KANTNER: So there were no subgroups 

2 analyzed at the preliminary analysis stage, but 

3 we do intend to look at low income individuals -- 

4 MR. GATTO: Okay. 

5 MS. KANTNER: -- as one of the subgroups 

6 (Multiple Speakers) -- 

7 MR. BROOKMAN: So, Dave, if you have any 

8 to suggest now -- 

9 MR. GATTO: That was the main one and I 

10 thought you had already -- I had talked to 

11 somebody, it might have been you, John, offline 

12 that I thought you were going that way. But I 

13 didn't want to not ask the question and find out 

14 that if we didn't include it in the comments it 

15 wouldn't get done. So. 

16 MR. CYMBALSKY: We do that in all the 

17 rulemakings. 

18 MR. GATTO: I thought so. 

19 MR. CYMBALSKY: This one won't be any 

20 different than the rest, so we -- 

21 MR. GATTO: Yeah. Thank you. 

22 MR. CYMBALSKY: The impact might be 
263 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 different but the analysis -- 

2 MR. GATTO: Yes. 

3 MR. CYMBALSKY: -- will be the same. 

4 MR. GATTO: Thank you very much. 

5 MR. BROOKMAN: Okay. So now an 

6 invitation and opportunity for anybody that 

7 wishes to, to make closing remarks. 

8 (Discussion off the record.) 

9 MR. BROOKMAN: No closing remarks, so 

10 then back to Lucy deButts for a recitation on how 

11 to submit comments. 

12 MS. DEBUTTS: Well, first of all thanks 

13 everyone for coming. We are looking for your 

14 comments and it seems like we're going to have 

15 quite a bit of information from you guys. And 

16 again, this slide shows how to submit comments. 

17 Hopefully we can get them all by December 30th of 

18 this year. So next year is going to be very 

19 productive for us. 

20 And that's it. Thank you. 

21 MR. BROOKMAN: Thanks to all. Safe 

22 travels. And we'll see many of you, most of you 
264 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 tomorrow. Yes. 

2 Dick, you have a comment? 

3 MR. UPTON: May I have this room for 

4 about three minutes after the meeting is 

5 adjourned. I've got a subject I've got to raise 

6 with him and this is the only time I can get him 

7 to get it. 

8 MR. BROOKMAN: Sure. 

9 MR. CYMBALSKY: There's also a back room, 

10 a holding room in the back. You can close the 

11 door and have privacy. 

12 MR. BROOKMAN: Yeah. 

13 MR. UPTON: Thank you, John. 

14 MR. CYMBALSKY: Yup. 

15 MR. BROOKMAN: If you could help us clean 

16 up this room, please remove your cups and other 

17 paraphernalia. 

18 (Meeting concluded at 3:08 p.m.) 

19 

20 

21 

22 
265 

OLENDER REPORTING, INC. 

1100 Connecticut Avenue NW, #810, Washington, DC 20036 

Washington: 202-898-1108 • Baltimore: 410-752-3376 

Toll Free: 888-445-3376

1 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. 

11 _______________________ 

12 BRIAN KNIESER 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 
265 

1 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. 

11 

12 

13 

14 

15 

16 

17 

18 

19 

20 

21 

22 

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