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 Energy Conservation Standards Meeting

 Notice of Proposed Rulemaking

 for

 General Service Fluorescent Lamps and

 Incandescent Reflector Lamps

 1614-1 EE-5B

 Thursday, May 1, 2014

 Department of Energy

 1000 Independence Avenue SW

 Forrestal Building

 Washington, DC 20585
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1 A P P E A R A N C E S

2 Doug Brookman Maureen Kienle

John Cymbalsky Julie Pierce

3 Lucy deButts Brian Gerke

Sarah Butler Karina Garbesi

4 Michael Rivest Aisha Husain

Timothy Ballo Hayden Cook

5 Andrew DeLaski

Susan Callahan

6 Joe Howley

Mark Duffy

7 Dave Gatto

Keith Cook

8 Alex Boesenberg

Garry Fernstrom

9 Charlie Stevens

Michael McGaraghan

10 Eric Montgomery

David Nesting

11

12

13

14

15

16

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19

20

21

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

2 MR. BROOKMAN: Okay. We are going to

3 start. Good morning everyone. Welcome. This is the

4 Energy Conservation Standards Meeting Notice of

5 Proposed Rule Making meeting for General Service

6 Fluorescent Lamps and Incandescent Reflector Lamps.

7 Today is May 1, 2014, here in the Forrestal

8 Building, Department of Energy in Washington D.C.

9 My name is Doug Brookman, Public Solutions

10 in Baltimore.

11 We are going to start this morning with

12 welcoming remarks from John Cymbalsky.

13 MR. CYMBALSKY: Thank you Doug. Welcome

14 everyone. So today is May Day. And you are lucky

15 enough to have two Ukrainian-American kind of

16 running the show here. And so as opposed to talking

17 about world events we will talk about something much

18 more pleasant, the GSFL-IRL NOPR that we are going

19 to discuss today. I would like to particularly

20 point out, I know I have talked to a few of you

21 already, Section 6 of the agenda where we will talk

22 about shipments. We have rolled out a refinement to
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1 our consumer choice modeling and we are hoping that

2 we get a lot of good comment on what we have done

3 here. We realize that with LEDs really moving along

4 things in this market are quite dynamic and so we

5 are hoping that our modeling techniques actually did

6 a good job of picking up on it. I think it did.

7 But of course we are looking for you to offer good

8 public comment here.

9 I will have to duck out just before 10:30

10 for other meetings and such but please have a good

11 meeting and thank you once again for all your public

12 comment.

13 MR. BROOKMAN: Let's start with

14 introductions. And apparently these microphones

15 need to be quite close to your face. You can get

16 used to turning them on and off.

17 MR. FERNSTROM: Good morning I am Garry

18 Fernstrom representing the California Investor Owned

19 Utilities which are the Pacific Gas and Electric

20 Company, the Southern California Edison Company, the

21 San Diego Gas and Electric Company and the Southern

22 California Gas Company. And my associate, Mike
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1 McGaraghan who normally represents us on lighting

2 issues is not here this morning but he is either on

3 the phone or will be on the phone shortly. He is

4 with Energy Solutions and similarly represents our

5 utilities. Thank you.

6 MR. BROOKMAN: Thank you.

7 MR. BOSENBERG: I am Alex Boesenberg,

8 Manager of Regulatory Affairs for the National

9 Electrical Manufacturer's Association.

10 MR. K. COOK: Keith Cook with Philips

11 Lighting.

12 MR. GATTO: Dave Gatto with Westinghouse

13 Lighting.

14 MR. DUFFY: I am Mark Duffy, GE Lighting.

15 MR. HOWLEY: Joe Howley, GE Lighting.

16 MS. CALLAHAN: Sue Callahan, OSRAM

17 Sylvania.

18 MR. DeLASKI: Andres DeLaski, Appliance

19 Standards Awareness Project.

20 MR. BALLO: Tim Ballo, Earth Justice.

21 MS. BUTLER: Sarah Butler, DOE General

22 Counsel's Office.
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1 MS. HUSAIN: Aisha Husain, Navigant

2 Consulting.

3 MS. PIERCE: Julie Pierce, Navigant

4 Consulting.

5 MS. KIENLE: Maureen Kienle, Navigant

6 Consulting.

7 DR. GERKE: I am Brian Gerke, Lawrence

8 Berkeley National Lab.

9 MR. BROOKMAN: If you could just stand.

10 We don't need the mike in the back.

11 MR. COOK: Hayden Cook, Navigant.

12 MR. STEVENS: Charlie Stevens, Northwest

13 Energy Alliance.

14 MR. BROOKMAN: Thanks to all of you for

15 being here.

16 MS. deBUTTS: Lucy deButts, DOE.

17 MR. BROOKMAN: Thank you, Lucy. Thanks to

18 all of you for being here so we can get an early

19 start on the day. All of you received a packet of

20 information when you checked in this morning.

21 And I am going to do a very brief agenda

22 review. Following this agenda review is an
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1 opportunity for anyone that wishes to offer some

2 introductory remarks or opening statements and then

3 moving on directly from there Market and Technology

4 Assessments, Screening Analysis and then Engineering

5 Analysis. We will take a break mid-morning, say

6 10:45 or so. Following that Product Price

7 Determination, Trial Standard Levels, Energy Use

8 Analysis and Life- cycle Cost Analysis. We will

9 take the lunch midday and moving on from lunch

10 Shipments Analysis, National Impact Analysis,

11 Manufacturer Impact Analysis. Following from there

12 and then directly Emissions Modernization of

13 Emissions, Utility Impact, Employment Impact,

14 Regulatory Impact Analyses. And then culminating

15 around about 3:00 or so whenever we get there, the

16 proposed standard.

17 At the end of the day yet another

18 opportunity for you to make closing remarks, any

19 issues that you would like to bring to the fore that

20 haven't been covered sufficiently, that would be the

21 time for that.

22 And I would ask for your consideration if
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1 you would, speak one at a time. Please say your

2 name for the record. There will be a complete

3 transcript of this meeting. Be concise. Share the

4 air time. There is a lot to be said during the

5 course of this meeting. If you'd keep the focus

6 here; turn your cell phones on silent; and limit

7 sidebar conversations.

8 And webinar participants we welcome you.

9 The Department of Energy is trying very hard to make

10 these meetings accessible to all via the web. If

11 you would keep your telephone on mute it will limit

12 the feedback here in the room. And if you raise

13 your hand in the software that is provided, we ought

14 to be able to hear you in the room. We will

15 recognize you to speak and unmute your phone and we

16 ought to be able to hear you right here in the room.

17 And I believe that is all of my

18 housekeeping items for now.

19 Lucy deButts?

20 We have five individuals.

21 We have 12.

22 MR. BROOKMAN: We have 12 on the line
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1 right now. I thought -- do you want to do slides

2 first?

3 MS. DeBUTTS: Okay. So the note for those

4 who are on the webinar we are going to make your

5 comments be part of the public transcript. And then

6 we also encourage everyone to submit written

7 comments. We can do the slides first and then we can

8 go with the opening statements. I think it is going

9 to be in a couple of slides if that is okay.

10 So let's discuss the purpose of today's

11 public meeting. It is to present the energy

12 conservation standards DOE is proposing to GSFLs and

13 IRLs as a result of the analysis we've conducted.

14 We certainly want to understand your

15 concerns. So that is why we are asking for

16 comments. Later we will discuss the next steps in

17 this rulemaking. And as always we will provide an

18 opportunity for opening remarks at the end, I am

19 sorry, at the beginning. And of course closing

20 remarks at the end.

21 If you have any information or data that

22 could help us to analyze this rule, please provide
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1 us with that.

2 In order to facilitate comments throughout

3 this presentation we will have issue boxes which

4 request comments on specific topics. These requests

5 for comments are also outlined at the end of the

6 Federal Register Notice. And the issue box number

7 corresponds to the numbering at the end of the

8 Federal Register Notice.

9 So the comment period for this rulemaking

10 ends on June 30 of this year. And that gives

11 everyone time to finalize your written comments.

12 These written comments can be submitted via email,

13 post, or courier. Of course we encourage the use of

14 electronic sources. And of course we encourage --

15 and information on how to submit these comments is

16 presented on this slide.

17 And now to opening remarks.

18 MR. BROOKMAN: Opening remarks.

19 Garry Fernstrom?

20 MR. FERNSTROM: This is Garry Fernstrom

21 for the California Investor Owned Utilities. I'd

22 like to at some point during the day ask DOE to
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1 address a question we have about testing and values

2 reported to the DOE database. So we are

3 particularly concerned about the efficacy of linear

4 fluorescent lamps as we design rebate programs

5 around them. Reported and I should say that our

6 regulators are increasingly requiring us to use

7 certified values of efficacy rather than

8 manufacturer's general specifications. So we look

9 to values that are reported to the Department of

10 Energy and to Energy Star to assure that we are

11 utilizing efficacy values that are creditable.

12 Specifically with regard to the DOE database we

13 would like to understand whether DOE requires the

14 exact value per product reported to be accurate or

15 whether it simply requires a pass fail relative to

16 what the standard is. That is to say if a

17 manufacturer reports 95 it passes. If a

18 manufacturer reports 115 lumens per watt is that

19 value required to be accurate and the manufacturer

20 in violation of the regulations in some way by

21 reporting a value higher than what it actually is if

22 it turns out the value they report cannot be
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1 substantiated. So we seek clarification about that.

2 Thank you.

3 MR. BROOKMAN: Thank you.

4 Other opening statements here at the

5 outset?

6 Yes, Alex Boesenberg.

7 MR. BOESENBERG: Alex Boesenberg, NEMA. I

8 want to thank the Department as always for having

9 the meeting and allowing us to be here and discuss

10 in real time these issues. I just wanted to note

11 that due to the complexity of the rule and the

12 quantity of the information there will be perhaps

13 more times than usual where I have to finish a

14 statement with and we'll give you more detail in the

15 written comments. This is a big one, so we want to

16 avoid any generalizations that might turn out to be

17 inaccurate. So maybe it will go faster then.

18 MR. BROOKMAN: We understand. And thanks

19 for the forewarning.

20 Additional comments here at the outset?

21 Tim Ballo?

22 MR. BALLO: Tim with Earth Justice. Just
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1 one quick point that is maybe a bit tangential given

2 the analysis that we have seen but the ERBR, the

3 exempted Incandescent Reflector Lamps should be

4 folded into this rulemaking. There is still an

5 outstanding obligation to complete a rulemaking for

6 those lamps. The white bulb rider even given the

7 broadest possible interpretation does not foreclose

8 the Department for setting standards that are

9 different from whether stronger or even weaker than

10 the levels that are in the EPCA table. So I think

11 the Department should revisit its interpretation of

12 the rider and reconsider including those lamps in

13 this rulemaking.

14 MR. BROOKMAN: Thank you.

15 Andrew DeLaski?

16 MR. DeLASKI: Thanks. Andrew DeLaski,

17 Appliance Standards Awareness Project. I have a few

18 comments to make at the outset and summary that we

19 will work on, develop on later today. I want to

20 begin by saying that we strongly support the

21 proposed rule in particular for General Service

22 Fluorescent Lamps. The standard builds on the 2009
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1 standards and combined the improvements achieved by

2 these two standards together will lead to the

3 largest savings from any standard every issued by

4 the Department of Energy. So it is a big -- as Alex

5 said it is a big one. It is a big one because we

6 are working with commercial lighting; commercial

7 lighting is a very large piece of commercial energy

8 consumption and therefore national energy

9 consumption. So the overall improvement as I said

10 is about 23 percent improvement compared to the

11 minimum levels in effect before 2009 standards. So

12 the combination -- when you put those two together

13 with the ballast standard it is really a

14 transformation for commercial lighting in this

15 combination of standards over the past several

16 years. That will be a tremendous step forward for

17 efficiency. It is important to note that this

18 progress has been enabled by a couple of decades of

19 work; work by the manufacturers to develop high

20 efficiency products across the -- from the lamp to

21 the ballast to the system, a tremendous amount of

22 progress there. Support from the Department enabled
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1 some of that progress, also billions of dollars

2 invested by utilities and their rate payers in

3 supporting commercial lighting improvements. So

4 there has been a lot of money, a lot of rate payer

5 money put into changing, creating the basis really

6 for this standard today and the standard that locks

7 in that benefit. So it is really an excellent

8 example of how standards can couple with utility

9 based programs and voluntary programs to shift

10 efficiency over a couple decade period. But the

11 standards are a crucial piece of that in locking in

12 the benefits.

13 We also appreciate the improvement that

14 DOE has made with respect to Incandescent Reflector

15 Lamps. Although the savings are modest and we are

16 going to want to understand that a little better

17 today because we are a little struck by the savings

18 estimate that come out of that rule. The standard

19 will help insure that buyers have a choice of

20 efficient options in that market place. Of course

21 in that market as John has already suggested the

22 LEDs is an excellent option for consumers because of
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1 its nature as a point light source. With this

2 standard consumers will have a choice of LED

3 efficient option or a very efficient option in the

4 incandescent category.

5 For both of these rules we strongly

6 support the NOPR in its entirety. We also want to

7 raise a few issues for both the GSFL and the IRL

8 category. With respect to IRLs we are disappointed

9 that DOE did not address the so-called exempt IRLs.

10 Tim has already mentioned this. We think that by

11 addressing -- if you have one -- the way this is

12 being set up now is that you have a choice for some

13 parts of the market of the very efficient LED, the

14 very efficient incandescent covered lamp or a 65

15 watt BR or equivalent lamp which is very, very

16 inefficient. So we are creating a market where

17 you've got options, some of which are very

18 efficient, some of which are at levels that aren't

19 even covered by the 1992 standards. And addressing

20 that loophole, addressing that exempt lamp category

21 could lead to a very large savings. We estimate

22 standards at the levels in today's rule that would
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1 cover the exempt IRLs would lead to annual bill

2 savings for consumers in the order of half a billion

3 dollars, annual bill savings of half a billion

4 dollars and could lead to CSU reductions by the year

5 2030 of about 50 megatons. So it is a big

6 opportunity, one the Department should address.

7 We also believe that DOE made a mistake in

8 not considering higher levels for the IRLs that are

9 covered by the rule. The California IOUs presented

10 testimony, written comments to the docket that we

11 believe put in a rock solid case for considering

12 higher levels. The Department basically gave them

13 the back of your hand. You basically dismissed the

14 arguments with a grab bag of what we feel are not

15 well substantiated rationales for why you didn't

16 consider higher levels. We think that the rule

17 should have considered higher levels for IRLs.

18 We also believe that the continued lower

19 standard for modified spectrum lamps is unnecessary.

20 There are two reasons for this. One is that

21 consumers have options in the marketplace today to

22 buy a modified spectrum lamp that offers no
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1 efficiency penalty. That utility is available in

2 the marketplace in LED product and other products

3 that offers no efficiency penalty. There is no

4 guarantee that you would be able to buy that utility

5 and part of it happens using incandescent

6 technology. To make that exemption or that lower

7 standard for modified spectrum lamps is no longer

8 necessary.

9 It also appeared based on the record that

10 there are very few modified spectrum lamps in the

11 covered lamp category. And we are still

12 investigating this trying to understand what lamps

13 are being covered, are they in the covered category

14 but if there are few to no lamps in the covered

15 category, modified spectrum then that suggests the

16 question of why even have the category.

17 With respect to GFSLs just two points. I

18 want to echo Garry's concern about rating systems,

19 the ratings. We need to understand better today the

20 numbers, how the ratings are being made both with

21 respect to DOE standards reporting and catalogs.

22 And then there are two categories of lamps
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1 that we are concerned about that are not covered by

2 today's standard that we think present the

3 possibility for substantial undermining of the

4 standard. One is high CRI lamps. Congress exempted

5 high CRI lamps in 1992 because it was a specialty

6 product. It was seen as being not a general service

7 lamp. Today manufacturers, including some of the

8 major manufacturers, are marketing high CRI lamps as

9 a general purpose lamp. There is work going on from

10 the utility industry to investigate or to understand

11 this now better but this is looking like a serious

12 emerging problem that will undermine the savings

13 from this standard. And we think that DOE needs to

14 better understand this emerging use of a specialized

15 lamp and marketing of it as a general service lamp.

16 And then move quickly to better understand it and to

17 address it ideally in this rulemaking. If that is

18 not possible as part of a follow on process to

19 address this exempted or this general service use of

20 this exempted lamp.

21 And then 2-foot lamps we understand DOE's

22 rationale for not covering 2-foot lamps based on the
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1 Navigant study. We continue to believe that there

2 is a growing product category and we hope to have

3 data soon from the Northwest that Charlie has been

4 gathering that will help us understand better a

5 little more about the market growth in that area.

6 And we believe that is a category that DOE should

7 look to address in the final rule.

8 MR. BROOKMAN: Okay. Thank you.

9 Additional comments?

10 Garry Fernstrom?

11 MR. FERNSTROM: Garry Fernstrom for the

12 California IOUs. Just a quick follow up. We are

13 members of ASAP and I would like to state for the

14 record we support Andrew's comments.

15 MR. BROOKMAN: Okay. Thank you.

16 Additional comments before we move to the

17 content in the packet?

18 Okay. Onward.

19 MS. DeBUTTS: Okay. So we will first

20 provide an overview of this rulemaking. And we've

21 already touched in the opening remarks on the

22 regulatory history but I just want to revisit it
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1 quickly. The Energy Policy and Conservation Act of

2 1992 amended the Energy Policy and Conservation Act

3 of 1975 by establishing energy conservation

4 standards for certain classes of GSFLs and IRLs. It

5 also authorized DOE to conduct two rulemaking cycles

6 to determine whether these standards should be

7 amended. It also directed DOE to adopt standards

8 for additional GSFLs if warranted.

9 DOE completed the first of those

10 rulemaking cycles and published the final rule in

11 2009. And we will refer to this rule as the 2009

12 rule for the rest of the presentation. The 2009

13 rule amended the standards for GSFLs and IRLs and

14 adopted standards for additional GSFL types. These

15 standards required compliance starting in July of

16 2012. And so we will refer to those standards as

17 July 2012 standards.

18 DOE initiated the second rulemaking cycle

19 for evaluating GSFL or IRL standards in September of

20 2011 and by publishing the framework document and

21 holding a public meeting in October of 2011. The

22 preliminary analyses followed in February 2013. It
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1 was a public meeting held in April of that year.

2 This led to the NOPR analysis which is the subject

3 of today's presentation. And the next stage of the

4 second review of GSFL and IRL standards.

5 The next couple of slides we will look at

6 the current standards for GSFLs and IRLs and we will

7 start with GSFLs.

8 GSFL standards are set in lumens per watt.

9 They differ by lamp type and CCT in Kelvin. And

10 these standards are consistent across wattages. And

11 of course they came into effect in July 2012.

12 These are IRL standards. They vary by

13 spectrum, diameter and voltage. They are based on

14 the power law equation. These do not include ERBR

15 and certain R lamp types.

16 This is the outline of the rulemaking

17 schedule. As I stated earlier the framework was

18 published in September of 2011. We had the public

19 meeting, the preliminary analysis and technical

20 support document and the notice of the public

21 meeting for that were published on February 28,

22 2013. And the notice for the NOPR was published on
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1 April of this year.

2 The NOPR will be followed by one last

3 major publication which is the final rule notice.

4 We are projecting this to be issued in December

5 2014. The final rule will be responding to comments

6 received during today's public meeting and the

7 written comments which are submitted prior to the

8 comment period end date. It will also present the

9 revised analysis and the standards adopted by DOE.

10 And finally the compliance date will be --

11 we are projecting it for December 2017 which is

12 three years after the projected final rule

13 publication.

14 This slide talks a little bit about EPCA

15 factors. So when setting energy conservation

16 standards DOE is directed by EPCA to consider seven

17 factors. These factors and their corresponding

18 analysis are shown in this table. And you will be

19 examining these factors throughout this rulemaking

20 as we evaluate standards for GSFLs and IRLs.

21 Let's move on and discuss the scope of

22 coverage for this rulemaking starting with GSFLs.
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1 Currently standards set may cover six fluorescent

2 lamp types with certain wattage ranges as shown on

3 this slide. These include the 4-foot medium bipin,

4 2-foot U-shaped, 8-foot slimline, 8-foot high output

5 and 4- foot mini bipin standard output and high

6 output lamps.

7 This rulemaking also considers expanding

8 coverage to other fluorescent lamp types and

9 wattages. So in order to determine whether a lamp is

10 a candidate for standards it should meet the general

11 technical description of a fluorescent lamp and not

12 fall under any exclusion specified in DOE's

13 definition of general service fluorescent lamp.

14 After that DOE determines whether standards for the

15 candidate lamp would result in significant energy

16 savings. And further if those standards would be

17 technologically feasible and economically justified.

18 We've considered fluorescent shapes not

19 covered such as circline lamps and also linear

20 lengths not covered such as five and six-foot lamps.

21 However DOE was not able to identify additional lamp

22 types that have market share and/or would end up in
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1 energy consumption that results in substantial

2 energy savings for the standards. So based on

3 these findings DOE is not extending scope of

4 coverage to additional lamp types.

5 However we did decide to consider

6 inclusion of additional wattages for fluorescent

7 lamp types already covered. As stated during the

8 preliminary analysis public meeting DOE determined

9 that certain covered lamp types are being offered in

10 lower wattages and may gain market share. Therefore

11 standards for those lamps may offer energy savings.

12 The new wattage limits under consideration are shown

13 in this table.

14 We are also considering modifications to

15 clarify the definition of General Service

16 Fluorescent Lamp which exempt lamps that are

17 designed and marketed for certain non-general

18 applications. DOE is considering further clarifying

19 on some of these exemptions shown in bold on this

20 slide.

21 DOE is also proposing a definition for the

22 term 700 series fluorescent lamp. This definition
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1 is aimed to provide clarification in identifying

2 these types of lamps.

3 DOE is also proposing the definition for

4 defining the term designed and marketed and similar

5 terminology as it applies to all lighting products.

6 So now we are moving on into scope of

7 coverage for IRLs which was discussed earlier as

8 well. And the scope of coverage for this rulemaking

9 applies to those IRLs that meet the definition of

10 DOE's definition of Incandescent Reflector Lamp. It

11 is shown on this slide here. Although DOE's

12 definition of IRLs does not set an upper limit of

13 wattage, the existing IRL standards are set for the

14 40 to 205 watt range because wattages greater than

15 205 are mainly specialty lamps which are a small

16 portion of the market and would not result in a

17 significant energy savings.

18 DOE's analyses, the NOPR analysis also

19 confirmed that this remains true. So this

20 rulemaking is proposing standards for this range of

21 40 to 205 watts.

22 MR. BROOKMAN: Tim Ballo?
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1 MR. BALLO: I wonder if we can go back to

2 slide 18. The definition of design and marketed and

3 the reason I bring this up is because as Andrew

4 mentioned we are seeing high CRI lamps that are

5 designed -- that are being marketed for general

6 purpose lighting applications either by the retailer

7 or at least in some cases by the manufacturer. The

8 definition you have here for designed and marketed

9 by stating that the application of the lamp is

10 stated in a publicly available document, that

11 suggests to me that as long as the manufacturer has

12 a document somewhere that is publicly available that

13 says well this is just for high CRI applications

14 then it is sort of insulated from liability.

15 Whereas I think that if the lamp is out there being

16 marketed for general purpose applications regardless

17 of the fact that there is some document somewhere

18 that is publicly available that says it's really

19 just for high CRI. I see a problem there with that.

20 I think the definition needs to be broader to

21 account for the fact that there are potential

22 problems with the exempt lamps.
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1 MS. DeBUTTS: Okay. Thanks.

2 MR. BROOKMAN: Garry Fernstrom?

3 MR. FERNSTROM: This is Garry for the

4 California IOUs. I certainly agree with Tim. The

5 definition we use ought to relate to the way these

6 products are represented in the marketplace and

7 might be utilized.

8 MR. BROOKMAN: Okay. Thank you.

9 Andrew DeLaski?

10 MR. DeLASKI: So just to follow on. I

11 said in my opening remarks I was (inaudible). This

12 is a problem that we are still frankly wrapping our

13 arms around as well. And we hope to have more

14 detailed comments for you in the written comments.

15 I think that the opportunity in this docket probably

16 is or one of the opportunities is through

17 definitions to perhaps address this emerging

18 loophole. And the definition number eight on the

19 prior slide is not emboldened and I would suggest

20 that it should be; that we should be thinking about

21 or we should be considering what modifications to

22 that definition in addition to what Tim just
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1 described could be made to address the use of high

2 CRI lamps in a general service -- as a general

3 service fluorescent lamp.

4 I also want to comment on slide 13. We

5 think that obviously you need a reasonable amount of

6 time between the NOPR and the final rule and that is

7 what you have sketched here. It is that the

8 legislative deadline I think as you noted is July so

9 we are looking at this rule being a few months late

10 from what it was legally required to be due. I just

11 urge you to stick with the schedule so that it

12 doesn't get any further behind than what you have

13 already sketched out.

14 MS. DeBUTTS: Correct with time. Thank

15 you.

16 MR. DeLASKI: Thank you.

17 MR. BROOKMAN: Additional comments here?

18 MS. DeBUTTS: Okay. Well so this

19 basically concludes the overview section. The last

20 slide I have is on the NOPR stage which represents

21 the flow and the type of analysis we've conducted.

22 And we will discuss those during this presentation.
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1 MR. BROOKMAN: Okay. Yes. John

2 Cymbalsky.

3 MR. CYMBALSKY: So I would like to address

4 Garry Fernstrom's remark about the ratings and what

5 they represent. I will make a statement and cite

6 some sections in the CFR. And I would request that

7 if you would like to have further discussion about

8 this that we have a separate meeting about ratings

9 enforcement. All those questions should be separate

10 from this public meeting.

11 So here we go. The certified values

12 represent the manufacturer's declared rating of a

13 basic model that is derived from testing a set of

14 units of that basic model in accordance with the

15 test procedure found in 10 CFR Part 430 Subpart b,

16 appendix R, and the sampling plan found in 10 CFR

17 429.27. This rating should be identical to the one

18 on the label and in marketing literature. Again and

19 if we want to get into more detail about what that

20 means I suggest a separate follow on meeting with

21 whomever you'd like when we have the appropriate

22 personnel in the room.
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1 MR. FERNSTROM: This is Garry for the

2 California IOUs. Thank you John. Just one quick

3 question. I understand what you just said in that

4 what is reported must be identical to what is on the

5 label. And can you at this point indicate whether

6 or not the value reported to DOE is one that

7 manufacturers -- or that is expected to be realized

8 if products were tested to validate that value?

9 MR. CYMBALSKY: John Cymbalsky, DOE. So I

10 can tell you we actively enforce all of our

11 standards. So that is all I will say on that.

12 MR. FERNSTROM: Okay. So I would

13 interpret that to mean that the value reported is

14 the value expected? Thank you.

15 MR. BROOKMAN: Okay. Additional comments

16 before we move to the next section. Okay.

17 MS. DeBUTTS: Okay. So now Aisha Husain

18 with Navigant will present Market and Technology

19 Assessment and Screen Analysis.

20 MS. HUSAIN: Hi my name is Aisha Husain

21 and I am with Navigant Consulting. And I will be

22 going over the Market and Tech Analysis and
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1 Screening Analysis. So the purpose of the Market

2 and Technology Assessment is to determine product

3 classes and identify technology options that will

4 improve lamp efficacy.

5 Technology options identified are then

6 evaluated against four screening criteria which are

7 that the option is technologically feasible, that

8 it's practicable to manufacture, that there is no

9 adverse impacts on product utility, that there is no

10 adverse impacts on health or safety. The technology

11 options that passed these screening criteria are

12 then used as design options in the engineering

13 analysis.

14 For product class determination DOE

15 divides covered products into classes based on

16 energy use, capacity of the product, or any other

17 performance related features. And then a separate

18 standard is set for each category or product class.

19 So here we have the product classes for

20 GSFLs. We are proposing three product class setting

21 factors. One is correlated color temperature or

22 CCT; CCT is the measure of perceived color white
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1 light and, therefore, different CCTs offer different

2 utilities. DOE has also determined that there is a

3 decline in efficacy for lamps with CCTs greater than

4 4500 K and so the division is at lamps with CCTs

5 equal to or less than 4500 K and lamps with CCTS

6 greater than 4500 K.

7 DOE also proposes physical constraint as a

8 class setting factor particularly lamp length and

9 shape. Different lamp geometries offer different

10 utilities in the sense that they can fit in

11 different building designs and footprints. Length

12 and shape also impact lamp efficacy.

13 Finally DOE is also proposing lumen

14 package as a class setting factor. So specifically

15 standard output and high output. High output lumen

16 packages offer a different utility in the sense that

17 they can be used in high ceiling applications or

18 outdoors. They also -- the lumen package also

19 impacts the lamp efficacy.

20 So the table here represents the 12

21 product class divisions being proposed for GSFLs.

22 MS. CALLAHAN: Susan Callahan OSRAM
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1 Sylvania. We'd just like to point out in the 2-foot

2 U-shaped lamps under physical constraints that there

3 are two different geometries for those lamps, six

4 inch spacing and 1 5/8th inch spacing.

5 MR. BROOKMAN: Are you suggesting they

6 should be in different product classes?

7 MS. CALLAHAN: Based on the analysis that

8 we have seen they should be in different product

9 classes based on the conclusions that you have

10 drawn; the proposed conservation levels.

11 MS. HUSAIN: Okay.

12 MR. BROOKMAN: Thank you, Susan.

13 MS. HUSAIN: We would welcome any written

14 comments on that as well.

15 So for IRLs DOE is also proposing three

16 product class setting factors. One is Lamp

17 spectrum. Modified spectrum IRLs usually use a

18 neodymium (ph) coating or some other kind of coating

19 that absorbs part of the visible light and therefore

20 gives off a different type of light and utility than

21 non-modified or standard spectrum IRLs. This also

22 results in a lower efficacy for these lamps.
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1 DOE is also proposing diameter as a class

2 setting factor. Small diameter lamps can be

3 installed in smaller fixtures, therefore, offering a

4 specific utility. They also have lower optical

5 efficiency than the larger diameter lamps and some

6 cannot utilize some of the technology options that

7 can be utilized by large diameter lamps such as

8 double-ended capsules. Specifically DOE is proposing

9 to divide lamps with diameters greater than 2.5

10 inches and then lamps that are 2.5 inches or less.

11 DOE is also proposing rated voltage as a

12 class setting factor. DOE has found that most

13 consumers operate 130 volts lamps at 120 volts which

14 reduces the efficacy while increasing the lifetime.

15 DOE test procedures require that 130 volts lamps be

16 tested at 130 and similarly 120 volts lamps be

17 tested at 120. Therefore compared to a 120 volt

18 lamp a 130 volt lamp will test at a higher efficacy.

19 If there is a single standard the 130 volt lamp

20 would likely not require as efficient technology and

21 might be -- to meet the standard as a 120 volt lamp.

22 And therefore the need for this less efficient
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1 technology could make the 130 volt lamp less costly

2 and potentially result in a migration to 130 volt

3 lamps and increased energy consumption.

4 So the table here shows the eight product

5 class divisions for IRLs.

6 MR. BROOKMAN: Joe Howley?

7 MR. HOWLEY: Similar to the U-lamp issue

8 there are actually two different diameter lamps

9 found in the greater than 2.5 category. There are

10 PAR38 lamps and there are PAR30 lamps. And while

11 the previous standards it was okay to group them as

12 we approach these sort of super max tech levels

13 those are modeled off what can be done with PAR38

14 technology and as you mentioned lamps with smaller

15 diameters have smaller efficiencies. It tends to be

16 exacerbated more with the PAR20 which is why the

17 PAR20 lamps, the less than 2.5 were pulled out in

18 the first rulemaking. But if you are going to

19 propose these types of levels it also creates a

20 problem where you model on PAR38, it creates a

21 severe problem for PAR30 lamps being able to meet

22 those levels because they are a less efficient
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1 diameter. And again it is something that needs to

2 be looked at and we will provide further comments.

3 MR. BROOKMAN: Thank you.

4 MS. HUSAIN: Sorry.

5 MR. K. COOK: Keith Cook with Philips.

6 One question we've got is has Navigant been able to

7 find any 130 volt lamps on the market today?

8 MS. PIERCE: Julie Pierce, Navigant

9 Consulting. No.

10 MR. K. COOK: So why are we spending any

11 time on it?

12 MS. PIERCE: DOE finds no reason that

13 these lamps cannot technologically be produced and

14 also the existing product class structure includes

15 them so there may be back sliding issues if we don't

16 include them.

17 MR. K. COOK: They can't be produced.

18 MR. BROOKMAN: Alex Boesenberg?

19 MR. BOESENBERG: Alex Boesenberg, NEMA.

20 We understand the DOE's statement that there is no

21 reason why they can't be produced. However I would

22 point you to the evidence that there are none
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1 available on the market. Whether that is a business

2 decision or a technological ramification as we

3 submitted in our comments to the previous rule.

4 Nevertheless they are no longer available. If they

5 are not being made available under today's standard,

6 there would seem no reason to invest time in

7 establishing a new standard for them. Furthermore

8 if they are not available under today's standard it

9 doesn't make any sense to claim any energy savings

10 from a new standard. We will conduct our own

11 analysis to attempt to identify these lamps or if

12 one can, in fact, be made and submit what we can

13 with our written comments.

14 MR. BROOKMAN: John Cymbalsky?

15 MR. CYMBALSKY: John Cymbalsky, DOE. So

16 what I am interpreting that a saying that they don't

17 exist, the manufacturers don't plan on ever making

18 them again so that if we create a standard no harm,

19 no foul; is that what I am hearing?

20 MR. BOESENBERG: With the understanding

21 that when you get to the energy savings equation the

22 multiple variable is zero.
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1 MR. BROOKMAN: Garry Fernstrom?

2 MR. FERNSTROM: Garry for the California

3 IOUs. Our concern here is the possibility of

4 leaving the door open to a potential loophole. And

5 I understand and agree with the manufacturers there

6 may not be a lot of value in creating a standard for

7 a product that isn't in the market anyway. But

8 looking back to incandescent reflector lamps the

9 Department of Energy regulated R lamps but exempted

10 BR and ER lamps and low and behold the market was

11 full of BR and ER lamps. So we want to avoid the

12 possibility of that happening again. That is our

13 only concern with respect to this. And I think if

14 establishing a regulation to preclude migration of a

15 product into an area where products are exempted

16 from regulations is considered we should regulate

17 the product that may not be on the market now but

18 where we have a concern that it might return.

19 MR. BROOKMAN: Alex Boesenberg?

20 MR. BOESENBERG: Alex Boesenberg, NEMA.

21 Garry I understand your argument, however, I would

22 point out that the lamps are regulated. And at the
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1 current regulation they are not being produced. So

2 I -- it does not make sense to elevate the

3 requirement. It is already -- they have already had

4 their efficiency raised if you will considering

5 unexisted test, it is hard to say it was raised.

6 But anyway there was an analysis that rule is over.

7 So I think the logic doesn't hold up under those

8 conditions.

9 MR. BROOKMAN: Joe Howley?

10 MR. HOWLEY: Yes, I think it is because

11 the wrong question was asked and analyzed by

12 Navigant. And the question should have been asked is

13 why aren't they available today. And the answer

14 seems to be there is no reason why they are not

15 available but they didn't ask the question why

16 aren't they available. And the reason is in the

17 previous rulemaking I agree with Alex this is a

18 completely different situation than an exempted

19 lamp. This is actually the opposite of that

20 situation. This is a situation where an existing

21 standard is set so high it exceeds the capability to

22 make a practical lamp. That is where we are at
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1 today. So it is the opposite of an exemption. It is

2 a standard so high it exceeds technology limits. The

3 way it was originally analyzed they looked at max

4 tech for PAR38 lamps and the last standard was set

5 at a max tech level. And then for 130 volt lamps

6 they put an adder on it of 15% higher. So the

7 standard is set at 15% higher than the maximum known

8 technology at the time. And when you look at it

9 that way you realize the manufacturers have no

10 other, there is no other tricks here to increase

11 efficiency on either the halogen IR tube or on the

12 reflector technology. The only thing left is to

13 shorten life. But you have to shorten life so much

14 by increasing efficiency 15% you'd affect life by

15 probably about two-thirds. There would be a two16 thirds reduction. And that is if it is operated at

17 120. If it is actually operated as intended at 130

18 volt circuit it would have an extremely short lamp

19 life such that it would be completely impractical to

20 sell. So the level that you have although you might

21 argue just philosophically it can technically be

22 made, the point is it could be technically made at a
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1 level, at a life that is so short to have no

2 practical salability; and that is where we are at

3 today. And so we are at there in today's regulation

4 and yet there is a proposal to take that even five

5 percent higher than what is impossible to meet

6 today. And I suppose for that reason this is simply

7 philosophical because we are talking about taking

8 something not able to be made today and making it

9 even more impossible to be made tomorrow.

10 MR. BROOKMAN: Mike Rivest?

11 MR. RIVEST: Mike Rivest, Navigant. Joe I

12 appreciate the comment. On the first point that it

13 doesn't exist today I think there are instances even

14 in lighting where we've created a standard for a

15 lamp in case it would become available. Halo16 Phosphor T5s is the one I remember. So that in

17 itself wouldn't be a reason not to regulate it but

18 the argument that it is already regulated and that

19 the standard exceeds technological feasibility is

20 compelling. We will have to look into it. But we

21 understand.

22 MR. BROOKMAN: Thanks for your comment.
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1 Let me see. Dave.

2 MR. GATTO: Dave Gatto, Westinghouse

3 Lighting. Not to beat a dead horse but I think the

4 important thing that we would like for DOE to see in

5 here is that and Garry we appreciate the concern

6 that there may be back sliding but two things

7 happened in here I think that were missed in the

8 last rulemaking and I am kind of where Joe is, I

9 think it was just that we were all asking the wrong

10 questions. One is that we remove the utility from

11 the market that consumers like because in certain

12 parts of the country we have transients, we have

13 voltage spikes, we have power issues. When 130 volt

14 lamps were able to absorb and deal with these and

15 maintain product lifetimes that were acceptable to

16 consumers and at this point that utility is gone.

17 Consumers simply in those markets have to buy a lot

18 of light bulbs regardless of the technology in some

19 cases because of these voltage issues. The other

20 thing that I think was missed from an energy savings

21 standpoint was that you acknowledged that when 130

22 volt lamps operated at 120 volt are less efficient
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1 but what you left out of that was that they also use

2 less energy. So a 60 watt halogen PAR operated at

3 130 volt 60 watts when operated at 120 volts would

4 use I think it is eight to ten percent, call it 55

5 watts, so in essence what you did was you set an

6 efficiency standard so high that an energy saving

7 product that also can deal with voltage issues that

8 are common in certain parts of the U.S. was

9 eliminated from the marketplace. Now we are not

10 suggesting that you go back and fix that. We know

11 you can't. But what we would suggest is that this

12 is the kind of unintended consequence that we'd like

13 to be very very careful about and will include in

14 our comments to NEMA when we are establishing new

15 IRL standards because I think once that bar is set

16 if I understand correctly, John, that back sliding,

17 we can go back and say oops but we can't undo what

18 we did.

19 MR. BROOKMAN: Okay. Thank you.

20 Additional comments on this series of

21 product classes?

22 Okay.
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1 MS. HUSAIN: I just wanted to quickly

2 follow up on Joe's comment on PAR38 and 30s if you

3 could include in your written comments difference in

4 utilities and sort of efficacy differences and the

5 same for the 2-foot that would be really helpful.

6 MR. BROOKMAN: Thank you.

7 MS. HUSAIN: Okay. So now we will move on

8 to Technology Options and Screening Analysis. DOE

9 identified technologies that can improve efficacies

10 for GSFLs as well as IRLs. For the screening

11 analysis DOE reviewed these six technology options

12 and assessed them against the screening criteria and

13 then determined which ones should be design options

14 that would be used in the engineering analysis.

15 So for GSFLs the following are the

16 technology options that were identified. Of these

17 DOE determined that multi-photon phosphors would be

18 screened out. They are in the research and

19 development phase so DOE determined that they are

20 not technologically feasible at this point.

21 For IRLs DOE identified the following

22 technology options. Of these DOE determined those
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1 shown in red would be screened out. The majority of

2 these were screened out because they were not found

3 to be in commercially available lamps, therefore,

4 could not be determined to be practical to

5 manufacture. Some of the other reasons were that

6 they were not technologically feasible. And a few

7 had adverse impacts on product utility.

8 MR. BROOKMAN: Susan?

9 MS. CALLAHAN: Susan Callahan from OSRAM

10 Sylvania. I'm just looking for clarification in the

11 options that you have screened in for both IRL and

12 GSFL that could you tell me how to do that? Could

13 you tell me what that higher emissive coating

14 material is? Can you tell me how to run my lamp

15 hotter? How from an industry perspective -- there

16 are a number of these things that we actually do and

17 we actually optimize them and that is why we are in

18 the business that we are in. But some of these I

19 guess part of me is taken with the fill gas that

20 there are higher efficacy fills available. And from

21 a lamp maker's perspective I am just curious what

22 they are and hopefully they are not patented and I
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1 can go and make my lamp do that.

2 MS. HUSAIN: Fill gas for GSFLs and IRLs?

3 MS. CALLAHAN: Yeah.

4 MS. HUSAIN: So we have identified certain

5 fill gas compositions and in talking to

6 manufacturers, for example for fluorescent it is

7 argon and krypton and for IRLs it is xenon mainly.

8 But we've --

9 MS. CALLAHAN: But if I have already done

10 that. If those are part of what you need to do to

11 make the lamp, how does that become an option if it

12 is something that is inherent to the lamp?

13 MS. HUSAIN: So based on interviews and

14 research and looking at patents we've seen that

15 there are different ratios, there are different

16 combinations of these fill gases that can be used.

17 So there are ways to manipulate the fill gas

18 composition to get an increased efficacy.

19 MR. BROOKMAN: Mike Rivest?

20 MR. RIVEST: Mike Rivest. I think we have

21 to step back here and think about how the

22 engineering analysis was created. We didn't run a
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1 computer model to try to simulate a lamp and come up

2 with the design options and model the efficacy. I

3 believe we used commercially available lamps. And

4 so these are not you know the burden of proof that

5 it is technologically feasible, it is in the

6 commercial availability; right. And you have

7 proprietary means of achieving those efficacies. We

8 didn't probe that. What we did take -- what we are

9 trying to do is take off the table things that for

10 reasons such as patents or a scarcity of materials

11 would not be generally available for a standard for

12 example. So we are coming at it from a screening

13 prospective, not from a this is how you will get to

14 that level, a prescriptive path if you will.

15 MR. BROOKMAN: Mark first.

16 MR. DUFFY: I just wanted to -- I am

17 sorry, Mark Duffy, GE Lighting. Thank you Alex. I

18 just wanted to say it in a slightly different way.

19 Frankly the items especially with GSFL where my

20 expertise is the highly emissive coatings and the

21 gas fill composition are being used to meet the

22 current requirements of the rulemaking in the 2009
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1 rulemaking. So in order to use that as justification

2 for even more I think you're applying the advantages

3 once again to go to higher levels. And I don't

4 think that is a logical approach. Those of us who

5 design these lamps are already designing them using

6 these tools and techniques to get the maximum out of

7 the performance of the lamp.

8 MR. BROOKMAN: Keith Cook.

9 MR. K. COOK: The problem I've got with

10 this approach is the fact is that it is looking for

11 a singular outcome. It is only looking for

12 efficacy. When in reality we are having to meet the

13 market requirements they are also looking for

14 lifetime, they are looking for dimability, they are

15 looking for CRI and those are all trade-offs that

16 are included in this. And so therefore I don't

17 think that this is comprehensive enough to really

18 screen out what is necessary for meeting the market

19 requirements.

20 MR. BROOKMAN: Okay. Thank you.

21 Eric Montgomery, who is joining us via the

22 web, has a comment or question. Unmute your phone
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1 Eric and let's see if we can hear you. Try it

2 again. Speak clearly. Let's try again.

3 MR. MOTGOMERY: Well on the IRL subject

4 there are several things mentioned in here as

5 options that are already used to the maximum extent

6 that they can be. For example Xenon is mentioned.

7 There is no more Xenon that you can put in than the

8 quantity that is already put in. So that is not a

9 new design pathway. The other -- some of these

10 other things that are mentioned in here is design

11 pathways. Someone would have to explain to a large

12 extent how these would even improve efficiency.

13 MR. BROOKMAN: Okay. Thank you.

14 Yes, Andrew DeLaski?

15 MR. DeLASKI: I just want to follow up on

16 a point that I think Mike made. So my understanding

17 is that for both IRLs and GSFLs that the levels that

18 were selected and proposed that there are existing

19 lamps on the market that meet the levels.

20 MR. BROOKMAN: Mike Rivest.

21 MR. RIVEST: That is my understanding and

22 when we get to the section on those levels we can --
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1 we certainly can talk about that.

2 MR. DeLASKI: My understanding is that the

3 GSFLs that that is the case as well and including

4 that a constraint that you would use was to insure

5 that full wattage lamps were available and that was

6 for both levels; that was a constraint in the

7 decision making.

8 MS. HUSAIN: Yes. And the levels are

9 based on commercially available --

10 MR. DeLASKI: And again it is a

11 performance standard. It is not a design standard.

12 It is up to the manufacturer how they meet it. It

13 is not to be dictated to use one or the other.

14 MR. BROOKMAN: Mike Rivest.

15 MR. RIVEST: And if in meeting those

16 levels some other utility features, consumer utility

17 attributes are being sacrificed such as life, such

18 as color we would like to know about that.

19 MR. BROOKMAN: John Cymbalsky?

20 MR. CYMBALSKY: John Cymbalsky, DOE. So

21 my question to the manufacturer is it almost sounded

22 like you were implying that you were maximizing or
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1 optimizing everything that is not in red on this

2 chart to just meet the current standard if my logic

3 and my mind works from what I have heard from the

4 comments that you are already doing all this and you

5 are barely making the standard now; did I interpret

6 that right? There is no room to go higher to

7 optimize these things? Is that what I heard?

8 MR. BROOKMAN: Keith Cook?

9 MR. K. COOK: I wasn't going to address

10 that one. But I will. No there are still some

11 good, better, best scenarios. Although I think the

12 good is gone, we are now down to better and best and

13 there is an upper level that we can provide at a

14 significant cost premium. It is typically about 40%

15 higher than what is out there and it is usually only

16 professional grade. It is not usually available for

17 the general market because it is such a premium.

18 Back to my other -- okay, go on John.

19 MR. CYMBALSKY: Just to respond. Thank

20 you that is very helpful. So I think as Mike and

21 Andrew both said the focus of the conversation then

22 should not be the screening, it should be the
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1 engineering cost curve and the price assumed to move

2 up on the efficiency curve which I think is going to

3 be a good conversation.

4 MR. BROOKMAN: Joe Howley?

5 MR. HOWLEY: If I could make just one

6 comment on that. I think you are discussing the

7 right area though about as you move these up what

8 happens is you remove utilities. There are certain

9 things that you lose as you go higher and higher and

10 higher with efficiency. Not -- there might be a

11 lamp that could be made at a certain level but it is

12 with removing a lot of utilities that consumers

13 want. And we will talk more about those in our

14 comments about what utilities you lose as you go

15 higher even though that might be possible you are

16 left with -- you are left with a product that

17 doesn't have a lot of utilities left to it.

18 MR. BROOKMAN: Keith Cook?

19 MR. K. COOK: Yeah and as we point out

20 many times before and it is still very true we can

21 definitely improve efficacy but it is usually at the

22 expense of life; pure and simple. It is always the
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1 trade off.

2 MR. BROOKMAN: Okay.

3 MR. COOK: And that is the utility.

4 Right.

5 MR. BROOKMAN: Dave.

6 MR. GATTO: If I could just make --

7 MR. BROOKMAN: You are not finished. I am

8 sorry, Keith. Keep going.

9 MR. K. COOK: I still have one question.

10 Going back to Andrew's remark that they have found

11 lamps that meet these requirements in this analysis.

12 I would like to see the one for the 130 volt IRL

13 please.

14 MR. BROOKMAN: Okay. Dave.

15 MR. GATTO: Sorry, didn't mean to cut you

16 off there, Keith. So two things. Dave Gatto,

17 Westinghouse. Thank you Alex. Going to be hearing

18 thank you Alex quite a bit today.

19 I just want to make a point John because

20 what Joe said is true for GSFL that there are, and

21 Keith, there are opportunities for higher

22 efficiencies, for reduced life, for changes in color
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1 or some other options or at a premium cost which

2 typically remember these products fall within the

3 consumer and the commercial market. So there is a

4 consumer impact here if the cost increases beyond a

5 certain point.

6 I don't think that that is actually true

7 in IRL. I think in IRL where we are at is we are at

8 max tech. You've got some potential improvements if

9 you take all of those pathways but to do so the

10 combination of patents and infringement issues that

11 you have there makes it -- and we appreciate DOE's

12 statement about that in the NOPR that you

13 acknowledge that.

14 I don't know that -- we will include some

15 comments officially in the written comments but I

16 think it is important here to just separate the fact

17 that in GSFL there is still opportunity with the

18 trade off to utility for energy efficiency which is

19 something that we've been talking about. In IRL

20 that just simply doesn't exist and I don't want it

21 to get lumped in there because I think we are

22 already in the danger zone with IRL as we stand
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1 today.

2 MR. BROOKMAN: Okay. Thank you.

3 Additional comments here?

4 MS. HUSAIN: Okay. Then I will pass it on

5 to my colleague, Maureen to start us on the

6 Engineering Analysis.

7 MS. KIENLE: Good morning. My name is

8 Maureen Kienle. And I am with Navigant. We are

9 going to get started now with Engineering Analysis.

10 DOE used the following general methodology to

11 develop the engineering for GSFLs and IRLs. Of the

12 product classes identified DOE first selected

13 certain representative classes to directly analyze.

14 DOE then selected baseline lamps for each

15 representative product class to use as the reference

16 point. After that for each baseline lamp DOE

17 identified more efficacious substitutes based on

18 design options identified in the screening analysis.

19 DOE then identified efficacy levels or ELs that span

20 the range of efficacy from baseline to the maximum

21 technologically feasible level. Finally DOE scaled

22 its results to the product classes analyzed.
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1 So we are going to first cover the GSFL

2 engineering analysis. As stated earlier DOE is

3 proposing standards for 12 product classes for

4 GSFLs. From this list DOE plans to focus its

5 analytical efforts on the product classes shown in

6 darker green. DOE directly analyzed all product

7 classes with CCT less than or equal to 4500 K with

8 the exception of the 2-foot U-shaped product class.

9 These representative product classes were primarily

10 chosen on the basis of high market volumes.

11 Next move on to the baseline discussion

12 for GSFLs. A baseline lamp typically represents the

13 most common least efficacious model on the market.

14 DOE identified three representative product classes

15 that did not have commercially available lamps at

16 the existing standard level. For the NOPR analysis

17 DOE modeled baselines for the 8-foot high output, T5

18 standard output, and T5 high output product classes

19 based on feedback from manufacturers and

20 stakeholders. To determine the efficacy of the model

21 baselines DOE used the ANSI rated wattage of the

22 most common least efficacious commercially available
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1 lamp for the product class and calculated the

2 initial lumen output that would be required to meet

3 the existing standard level. For all other

4 characteristics such as lifetime and CRI, DOE

5 assumed the modeled baseline lamp would have similar

6 characteristics as the most common commercially

7 available lamps in each product class.

8 In the case of GSFLs one baseline lamp was

9 analyzed for each product class and the baselines

10 are presented in the table here. Also to note when

11 discussing efficacy in this analysis we are

12 referring to the rated efficacy of the lamp. So for

13 GSFLs rated efficacy is the catalog initial lumen

14 output divided by the ANSI rated wattage. The ANSI

15 rated wattage is listed in this table as rated

16 wattage. DOE requests comments on the baseline

17 lamps selected for GSFLs.

18 MR. BROOKMAN: Andrew DeLaski?

19 MR. DeLASKI: Can you just state again the

20 - - what you just said that the -- what is listed as

21 the catalog?

22 MS. KIENLE: The rated efficacy?
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1 MR. DeLASKI: The catalog, yeah, rated

2 efficacy.

3 MS. KIENLE: Yes, so in the GSFL

4 engineering analysis we look at the ANSI rated

5 wattage so that is listed here under the rated

6 wattage column and that differs from the nominal

7 wattage which is also presented. And that is what

8 you typically see in the catalogs is the nominal

9 wattage. However the ANSI rated wattage is the

10 value that we base the engineering off of as it is

11 the industry accepted value for the wattage where it

12 is expected to perform.

13 MR. BROOKMAN: You see the comment box

14 there. Comments here?

15 Susan?

16 MS. CALLAHAN: Thank you. Susan Callahan,

17 OSRAM Sylvania. I guess this is as good a place as

18 any to bring up our 2-foot U-bend discussion. The

19 concern that we have and it is something that Joe

20 brought up is that in previous rulemakings the

21 values were such that it didn't matter that we

22 covered two different product geometries in the 2-
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1 foot category but the point that I'd like to bring

2 up is that in the 1 5/8 inch spacing which is

3 typically used in a retail application, think very

4 large department stores, is that when we look at

5 this as a whole the only lamps that survive through

6 the analysis are full wattage lamps. And most of

7 these retailers currently use low wattage lamps such

8 that when they go to replace there will be an

9 immediate increase in the amount of energy required

10 because the lower wattage lamps will have been

11 eliminated by the rulemaking. And that in the six

12 inch geometries that we run into is where we have

13 reduced wattage lamps and no full wattage lamps. So

14 we can't dim them.

15 MR. BROOKMAN: Alex Boesenberg?

16 MR. BOESENBERG: Alex Boesenberg, NEMA.

17 To state that in another context and correct me if I

18 am wrong Susan. In our previous comments we

19 commented our significant concerns that if the

20 efficacy levels were raised to a point that only the

21 28 watt or similar categories of low wattage lamps

22 could meet the efficiency requirement that there
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1 would be the loss of utility for diming. I believe

2 what I have interpreted from what Susan has said is

3 that in this particular category it is actually the

4 converse if the efficiency levels get raised too

5 high that the low wattage option will be the lost

6 utility; is that right?

7 MS. CALLAHAN: Yes for the 1 5/8 inch.

8 MR. BOESENBERG: For 1 5/8.

9 MR. HOWLEY: Joe from GE. Also note that

10 the U-lamp category was scaled so it wasn't analyzed

11 directly and that might have partially led to this

12 conundrum is that it was not a directly analyzed

13 category, it was a scaled category. So it may be a

14 fundamental problem with the scaling or it may be a

15 fundamental problem with where the 4-foot lamp level

16 is set which also may be a concern. So we'll

17 analyze and comment further.

18 MR. BROOKMAN: Okay. Thanks Joe.

19 MR. DeLASKI: Just to follow on --

20 MR. BROOKMAN: Andrew DeLaski.

21 MR. DeLASKI: Alex, How come you don't hop

22 on me?
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1 MR. BOESENBERG: Sorry. The pumps guys

2 are even worse than us to make sure --

3 MR. BROOKMAN: But they are learning

4 though. They are getting better.

5 MR. DeLASKI: So I am not a lamp designer

6 so if you could help me out with the engineering.

7 Why is it that in the 1 5/8 inch U-bend only the

8 full wattage can meet the levels where as in the

9 larger just the shape of the lamp it is only the

10 reduced wattage. It is an odd outcome; right.

11 You've got the opposite outcome --

12 MR. BOESENBERG: Sorry, you need to speak

13 into the microphone.

14 MR. BROOKMAN: Who wants to address that?

15 MS. CALLAHAN: We don't know.

16 MR. BROOKMAN: Susan says she doesn't

17 know. Okay.

18 MR. BOESENBERG: Alex Boesenberg. We will

19 attempt to give better technological explanation in

20 our comments.

21 MR. DeLASKI: You are just giving -- you

22 are expressing just the facts, the observation --
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1 MS. CALLAHAN: Yes.

2 MR. DeLASKI: -- here is what we have

3 available; right?

4 MR. BOESENBERG: Alex Boesenberg, NEMA.

5 Our initial review by our technical experts

6 identified this problem so we are raising it. But

7 we don't have the detailed analysis yet.

8 MR. BROOKMAN: Garry Fernstrom?

9 MR. FERNSTROM: Garry for the California

10 IOUs. Well you phrased my concern because we are

11 generally beginning to require dimming in all

12 applications in California and if there is a

13 compatibility issue we sure want to understand that.

14 Thank you.

15 MR. BROOKMAN: Okay. Thank you.

16 Other points responsive to this comment

17 box?

18 Mike Rivest?

19 MR. RIVEST: Do I have to repeat it after

20 you said it? Mike Rivest.

21 MR. BROOKMAN: No you do not.

22 MR. RIVEST: Okay. Just to explain a
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1 little bit how the Engineering Analysis is

2 structured and then how it then follows into the

3 national impacts analysis. The Engineering Analysis

4 will compare technologies that are incrementally

5 more efficient but will not take into account the

6 fact that consumers may for example not be able to

7 dim. That is, however, taken into account in the

8 energy savings calculation in the National Impacts

9 Analysis. So if the Engineering Analysis says that

10 you will save two watts but in fact the loss of

11 dimming would result in much higher energy

12 consumption that all gets washed out and the

13 effectiveness of that efficiency level would

14 disappear. So just so you don't react to the fact

15 that we wouldn't screen out a technology for reasons

16 such as you stated at this stage of the analysis.

17 MS. KIENLE: Can I step in for a second

18 too.

19 MR. BROOKMAN: Please.

20 MS. KIENLE: Just to clarify too and we

21 are going to discuss this a little bit more on the

22 next slide but specific to this analysis we insured
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1 for the directly analyzed product classes that a

2 full wattage lamp could meet each level so that the

3 dimming utility was preserved. And if you are

4 finding issues with that we are listening to your

5 comments and will certainly take a look at that for

6 the 2-foot U-shaped product class as well.

7 MR. BROOKMAN: Andrew DeLaski.

8 MR. DeLASKI: I also want to test a little

9 bit, I don't want to dwell on it, but we're not --

10 it appears to us that we shouldn't think about

11 reduced wattage lamps as never being able to be

12 dimmed; that there are dimming options, there can be

13 dimming options with reduced wattage lamps and that

14 it is an improving situation and that we shouldn't

15 be seeing this as a forever and ever you are never

16 going to dim a reduced wattage lamp. We understand

17 that it is harder. But we don't think it is

18 impossible. So we - - I want to be careful that we

19 are not sort of setting this as a rigid we always

20 have to have full wattage lamps because we can't dim

21 because in some cases you can dim reduced wattage

22 lamps.
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1 MR. BROOKMAN: Okay. Thank you.

2 Yes, please. Aisha?

3 MS. HUSAIN: Aisha Husain, Navigant

4 Consulting. Sue you had mentioned that the 1 5/8

5 inches used in retail application and then so six

6 inches are they used in specific applications?

7 MS. CALLAHAN: Susan Callahan. I would

8 have to get back to you on that. But the concern

9 that had been raised for us with the 1 5/8 is that

10 there are consumers who are using reduced wattage

11 lamps already that will not be able to replace them

12 with reduced wattage lamps so that the effect of

13 this rulemaking is a net energy loss as opposed to a

14 net energy savings. An energy increase.

15 MR. BROOKMAN: Okay. Thank you.

16 Yes, Mark.

17 MR. DUFFY: Yeah, I just wanted to address

18 unfortunately Andrew DeLaski has left. This is Mark

19 Duffy from GE. Unfortunately Andrew has just

20 stepped out of the room but I wanted to address his

21 statement about dimming the reduced wattage 28 watt,

22 25 watt other reduced energy saving type lamps. It
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1 is not that you can't physically dim them. They can

2 be dimmed. It is that you will find that they are

3 much more susceptible to an unacceptable striation

4 which is visible and we get calls and complaints

5 your lamps look like barber poles and that sort of

6 thing. So this is what happens. You have

7 susceptibility to that when you use the krypton gas

8 in the lamps. And therefore we do not advise

9 dimming with krypton because it makes aesthetic

10 problems in the field. Can you do it? Yes. Are

11 you still getting light out of it? Yes. Does it

12 generate dissatisfaction among customers? Yes.

13 That is why companies like the major companies say

14 you want to do a dimming system please use the full

15 wattage, we are glad you are dimming because you are

16 saving energy by using the dimming and the actual

17 energy savings from lamps has to do with the wattage

18 that they are being operated at; not the efficiency

19 that they are measured at.

20 MR. BROOKMAN: Okay. Thank you.

21 Additional comments before we move on?

22 MS. KIENLE: Okay. So we will move on to
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1 the more efficacious substitutes. DOE selected more

2 efficacious substitutes for each baseline lamp. DOE

3 sought to keep characteristics such as rated life,

4 CRI, and CCTs similar to the baseline lamp. As you

5 can see here in this 4-foot medium bipin example

6 table reduced wattage lamps are identified as more

7 efficacious substitutes as are full wattage lamps

8 with higher efficacies.

9 DOE requests comment on the GSFL baselines

10 and more efficacious substitutes and in particular

11 their rated lifetimes.

12 MR. BROOKMAN: Mark?

13 MR. DUFFY: This is Mark Duffy of GE. One

14 thing that we've looked at carefully and in our

15 designing of lamps is what the various tradeoffs

16 are. With IRLs it is extremely strong tradeoff

17 between life and efficacy. If you go to extremely

18 high efficacies you can get one day, one week type

19 life. Okay. With fluorescent lamps it is not quite

20 as strong. But it is definitely present. And since

21 we are discussing very small increases in efficacy

22 baseline or required efficacies in these ELs it is
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1 now coming into play and that is that you are going

2 to lose your long life lamps. Fluorescent lamps,

3 GSFL lamps at long life, long service life will be

4 less and less possible because as you reduce the

5 life -- as you go for higher efficacy you can reduce

6 the life of the lamp to get there. Now what does

7 that mean for our nation's energy savings?

8 Absolutely nothing because the amount of power that

9 is being consumed is going to be fixed. The amount

10 of light you get might change. But if you have

11 reduced the life of the lamp the amount of scrap

12 which includes rare earth phosphors which are very

13 difficult materials to obtain and use, they are

14 expensive materials. It includes the mercury. We

15 don't do a perfect job of recycling in this

16 industry. So think about how many more lamps need to

17 be generated to support lifetimes that are maybe

18 half as long as you are used to with fluorescent

19 lamps when you start to push efficacies

20 incrementally up into that region where that life

21 starts coming down.

22 MR. BROOKMAN: Garry Fernstrom?
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1 MR. FERNSTROM: Garry for the California

2 IOUs. So a question for GE. You talk about the

3 reduction in life. What does that do for mean

4 lumens? I am not clear whether when we have these

5 discussions we are talking about initial or mean

6 lumens for lamps but we base our calculations on

7 mean lumens. And I am wondering how that is

8 affected.

9 MR. DUFFY: Well you are correct as you do

10 design to use mean lumens if you are asking for the

11 life of the appliance, the lighting appliance as you

12 mention. I am sorry, this is Mark Duffy responding

13 from GE Lighting. I am not going to get used to

14 that. What I will say though is that this rulemaking

15 is about initial performance. It is the 100 hour

16 measurements and it is not about mean lumens. So we

17 do our best to give you an estimate of the mean

18 lumens of a population of lamps and give you that

19 rating for your design layouts.

20 MR. FERNSTROM: Well, Garry again, but I'm

21 curious about what this issue increased efficiency

22 with the consequence of reduced life what that does
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1 to mean lumens. Does it put us in the same, a

2 better or a worse position with respect to the

3 energy used by the lamp for the life that you get

4 during the life of the lamp?

5 MR. BROOKMAN: Joe Howley?

6 MR. HOWLEY: We could look at that further

7 Garry but I don't expect it to have a significant

8 impact with using these tri-phosphor lamps. If we

9 were back in the days of using halo-phosphate cool

10 light and warm light which had significantly higher

11 lumen depreciation issues you would probably have a

12 significant difference in the design. But with tri13 phosphors they hold up very well over time and with

14 the levels you are talking about these are heavily

15 coated with tri-phosphors which is going to hold up

16 very well. So the difference between these long

17 life lamps and really long life lamps in design are

18 -- probably don't produce a practical difference in

19 the lighting design in terms of spacing and layout,

20 things like that.

21 MR. BROOKMAN: Thank you.

22 Alex Boesenberg?
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1 MR. BOESENBERG: Alex Boesenberg, NEMA. I

2 want to make sure that we are looking at extra long

3 life linear fluorescent in the right context. I

4 believe our position and our concern at preserving

5 this category; it is not a product class which is

6 part of the topic we are raising up here is there

7 need to be a concession made for it. The issue is

8 there are consumers who prefer to have ultra long

9 life say 80,000 hour fluorescent lamps. And the

10 reasons for that are not as much in the energy

11 savings side of it as in the overall cost savings

12 which the DOE and Navigant do analyze regarding

13 maintenance cycles and cost of buying new lamps

14 during re-lamping and replacement of failed lamps.

15 So from the consumer standpoint I'd buy a long life

16 lamp because I don't want to get up on a ladder

17 again anytime soon and I am willing to pay if

18 necessary a premium for that within reason. I say

19 within reason because obviously as the later

20 sections will talk about there are technology

21 options with very long life LED but one of the

22 additional consumer utilities or consumer
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1 considerations we want to make sure is balanced when

2 talking about long-life fluorescent is that there

3 are still plenty of consumers who cannot afford

4 first cost of LED systems even if they are very long

5 life and very efficient and in the analysis pay back

6 within an acceptable period of time. If they cannot

7 afford to make that investment then the answer today

8 is a long life linear fluorescent product which at

9 least one manufacturer has told me they are pretty

10 sure will be eliminated.

11 MR. BROOKMAN: Mark Duffy.

12 MR. DUFFY: Yes. This is Mark Duffy with

13 GE. I appreciate what Alex just said. I completely

14 agree with that. I'd like to remind the room though

15 that national energy savings and what we're trying

16 to do here with reduction of energy it turns out

17 that throughout the life of a fluorescent lamp it

18 consumes a very steady amount of energy. You do not

19 get an increase in the power consumption as it ages.

20 So from the standpoint of the power consumption what

21 you see in the initial is what you have at the mean

22 life and what you have pretty much all the way to
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1 the end of the life for a fluorescent lamp.

2 MR. BROOKMAN: Thank you.

3 I am going to let Mike Rivest follow on

4 with this string and then I am coming to you

5 Charlie.

6 Mike Rivest?

7 MR. RIVEST: The extra long life GSFLs

8 what portion of the market might we be talking

9 about?

10 MR. BROOKMAN: Susan?

11 MS. CALLAHAN: Susan Callahan OSRAM

12 Sylvania. These products have only been recently

13 introduced into the marketplace and so we don't have

14 a good feel for that yet.

15 MR. RIVEST: Okay. You know if setting a

16 product class for an extra long life lamp were done

17 and the standard were set in such a way that it was

18 at a stringency equivalent to that of a standard

19 life lamp so that it is not a loophole. In other

20 words you would require the same level of phosphors

21 for example then it doesn't represent a loophole

22 where the market would shift extra long life just to
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1 avoid meeting the standard. Personally I don't see

2 why that couldn't be done. But it can't create a

3 migration to there.

4 MR. BROOKMAN: Alex?

5 MR. BOESENBERG: Alex Boesenberg, NEMA.

6 In response to your first question I will poll my

7 members and see if we can find out any market share

8 data. I don't know if we survey that as a separate

9 product or not. But we will see what we can

10 provide. And --

11 MR. RIVEST: Just before -- you realize

12 that there is a back sliding provision so that level

13 could never be less than what it is today for the

14 standard life product.

15 MR. BOESENBERG: We understand that

16 absolutely. And at least I would like to think that

17 we are meeting today's standards so that is not the

18 issue. It is the lost utility and the cost benefit

19 analysis with the reduced maintenance times and

20 things like that. And then I will also then in

21 response to your second point within the constraints

22 I have to operate under regarding cost and pricing I
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1 will attempt to identify if there is a mitigating

2 factor of cost for long life lamps. If they are

3 more expensive logically the market isn't as liable

4 to migrate to them if they represent a -- if the

5 raising of the cost of a general standard life lamp

6 for tomorrow's rule is on par with a long life lamp

7 today and arguing that that standard not be raised

8 then there is no loop- holing; right? Did I make

9 sense?

10 MR. RIVEST: I don't know if extra life

11 would be sufficient to induce people to buy that. I

12 think our economic analysis would probably say it

13 would because it would have a lower life cycle cost

14 because of the reduced maintenance and operation

15 costs. So the LBL folks can speak to that.

16 MR. BROOKMAN: Joe Howley?

17 MR. RIVEST: But all is said is that it is

18 not infeasible that it could be a class. But these

19 types of things would have to be considered.

20 MR. HOWLEY: Just one comment on that

21 although I agree anything is possible including

22 that. That we really though should be indifferent
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1 with regard to energy savings because whether a

2 consumer chooses a long life or a standard life the

3 national energy savings will be exactly the same

4 presuming that with the shorter life lamp if they

5 have to buy two of them, they will buy the same

6 lamp; they are both running at 32 watts or so. We

7 should not care which the consumer chooses to pick

8 from purely an energy savings viewpoint. It really

9 doesn't matter. So that might factor into whether

10 or not you need to create two classes or not.

11 MR. RIVEST: The tradeoff is if it turns

12 out that it has a substantial market share we don't

13 want to be limited to how high we go on the standard

14 life lamp because of the existence of the extra

15 life. And so that would argue for a separate class.

16 What would argue to having a single class is that we

17 don't want people to migrate to the long life. So

18 that is the tradeoff.

19 MR. BROOKMAN: Charlie Stevens thank you

20 for being patient.

21 MR. STEVENS: No it has been interesting

22 dialogue. Charlie Stevens, Northwest Energy
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1 Efficiency Alliance. I don't know it is so

2 interesting. No one has been more concerned about

3 product lifetime than I have since about 1970 when I

4 understood the macro economic impact of short

5 product life throughout the economy. But there is

6 an inherent bias in our economy toward short product

7 life. And you can see it pretty much across the

8 entire economy. But here the existence there is a

9 lot of product out there like lighting product out

10 there that is not very efficacious and has a very

11 short lifetime. I don't see a lot of demonstrated

12 concern about product lifetime out there. And I'm

13 very much in favor of taking it into account because

14 the true energy savings should include embodied

15 energy but they don't. But I don't necessarily

16 believe that it is impossible to maintain good long

17 lifetime of a product as well as an efficacious

18 product. I see it often enough in the marketplace.

19 It is a choice. But I also see a lot more sales of

20 very non-efficacious product that has a very short

21 lifetime. So I would love to see more concern about

22 lifetime but I don't see it. And I don't expect it
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1 to be very well addressed in this rulemaking except

2 through as Mike points out the economic analysis of

3 what it costs directly to have a short lifetime in

4 terms of maintenance and lamp replacement and that

5 sort of thing. But I don't necessarily believe

6 based just on what is available in the marketplace

7 that you can't do better in the way of efficiency or

8 efficacy in this case and lifetime. If it exists it

9 is possible.

10 MR. BROOKMAN: We are moving on now.

11 MS. KIENLE: If I could just add that if

12 anyone has data particularly that demonstrates the

13 relationship between efficacy and lifetime and how

14 that changes particularly at the higher efficacy

15 levels that would be really helpful to have as well.

16 MR. BROOKMAN: Final comment?

17 DR. GARBESI: Karina Garbesi at LBNL. I

18 was just going to say that if there are data on

19 differences in embodied energy that relate to

20 lifetimes that is easy to incorporate in the

21 analysis so we can do that.

22 MR. BROOKMAN: Okay. Thank you.
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1 MS. KIENLE: So next DOE developed

2 efficacy levels. DOE used commercially available

3 lamps and their associated rated efficacies to

4 determine the initial ELs. To establish final

5 minimum efficacy requirements for ELs DOE coupled

6 publicly available compliance data with rated

7 efficacy to determine if any adjustments were

8 necessary to the initial ELs. For the NOPR analysis

9 DOE again only analyzed ELs at which full wattage

10 version of the lamp type was available because

11 reduced wattage lamps cannot be used in all

12 applications such as cold temperature applications

13 and also because striations remain an issue for

14 reduced wattage lamps which we've discussed already

15 some.

16 Because fluorescent lamps operate on a

17 ballast in practice DOE analyzed lamp and ballast

18 systems in order to capture a real world energy use

19 and light output. DOE used manufacturer input and

20 information from the 2011 ballast rule to identify

21 the ballast type most commonly used with each lamp.

22 As you can see by the table here the 4-foot medium
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1 bipin lamps were paired with multiple ballast types.

2 Both the instant start and programmed start ballast

3 were analyzed for this product class as well as

4 ballasts that operate 2 and 4 lamps and a

5 residential use ballast. All other product classes

6 were analyzed with one ballast type.

7 When developing lamp and ballast systems

8 DOE tried to select ballast models to pair with

9 lamps that would maintain system mean lumen output

10 within 10% of the baselines when possible. At the

11 higher ELs DOE selected ballasts with lower ballast

12 factors when possible to further improve energy

13 savings. This example table is of the 4-foot medium

14 bipin two lamp programmed start, lamp and ballast

15 replacement scenario. The table presents the

16 characteristics of the lamp and ballast systems

17 analyzed. For the NOPR analysis DOE also added a

18 replacement option in which the consumer could

19 choose to prioritize energy savings over maintaining

20 lumen output. So you can see at EL1 and EL2 two

21 ballast selections exist for the full wattage

22 representative unit only. The first ballast
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1 maintains the system mean lumen output within 10% of

2 the baseline. This replacement results in the same

3 energy consumption as the baseline as well. The

4 second ballast listed achieves energy savings but

5 does not maintain system mean lumen output within

6 10% of the baseline.

7 This table displays the final ELs for the

8 representative GSFL product classes after accounting

9 for compliance requirements. As you can see in the

10 table for the NOPR analysis each product class has

11 two ELs with the exception of the T5 high output

12 product class which has one EL.

13 Issue 4 requests comment on the

14 methodology for developing lamp and ballast systems

15 as well as the results of these GSFL systems.

16 Issue 5 requests comment on the max tech

17 levels including the accuracy of catalog and

18 certification data which were used to identify these

19 levels.

20 And in Issue 6 DOE requests comment on the

21 methodology used to develop ELs for GSFLs and the

22 resulting efficacy levels.
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1 MR. BROOKMAN: Keith Cook?

2 MR. K. COOK: One question we have is in

3 the previous comments from the California IOU they

4 stated that increasing light levels is problematic

5 and that really it should be decreasing by up to 10%

6 and yet our data is showing that with the aging

7 population increasing light levels are favored

8 because the aging population having difficulty to

9 see. I was wondering what the IOU comment was based

10 upon?

11 MR. BROOKMAN: Garry Fernstrom.

12 MR. FERNSTROM: Well this is Garry on

13 behalf of the California IOUs. I wouldn't disagree

14 with you that with increasing age more light is

15 beneficial. I've personally dealt with that myself.

16 I think our comment relates to general area lighting

17 versus task lighting. So we commonly see these

18 fluorescent lamps used in general area lighting and

19 California has been decreasing the wattage per

20 square foot allowable for that over time as a

21 certain reliance is diverted to task lighting such

22 that we have adequate light at our work spaces so
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1 those of us who are older can see what we are doing.

2 MR. BROOKMAN: You see the comment boxes

3 there. Let's see if we can respond to those.

4 Yes, Tim Ballo?

5 MR. BALLO: Just I had a question on

6 something you said in introducing slide 39 and I am

7 paraphrasing it. I think you said something like

8 the levels were adjusted to account for compliance

9 requirements or certification requirements. I

10 wonder if you could explain that a little bit more.

11 MS. KIENLE: Sure. This is outlined in

12 the NOPR. It is also in the TSD if you want more

13 information. But in general we based the efficacy

14 levels initially on catalog information. So that

15 means the ANSI rated wattage which I explained

16 already and the catalog initial lumen output. And

17 then we compared the levels in our data against the

18 DOE certification data and took into account if any

19 adjustments were necessary based on where the lamps

20 were performing.

21 MR. BROOKMAN: Comment Box 4 asks about

22 the methodology. Comment Box 5 asks about max tech.
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1 MR. DeLASKI: Can I follow up on the

2 question you just answered. So --

3 MR. BROOKMAN: Andrew DeLaski.

4 MR. DeLASKI: -- does that mean you

5 adjusted -- what did you trust? It sounds like you

6 trusted the certification data; that was ultimately

7 what you trusted?

8 MS. KIENLE: I would say we trusted both.

9 We started with the catalog data. And if we could

10 insure that the lamps were reliably meeting that

11 level then the catalog data is generally used. But

12 yeah we took into consideration those certification

13 data.

14 MR. DeLASKI: But to insure you were using

15 the certification data to do that insuring task?

16 MS. KIENLE: Yeah. You work -- right. So

17 yes.

18 MR. BROOKMAN: Joe Howley?

19 MR. HOWLEY: Yes. In terms of comments on

20 these levels and particularly looking at column 2;

21 we are concerned about the levels that are being

22 proposed here in particular for the 4-foot medium
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1 bipin lamp. We did make a comment at the last

2 rulemaking that we feel first of all that these

3 should be to the watt and not a tenth of a lumen per

4 watt. But we should set these at a lumen per watt

5 due to measurement variability and ability to

6 measure accurately down to a certain level. So 92.4

7 seems a little extreme to us in terms of the

8 specificity of that. Also the level itself is set

9 at a quite high level.

10 Mark would you like to comment further

11 about where we think that might have been obtained

12 from a statistical standpoint.

13 MR. BROOKMAN: Mark?

14 MR. DUFFY: This is Mark Duffy of GE

15 Lighting. I wasn't the person making this analysis.

16 But just from the observation and the knowledge that

17 I have of our measurements and so forth plus what

18 you can find in the DOE database I am very concerned

19 that efficacy levels 1 may be an indication of the

20 central tendency of a distribution and levels 2 may

21 be an indication of the higher tail of a

22 distribution. So if you have selected this 92.4
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1 because there is some data point in the DOE database

2 that happens to have come out on the high end that

3 is a very normal situation when taking small samples

4 of large quantities of lamps and so forth. So this

5 is really that measurement statistical variation of

6 the production measurement variation of several

7 percent and so forth. So if we have a rulemaking

8 that says everything has to be above 89 you get a

9 population that is going to spread above 89

10 generally, okay, especially what is being reported

11 should all be above 89 and have a distribution. If

12 you now move to the top of that distribution, this

13 is just a single design let's say or a single

14 situation, if you move to the top of that

15 distribution and you now say everything needs to be

16 above the top of that distribution, you are not

17 actually making any -- what you are doing is doing

18 the same kind of thing that wiped out the IRL 130s.

19 You could wind up in a situation where you have set

20 it above the max tech. Max tech sits at the center

21 of that distribution. If you drive it to the upper

22 tail of that distribution you've actually gone above
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1 what is max tech. So I think something that needs

2 to be indicated is we are with you on making a

3 rulemaking to drive the country toward the more

4 efficient products. But what we would like to do is

5 set those levels so that the normal production can

6 meet the levels as it is today rather than going to

7 the maximum observed value and then driving

8 everything above that.

9 So one more point I would like to draw

10 your attention to; there is an open paper that I

11 know all of you are aware of, it is LSD-63 from

12 NEMA. And I am sure you all have copies of it.

13 Utilize the information in there as you analyze what

14 you are getting into this DOE database because it's

15 going to show that kind of variation both in

16 measurement and in production variation. Thank you.

17 MR. BROOKMAN: Mike Rivest.

18 MR. RIVEST: This is getting to my

19 understanding of the certification database and the

20 way we used it. If we use the certified values for

21 particular lamps wouldn't that take into account the

22 normal distribution and wouldn't you have taken that
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1 into account in the certification?

2 MR. DUFFY: Actually the answer to that is

3 no. And the reason that the answer to that is no is

4 that what is being reported into that database

5 complies with the existing law. So it goes back to

6 the CCE rule, okay, what needs to be reported is

7 based on 21 lamps taken from seven different -- we

8 can all recite the thing. And those are the numbers

9 that are being reported into that database. So if I

10 do a sampling 21 lamps is a small sample of a large

11 population of product and if my lab has a bias and

12 that is in the paper, if my lab has a bias of a

13 percent or two I might be reporting a percent or two

14 higher than somebody else who would measure perhaps

15 the same set of lamps at a different laboratory and

16 come up with one or two percent lower number. So

17 your database is going to contain all the variation

18 of both production and the variation of the

19 measurement bias between laboratories.

20 MR. RIVEST: So the certified value is

21 based on what you just described. There is also an

22 enforcement equation I assume that would be I guess
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1 more generous or --

2 MR. DUFFY: No the CCE enforcement is less

3 generous, much less generous.

4 MR. RIVEST: But you are held to -- so you

5 are held to that enforcement equation; right?

6 MR. DUFFY: I am telling you that what

7 goes into the database are actual measured values

8 drawn from the --

9 MR. RIVEST: I heard that.

10 MR. DUFFY: -- population of lamps and

11 that there exists variation between measurement

12 laboratories as well as within the population of

13 manufactured lamps.

14 MR. BROOKMAN: Keith Cook.

15 MR. RIVEST: I heard that and what I asked

16 you was what you are legally obligated to sell based

17 on the enforcement equation. I don't know

18 specifically about lamps but in other products the

19 enforcement equation has more slack in it. But you

20 are saying in lighting it doesn't?

21 MR. DUFFY: There is no tolerance at this

22 point -- we have had this discussion with the
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1 Department of Energy, there is no tolerance in

2 lighting. If you have a MEPS, Minimum Energy

3 Performance Requirement, at 89 LPW you have to over

4 perform with your design in order to --

5 MR. RIVEST: So you are saying 100% of the

6 population has to meet --

7 MR. DUFFY: In essence.

8 MR. RIVEST: -- equation.

9 MR. DUFFY: It depends on what you want to

10 risk. If you set yourself up right at 89 you could

11 have a completely compliant mean to your population.

12 MR. RIVEST: So that is why you are

13 interpreting these numbers to mean that every lamp

14 you manufacture will have to meet this --

15 MR. DUFFY: Absolutely.

16 MR. RIVEST: -- based on the enforcement.

17 MR. DUFFY: At the moment that CCE require

18 - - the CCE rulemaking, different rulemaking but the

19 CCE rulemaking requires that this is a minimum of

20 that population.

21 MR. BROOKMAN: Keith?

22 MR. K. COOK: Keith Cook with Philips.
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1 You are getting into exactly what my point was going

2 to be and my concern is the fact that it is quite

3 feasible that you could have an offshore

4 manufacturer today that is sorting product and

5 shipping the upper end of his distribution to the

6 United States to meet the requirements. And so he

7 has got a skewed distribution. He sells everything

8 else in China or wherever, I don't care where. But

9 now all of sudden you've got a point that is way out

10 there and that is a reported mean value. It is not

11 the minimum. So all of a sudden we are doing this

12 analysis, we look at this and say well this guy is

13 producing this exemplary product; that now becomes a

14 minimum value. For us to meet that minimum value

15 means that 50% of everything we are producing would

16 have to be thrown away because that was his mean

17 value to start with. That is a real concern.

18 MR. BROOKMAN: Michael McGaraghan has a

19 question or a comment. Michael unmute your phone

20 and we will see if we can hear you.

21 MR. McGARAGHAN: Hi. Can you hear me?

22 MR. BROOKMAN: Yes. You are good.
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1 MR. McGARAGHAN: Great. So my comment was

2 actually about the previous discussion around the I

3 think it was one slide back.

4 MR. BROOKMAN: We can go back.

5 MR. McGARAGHAN: Yeah. So Keith Cook asked

6 what the California comment was referring to when we

7 suggested that DOE waive the scenarios that result

8 in less light rather than more light. So Garry

9 Fernstrom got at part of that in his response. And

10 I just wanted to expand on that and say that in

11 commercial settings we all know that lumens

12 depreciate over time. So at the end of life of a

13 lighting system we are already down at about 594 or

14 30% of initial lumens. So if you just replaced all

15 the equipment with exactly identical equipment after

16 that lighting retrofit you are going to see an

17 increase of light, 6%. It is going to seem very

18 bright to everybody. If on top of that you replace

19 the equipment with new lamps that are actually 10%

20 brighter, the lamp and ballast system is 10%

21 brighter than you are talking about maybe a 15, 16,

22 17% increase in light and consumers always seem to
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1 respond negatively in that scenario. You hear a lot

2 of comments after lighting retrofit that the new

3 lights are too bright. So I am not suggesting that

4 we just keep making baselines dimmer and dimmer, I

5 am suggesting that DOE apply some sort of weighting

6 for approach to different scenarios. Energy savings

7 is a huge motivator in any kind of lighting retrofit

8 and if the building owner or operator has an option

9 ahead of them of going to 95% light and saving

10 energy or going to 102%, 105%, 108% light and not

11 saving energy, they are going to choose the energy

12 saving option every time. So the request in our

13 comment was that DOE consider that when looking at

14 these different scenarios and prioritize or

15 emphasize the cases where people actually get to

16 save energy and keep light within a reasonable

17 level.

18 The other comment on this slide that I

19 wanted to ask about was and I realize that this is

20 just one example table and you guys have a lot of

21 different tables. But I don't see 30 watts lamps on

22 here. I see 25 and 28 but 30 watts -- opportunity
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1 to stay within 90% of initial lumens and save

2 energy. I also don't know if DOE considered has

3 considered dimming ballast in any of these scenarios

4 but in California in particular new building codes

5 are going to result in -- ballast, potentially

6 almost all lighting is going to dimming ballast. So

7 that is going to be a much more common approach in

8 other states as well and as other places pick that

9 up; so that is another opportunity for lighting

10 designers to design a space that saves energy

11 without increasing light inadvertently particularly

12 through tuning. So those are a couple of questions

13 that I wanted to propose on that slide.

14 MR. BROOKMAN: Okay. Thank you.

15 MR. McGARAGHAN: And just real quickly on

16 the next slide and all this discussion about

17 reporting I think I am stuck where Mike Rivest is in

18 the DOE certification database. I understand that

19 that is the value that gets reported for compliance.

20 So it should be apples to apples. If the values in

21 that database are above 92.4 then we could expect

22 future values reported to DOE to be above 92.4. So
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1 the disconnect then that is a big problem and we

2 need to get to the bottom of that. I am confused

3 about that discussion. Thank you.

4 MR. BROOKMAN: Thank you.

5 Garry Fernstrom, follow on?

6 MR. FERNSTROM: This is Garry. Thank you

7 Mike. Following on your point we were just

8 discussing the database and what some of the numbers

9 mean and I heard the folks from industry say there

10 may be an issue with some offshore manufacturers

11 that may be sorting their production and sending the

12 best of their production here. I don't think it

13 matters as long as when tested the production sent

14 to the United States and sold in the United States

15 performs as reported because in fact that is the

16 distribution that we are getting whether it is

17 screened before it gets here is kind of irrelevant

18 from this standpoint of the reality of its

19 performance relative to what is reported.

20 MR. BROOKMAN: Let's hear from Brian.

21 DR. GERKE: This is Brian Gerke from LBNL.

22 Just to respond to -- is this not audible. It is
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1 on. I am probably in the dead zone here. Is that

2 better?

3 MR. BROOKMAN: Yes.

4 DR. GERKE: Just to respond to Mike

5 McGaraghan's questions about lamp and ballast

6 combinations and dimming and the choices that

7 consumers make we can get into that in more detail

8 when we discuss the shipments analysis.

9 MR. BOESENBERG: We are losing you.

10 MR. BROOKMAN: Just take that.

11 DR. GERKE: Try the other microphone.

12 MR. BROOKMAN: Yeah.

13 DR. GERKE: Is that better? We can get

14 into those questions about what choices consumers

15 make for lamp and ballast combinations and dimming

16 and building codes in the shipment analysis where we

17 took that all into account.

18 MR. BROOKMAN: Alex?

19 MR. BOESENBERG: Alex Boesenberg, NEMA. I

20 would like to respond to Garry's statement. Garry I

21 would agree with you from the standpoint of your

22 statement that said that if somebody wants to sort
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1 their lamps then that is fine as long as what hits

2 the market here in the U.S. which is what we are

3 talking about today, as long as those are compliant.

4 But I would challenge the logic if you carry it a

5 step further and say that we shouldn't be wary of

6 the fact that that can skew the overall curve as

7 Mark Duffy was speaking to. And by that I mean if

8 someone has made a conscious decision to only put

9 for a given design. Let's say everybody is designing

10 the same because everyone is trying to hit the same

11 number of minimum performance or exceed it. If

12 someone has decided to further cherry pick, not

13 cherry pick but make a personal business decision to

14 increase the performance by a selection. If for

15 that design, that same design, that same level

16 everyone is designing to if somebody does that to

17 set the new national minimum at that level that

18 represents a individual business decision or

19 additional steps that other manufacturers aren't

20 taking. That obligates everybody else to then incur

21 those additional costs and do that too or design to

22 an even higher level as a result. So it is not
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1 apples and apples.

2 MR. FERNSTROM: Okay. So this is Garry.

3 I understand your point relative to setting

4 standards. Thanks for that clarification.

5 MR. BROOKMAN: I am wanting us to move on.

6 But a final chance to provide comment on issue 4

7 GSFL systems, 4 max tech levels, and 6 GSFL efficacy

8 levels.

9 Okay.

10 MS. KIENLE: Okay. So we will move on to

11 the scaling analysis now. So once ELs are

12 established for the representative product classes

13 DOE develops scaling factors to apply those ELs to

14 the remaining product classes. This process

15 involved the comparison of lamps that differ only by

16 one parameter. The parameter under consideration

17 for scaling which in this case was either the shape

18 or CCT. To develop a scaling factor to account for

19 shape DOE compared commercially available 2-foot U20 shaped lamps with CCTs less than or equal to 4500 K

21 and the equivalent 4-foot medium bipin version. By

22 comparing catalog ratings DOE found that an average
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1 efficacy reduction of 6% from the 4-foot medium

2 bipin ELs was appropriate for the 2-foot U-shaped

3 lamps.

4 Similarly to develop a scaling factor to

5 account for CCT DOE identified pairs of lamps in

6 which the only difference was CCT. For the NOPR

7 analysis DOE analyzed differences in efficacy due to

8 CCT by product class. DOE compared lamps with a CCT

9 of 4100 K to lamps with a CCT of 5000 K and 6500 K

10 to determine differences in efficacy. DOE

11 determined that a 2% scaling factor for the 4-foot

12 medium bipin product class, 5% for the 8-foot

13 slimline, 2% for the 8-foot high output, 6% for the

14 T5 standard output, and 5% for the T5 high output

15 and 3% for the 2-foot U- shaped lamps were

16 appropriate. DOE confirmed that the scaling factors

17 did not result in back sliding from the current

18 standards.

19 In issue 7 DOE requests comment on the

20 methodology and the results of the scaling analysis

21 for GSFLs.

22 MR. BROOKMAN: Comments here.
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1 Joe Howley?

2 MR. HOWLEY: Just in general on the

3 scaling factors we continue to receive comments

4 through some industry members that the scaling

5 factors seem to be a little bit low on the high CCT

6 and we realize you can't back slide. So maybe that

7 creates stability to not back up too much. But just

8 from a pure and I know you are looking at catalog

9 ratings which probably produces what you are finding

10 but from a pure physics standpoint they point out

11 that it is more of a 4 to 6% reduction when you got

12 to 5000 Kelvin and it could be as high as 6 to 8%

13 when you go up to the 6500 type of products. The U14 lamp scaling factor at 6% I think we have used that

15 in the past, it sounds about right. However, the

16 levels are we believe set too high on U- lamps

17 producing the problems indicated earlier. But that

18 could be just an issue with the 4 lamp level being

19 set too high as well so producing a problem in both

20 of those categories. We'll provide more analysis

21 and comment in our written comments about this.

22 MR. BROOKMAN: Thank you.
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1 Additional comments here?

2 MS. KIENLE: In issue 31 DOE requests

3 comment on its assumption that there will be no

4 lessening of utility or performance such that the

5 performance characteristics would be adversely

6 affected for the GSFL efficacy levels.

7 And in Issue 32 DOE requests comment on

8 whether there are features or attributes of the more

9 energy efficient GSFLs that might affect how they

10 would be used by consumers.

11 Okay. If there aren't any further

12 comments. I am going to hand this off to my

13 colleague Julie --

14 MR. BROOKMAN: I think we need to take a

15 break at this point. It is five minutes after

16 11:00. We've covered a lot of ground already. We've

17 done well. Let's take a 15 minute break.

18 Please make sure you have got our badge

19 visible while you walk around the Forrestal

20 Building. For those of you that aren't aware there

21 are bathrooms at both ends of the hallway. There is

22 a coffee shop on the ground floor just about on the
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1 opposite side of the hall just about the same

2 location we are in this building. So go to the

3 elevator and head down. Go quickly though because

4 we will resume let's say 20 after 11:00

5 (WHEREPUON, a recess was taken.)

6 MR. BROOKMAN: Let's resume.

7 We are going to proceed where we left off

8 which I believe is 44.

9 MS. PIERCE: Yes. Hi my name is Julie

10 Pierce. And I am with Navigant.

11 MR. BROOKMAN: Folks let's take our seats

12 and get settled here please.

13 MS. PIERCE: Okay. I will discuss the IRL

14 Engineering Analysis. In general DOE chooses

15 representative product classes on which to focus its

16 analytical effort. Of the eight IRL product classes

17 which are shown in this table the standard spectrum

18 greater than 2.5 inches, less than 125 volt product

19 class shown in darker green was chosen as

20 representative based on its high market volume. The

21 baseline lamp is the most common, least efficacious

22 model on the market for each representative product
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1 class.

2 For IRLs DOE found that the most common

3 least efficacious lamp for the representative

4 product class is the 60 watt PAR38. It is an

5 improved halogen lamp which means it is a halogen

6 lamp with an improved reflector. It has a light

7 output of 1070 lumens, an efficacy of 17.8 lumens

8 per watt, and a lifetime of 1500 hours.

9 DOE request comment on the baseline lamp

10 selected for IRLs.

11 MR. BROOKMAN: Joe Howley?

12 MR. HOWLEY: We would agree that

13 represents a baseline lamp for this category.

14 MR. BROOKMAN: Okay. Thank you.

15 MS. PIERCE: DOE identified more

16 efficacious replacement lamps using the following

17 criteria:

18 commercially available, lower wattage than

19 the baseline, lumen output within 10% of the

20 baseline, and lifetime greater than the lifetime of

21 the baseline. One replacement lamp that DOE selected

22 was a 55 watt PAR38 HIR lamp with a light output of
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1 980 lumens, an efficacy of 18.5 lumens per watt and

2 a lifetime of 2500 hours. The other replacement

3 lamp was a 55 watt PAR38 improved HIR lamp which

4 means it is an HIR lamp with an improved reflector.

5 It has a light output of 1120 lumens, an efficacy of

6 18.5 lumens per watt and a lifetime of 4200 hours.

7 DOE requests comment on the rated

8 lifetimes of 1500 hours of the baseline and 2500 and

9 4200 hours for the more efficacious substitutes.

10 MR. BROOKMAN: Joe Howley?

11 MR. HOWLEY: Just a quick comment on

12 lifetimes. There are two general lifetimes

13 available for this product category. The shorter

14 lives tend to be representative of lamps sold in the

15 consumer market. The longer lives are generally

16 required in the commercial market. So 1500 hours

17 typically isn't acceptable in the commercial market

18 but it would be acceptable in the residential market

19 where residents might burn these lamps 1000 hours a

20 year or less. So you get a two year life or longer

21 if they have it on a dimmer and many of these are on

22 dimmers. On the commercial a lot of retailers will
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1 burn these up to 16 hours a day so they are looking

2 for lifetimes of 3000 to 4000 hours. The analysis

3 we think in this category really should be done in

4 two ways; one analysis for the residential market

5 and one for the commercial market. We think in some

6 cases this analysis is somewhat skewed between the

7 two of those different markets sort of being

8 interwoven in a way in the analysis and could

9 produce negative affects especially for the

10 residential market because the cost savings,

11 paybacks, things of that nature tend to work okay

12 for the commercial market where you have very long

13 operating hours and therefore you get fairly quick

14 paybacks, and you can get a payback from a fairly

15 expensive technology but not very well at all in the

16 residential sector.

17 MR. BROOKMAN: Michael McGaraghan has a

18 comment. Michael go right ahead.

19 MR. McGARAGHAN: Great thanks. Can you

20 hear me?

21 MR. BROOKMAN: Yes.

22 MR. McGARAGHAN: So I wanted to make a
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1 comment on the previous slide. Great. So Andrew

2 mentioned earlier that we were a little disappointed

3 at the identification of higher performance products

4 and the fact that DOE only identified one CSL. The

5 rational that DOE gave in a NOPR was that it was

6 only looking at PAR38 because they are the most

7 popular product on the market. And specifically

8 that DOE was only looking at PAR38 of a very tight

9 lumen range, within 10% of the baseline lamp so I

10 think that puts it between 963 lumens and 1170

11 lumens or something. So that right there just limits

12 BP to a very small subset of IRL products while

13 there are high performing products outside of that

14 range that are completely relevant to this

15 rulemaking. Any design strategies used in an 800

16 lumen lamp or 1200 lumen lamp or PAR30 lamp or any

17 other type of covered product if it improved

18 efficiency is important to consider and it is fairly

19 transferable between these different lamp types. So

20 we were not -- that approach of just looking at one

21 very lamp and identifying commercially available

22 improvement on that one lamp type.
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1 Secondly maybe it is a typo here on this

2 slide that second product there I think should say

3 20 lumens per watt.

4 MS. PIERCE: That is the certification

5 efficacy.

6 MR. McGARAGHAN: Okay. So I guess I am

7 lost again on the different --

8 MS. PIERCE: The catalog initial --

9 MR. McGARAGHAN: I was going to comment

10 that

11 --

12 MS. PIERCE: The catalog initial output

13 and wattage are shown and the certification efficacy

14 is shown.

15 MR. McGARAGHAN: So why do those two

16 products have the same certification efficacy?

17 MS. PIERCE: That is how they were

18 reported in the certification database.

19 MR. McGARAGHAN: Okay. Then the only

20 other comment I was going to make was that and

21 somebody mentioned earlier that DOE did not make any

22 attempt to model higher performance and that is
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1 another area where we think DOE could have improved

2 the analysis. There are lamp designs as everybody

3 has mentioned, tradeoffs between lifetime and

4 efficacy and I'm kind of skimming through DOE's

5 response here and it doesn't explain why DOE has not

6 considered the potential efficacy improvement that

7 are commercially available in certain products and

8 scaled those increments into other representative

9 products.

10 MS. PIERCE: Sure. Well for one I would

11 point you to Appendix 5A. We did a very in depth

12 analysis of considering higher efficacy IRLs

13 including some prototype lamps that we tested and we

14 go in to depth as to why we cannot consider those.

15 And also we regarding having more efficacious

16 substitutes that would be for instance outside of

17 the 10% range we feel it is important to maintain

18 those baseline characteristics. So we would welcome

19 feedback on the criteria we used and if you can find

20 lamps using those criteria.

21 MR. BROOKMAN: Garry Fernstrom.

22 MR. FERNSTROM: Well this is Garry. I am
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1 a little puzzled at your response. We found better

2 lamps. We pointed them out to you. You seem to

3 have not considered them. And it is a little bit of

4 a puzzle to me why? It would seem to me like DOE

5 didn't comply with its regulatory requirement to

6 investigate max tech. Now --

7 MR. BROOKMAN: Which better lamps were

8 they?

9 MR. FERNSTROM: Mike can you help me out

10 here?

11 MR. MCGARAGHAN: Sure. If I am still

12 unmuted. So some of them were commercially

13 available products that were available in different

14 lumen bin or that were different lamp shapes that

15 weren't PAR38. Some of them were certification

16 values reported to DOE that I don't have the

17 products but that is what the manufacturers have

18 reported in terms of their value for compliance.

19 And some of those products were prototype products

20 that have been developed either in the past by our

21 team or by specific manufacturers.

22 MR. BROOKMAN: Charlie Stevens?
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1 MR. STEVENS: Charlie Stevens. Then I

2 have a question here. I mean the -- notwithstanding

3 the prototype products, set those aside for a

4 moment. Are all of the products that Mike

5 McGaraghan just described going to be subject to the

6 standards?

7 MS. PIERCE: Yes. I believe so.

8 MR. STEVENS: Then why wouldn't you

9 analyze them?

10 MS. PIERCE: Again we used very specific

11 criteria. We feel that it is important to maintain

12 the baseline characteristics. If you have comments

13 about whether those criteria could be changed we

14 would welcome those. But we definitely considered

15 all the lamps that were pointed out in comments.

16 MR. STEVENS: Yeah but I am trying to

17 understand -- I mean I understand -- what fraction

18 of the shipments is this one lamp, the 60 watt PAR38

19 or its substitute 55 watt PAR38, what fraction of

20 the total number of lamps that are subject to the

21 standards does that one lamp represent?

22 MS. PIERCE: I was not involved with the
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1 shipment analysis but maybe Brian --

2 MR. STEVENS: Well if it is not something

3 close to 90% then I'd suggest your analysis is not

4 complete.

5 MR. BROOKMAN: Keith oh, pardon me, Joe

6 Howley?

7 MR. HOWLEY: Just to weigh in on the

8 manufacturer's side we did see the analysis that

9 Navigant performed as well. We believe the analysis

10 was fairly accurate in terms of addressing and

11 looking at these other products that were proposed.

12 Some of them I would suggest would not be covered by

13 the standard because some of them in certain cases

14 were 12 volt lamps and other types of lamps that are

15 not covered. So not everything that was proposed by

16 various commenters as more efficient were

17 appropriate and the technology was not

18 transferrable. I think Navigant did a pretty good

19 job at analyzing these proposed products and ruling

20 them out as appropriate for a lot of very accurate

21 technical reasons.

22 MR. BROOKMAN: Andrew DeLaski?
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1 MR. DeLASKI: I'd push back a little bit

2 is that this criteria of the lumen maintenance --

3 MS. PIERCE: Uh-huh.

4 MR. DeLASKI: -- it seems to me that you

5 understand that what you can make in one lamp you

6 can make with a different package. So if you can

7 make it at that -- you should be able to scale from

8 one to the other to get the lumen to maintain lumen

9 output. It strikes me that that criteria as a

10 criteria to eliminate. That lamp could not produce

11 the lumen package if I adjusted it. It seemed to be

12 a pretty strong criteria.

13 MS. PIERCE: Well that also goes along

14 with the commercially available criteria. So we

15 wouldn't have done scaling from one lumen package to

16 another if that second lumen package wasn't

17 commercially available.

18 MR. RIVEST: This is Mike Rivest. I think

19 we will look at what was done exactly. I think the

20 concept of scaling to different lumen packages if we

21 can demonstrate that is a valid way of doing it

22 within the accuracy needed to set the standard I
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1 think we need to look at that. But when you start

2 moving too many variables like bulb shape and lumens

3 we can stray off course quickly --

4 MR. BROOKMAN: Garry Fernstrom?

5 MR. RIVEST: -- and throw in a prototype.

6 MR. FERNSTROM: So this is Garry. Let's

7 just leave it at this for this meeting. We don't

8 think that DOE considered max tech adequately. And

9 we believe that we provided alternatives that should

10 have been evaluated that we summarily dismissed.

11 MR. BROOKMAN: Okay. Thank you.

12 Final comments on issue 9? IRL lifetimes,

13 did anybody address IRL lifetimes yet? Don't think

14 so. Thanks Joe.

15 MR. DeLASKI: Andrew DeLaski. The point

16 that I think Joe that you made was that you were

17 suggesting that consumers -- a separate treatment

18 for consumer product and a commercial product line.

19 And I think one thing that we have to keep in mind

20 in this market is that there are substitutes outside

21 of the covered products. And I would submit I think

22 that most consumer reflectors being sold today are
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1 not subject to the standard they are buying --

2 MR. BROOKMAN: Andrew, you have got to get

3 that mike in front of your face.

4 MR. DeLASKI: So and then also the growing

5 LED market. So consumer's options are and for both

6 the residential and the commercial market extend

7 beyond the products covered by the regulation and

8 that any analysis you need to consider what consumer

9 choices are making amongst these product options out

10 there that are both regulated and unregulated by

11 this particular docket.

12 MR. BROOKMAN: Joe?

13 MR. HOWLEY: So my response to that is

14 that the consumers do purchase quite a number of

15 products in this regulated category. In general the

16 PAR38s for outdoor use because the BR30 lamps are

17 not acceptable in outdoor harsh weather environments

18 and there are a lot of products sold, driveways,

19 garages, other places. A 90 watt PAR38 is a very

20 popular choice for that type of application in the

21 consumer segment. And the PAR30s are a substitute -

22 - PAR30s and PAR20s are used by consumers who want a
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1 little more dramatic lighting effect than a BR30

2 because it has a tighter beam, has a wider beam.

3 And that is also fairly popular in the consumer

4 segment for indoor that competes with the BR30 in

5 that case. So there is quite a bit of use. On the

6 other hand there is also quite a bit of use in the

7 retail sector. But there is a significant volume of

8 products sold into both sectors. But they operate

9 very differently and that is why I am suggesting we

10 really and I don't think it is done now. Everything

11 is lumped together right now in the proposed

12 standards. I think there needs to be a different

13 kind of analysis done for these two different market

14 segments because you will reach different

15 conclusions based on their operation. And NEMA will

16 provide more comments about perhaps some ideas in

17 this area.

18 MR. RIVEST: Mike Rivest. Joe, you are

19 not suggesting that these can be differentiated for

20 the purposes of having two standards. You are just

21 saying that you would like to have an analysis that

22 shows the economics for the two sectors?
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1 MR. HOWLEY: Well I believe they also

2 could be differentiated not by use certainly but by

3 knowing where they are used and what the common

4 wattages are. There are some ways you could

5 differentiate them. Certainly PAR30s could be

6 treated as a residential type of product versus

7 PAR38s. And you might also be able to do some other

8 types of differentiation, technical differentiation.

9 I understand it would be very difficult to

10 differentiate it by you can only sell this product

11 in the residential sector and you can only sell that

12 product in the commercial sector. But knowing how

13 the markets behave and knowing what products are

14 used in what market you can create different

15 technical classifications for products commonly used

16 residentially and commonly used commercially. And

17 we will propose some ideas in that area. I think

18 that become more critical as we again reach these

19 max tech levels because it has the unintended

20 consequences of wiping out products in and utility

21 in some of these application sectors.

22 MR. BROOKMAN: Garry Fernstrom?
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1 MR. FERNSTROM: The question was raised

2 earlier about what some of the better performing

3 lamps might be and I'd just like to mention a few of

4 them here for the record: the GE 60PAR HIR Plus

5 operating at 21 lumens per watt, the Philips PAR38

6 Energy Halogen DiOptic operating at 20 lumens per

7 watt, the OSRAM Sylvania PAR38 medium base warm

8 white outdoor halogen flood operating at 20 lumens

9 per watt, and the OSRAM Sylvania PAR38 warm white

10 outdoor halogen flood operating at 21 lumens per

11 watt. So just to be specific here are some

12 references.

13 MR. BROOKMAN: Thank you. That is

14 helpful.

15 Yes, Aisha?

16 MS. HUSAIN: Hi, this is Aisha. I just

17 wanted to note that we did look very closely at all

18 those specific lamps that were stated in the

19 comment. And we can provide more detailed responses

20 for each lamp as to why they weren't considered.

21 But I just wanted to assure everyone that we did

22 look at all the comments that CIOUs provided
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1 including every specific lamp. And as it was noted

2 some of them were MR16s and 12 volts which cannot be

3 considered under this rulemaking. And as for the

4 prototype lamps you will see in Appendix 5C that we

5 did testing on the prototype lamps and there are

6 requests for more information in order to proceed

7 further in that realm. So if you could provide

8 comments regarding that Appendix that would be

9 helpful as well.

10 MR. FERNSTROM: Thank you.

11 MR. BROOKMAN: Yes, thank you.

12 Okay.

13 MS. PIERCE: After identifying more

14 efficacious substitutes for each of the baseline

15 lamps DOE developed ELs based on the consideration

16 of several factors including the design options

17 associated with the specific lamps being studied for

18 example the use of infrared coatings for IRLs, the

19 ability of lamps across wattages to comply with the

20 standard level of a given product class and the max

21 tech level. DOE used an equation that is a function

22 of wattage to determine the EL. To determine the
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1 coefficient of the EL equation DOE reviewed catalog

2 data of commercially available lamps and their

3 associated catalog rated efficacies. To establish

4 final minimum efficacy requirements for ELs DOE

5 analyzed publicly available compliance data and

6 adjusted the ELs when necessary. As shown in this

7 table EL1 is 6.2 times the wattage to the .27 power.

8 DOE requests comment on the max tech

9 levels identified in this analysis and information

10 on high efficacy IRLS including prototype lamps in

11 Appendix 5A of the TSD.

12 DOE developed a potential EL2 based on

13 tested prototype lamps. DOE is seeking information

14 on the cost to manufacture lamps that comply with

15 the

16 EL2.

17 Additionally DOE is seeking information on

18 whether the equipment required to apply IR coatings

19 to lamps at EL1 can also be used for lamps at that

20 EL2.

21 DOE is also seeking information on whether

22 any other additional equipment is required and
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1 product conversion costs.

2 MR. BROOKMAN: Joe Howley?

3 MR. HOWLEY: So the level being proposed

4 is quite high and leaves only a few products left on

5 the market that would be available today that are

6 mainly commercial type products, not consumer

7 products. It doesn't leave any what we would

8 consider consumer products left on the market. And

9 it also we believe would not allow us to make a

10 PAR30 lamp due to some limitations with that

11 technology that don't exist with the PAR38. So it

12 would also eliminate the utility of the halogen

13 PAR30s which as we mentioned before are often used

14 as a substitute for a BR30 and is much more

15 efficient than a BR30. So we don't believe it would

16 be good policy to eliminate the halogen PAR30s from

17 the marketplace because it would actually increase

18 energy efficiency because the most logical product

19 that people would go back to would be a 65 watt

20 BR30. And we believe there are some different

21 approaches here perhaps to produce more intelligent

22 and preferable outcomes for the consumer and for
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1 producing energy savings. As proposed now at this

2 level we don't believe it produces the right outcome

3 with regard to the products that would be available

4 for consumers.

5 MS. PIERCE: Could you expand on the

6 limitations of the PAR30?

7 MR. HOWLEY: Well it centers around the

8 fact the PAR38s are hermetically sealed and the

9 PAR30s use a different type technology which limits

10 some of the efficiency technologies that we can use

11 in that. We can provide more comments in our

12 written comments about that.

13 MR. BROOKMAN: Thank you. That would be

14 helpful.

15 Additional comments before we move on?

16 MS. PIERCE: Once DOE determined ELs for

17 the representative product classes it scaled the

18 results to non-representative product classes. For

19 IRLs DOE used a 15% decrease from standard spectrum

20 to modified spectrum, a 15.5% decrease from large

21 diameter to small diameter, and a 15% increase for

22 120 volt to 130 volt lamps.
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1 DOE requests comment on any technological

2 barriers in manufacturing more efficacious small

3 diameter modified spectrum or 130 volt rated lamps

4 for commercial production.

5 MR. BROOKMAN: Mark Duffy?

6 MR. DUFFY: This has actually been covered

7 before but I found a very simple way to explain it

8 to you. Max tech for a 120 volt and max tech for a

9 130 volt are almost identical, not much different.

10 So the scaling factor of 15% increase for 130 volt

11 lamps has in fact eliminated them as a viable

12 product from the market place and their utility.

13 MR. BROOKMAN: Additional comments.

14 Keith?

15 MR. COOK: But it is academic. I mean it

16 doesn't matter. We can go ahead and put whatever

17 you want on it because it is out of the market.

18 MR. BROOKMAN: Okay. Thank you.

19 MS. PIERCE: Thank you. DOE requests

20 comment on its assumption that there will be no

21 lessening of utility or performance such that the

22 performance characteristics would be adversely
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1 affected for the IRL efficacy levels.

2 DOE also requests comment on whether there

3 are features or attributes of the more energy

4 efficient IRLs that might affect how they would be

5 used by consumers.

6 MR. BROOKMAN: Michael McGaraghan has a

7 comment. Michael please speak.

8 MR. McGARAGHAN: Great. Thank you. I had

9 a comment on the scaling factor for small diameter

10 lamps but I think it is back a slide. DOE explained

11 that through manufacturer interviews they found that

12 fitting a double ended burner into a small diameter

13 lamp required changes to the physical shape of the

14 lamp. And they went on to say here that the

15 modified lamp might still meet ANSI standards for

16 small diameter lamps but would be larger than any

17 PAR20 lamp sold in the past and currently installed.

18 I have I guess I would like some additional detail

19 on that statement. What is the length of all PAR20

20 lamps sold in the past? Did DOE go out and buy a

21 bunch and measure them and, if so, is that in the

22 NOPR somewhere?
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1 MS. PIERCE: No it is not in the NOPR.

2 Can the manufacturers respond to that?

3 MR. BROOKMAN: The length of the lamps.

4 MR. HOWLEY: Only to confirm what was in

5 the NOPR that most PAR20s are designed with a single

6 ended halogen burner in the past in a compact size

7 and to squeeze a double ended halogen burner into

8 that envelope, the envelope had to be increased in

9 size. And therefore again as correctly analyzed in

10 the NOPR there are some fixtures and applications

11 where that -- where a newer PAR20 which is longer

12 than the old PAR20 simply wouldn't fit. Obviously

13 some it doesn't matter on a track fixture. But

14 other fixtures there would be problems with fit. So

15 you couldn't say that that new design would fit into

16 all existing fixtures. It will fit in some. It

17 will not fit in others.

18 MS. PIERCE: Thank you.

19 MR. McGARAGHAN: Yes, thank you Joe. It

20 is good to hear from you. It is a little

21 disconcerting that DOE doesn't have that information

22 themselves or haven't looked into that question,
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1 doing a little bit of research I found a range of

2 available lengths for R20 lamps from 3.1 inches to

3 4.2 inches. The lamps that we submitted was three

4 and a half inches. So it is right in the mix of

5 what is commonly sold as R20 lamps. It may be about

6 five millimeters longer than some other R20 lamps

7 and in that case I am wondering if DOE has

8 researched the fixture availability on the market

9 and identified which fixture that it -- or housing

10 that we are talking about where there is not five

11 millimeters of space and if that is a large portion

12 of the market or a rare housing or if it exists. I

13 would encourage DOE to look at that issue pretty

14 closely on its own and publish some of that

15 information if you are basing your findings on the

16 assumption that double ended burners make lamps too

17 long to fit in housings then we should have some

18 more specific information written up by DOE about

19 that situation. Thanks.

20 MR. BROOKMAN: Okay. Thank you.

21 Eric Montgomery has a comment. Thank

22 you. Eric unmute your phone, give it a try.
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1 MR. MONTGOMERY: Can you hear me now.

2 MR. BROOKMAN: Speak up.

3 MR. MONTGOMERY: Speak up?

4 MR. BROOKMAN: Yes.

5 MR. MONTGOMERY: You know the comment on

6 small lamps it is not just an issue of fitting a

7 double ended burner into smaller packages. It is

8 also issues associated to burners also have

9 temperature limits that the smaller reflector size

10 don't allow them to operate. In actuality when in

11 this rulemaking where we are using a standard of a

12 PAR30 there are some technologies that when you

13 apply it to a PAR30 it cannot be applied to a PAR20

14 and that is not just in the double ended burner but

15 it is also in other technologies.

16 MS. PIERCE: Could you expand on those

17 technologies?

18 MR. MONTGOMERY: for example it was

19 mentioned earlier PAR38s are hermetically sealed in

20 most cases. So some of the reflector coating

21 technology that can be used there can't be used in

22 non-hermetically sealed lamps in some cases.
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1 MR. McGARAGHAN: So am I still unmuted?

2 MR. BROOKMAN: Yes, you are.

3 MR. McGARAGHAN: I just wanted to respond

4 and clarify my comment. I fully acknowledge that

5 R20s or PAR20s the smaller diameter lamp are less

6 efficient by nature than the larger diameter lamp.

7 And DOE has assessed a scaling factor which we think

8 is appropriate, the starting scaling factor was I

9 think around 9%. But then DOE added an additional

10 three and a half percent just for the double ended

11 burner part. So my whole comment was about that

12 additional three and a half percent.

13 MR. BROOKMAN: Okay. Thank you, Michael.

14 Keith -- oh, Eric is not done yet. Eric

15 keep going?

16 MR. MONTGOMERY: As far as the last

17 question about polling different fixture

18 manufacturers and you know additional five

19 millimeters being used this has been looked at for

20 many, many years. And all the fixture manufactures,

21 they don't use ANSI for what will fit. They take

22 the actual length that is on the market and design a
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1 fixture around it. And if you change the shape of

2 that lamp it will not fit in many, many fixtures.

3 MR. BROOKMAN: Okay. Garry Fernstrom?

4 MR. FERNSTROM: Garry for the California

5 IOUs. Well again we would simply like to see the

6 data in DOE's analysis to substantiate that. I

7 don't think that is asking for too much.

8 MR. BROOKMAN: Now Keith.

9 MR. K. COOK: I just want to make a

10 clarification. An R20 and a PAR20 are not the same

11 thing.

12 MR. BROOKMAN: Thank you. Are we ready to

13 move on?

14 MS. PIERCE: I think so.

15 DOE requests comments on the overall

16 methodology, assumption and results of the GSFL and

17 IRL engineering analyses.

18 MR. BROOKMAN: No comments.

19 MS. PIERCE: Okay. I will move on to the

20 Product Price Determination then. DOE estimated end

21 user lamp prices directly rather than developing

22 manufacturer selling prices because GSFLs and IRLs
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1 are difficult to break down to discrete components

2 and reverse engineer. In its research DOE found a

3 range of end user prices that were dependent on the

4 distribution channel used. To represent this range

5 DOE developed three discounts using lamp bluebook

6 prices. The low end user lamp prices are based on

7 purchases through state procurement channels, the

8 medium prices are representative of purchases

9 through large distributors or DIY stores and high

10 prices are based on internet retailers. In the NOPR

11 analysis DOE used a weighted average end user price

12 in the LCC and NIA. Based on shipment estimates

13 through each channel DOE applied 85% to the large

14 distributor price, 10% to the state procurement

15 price and 5% to the internet retail price. DOE also

16 estimated end user prices for fluorescent lamp

17 ballast using the pricing information developed in

18 the 2011 ballast rule.

19 DOE requests feedback on the pricing

20 methodology used in this analysis.

21 MR. BROOKMAN: Comments here? Joe?

22 MR. HOWLEY: It seems like a reasonable
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1 approach.

2 MR. BROOKMAN: Thank you. That is

3 helpful. Garry Fernstrom?

4 MR. FERNSTROM: Garry for the California

5 IOUs. It seems like a reasonable approach for

6 linear fluorescent lamps for sure. But IRLs are

7 found in homes and small businesses and I think

8 would predominantly be purchased through retail

9 channels rather than distributors or state

10 procurement arrangements. So I think your approach

11 is appropriate for GSFLs but not necessarily for

12 IRLs.

13 MR. BROOKMAN: Charlie Stevens?

14 MR. STEVENS: Yeah. Charlie Stevens. I

15 think that would go along with Joe's suggestion that

16 separate analyses be done for commercial and

17 residential sectors I think or residential and small

18 commercial, the mom and pop kind of stores and

19 people who buy like a residential homeowner. So I

20 think that is not a bad idea, that kind of

21 segregation of the analysis. And then I would

22 support Garry's comment that if you do that you are
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1 going to have to develop different percentages for

2 those two sectors.

3 MR. BROOKMAN: Okay. Thank you.

4 MS. PIERCE: Now we will discuss the Trial

5 Standard Levels or TSLs. In the next two slides DOE

6 will describe the TSLs proposed in this rulemaking.

7 DOE analyzed the benefits and burdens of the TSLs

8 which will be discussed in more detail later in the

9 presentation. DOE selected TSLs which designate an

10 EL for each product class. For GSFLs TSL1

11 corresponds to setting energy conservation standards

12 at the efficacy levels of the least efficient

13 products currently on the market for each product

14 class. TSL2 would set energy conservation standards

15 for GSFLs that would bring all product classes to

16 approximately the same level of rare earth phosphor.

17 TSL3 represents the maximum NES and NPV that can be

18 achieved without requiring EL2 for any product

19 class. TSL4 represents the maximum NPV that was

20 achievable in the analysis from any combination of

21 ELs. TSL5 which is the TSL that DOE is proposing

22 represents the max tech EL for all GSFL product
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1 classes. TSL5 also represents the maximum NES that

2 was achievable in the analysis.

3 For IRLs TSL1 which is the TSL that DOE is

4 proposing represents the max tech EL for all product

5 classes.

6 These tables present the TSLs and the

7 corresponding ELs for each representative product

8 class.

9 Now we will discuss the energy use and

10 life cycle cost or LCC analyses. The purpose of the

11 energy use characterization is to estimate the

12 energy consumption of baseline and higher efficacy

13 lamps. The results of this analysis are used in the

14 LCC, payback period, and NIA analyses. Energy use

15 is calculated as input power times operating hours.

16 Various DOE sources were used to derive the

17 operating hours including the lighting market

18 characterization and EIA's CBECS, RECS and MECS data

19 sets. Using these sources allows DOE to account for

20 variation in annual operating hours across census

21 divisions and large states by building type, lamp

22 type and lighting application.
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1 This table shows average annual operating

2 hours for GSFLs and IRLs in each sector. IRLs were

3 not analyzed in the industrial sector since they

4 have such a small market share in that sector.

5 DOE assessed impacts on life cycle costs

6 and payback periods in sensitivity scenarios where

7 GSFLs and IRLs are operated on dimming systems. To

8 develop annual energy consumption for these dimming

9 systems DOE used the system input power ratings as a

10 result of dimming and the annual operating hours.

11 DOE made certain assumptions to determine the system

12 input power ratings. For GSFLs DOE assumed a 33%

13 lamp and ballast lumen reduction on average. The

14 associated system input power reduction was

15 calculated based on characteristics of the dimming

16 ballast analyzed. DOE assumes that dimming does not

17 change lamp lifetime for GSFLs.

18 For IRLs DOE assumed a 20% wattage

19 reduction on average which corresponds to a 25%

20 reduction in lumens and a lifetime multiplier of

21 3.94. For IRLs in addition to calculating LCC

22 savings for individually dimmed lamps, DOE also
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1 assessed an LCC scenario in which a certain

2 percentage of the population used dimmers; 29% for

3 the residential sector and 5% for the commercial

4 sector. Lighting controls are also analyzed as part

5 of the NIA.

6 Now I will discuss the LCC and payback

7 period analysis. This analysis is used to assess

8 the impacts on a consumer due to potential energy

9 conservation standards. It is conducted from a

10 consumer's perspective and shows the cost of owning

11 and operating the lamp over its lifetime. As

12 indicated in the diagram the LCC considers two

13 components; one is first cost which is the product

14 price and installation cost, the other is the

15 operating cost of the lamp which is discounted to

16 the present value. When the standard level lamp

17 lifetime is different from the baseline lamp

18 lifetime DOE also calculates a residual value for

19 the remaining useful life of the lamp at the end of

20 the analysis period and subtracts this from the

21 total LCC value. From this DOE calculates the total

22 LCC for each standard level considered. Results are
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1 expressed as LCC savings which are the baseline LCC

2 value minus the standard level LCC value. The

3 simple payback period is also calculated and

4 reported.

5 Now I will discuss some of the key inputs

6 to the LCC model such as electricity prices,

7 installation costs, ballast lifetimes and discount

8 rates. DOE calculated average electricity prices

9 using EIA 861 data. DOE then applied electricity

10 price trends from AEO to project future electricity

11 prices. DOE used the 2011 ballast rule, RS Means

12 and the US Bureau of Labor Statistics to calculate

13 installation costs. DOE calculated ballast

14 lifetimes in hours which translated to approximately

15 12 years for the commercial sector, 11 years in the

16 industrial sector and 15 in the residential sector.

17 DOE used a discount rate to calculate the present

18 value of expenses over the analysis period. For the

19 commercial sector DOE calculated a discount rate of

20 5.1%, for the industrial section 6.3% and for

21 residential 5.2%.

22 In the preliminary analysis DOE determined
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1 the probability of a particular building in each

2 census division and large state using the lighting

3 market characterization and EIA's CBECS, MECS and

4 RECS data. In the NOPR analysis DOE used the same

5 data sources but made the calculation more specific

6 by determining the probability of a GSFL or IRL in

7 each building type instead of just using the

8 probability of the building type. These

9 probabilities were used to determine national

10 weighted averages for electricity prices, sales tax

11 and operating hours.

12 DOE requests comments on using this

13 methodology for electricity prices.

14 MR. BROOKMAN: Keith?

15 MR. K. COOK: I am not really commenting

16 on electricity price but on slide 60 you state that

17 dimming is only used 5% in commercial sector. I

18 think that over this analysis period of 30 years

19 that is way, way understated considering the fact

20 that California is now requiring dimming for all of

21 their renovations and new buildings as well as

22 ASHRAE is significantly driving it across the
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1 country. So that is way understated.

2 MS. PIERCE: Thank you. The NIA analysis,

3 the lighting control analysis in that accounts for

4 that. But thank you.

5 MR. BROOKMAN: Let me see. Garry

6 Fernstrom?

7 MR. FERNSTROM: Garry for the California

8 IOUs. I am not sure I understood your answer. What

9 analysis would account for greater use of dimming?

10 MS. PIERCE: The National Impact Analysis

11 which will be discussed by Brian Gerke after this

12 analysis.

13 MR. FERNSTROM: Thank you.

14 MS. PIERCE: Uh-huh.

15 MR. BROOKMAN: Charlie?

16 MR. STEVENS: Charlie Stevens. Like some

17 other people, Keith, I agree with Keith that 5%

18 dimming for the commercial sector way undershoots

19 where it should be for the forward analysis. The

20 29% for the residential sector is probably way too

21 high. I just sent John Cymbalsky a couple of days

22 ago for distribution the report from our 13 month
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1 residential metering study which metered all of our

2 lighting fixtures in 103 houses. There were 2200

3 sensors altogether but by fixture type, by

4 technology, by room. We also have a census across

5 1400 houses that surveyed all those fixtures so we

6 could apply those metered results across the entire

7 region so you can probably do the same thing. That

8 data itself will be available for download probably

9 within the month to anybody who wants it. So I am

10 hoping you will be able to update an awful lot of

11 your residential lighting data. I am not sure if

12 our commercial building stock assessment data will

13 be available to you in a timely fashion but if it is

14 I will make sure it gets to you. We are also going

15 to be providing some other data but we will talk

16 about that when we talk about shipments.

17 MR. BROOKMAN: Thank you Charlie.

18 MS. PIERCE: Thank you. Would you provide

19 that with your written comments, the link to that

20 please?

21 MR. STEVENS: Sure.

22 MS. PIERCE: Thank you.
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1 MR. BROOKMAN: Lucy do you have --

2 MS. deBUTTS: No I just wanted to say --

3 this is Lucy deButts, I just wanted to say that I

4 will check with John on that data that you provided.

5 MR. BROOKMAN: Okay. Dave. Charlie was

6 saying he provided him a report.

7 MR. STEVENS: Yeah I sent him the report

8 wherein you can see some summary data in that report

9 that might be useful immediately but within the

10 month the database itself will be available on our

11 website on NEMA's website for download for anybody

12 who wants it.

13 MS. DeBUTTS: Okay. Thank you.

14 MR. STEVENS: Yeah the survey data is

15 already available. You can download the 1400 house

16 survey data now. It is on our website for download.

17 So all you need now is the metering data to apply to

18 that.

19 MR. BROOKMAN: Charlie I think Dave wants

20 you to stay there.

21 Find a way to get that microphone Dave.

22 MR. GATTO: Hey, Charlie, I am sorry.
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1 Just a question because I am not suggesting, I don't

2 know that I agree 29% for residential is correct.

3 At the same time is -- I believe your analysis is at

4 the fixture so I think maybe the question I would

5 have for Navigant is are you -- if that 29% was just

6 on IRL in residential that number might be closer to

7 real than if you were considering fluorescent which

8 I don't believe homeowners dim at all.

9 MR. GATTO: Or the whole home which might

10 have a lot of simple on off switches. So Charlie is

11 that something you can comment on here.

12 MR. STEVENS: Well our data will include

13 and does include controls. So there -- when you

14 look at the data you'll see data that shows the

15 technology in the socket and we use the term socket

16 loosely for fluorescent and other but the technology

17 in the socket, the wattage of the lamp, the controls

18 on that socket, and number of lamps per fixture,

19 type of fixture and the room in which it is located.

20 So all of that data is in there so you can analyze

21 it however you like. But there is enough data there

22 we think to characterize the lighting in four states
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1 for residential.

2 MR. K. COOK: Charlie does it also include

3 the number of lamps on a single switch?

4 MR. STEVENS: Yes it does.

5 MR. BROOKMAN: Thank you Keith.

6 MR. STEVENS: The wattage on a single

7 switch.

8 MR. GATTO: So I would just end with and

9 this is really, thank you Charlie, that is kind of

10 what I thought. I've looked at the data but I am

11 not as close to it but I would just suggest that

12 Navigant review these percentages and then I would

13 look at the -- this might be another one of those

14 examples where lumping IRL and GSFL together is not

15 appropriate because I think in commercial it

16 probably skews the other way, heavier dimming on the

17 GSFL side with a lot more of the IRLs being in re18 complications that are simply on an on/off circuit;

19 and in residential I think it is going to be IRL are

20 dimmed quite a bit and GSFLs as close to zero as

21 statistically possible to get to.

22 MR. BROOKMAN: Okay. Thank you.
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1 Appreciate that Dave.

2 Additional comments here.

3 MS. PIERCE: DOE uses several lamp

4 purchasing events in the LCC model the first of

5 event is lamps failure in which a lamp fails and

6 must be replaced. The second event ballast failure

7 is only for GSFLs and includes situations where the

8 failure of the installed ballast requires a new lamp

9 and ballast purchase. The third event is new

10 construction and renovation where new fixture

11 installations occur and are not restrained to the

12 previous configuration. DOE requests comments on

13 these lamp purchasing events.

14 MR. BROOKMAN: Keith, do you want to -- go

15 ahead Mark?

16 MR. DUFFY: This is Mark Duffy of GE

17 Lighting. My question is did you consider group

18 relamping in this?

19 MS. PIERCE: Yes we did. I actually have

20 a request for comment on that. So we did. We

21 calculated the percentage of time at which group

22 relamping occurs and we used that to weight the
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1 lifetime. So the request for comment is the

2 assumption at the rated life at which group

3 relamping occurs which we assumed was 85%.

4 MR. BROOKMAN: Dave.

5 MR. GATTO: Dave Gatto, Westinghouse. I

6 think I am going to repeat my residential versus

7 commercial statement again. I think in residential

8 when they can't see or when the bulb actually burnt

9 out is more likely going to be the -- what they

10 consider the end of life. Whereas in commercial it

11 is a much higher percentage, 85% seems reasonable.

12 MR. BROOKMAN: Okay.

13 MS. PIERCE: Thank you.

14 MR. BROOKMAN: Keith?

15 MR. K. COOK: Keith Cook with Philips.

16 But with the aging population that can't see as

17 stated earlier.

18 MR. BROOKMAN: In my experience it is

19 getting pretty dim.

20 Yes, Susan?

21 MS. CALLAHAN: Susan Callahan, OSRAM

22 Sylvania. Does -- in the event of ballast failure
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1 in the new construction and renovation since we've

2 been talking about building codes does that include

3 the price of the required controls that are called

4 out by code, especially ASHRAE 90.1?

5 MS. PIERCE: No it does not. The lighting

6 controls are conducted as a sensitivity but

7 definitely we would welcome written comments on

8 which codes we should consider specifically.

9 MS. CALLAHAN: Thank you.

10 MR. BROOKMAN: Dave?

11 MR. GATTO: Dave Gatto, Westinghouse. On

12 an earlier slide, I don't remember which one you

13 included installation cost in the analysis. I would

14 just suggest that if you have to buy a control no

15 different than having to hire an electrician if it

16 is an appliance requires a qualified installation

17 that is actually part of the installation cost for a

18 typical end user product.

19 MR. DeLASKI: Just a follow on, Andrew

20 DeLaski. That is a cost of the code of the building

21 code, of the ASHRAE code; right. I am trying to

22 figure out how that relates to the standards
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1 analysis.

2 MR. BROOKMAN: Susan?

3 MS. CALLAHAN: If in order to replace the

4 ballast if I -- and I am doing it by rules, lamp and

5 ballast is not maintenance together, it can be

6 considered renovation depending upon on how many you

7 are doing. Or the renovation then putting in the

8 required controls is just part of this entire

9 package. I don't understand why that isn't part of

10 the total cost of doing that. I guess is my

11 question.

12 MR. BROOKMAN: Charlie Stevens?

13 MR. STEVENS: Excuse me, yeah, Charlie

14 Stevens. I think what Andrew is trying to get at is

15 that those costs would be applied to every EL.

16 MS. CALLAHAN: Okay.

17 MR. STEVENS: So it would wash out because

18 it is required by the code regardless of which EL

19 the standard picks, it is just going to be -- that

20 cost is going to be there always. And you can add

21 it in if you want but it won't really change the

22 outcome of anything.
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1 MR. BROOKMAN: Okay. Thanks Charlie.

2 Additional comments?

3 MS. PIERCE: Okay. DOE requests comments

4 on its LCC analysis period assumptions in particular

5 DOE requests comment on basing the analysis period

6 on the baseline lamp life divided by the annual

7 operating hours of that lamp for the IRL and the

8 commercial and industrial sector GSFL analyses.

9 DOE also requests comment on basing the

10 analysis period on the useful life of the baseline

11 lamp for a specific event for residential GSFLs in

12 particular DOE requests comment on its residential

13 GSFL analysis period of 15 years which is based on

14 the average useful lifetime of ballast in the

15 residential sector being approximately 15 years

16 regardless of operating hours.

17 MR. BROOKMAN: Joe?

18 MR. HOWLEY: Just a comment that it seems

19 like a reasonable approach.

20 MS. PIERCE: Okay.

21 MR. BROOKMAN: Thank you.

22 Other thoughts on these two comment boxes?
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1 Keith?

2 MR. COOK: Keith Cook with Philips. The

3 approach we don't have a problem with but some of

4 the analysis we do. And we will provide details in

5 written comments.

6 MR. BROOKMAN: Thank you.

7 MS. PIERCE: In the next few slides we

8 will go over the range of LCC results as well as the

9 weighted average LCC savings based on shipment at

10 the proposed TSL. For all GSFL product classes

11 there are negative LCC savings for replacements with

12 the same wattage and ballast factor as the baseline

13 since there are no energy savings for those

14 replacements. For all GSFL results the results are

15 the same for the ballast failure and new

16 construction and renovation events since we assume

17 no spacing adjustments in the latter event. This is

18 because the replacement systems were chosen such

19 that the lumen output was within 10% of the baseline

20 system when possible.

21 This table shows the range of results for

22 4- foot medium Bipin lamps across all sectors and
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1 replacement scenarios for EL2 which is the EL that

2 corresponds to the proposed TSL5 for this product

3 class.

4 Here are some of the key conclusions for

5 the 4-foot medium Bipin product class. For the

6 commercial and industrial sectors savings were

7 generally positive. For the residential sector

8 savings were generally negative. The weighted

9 average LCC savings based on shipments for the 4-

10 foot medium Bipin product class is positive.

11 This table shows the range of the results

12 for T5 high output lamps across all sectors and

13 replacement scenarios for EL1 which corresponds to

14 the proposed TSL5. Replacements with the same

15 wattage and ballast factor as the baseline had

16 negative LCC savings but all other replacements had

17 positive LCC savings. The weighted average LCC

18 savings based on shipments is positive.

19 This table shows the range of results for

20 T5 standard output lamps across all sectors and

21 replacement scenarios for EL2 which corresponds to

22 the proposed TSL5. LCC savings were generally
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1 positive. The weighted average LCC savings is also

2 positive.

3 This table shows the range of results for

4 8- foot slimline lamps across all sectors and

5 replacement scenarios for EL2 which corresponds to

6 the proposed TSL5. In the lamp replacement

7 scenarios LCC savings were generally negative. In

8 the lamp and ballast replacement scenarios LCC

9 savings were generally positive. The weighted

10 average value was positive.

11 MR. BROOKMAN: Michael McGaraghan has a

12 comment. Michael please speak up.

13 MR. McGARAGHAN: Hi. Thanks. I just had

14 a question about the residential 4-foot lamp

15 scenario. It looked like there were no LCC saving,

16 it is all negative. Did DOE assume that low wattage

17 lamps will never be sold into the residential

18 sector?

19 MS. PIERCE: You said low wattage lamps?

20 MR. BROOKMAN: Michael repeat --

21 MR. McGARAGHAN: Yeah.

22 MR. BROOKMAN: Low wattage, yes?
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1 MR. McGARAGHAN: Yes, I am trying to

2 understand why low wattage wouldn't be an option

3 that might save energy and result in LCC savings in

4 the residential sector?

5 MS. KIENLE: This is Maureen of Navigant.

6 We did consider low wattage lamps in the residential

7 sector so those were analyzed and included.

8 MS. PIERCE: Yes, the negative LCC savings

9 for the residential sector were largely due to that

10 constraint that I discussed earlier, the 15 year

11 analysis period based on the ballast lifetime

12 regardless of operating hours. So you are not

13 getting as many operating hours to accumulate energy

14 savings in that time period to make up for your

15 initial increased purchase price.

16 MR. McGARAGHAN: Okay. Thank you.

17 MS. PIERCE: Uh-huh.

18 Okay. This table shows the range of

19 results for 8-foot high output lamps across all

20 sectors and replacement scenarios for EL2 which

21 corresponds to the proposed TSL5. LCC savings were

22 negative in all cases. So the weighted average is
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1 also negative.

2 MR. GATTO: Dave Gatto, Westinghouse. So

3 I am not sure what to say other than how are we

4 explaining that to the American people? We are

5 proposing a rule where they will lose 16, 17% of

6 their value on average across the lifetime of the

7 product that we are going to have to make?

8 MR. BROOKMAN: Thank you Dave.

9 MS. PIERCE: This table shows the range of

10 results for IRLs across all sectors and replacement

11 scenarios for EL1 which corresponds to the proposed

12 TSL1. LCC savings were positive in all cases. So

13 the weighted average is also positive.

14 MR. BROOKMAN: Joe Howley?

15 MR. HOWLEY: Yes. Again on this one I

16 think the analysis was done mostly for commercial

17 customers for PAR38 lamps. And the residential

18 sector I believe would have a dramatically different

19 outcome also being negative and maybe this is a

20 question for DOE, it didn't get an answer from Dave

21 but how are we allowed to go forward when there is

22 clearly no economic benefits to anyone.
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1 Well there was a negative.

2 MR. RIVEST: On the previous one?

3 MR. GATTO: Yes on the previous one or on

4 this one if it is done for residential it would be

5 negative as well.

6 MR. RIVEST: I think it is a decision

7 making -- it is something that will be considered.

8 Your comments will be taken as we go.

9 MS. deBUTTS: Yes, this is Lucy. As Mike

10 stated we are presenting the analysis right now, we

11 are not making a decision at this particular moment

12 whether or not we are going to proceed but the

13 decision will have to be made, yes.

14 MR. BROOKMAN: So thank you Lucy and thank

15 you Mike.

16 Additional questions and comments here?

17 MR. RIVEST: I have just a question.

18 MR. BROOKMAN: Mike Rivest.

19 MR. RIVEST: Julie, does the TSD contain

20 sub-group analysis for residential and commercial

21 for any of these lamps?

22 MS. PIERCE: Yes. I am about to discuss
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1 that. Uh-huh.

2 DOE examined two sub-groups for the LCC

3 sub- group analysis. For low income consumers DOE

4 filtered EIA RECS data such that it only included

5 data for consumers below the poverty line. This

6 impacts the probability of a GSFL or IRL within each

7 building type and division or large state which are

8 used as inputs to the operating hours, electricity

9 prices and sales tax calculations. All LCC savings

10 that were positive in the main analysis remained

11 positive. And all savings that were negative in the

12 main analysis remain negative in the low income

13 consumer sub-group analysis.

14 For institutions that serve low income

15 populations DOE expects that the majority of the

16 organizations are small non-profit groups and

17 calculated a commercial discount rate of 9.6% for

18 these groups. The sign of the LCC savings remain

19 the same except for two cases which shifted from

20 positive to negative savings. The first was in the

21 T5 standard output product class and the second as

22 in the 8-foot slim line product class.
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1 MR. BROOKMAN: From positive to negative?

2 MS. PIERCE: Yes.

3 MR. BROOKMAN: Okay. Questions, comments

4 here on these sub-group analysis.

5 Joe?

6 MR. HOWLEY: I think our request wasn't

7 this tiny little sub-group but just the entire

8 residential market in general versus the entire

9 commercial market especially on IRL products is what

10 we were requesting, not this sub-sub-group analysis.

11 MS. PIERCE: We do have separate

12 residential and commercial results presented in the

13 TSD for IRLs and GSFLs.

14 MR. HOWLEY: All right. Thank you. We

15 will take a look at those and make our comments.

16 MS. PIERCE: Thank you.

17 MR. BROOKMAN: Additional comments here

18 because I think it is time to go to lunch. And this

19 is a good stopping point. It is now almost 12:30.

20 So let's resume here at 1:30. A reminder you must

21 have a badge visible in the building. If you are

22 going to go to the big cafeteria you need to pass
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1 through a security portal and you will need an ID to

2 get back in very likely. This room will be

3 supervised. You can leave your stuff here. And we

4 made a good start on the day. We will see you back

5 here at 1:30.

6 (WHEREUPON, a lunch break was

7 taken.)

8 MR. BROOKMAN: Welcome back. Let's

9 resume. We are going to pick up where we left off

10 which is on Shipments Analysis and National Impact

11 Analysis. We are going to hear from Brian.

12 DR. GERKE: Welcome back everybody. I am

13 Brian Gerke from Lawrence Berkeley National Lab. I

14 will be telling you about the shipments and national

15 impact analyses for this NOPR.

16 So the purpose of these two analyses taken

17 together is to estimate the impacts on the nation on

18 the consumer side that the different TSLs might

19 have. The Shipments Analysis estimates GSFL and IRL

20 shipments over the 30 year analysis period which in

21 this case runs from 2017 to 2046 and the National

22 Impact Analysis estimates the national energy
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1 savings from those shipments that would be achieved

2 from the shipments at various trial standard levels

3 and also estimates the net present value to

4 consumers of those savings at the various trial

5 standard levels less any increases in cost.

6 So I have to look down at my notes a

7 little more carefully here to make sure I go through

8 all the parts of this slide. The Shipments Analysis

9 is made up of three different modules, the lumen

10 demand module, the price learning module and the

11 consumer choice module which work together to

12 produce a forecast of the shipments of GSFLs and

13 IRLs.

14 The lumen demand module computes the

15 lighting demand in GSFL and IRL applications that

16 must be met by new shipments in each year of the

17 analysis period. It depends on the rate of

18 renovations and new construction and on the need for

19 replacement of failed lamps. Some fraction of that

20 demand and a growing fraction of that demand

21 throughout the analysis period is soon to be taken

22 over by LEDs nearly all of the market by the end of
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1 the analysis period. I'll discuss that assumption

2 in more detail a little bit later on. The remainder

3 of the demand is input to the consumer choice

4 module.

5 The price learning module estimates the

6 prices of lamps in each year of the analysis period

7 based on a learning curve analysis that I will

8 discuss in more detail later. The price learning

9 module feeds into the lamp cost, the first cost and

10 the O&M cost of various lamp options which are then

11 also fed into the consumer choice module.

12 The consumer choice module apportions the

13 demand among the various product classes and the

14 lamp types within those product classes according to

15 consumer sensitivity to first costs and O&M costs.

16 The model I want to point out at this stage allows

17 consumers to switch between product classes when

18 they are undertaking renovations or lighting

19 retrofits but if they are replacing failed lamps

20 they remain in the same product class that had

21 before.

22 The shipments in each year are then used
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1 as an input to the price learning module in the

2 following year to update the price estimate.

3 So to talk a little more about the

4 assumptions regarding the incursion of LEDs into the

5 market. LEDs are expected to erode the total lumen

6 demands satisfied by both GSFLs and IRLs over the

7 analysis period. The chart shows the total lumen

8 capacity in the installed stock for IRLs, GSFLs, for

9 LEDs used in IRL applications and for LEDs used in

10 GSFL applications. And as you can see by the end of

11 the analysis period nearly the entire market has

12 been taken up by LEDs. That sharply attenuates the

13 savings that can be achieved from a rule on GSFLs

14 late in the analysis period simply because there

15 aren't as many products.

16 To determine the demand for replacement

17 lamps in each year of the analysis period DOE

18 projected the stock of fluorescent lamp ballasts and

19 then determined the probability that they would

20 require relamping as a function of their age.

21 Example relamping probability curves are shown here.

22 When a ballast is new it is assumed that it is
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1 coupled with a new lamp. And then in future years

2 the probability that the ballast needs to be

3 relamped depends on the distribution of hours of use

4 and also on assumptions about group relamping which

5 as was mentioned previously is used to scale the

6 lifetime of the lamps.

7 The price learning module as I mentioned

8 before projects the prices of lamps in each year of

9 the analysis period. This uses a learning curve

10 analysis that is now standard in DOE rulemaking

11 analyses which assumes that the price of a product

12 will drop by a certain fraction each time the

13 cumulative shipments of that product double. In the

14 case of GSFLs and IRLs because LEDs are entering

15 into the market so strongly the growth in cumulative

16 shipments and because they are relatively mature

17 products the growth in cumulative shipments is

18 fairly modest over the analysis period so the drop

19 in price is quite low. Here I am showing the

20 historical price trend of GSFLs in red and in blue

21 the price learning model as a function of time that

22 was used in this analysis and between today and the
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1 end of the analysis period. The price in that model

2 drops only by about 7%. I want to point out that

3 this is shown as a function of time. But the

4 learning curve analysis as I mentioned earlier was

5 actually fitted and modeled as a function of

6 cumulative shipments.

7 A key component of this analysis is that

8 it allows for the possibility that consumers will

9 switch between product classes in response to

10 changing price signals. And in particular that

11 means that the market shares of different lamp types

12 can be different under the different standards

13 cases. The most striking such result has to do with

14 shifting from 4-foot medium Bipin lamps to T5 lamps.

15 As you can see here in the base case the market

16 share of T5s grows but it grows relatively modestly

17 and never really exceeds 10% of the total market

18 share for standard output lamps. In TSL5 when the 4-

19 foot medium Bipins become quite expensive the shift

20 to T5s is substantially stronger and they grow to

21 nearly 30% of the market by the end of the analysis

22 period. However that market, of course, is quite
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1 attenuated by that point. So this is the fraction

2 of GSFL in each of those product classes and that

3 has grown very small by that period.

4 So this summarizes the result of the

5 shipments analysis for each of the product classes

6 in the base case and at TSL5 which is the proposed

7 standard level. The increase in shipments of T5s in

8 the standards case is much more striking in this

9 plot although I note that the difference in scale

10 for the different plots here. You can see that each

11 product class declines in shipments over time

12 because of the incursion of LEDs into the market.

13 And furthermore shipments of IRLs drop in the

14 standards case because the products have a longer

15 lifetime in the standards case on average than they

16 do in the base case. So there are fewer shipments

17 needed to fulfill the lighting demand.

18 There are a number of different points for

19 comment in all of this. First DOE seeks comment on

20 the reasonableness of its assumption that first cost

21 is a significant driver of consumers choice of

22 product class in particular that it might cause a
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1 shift from 4-foot medium Bipin T8s to standard

2 output T5s in the TSL5 standards case.

3 MR. BROOKMAN: Keith?

4 MR. K. COOK: Keith Cook with Philips. We

5 don't believe that is going to happen. If you

6 actually look at the shipment information on T5s it

7 has been flat and all of our data shows it will

8 continue to be flat. We do not see in fact the T5s

9 have been available for 20 years in this country so

10 we do not see that change happening.

11 MR. BROOKMAN: Thank you. Mark.

12 MR. DUFFY: Yeah, I agree with Keith. And

13 I basically have a question for the analyst here.

14 What did you think was driving a switch from T8 to

15 T5 because as you know they are not retrofitable,

16 they are not the same lengths. And the other thing

17 you should be completely aware of is there is not

18 much difference in energy efficiency between T5s and

19 T8s in reality. Okay. You are measuring T5s at

20 high frequency. You are measuring T8s at low

21 frequency. There is a big difference. You are going

22 to operate your T8s and your T5s both at high
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1 frequency. So they are going to be roughly the same

2 energy efficiency. So there is no energy argument

3 and there is a huge renovation challenge with your

4 fixture. You have to just do the whole thing if you

5 make that change. So what was the thinking because

6 if the thinking is based on a simple cost free or

7 renovation free change, I don't see that happening.

8 DR. GERKE: So to answer that first

9 question the switching can only occur when consumers

10 are already undertaking a retrofit or renovation and

11 the assumption in that case was that the price

12 differences between those two were simply the lamp

13 and ballast choice.

14 MR. DUFFY: Why would they not go to LEDs?

15 DR. GERKE: A large fraction of people do.

16 So as I said this becomes an increasingly small

17 wedge. I am showing you that, the fractions of.

18 MR. BROOKMAN: Keith?

19 MR. K. COOK: What you need to understand

20 is T5s really get the majority of their efficiency

21 from an optical standpoint. With them being smaller

22 in diameter it is much easier for us to focus that
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1 light where we need it as oppose to the larger

2 diameter T8s. But of course that is not included in

3 this NOPR, the luminaire efficiency.

4 MR. BROOKMAN: Okay. Andrew DeLaski?

5 MR. DeLASKI: I reckon I understand this

6 analysis but I guess what I am struck by is what

7 gets counted and what doesn't when it comes time to

8 count the energy savings. So for example I think

9 what you show is there is a change in the national

10 energy consumption for T8s and T5s. What you are

11 seeing is T8 -- T5 consumption is a negative

12 savings; right? And you are showing increased

13 consumption in T5s over the analysis period because

14 there is so much more of them being sold.

15 DR. GERKE: Correct. If you look at the

16 national energy savings on a product class by

17 product class level you can get --

18 MR. DeLASKI: Right.

19 DR. GERKE: -- unusual results because of

20 the change --

21 MR. DeLASKI: As a result of what you've

22 modeled.
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1 DR. GERKE: Yeah.

2 MR. DeLASKI: And what really is happening

3 is that is moving -- that is just consumption moving

4 from the T8 line down to the T5.

5 DR. GERKE: Correct.

6 MR. DeLASKI: But some of that T8

7 consumption is moving to the LED market. And there

8 is no LED line in the analysis; right. And the same

9 thing with the IRL market which is that some of that

10 consumption is moving to the LED line but yet we are

11 not capturing that. We are not modeling -- you've

12 modeled the shipments but you've not translated that

13 to what does that mean for national energy

14 consumption.

15 DR. GERKE: Right. So the assumption in

16 this analysis simply because modeling the future of

17 LEDs is highly uncertain we used an earlier DOE

18 estimate of the market share of LEDs going forward

19 and assumed that fixed for this analysis, assumed

20 that the switching then beyond that occurred only

21 within the product classes being considered.

22 MR. DeLASKI: Okay. So your assumption is
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1 that the standards have no -- don't cause there to

2 be any change in the shift to LED?

3 DR. GERKE: That is what is in the current

4 analysis, yeah.

5 MR. BROOKMAN: Joe Howley?

6 MR. HOWLEY: I was going to make a comment

7 on T5 to T8 but to follow on to this conversation I

8 think that is right this rulemaking is not causing

9 the shift to LED, that is an externality that is

10 happening regardless of whether we pass this rule or

11 not. So that is probably the right way to look at

12 it. It is just the energy savings in this product

13 line from these products that are left versus what

14 products aren't left.

15 On the T8 T5 again to suggest that that is

16 probably overreaching another issue is design

17 consideration. The T5 lamp has a much higher

18 luminance which means it is very bright to look at.

19 And T8 lamps have lower luminance so you tend to

20 find T8s in lower ceiling heights such as an 8-foot

21 ceiling height. If we use a T5 in that kind of

22 ceiling height we usually only use it in indirect
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1 applications or in very high ceiling applications,

2 like high warehouses or perhaps high gymnasiums,

3 things like that. So the applications are quite a

4 bit different today from T5 to T8 which means there

5 really is no natural driver to drive T8 lamps to T5

6 lamps because it has more to do with the application

7 and use. It is not that they are viewed today as

8 directly interchangeable in the way they are being

9 used.

10 I guess the last comment I have is just

11 the decrease in T8s that you've modeled, decrease in

12 price seems counter intuitive for two reasons. One

13 is that we would have to add more rare earth

14 material to these lamps which is going to increase

15 their price and we expect there to be continuing

16 volatility on the rare earth market over time which

17 is hard to predict and you talk about that in your

18 rulemaking. You talk about how it is hard to

19 predict. But it could certainly spike again which

20 is going to increase prices. And the other thing as

21 the volumes go down, we are very much a volume

22 driven kind of production operation. There are base
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1 costs built into that production and if we have to

2 start running all of our production equipment at a

3 much lower volume there is still going to be all

4 that base cost there. And it is going to cause the

5 percent amount of base cost to each lamp to go

6 higher again driving the price higher. So I would

7 expect the price of these products actually to go up

8 over time, not to go down.

9 MR. BROOKMAN: Keith?

10 MR. K. COOK: On the issue 30 one of the

11 concerns we've also got is the fact that as stated

12 earlier we'll be losing utility. And the reason is

13 it is going to force the market by going to the

14 higher efficiency standards go to the energy saver

15 type lamps. Energy saver lamps do not have the same

16 dimability, they don't have the same lumen packages,

17 and they do not perform at cold temperatures. And

18 so you end up with the loss of utility as a result

19 of the higher standards.

20 MR. BROOKMAN: Thank you.

21 DR. GERKE: I will respond to that comment

22 in a later slide. I wanted to respond to Joe's
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1 question about rare earth briefly. The learning is

2 applied only to the portion of lamp cost that does

3 not include the rare earth. So we estimate the

4 fraction of the lamp cost that comes from rare

5 earth, subtract that out and apply the learning

6 analysis to the rest. And keep the rare earth -- do

7 a separate model for the rare earth price.

8 I want to ask a more pointed question

9 about issue 30. What we are assuming at the moment

10 is that T8s and T5s are interchangeable. I am

11 hearing that they are not. An estimate of the

12 fraction of applications in which they might be

13 interchangeable would be very helpful for improving

14 that analysis.

15 MR. GATTO: Dave Gatto, Westinghouse. It

16 would be small. I don't know that any of us could

17 come up with a number. A lot of it is design

18 driven. So to Joe's point it is very rarely a

19 decision that is made on lifetime cost savings or

20 energy savings. It is typically there is an

21 architectural element that someone is striving for

22 or they want indirect lighting because of the
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1 ceiling height and the amount of foot candles they

2 need per lead, those are all variables that we

3 wouldn't have any way to predict other than just

4 saying that it is a pretty small percentage. It is

5 much more likely that someone would shift if there

6 was no dimming requirement like you have now in

7 certain states and possibly others that they would

8 simply move from a 32 watt nominal wattage to a 28

9 or a 25 if they can afford the lumen loss.

10 MR. BROOKMAN: Michael McGaraghan has a

11 comment. Michael you have the floor?

12 MR. McGARAGHAN: Thank you Doug. I have a

13 similar question to the group I'm at. I am

14 wondering about this modeled shift from T8 to T5.

15 But I am curious to understand why DOE made that

16 assumption in the first place. It sounded like it

17 was related to pricing; so does DOE's analysis

18 assume that the T8 standards have much higher

19 incremental costs than the T5 standards? If so, I

20 haven't found that in the analysis that the LTC

21 table that I looked through make it look like they

22 generally have the same incremental cost. So if
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1 that is true you'd expect or you would not expect

2 that shift based on price.

3 DR. GERKE: I am going to probably defer

4 pretty quickly to Navigant who did the product price

5 determination and may remember the numbers more

6 clearly than I did but I believe the first cost of

7 T8s, the incremental increase in first cost of T8s

8 at the proposed standard level was higher than that

9 for T5s if I am not misremembering which is a large

10 part of what is driving that shift.

11 MR. BROOKMAN: Aisha?

12 MS. HUSAIN: I can check really quickly.

13 MR. BROOKMAN: Let us know.

14 MS. HUSAIN: Okay.

15 MR. BROOKMAN: Michael do you have other

16 issues?

17 MR. McGARAGHAN: No I would echo industry

18 sentiment that that dramatic of a shift seems

19 unlikely but I also look forward to hearing from DOE

20 about why they modeled that.

21 MR. BROOKMAN: Well we will insert that

22 once Aisha digs that out.
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1 Do we have additional comments on issue 35

2 product class switching?

3 DR. GARBESI: We are on. Okay. I just

4 wanted to comment also on the assumptions. Karina

5 Garbesi, at LBNL. Sorry. I wanted to comment on

6 the assumptions that we used and how we dealt with

7 the rare earth price issue. The industry had

8 suggested last time around that we talk to King. Was

9 that his name, Brian? Alex King. And we did do

10 that. And he suggested that Cobalt would give a

11 price series that could give us a long history on

12 something that would behave similarly to potentially

13 other critical materials. And so what we did is use

14 that as a type of model and just looking at the long

15 term price history and the variability over time.

16 And then we took as Brian will show a point relative

17 to the baseline to the peak excursion that we've

18 seen in this first very large spike for rare earths.

19 We basically took the highest point that all the

20 subsequent spikes went to in the Cobalt series in

21 fractional terms and said -- we did a sensitivity

22 analysis that said what if in steady state it was
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1 always at that highest level throughout. And so you

2 will see the results of that sensitivity analysis.

3 So I think we captured a very large possible long

4 term excursion there.

5 MR. HOWLEY: Okay. Thank you. I guess

6 the only other aspect of that is with the volumes

7 decreasing, projected to decrease that you have --

8 you are going to have increased efficiencies, you

9 notice that the price came down since the 50s or 60s

10 because your model goes way back almost to the

11 beginning of fluorescent in 1939. And of course

12 back then the volumes are much lower and you see how

13 high the prices were. And we are going to return

14 almost like a bathtub where the volume is much lower

15 and the prices are going to go back up to those

16 kinds of levels.

17 MR. K. COOK: Keith Cook from Philips.

18 Yeah we are already starting to see problems with

19 the availability of these high end phosphors. And

20 we are concerned that with this switch on General

21 Service Fluorescent to nothing but high end

22 phosphors we are going to have the same problem we
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1 had two years ago with availability. We are headed

2 down that path.

3 MR. BROOKMAN: Okay. Thanks Keith.

4 Yes, Aisha?

5 MS. HUSAIN: This is Aisha. So looking at

6 the end user prices between the 4-foot T8 and the 4-

7 foot T5 standard outputs at the baseline in EL1, the

8 prices are comparable but once you get to EL2 you

9 have a difference of one or two dollars where the

10 prices are a bit higher for the T8.

11 DR. GERKE: The other thing that goes into

12 that analysis that decision because it is a decision

13 being made during a retrofit it is assumed that

14 issues of lifetime also come in to the decision.

15 The final request for comment is whether

16 there are any other factors that may preclude or

17 limit the shifting that may not be considered in

18 DOE's analysis. I think we've got a lot of comments

19 on that. But if there are others we can continue.

20 So that finishes the National Impact

21 Analysis --that finishes the Shipments Analysis.

22 The National Impact Analysis estimates the energy
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1 savings and the consumer net present value that

2 would accrue over the 30 year analysis period for

3 each of the trial standard levels. The national

4 energy savings is the difference between the --

5 difference in primary energy consumption that would

6 occur in the base case versus the standards case

7 accounting both for the effect of rebound and for

8 the full fuel cycle so the cost of extracting and

9 transporting fossil fuels for example. The consumer

10 net present value is the present value of those

11 savings to consumers less the present value of the

12 total increase in installed costs that is projected

13 to occur if the standards take effect.

14 This is an overall summary of the results

15 of the National Impact Analysis and in addition the

16 monetization of emissions reduction that would

17 occur, that would be projected to occur under each

18 of the different TSLs. The emissions calculation

19 will be covered later on this afternoon by Karina.

20 The national energy savings of today's proposed

21 standard of TSL5 is estimated to be 3.5 quads of

22 energy over the analysis period, with a reduction of
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1 CO2 emissions by 170 million metric tons and a

2 reduction in NOx emissions by 210,000 tons. These

3 are the highest values achieved at any of the trial

4 standard levels. The NPV of today's proposed

5 standard is $3.1 billion at a 7% discount rate and

6 $8.1 billion at a 3% discount rate. Notably at TSL4

7 the consumer NPV is marginally higher but when one

8 includes the monetized value of avoided emissions

9 the maximum net social benefit occurs at TSL5.

10 MR. BROOKMAN: Yes, Andrew?

11 MR. DeLASKI: Briefly on that point I

12 guess I would suggest that TSL4 it is the same given

13 uncertainty in the analysis the percent difference

14 in the TSL4 NPV at 7% and TSL5 it is a tie.

15 MR. BROOKMAN: Thanks.

16 DR. GERKE: This chart shows the annual

17 energy savings, the energy savings achieved each

18 year. TSL5 as well as the cumulative net present

19 value. I show this just to show that most of the

20 energy savings occurs very early in the analysis

21 period simply because of the shrinking of the GSFL

22 market. The NPV starts out negative as consumers
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1 purchase more expensive equipment and then becomes

2 positive as they achieve energy savings over the

3 analysis period. So that is the results for GSFL.

4 For IRL this is the same table as before

5 for IRL which only has one trial standard level

6 which is the proposed standard. The national energy

7 savings is 13/1000 of a quad. The NPV at 7% is $.18

8 billion and the NPV at 3% is $.28 billion.

9 And this is the same charts as before for

10 IRL this is even more strongly weighted toward the

11 early part of the analysis period because of the

12 shift toward LEDs mainly. And a similar shape

13 occurs for the NPV.

14 DOE conducted a number of alternative

15 analyses to determine the impact of various

16 assumptions on the outcome of the analysis because a

17 large number of assumptions were needed to perform

18 this analysis. These alternative analyses probed

19 the impact of assumptions about future materials

20 prices such as rare earths and Xenon gas,

21 alternative technology shifts, and so on. I will

22 discuss some of these in the following slides and
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1 the remainder can be found in Chapters 11 and 12 of

2 the TSD.

3 So this is the chart that Karina was

4 discussing earlier having to do with the price of

5 rare earth oxides. So DOE is aware -- is well aware

6 that the recent volatility in the price of rare

7 earth elements has been a matter of concern for GSFL

8 manufacturing. DOE developed a price index for the

9 rare earths that are utilized in GSFL phosphors

10 which is shown here. We can see a large spike in

11 late 2010 to 2011 which has largely evaporated by

12 the present time. Since the price of rare earth

13 oxides historically has been rather stable DOE's

14 reference analysis is that the price of rare earths

15 remains constant at real dollars, constant in real

16 dollars at its October 2013 level. To model the

17 impact of continued price volatility DOE performed

18 an alternative analysis in which the average price

19 of these rare earth oxides was assumed to be at the

20 midpoint between the pre spike value and the post

21 spike value in an attempt to get at what might

22 happen if there were a repeat in price swings on a
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1 similar level.

2 MR. BROOKMAN: Anyone want to comment on

3 that now?

4 Keith?

5 MR. K. COOK: Well as I pointed out

6 earlier we are concerned that there is a step

7 function that is going to directly affect these

8 prices that have not been accounted for

9 traditionally. And that is when everybody converts

10 over to rare earth the consumption will exceed the

11 ability to supply and so as a result just

12 availability if not pricing alone that is going to

13 drive this. It is just getting material is going to

14 be the biggest problem. The same thing is also true

15 of the Xenon. You point out the Xenon pricing is

16 based upon some October 2013 pricing levels. But

17 last year we were not able to get Xenon period. We

18 could not use the amount of Xenon that we needed in

19 our manufacturing just because it is flat out not

20 available in the world supply. And so by forcing us

21 to these higher standards is going to shut off our

22 ability to supply a product.
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1 MR. BROOKMAN: Yes.

2 MR. GATTO: I just want to second Keith

3 particularly the Xenon issue.

4 MR. BROOKMAN: This is Dave speaking.

5 MR. GATTO: I am sorry. This is Dave

6 Gatto, Westinghouse Lighting. Alex where were you.

7 I need your help. He drifted off after lunch.

8 We saw in some earlier comments to the

9 framework document that Xenon had been included in

10 halogen lamps for a long period of time and there

11 was some questions about why this is relevant. I

12 think it is important to note that a few small

13 product types had Xenon in it in small amounts

14 particularly in the commercial market. The current

15 standard requires Xenon in all product types to meet

16 those needs. Those standards went into effect mid17 2012 with many manufacturers and distributors having

18 enough inventory to carry them into let's call it

19 early 2013 and in early 2013 and you guys can chime

20 in on the timing of this but in early 2013 we had

21 repeated outages of the availability of Xenon.

22 MR. GATTO: Which resulted in repeated
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1 outages of product being available to distributors,

2 to consumers, to end users midyear and I believe

3 that was as close to industry wide as I've ever seen

4 for a shortage because typically when one of us it

5 out of something the others pick up the slack. And

6 in this case there was no slack, so no ability to do

7 that. So I think it is important that Navigant or

8 DOE acknowledges and looks a little harder at the

9 Xenon supply because in the NOPR it sort of

10 dismisses that as being a concern. I know you

11 analyzed the potential for it but I think that if

12 you actually looked at what happened last year you'd

13 see that the risk is much higher than you are giving

14 it credit for in the analysis.

15 MR. BROOKMAN: Charlie Stevens and I know

16 you haven't finished presenting but Charlie Stevens.

17 MR. STEVENS: I'm Charlie Stevens, NEMA.

18 From a systems prospective though I am not

19 necessarily buying the argument that all of this

20 will have the ultimate effect that people say. If

21 the suppliers of these materials fail to supply or

22 start gouging on the prices it seems to me it is
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1 just going to have -- the biggest effect is to drive

2 people to solid state lighting and accelerate the

3 shift to solid state lighting where such impacts are

4 much lower, not non- existent, just lower. So this

5 is a big model that has a lot of moving parts

6 including market shifts toward solid state lighting.

7 And while it might be unfortunate if prices spiked

8 up on this stuff or shortages occurred I'd think

9 that would start to give the edge to solid state

10 lighting again which as I think most people agree it

11 already has some hedges in the marketplace and I

12 think if you start taking that into account it is

13 going to put downward prices on rare earth materials

14 and Xenon because you are dampening the demand for

15 the products that use it and giving an edge to the

16 alternative which is solid state lighting. This is

17 a feedback kind of market thing. It is a bigger

18 system than what you are focusing on I think.

19 MR. BROOKMAN: Keith?

20 MR. K. COOK: Charlie may be absolutely

21 right. But that needs to be comprehended in the

22 economic model because a conversion to the LED
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1 products of course is much higher today than what it

2 is for the existing IRL products. And so it again

3 will affect the payback analysis that is included

4 here. And therefore may make it even less

5 attractive to make these standards reality.

6 MR. BROOKMAN: I kind of jumped ahead of

7 you.

8 DR. GERKE: That is fine. We grouped our

9 comments on single slides but we can cover them as

10 they come up.

11 Just to finish up this slide the actual

12 impact on the final results of doing this

13 alternative analysis was relatively modest at the 5%

14 level.

15 Moving on to Xenon which we discussed a

16 bit. DOE did an analysis in which the price of Xenon

17 spiked up by a factor of ten. That factor of ten

18 was intended to be an estimate of a large increase

19 in price because we don't really have a good

20 historical precedent for that kind of spike. The

21 impact of that price increase on the IRL analysis

22 did decrease the national energy savings by about
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1 1/4 but the impact on the NPV was modest.

2 An additional alternative analysis that

3 DOE performed was an analysis in which it was

4 assumed that rather than eliminating the baseline

5 lamp from the market in the IRL case some

6 manufacturers would respond by shortening the

7 lifetime of the existing baseline lamps to meet the

8 new standards. In that case there is a significant

9 reduction in NPV and a modest reduction in NES

10 although in that case both of those measures remain

11 positive for the rulemaking.

12 So this is the official time to comment on

13 both the previous two if there is more.

14 MR. BROOKMAN: We may have covered it but

15 anything additional.

16 MR. McGARAGHAN: I have a comment. Can you

17 hear me?

18 MR. BROOKMAN: Yes, I can.

19 MR. McGARAGHAN: Great. Thanks. This is

20 Mike McGaraghan. I just wanted to ask about the

21 Xenon issue. I thought we heard from the

22 manufacturers this morning that minimally compliant
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1 IRLs were already using the Xenon as a fill gas and

2 they didn't consider Xenon as an efficiency option.

3 They've already used as much of it as can be used.

4 So if that is the case then why are we even

5 assessing the impact of a standard on -- or the

6 impact of Xenon prices here? It seems like the

7 standard levels don't actually change the amount of

8 Xenon needed to be used in lamps.

9 DR. GERKE: All right. This is just

10 looking at what the impact would be of the change in

11 price that would occur for the lamps if the Xenon

12 prices were ten times higher. It was a matter for

13 concern last time, so we pursued it again this time.

14 MR. McGARAGHAN: Okay. So it doesn't

15 impact the incremental cost at all?

16 DR. GERKE: No I don't believe so.

17 MR. BROOKMAN: Andrew DeLaski?

18 MR. McGARAGHAN: So you said that it cut

19 into national savings by a 1/4? I don't follow how

20 it does that?

21 MR. BROOKMAN: Okay. Now to Andrew

22 DeLaski.
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1 MR. DeLASKI: I'm just echoing Mike's

2 comment that the NPV can't go down if the

3 incremental cost didn't go up. So if they are

4 already maxed out on Xenon, they can't use more.

5 DR. GERKE: It is a complete redo of the

6 analysis so the base case is also different. And

7 consumers are responding to higher price lamps. And

8 so the shift toward in the base case more consumers

9 end up choosing the higher efficacy lamps when the

10 price of Xenon is higher. And so the amount of

11 savings that is available at the standard is lower.

12 MR. DeLASKI: Okay. I am not sure I am

13 following but I am not going to hold us up on that.

14 MR. BROOKMAN: Charlie?

15 MR. STEVENS: Charlie Stevens. Are you

16 saying it is a technology shift is that what is

17 driving the savings from the standard is a shift to

18 alternative technologies because of the higher

19 prices?

20 DR. GERKE: No it is simply that in the

21 alternative analysis when Xenon prices are higher we

22 assume that the Xenon prices are higher in the base
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1 case and each of the standard cases.

2 MR. STEVENS: Right.

3 DR. GERKE: So the prices that consumers

4 see relative to the operating costs are shifted and

5 that shifts the choices that they make in the base

6 case in addition to the standards cases. So you are

7 comparing to a different base case. Same baseline

8 lamps but at a higher price.

9 MR. DeLASKI: You sold fewer lamps in the

10 base case is the --

11 DR. GERKE: Yes, that is also true.

12 MR. STEVENS: So the savings are being

13 offset by higher prices for lamps generally?

14 DR. GERKE: Right.

15 MR. BROOKMAN: Okay.

16 Final comments here?

17 DR. GERKE: So DOE also made the

18 assumption in the primary analysis that current

19 building codes will cause an increasing fraction of

20 lighting capacity to be under automated control

21 systems, California Title 24 for example, and then

22 that grows into the building stock over the analysis
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1 period. So on your left there is the reference case

2 for controls in which the fraction of the total

3 lighting capacity that is switching only controls in

4 green and dimming based controls in blue grows over

5 the analysis period.

6 To understand the impact that that had on

7 the analysis DOE did an alternative analysis in

8 which the fraction of lighting capacity that is

9 under control stays fixed at present day levels.

10 DOE doesn't feel like this is a realistic scenario

11 but it gives a sense of what the impact of the

12 assumption on control is on the analysis.

13 Interestingly the impact is relatively

14 modest for GSFL; the reason for that being that to

15 the extent that the amount of dimming capacity grows

16 consumers are able to achieve an immediate energy

17 savings from a lamp only rule which bumps up the

18 energy savings available which offsets the reduced

19 energy savings that is available because lamps

20 aren't used as often and it ends up being a close

21 offset.

22 MR. BROOKMAN: Alex Boesenberg?
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1 MR. BOESENBERG: Alex Boesenberg from

2 NEMA. So did I hear you correctly in the last

3 statement that due to the increased application of

4 controls you are factoring in a higher amount of

5 energy savings?

6 DR. GERKE: Due to the fact that people

7 have dimmers, so the analysis -- the energy savings

8 is available depends on what ballast people are

9 coupling their lamps to.

10 MR. BOESENBERG: Right.

11 DR. GERKE: As an increasing number who

12 have dimmers going to a higher lamp efficacy level

13 gives you energy savings immediately because the

14 assumption is that people dim to the light level

15 that they want and end up using less energy with a

16 higher efficacy lamp. If the fraction of dimmers is

17 not increasing then that energy savings has to wait

18 until you actually renovate and replace your

19 ballasts into your ballast factor.

20 MR. BOESENBERG: Okay. And so that

21 national energy savings FSC, so you add that in then

22 to your overall estimates of energy savings?
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1 DR. GERKE: Well that is simply the

2 reference analysis assumes this growth in controls

3 and for the switching only controls there is a

4 reduction in hours of use.

5 MR. BOESENGBERG: Right.

6 DR. GERKE: So the amount of energy

7 savings that is available in those standards case

8 relative to the base case is smaller but in the

9 dimming case people are getting additional energy

10 savings simply from the fact that they get that

11 energy savings immediately upon putting in the

12 dimming ballast.

13 MR. BOESENBERG: But so okay. So where

14 does this then factor into the rule?

15 DR. GERKE: This is simply an analysis to

16 determine how large the impact is of the assumptions

17 about controls on the final numbers. So the

18 reference case numbers are the numbers that factor

19 into the -- are the primary numbers in the primary

20 analysis, the fixed controls numbers are the numbers

21 that we get for this alternative analysis.

22 MR. BOESENBERG: Okay. Well I will ask
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1 the question a different way. Is DOE in the energy

2 savings assessment for this rulemaking taking credit

3 for the energy savings inherent due to the

4 installation of controls?

5 DR. GERKE: Only to the extent that by

6 having dimmers in place a lamp standard allows a

7 more immediate savings, a lamp only standard allows

8 a more immediate savings at full wattage. So it

9 factors -- certainly factors in to the analysis

10 because it is difficult for it not to. But that is

11 -- this is one of the assumptions we are trying to

12 test.

13 MR. K. COOK: But I think that is only

14 viable if the new lamp standard enables the use of

15 controls that wasn't already available. And I don't

16 see that happening. In fact as we pointed out

17 earlier in like the T5 case by going to the energy

18 savers because of the new standards you actually

19 reduce the availability of dimming in some

20 applications because of lack of compatibility

21 between the lamp and dimming ballast.

22 MR. BROOKMAN: That was Keith. Now
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1 Karina. Karina?

2 DR. GERKE: I might be able to answer more

3 clearly. If you have a dimmer and you buy a lamp

4 with a higher efficacy that is a full wattage lamp

5 you can reduce your energy consumption by a larger

6 amount than if you buy a lamp that has a lower

7 efficacy at fixed light level. Is that not the

8 case?

9 MR. BOESENBERG: I understand your

10 statement. I have to take a little while to wrap my

11 head around the logic of it.

12 MR. BROOKMAN: Charlie Stevens while he is

13 wrapping his head.

14 MR. STEVENS: Yeah. Charlie Stevens.

15 Just to be clear this is in a lamp replacement

16 scenario as percentage of systems controlled goes up

17 --

18 DR. GERKE: Correct. Yes.

19 MR. STEVENS: -- essentially? So you are

20 looking at all we are doing in this instance is

21 changing a lamp but now an increasing fraction of

22 those replacements are occurring on systems that are
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1 dimmable?

2 DR. GERKE: Yes.

3 MR. BROOKMAN: For which there are

4 controls?

5 MR. STEVENS: Yeah I think we are assuming

6 dimming; right?

7 MR. BROOKMAN: -- states, steady; right?

8 DR. GERKE: Right. Correct.

9 MR. STEVENS: Okay. I think I get the

10 scenario then. Thanks.

11 DR. GARBESI: Doug can I --

12 MR. BROOKMAN: Please do, yes.

13 DR. GARBESI: This is Karina from LBNL

14 again. In the bigger picture though it is analogous

15 to the LED issue where there is this exogenous

16 factor, a movement toward the use of controls that

17 changes the universe both through the base case and

18 the standards case. And so the numbers of types of

19 lamps that are required to respond to the different

20 conditions wind up changing if there is more demand

21 for controls in later years. If you operate on

22 controls, then there is more demand for dimming
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1 ballasts in the lamps that operate with them. But

2 the base case and the standards case are subject to

3 that same shift.

4 MR. BROOKMAN: Okay. I thought that was -

5 - I got that. Okay. We are going to move on.

6 We have Mark, please.

7 MR. DUFFY: I just have a question. Is

8 that the only source of national energy savings in

9 this model?

10 DR. GERKE: No.

11 MR. DUFFY: What are the others?

12 DR. GERKE: Shifts to reduced wattage

13 lamps and shifts to lower ballast factor ballast as

14 only higher efficacy lamps are available.

15 MR. DUFFY: Hum.

16 DR. GERKE: So these are two specific

17 questions request for comment. DOE seeks input on

18 the current fraction of GSFL ballast shipment that

19 are dimming ballasts and the likely rate of growth

20 of dimming ballasts in the future. We have made

21 assumptions about that that we would like to have

22 corroborated in this analysis.
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1 I also didn't mention up to this point the

2 assumption about reduced wattage lamps. DOE is

3 aware that reduced wattage lamps do not function as

4 well on dimmers in all applications. And in its

5 analysis DOE assumed that the fraction of consumers

6 with dimmers who might choose a reduced wattage lamp

7 was small based on comments from last time. The

8 particular number that was used in this analysis was

9 ten percent of consumers might consider that option.

10 And we request comment on that interpretation of

11 small so we can better analyze that part of the

12 rule.

13 MR. BROOKMAN: Joe?

14 MR. HOWLEY: That is a really hard number

15 to guesstimate at and all you are doing is it is a

16 random guess. I guess just another comment based on

17 your previous statement. You mentioned that three

18 factors that we are using to get national energy

19 savings. In the case of the ballast factor I would

20 suggest that in both the base case and in the

21 standards case the same ballast factor will be

22 picked in both cases because the lumen output
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1 difference of these lamps, these 32 watt lamps is

2 only about two or three percent. And ballast

3 factors change by at least 10%. And so there is a

4 much larger jump in a ballast factor. And there is

5 not enough of a jump in lumen output in any of these

6 lamps to cause someone to make a different choice in

7 ballast factor. So there should be almost no

8 difference or no savings from ballast factor choice

9 due to simply this rulemaking of making the lamps

10 more -- slightly more efficient.

11 The other aspect you are saying you'll

12 gain and I understand the comment that logically for

13 you will gain a little more energy savings with the

14 full wattage lamp because it will be a couple, two,

15 three percent higher in lumens so maybe you don't

16 have to dim it down as much. You could stop the

17 dimming and have the same light output. But you

18 lose -- so you gain there but you lose for this

19 percentage that is going to reduce wattage lamps

20 that wants to try to dim them and that the issue is

21 you can't dim them as much before these effects

22 start to happen. You can dim them a little bit but
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1 you can dim the argon base lamps a lot more. So you

2 are going to get a lot more energy savings from the

3 argon based lamps than you are from the reduced

4 wattage. So to the extent people are shifting to

5 these which I agree they might because it will

6 become much more available under this set of rules.

7 You actually lose energy savings now because they

8 are not -- you cannot dim them as much. So any

9 couple percent gain you might get from the two or

10 three percent more lumens you are going to lose from

11 the percentage of people that are using reduced

12 wattage lamps and trying to dim them because they

13 can only dim them down to a much lower percentage.

14 So they'll offset each other.

15 MR. BROOKMAN: Mark. Continue on.

16 MR. DUFFY: Yeah, this is Mark Duffy of GE

17 Lighting continuing on. If you go back to the slide

18 92. Okay. I understand that the right -- that the

19 left hand chart here called reference is the one

20 that you are using which shows a growth of controls.

21 The growth of controls will come along with a shift

22 to the full wattage argon lamps because of all the
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1 things we've talked about. So it almost offsets

2 that shift you think you are taking with claims of

3 going to lower wattage lamps. You don't go to

4 those energy saver lamps and put them on controls.

5 You either put the thing on controls or your

6 installation is the fixed wattage installation or

7 the fixed ballast installation and you put your

8 lower energy lamp on there. So don't take credit

9 for both of those at the same time. The model has to

10 keep that as a separate decision making.

11 MR. BROOKMAN: Okay. Garry Fernstrom?

12 MR. FERNSTROM: This is Garry for the

13 California IOUs. I'd like to ask a question of Joe

14 with regard to his statement about ballast factors

15 and their availability in increments of 10% or so.

16 I thought that in retrofit applications where

17 lighting retrofit contractors in California are

18 replacing lighting systems using more efficacious

19 lamps that they could select ballast factors in like

20 two percent increments such as to try and match the

21 replacement system illumination with the system for

22 which it is replacing. And secondly with more and
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1 more new installations going to dimming ballast it

2 is possible to adjust the ballast factor in effect

3 by very small increments in order to account for

4 differences in efficacies of lamps. So we are

5 assuming that new lighting systems would be tuned

6 and very precisely in order to match the replacement

7 illumination with the system for which it is

8 replacing. So I do think it is appropriate to value

9 the ballast effects in this analysis.

10 MR. BROOKMAN: Joe?

11 MR. HOWLEY: Okay. So on the dimming, I

12 agree. And we talked about that and they've already

13 modeled it and they've got their energy savings when

14 you have a fully dimmable system you can set it to

15 whatever level that you want. But the ballast

16 factor scenario is not true. There is not a

17 selection of ballast factors that vary by one or two

18 points all the way up and down from say .70 all the

19 way up to say 1.15 which is the top. They tend to

20 jump .78, .88, 1.0, 1.15. They are about a ten

21 percent jump. That is where the market is. And

22 that is where the products are designed. To the
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1 extent that anybody wants any more carefully crafted

2 light levels they will jump to a dimming ballast.

3 But if they are just going with a specific ballast

4 and a fixed installation their choices are in ten

5 percent increments. And I don't see that changing.

6 MR. FERNSTROM: Okay. Thank you.

7 DR. GARBESI: Can I ask a clarification

8 question, Joe. You were saying that the lower

9 energy use lamps don't dim as well, so you might not

10 get the same dimming energy savings. I think were

11 based on a couple of different sources that we had

12 found had estimates on the order of 30% energy

13 savings for systems that are operating on dimmers on

14 average. So that -- to me that sounds like you are

15 dealing with tuning at the higher level range. I

16 mean do those more efficacious, lower energy use,

17 lamps have problems up in that range or is it really

18 down at the lower part of the range.

19 MR. BROOKMAN: That was Karina. Now Joe.

20 MR. HOWLEY: Mark --

21 MR. BROOKMAN: Oh yeah, now Mark. Now

22 Joe.
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1 MR. HOWLEY: Well, okay.

2 MR. DUFFY: I'll advise you.

3 MR. HOWLEY: So clearly up in the higher

4 range where you are getting at almost full current

5 they will perform better than as you go down lower

6 and lower. As the current goes down you have a

7 harder and harder time maintaining stability. And

8 then it goes really to how the fixture was designed,

9 what the thermals are around, there are too many

10 variables now. But we do know that with an argon

11 lamp you certainly, those variables don't matter as

12 much, so I can get smooth dimming down quite low.

13 But I cannot do that with Krypton. It is hard to

14 determine when exactly that is going to stop

15 dropping out.

16 DR. GARBESI: So even at that top 30%

17 level you are not confident?

18 MR. HOWLEY: Not confident.

19 MR. BROOKMAN: Charlie Stevens.

20 MR. STEVENS: Hi, Charlie Stevens. I have

21 had a lot of conversations with our lighting and

22 retrofit folks and I would agree with the 30%
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1 savings which is pretty much on the order of what we

2 find in a lot of these things. But that is comprised

3 of quite a lot of hours where there is very little

4 or no dimming and other hours where there is 50 and

5 60% dimming. So it is -- the overall savings may be

6 30% but it -- and sometimes the ballast operate at

7 that level. But we also know that a lot of these

8 lower wattage lamp applications actually do work

9 pretty well. They will work pretty right down to 50

10 and 40% in some cases. Not all by any means. And

11 they have had to work pretty hard at figuring out

12 which ones so that they don't mess up and provide

13 bad performance. But it is not universal that it

14 doesn't work. And in some cases I think what I am

15 trying to say is 30% energy savings might reduce to

16 27% energy savings if you could only dim the lamp to

17 50% instead of 30% because the number of hours that

18 you are running between 30 and 50% is not a huge

19 fraction necessarily of the dimming hours. It is

20 there but the impact on energy savings could be

21 pretty small even if you had to restrict the level

22 at which the lights the lower wattage lamps were
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1 dimmed to. So it's not as simplistic as it sounds.

2 MR. BROOKMAN: Mark?

3 MR. DUFFY: Yeah. I wanted to dispel one

4 thing that I heard a little bit earlier. The

5 suggestion that the 28 watt and the 25 watt lamps

6 are inherently more efficacious than the full

7 wattage lamp is not true. Those lower wattages if

8 you look at the ANSI protocol for reference

9 photometry are on high frequency reference but

10 because the way the earlier rulemaking was we needed

11 to measure them at 60 Hertz, so at low frequency.

12 They are measured without cathode heat. The 32 watt

13 lamp is measured with cathode heat. So when you are

14 trying to figure out how much energy savings there

15 is or if one is more efficacious than another you

16 are comparing apples to oranges at that point.

17 Cathode heat in the reference photometry costs LPW.

18 MR. BROOKMAN: Okay.

19 DR. GERKE: Just to clarify one point that

20 I think may have gotten muddled a little bit there.

21 The assumption is that for those consumers who have

22 dimming ballasts only a very small fraction will
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1 even consider purchasing a reduced wattage lamp to

2 put on that ballast because of the performance

3 issues. And the fraction of those people who

4 actually chose one is yet smaller. So the fraction

5 of people that have both dimming ballast and reduced

6 wattage lamps in the model is exceedingly small.

7 There were some other alternative analyses

8 that impact only the National Impact Analysis not

9 the Shipment Analysis. One has to do with the

10 reference price of electricity. DOE uses AEO's

11 reference economic growth projections for the price

12 of electricity. DOE also considered the low and

13 high economic growth scenarios from AEO which have

14 modest to moderate impacts on the NPV.

15 DOE also explored alternative assumptions

16 about rebound rate. DOE's standard assumption in

17 this analysis is that the rebound for lighting

18 applications is zero. In the framework document for

19 this rulemaking there were numbers of a residential

20 rebound rate of 8.5% and a commercial rebound rate

21 of one percent. DOE considered those as well. And

22 they have a predictable impact on the national
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1 energy savings since most of this rulemaking is in

2 the commercial sector, reduces the NES by about one

3 percent. The national energy modeling system

4 assumes 15% rebound for lighting so DOE also

5 considered that and it also has a predictable impact

6 on the NES.

7 So DOE welcomes any comment on its

8 assumptions about the rebound rate for lighting

9 products or about the analysis period that it used

10 for this rulemaking.

11 All right. Now I will hand it off to

12 Hayden Cook who will tell us about the Manufacturer

13 Impact Analysis.

14 MR. H. COOK: Hi my name is Hayden Cook

15 from Navigant. And I will be discussing the

16 Manufacturer Impact Analysis or MIA that was

17 conducted for this

18 NOPR.

19 The MIA slides present three things.

20 First they present an overview of how the MIA was

21 conducted. Second they briefly discuss the

22 manufacture impacts at the proposed standard level.
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1 And third they introduce the MIA topics DOE is

2 seeking comment on.

3 So the main purpose of the MIA is to

4 assess the impacts of standards on manufacturers of

5 GSFLs and IRLs. A second purpose is to identify and

6 estimate the impact on manufacturer subgroups. In

7 the upcoming slides I will discuss the impact of

8 standards on the small business subgroup. In the

9 final portion of the MIA -- the final portion of the

10 MIA involves a discussion on direct employment,

11 manufacturing capacity and other federal regulations

12 that impact the same manufacturers around the

13 compliance date of this rulemaking.

14 The main tool DOE uses to evaluate the

15 impact of standards on manufacturer is a discounted

16 cash flow model called the government regulatory

17 impact model or GRIM. The major output from the

18 cash flow model is industry net present value or

19 INPV a metric used to represent the quantitative

20 impacts of amended standards on manufacturers of

21 GSFLs and IRLs.

22 For the MIA DOE also conducted interviews
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1 with manufacturers to refine the inputs to the cash

2 flow model and to understand the qualitative impacts

3 of standards.

4 This slide presents the basic structure of

5 the MIA process which takes place in three phases.

6 In the first phase which occurred during the

7 preliminary analysis DOE used publicly available

8 information such as manufacturer's annual reports to

9 develop a profile of the industry. Phases two and

10 three which were conducted as part of this NOPR

11 analysis in phase two DOE developed the interview

12 guide that was used to gather information from

13 manufacturers during the interviews and created the

14 cash flow spreadsheets that are used to estimate the

15 impacts on the industry. In phase three DOE

16 conducted interviews with manufacturers and used the

17 information to further develop the analysis and to

18 finalize the inputs that went into the GRIM.

19 Switching from the MIA methodology to the

20 specifics about this rulemaking this slide presents

21 the key issues we learned from manufacturers

22 concerning GSFL and IRL standards. First
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1 manufacturers are concerned that increasing GSFL

2 standards would require manufacturers to use more

3 rare earths in GSFLs. This increased demand for

4 rare earth due to GSFL standards could cause the

5 price of these materials to significantly increase.

6 Manufacturers also noted that since the majority of

7 rare earths are mined in China and controlled by

8 Chinese companies it could be difficult to insure

9 the sale of these rare earths at the quantities

10 necessary to meet higher GSFL standards.

11 Second manufacturers are concerned that

12 amended standards to these lamps could potentially

13 strand the substantial capital investments made by

14 manufacturers in order to comply with the previous

15 2009 lamps rule since these manufacturers might not

16 have fully recouped these capital investments that

17 were made.

18 Last manufacturers stated that regardless

19 of amended standards consumers are already shifting

20 away from the GSFLs and IRLs to more energy

21 efficient technologies such as LEDs especially in

22 the commercial markets. Amended standards could
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1 cause manufacturers to divert resources away from

2 the R&D of these more efficacious lighting products

3 thereby delaying the further potential energy

4 savings from those products.

5 I know we have discussed some of these

6 issues previously. But I would like to pause to see

7 if anyone has any comments on the key issues that

8 are presented here or any other key issues that are

9 not specifically addressed in this slide.

10 MR. DUFFY: Yeah, this is Mark Duffy of GE

11 Lighting. With regard to understanding the design

12 and how much additional rare earth there might be

13 and so forth you need to understand that in the

14 design of a fluorescent lamp as I increase the

15 weight of rare earths in the lamp it is not a linear

16 increase of lumens. So if I am thinking about how

17 many lumens per rare earth I get from the additional

18 incremental LPW that you are seeking here, it is an

19 enormous amount of rare earth that needs to be added

20 into these lamps and may not actually be possible

21 because the coating thicknesses get so thick that

22 the material doesn't stay on. So in other words you
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1 are already at that marginal return where the cost

2 of the additional rare earth may double to get just

3 a little bit -- or the amount of rare earth may

4 double to just get a little bit of incremental

5 improvement. And that is a resource waste that goes

6 on throughout the life of that whole lamp. Okay.

7 So think in terms of how many lumens I get per rare

8 earth within the reasonable design area here and

9 don't drive it to the point where you are wasting

10 rare earth or you are causing a potential rare earth

11 shortage to get a very small amount of additional

12 efficacy.

13 MR. BROOKMAN: Okay. Thank you. Charlie

14 Stevens?

15 MR. STEVENS: Yeah. Charlie Stevens. I

16 am getting a little confused here. I keep hearing

17 from some folks that DOE is asking them to produce a

18 product that doesn't exist. And the last I looked

19 while the levels are higher than all products

20 currently in production can meet, there are products

21 in production that do meet the standards.

22 MR. BROOKMAN: Keith.
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1 MR. STEVENS: And so I am trying to

2 understand if those products already exist and they

3 are already performing at that level I am trying to

4 understand how impossible or difficult it must be to

5 continue to do that.

6 MR. K. COOK: For GSFLs we are to meet

7 this new proposed specification. It today

8 represents 5% of our production. So you are

9 requiring us to convert 95% over to this design.

10 MR. STEVENS: Yeah. I understand the

11 increase in the amount of material you'll use

12 overall for the shipments of the lamps that will be

13 declining over the time. But what I am hearing is

14 product technology problems and these products

15 already exist. So I am trying to separate these

16 issues. I understand the increase in the total

17 demand for rare earths and I don't think it is

18 necessarily appropriate to treat all three of the

19 ones that are typically used the same by the way.

20 Last I looked one of them was not as constrained as

21 the other two. But I am trying to separate the

22 technology issue of can we build this lamp from the
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1 notion of yes if we have to build all of our lamps

2 this way yes the amount of demand for these

3 materials will increase. I understand that.

4 MR. BROOKMAN: Keith?

5 MR. K. COOK: In some cases no, we cannot

6 produce the lamp. The U-shape lamp for instance

7 just can't produce it. Others, yes, we can. So it

8 is on case by case basis.

9 MR. BROOKMAN: Okay. Thank you.

10 Michael McGaraghan has a comment.

11 MR. McGARAGHAN: Thanks. I have a

12 question for some of the manufacturers in the room

13 on the rare earth issue. We've notice in the last

14 few years a big increase in sales of 90 CRI T12s and

15 I am curious if those use rare earth phosphors and

16 if they use any of the specific elements that are in

17 short supply or have price fluctuations or if those

18 are somehow developed with a different strategy or

19 technology that is not hinging on rare earth price

20 fluctuation.

21 MR. BROOKMAN: What is that 90 CR whatever

22 12? Mark?
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1 MR. McGARAGHAN: 90 CRI 12.

2 MR. DUFFY: The 90+ CRI lamps are rare

3 earth based.

4 MR. BROOKMAN: Okay. Thank you.

5 Keith?

6 MR. K. COOK: No.

7 MR. BROOKMAN: Michael did that answer

8 your question?

9 MR. McGARAGHAN: Yes.

10 MR. BROOKMAN: Thank you. We are moving

11 ahead.

12 MR. H. COOK: This slide presents an

13 overview of the markup scenarios DOE ran for the

14 MIA. DOE analyzed two different markup scenarios for

15 the

16 GSFL and IRL MIAs: a flat or preservation

17 of gross margin markup scenario, and a preservation

18 of operating profit markup scenario.

19 Each markup scenario produces a unique set

20 of cash flows for the GSFL and IRL GRIMs. For the

21 flat markup scenario manufacturers earn the same

22 gross margin markup percentage as they do in the
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1 base case on any increase in the manufacturer

2 production costs due to a standard.

3 For the preservation of operating cost

4 markup scenario manufacturers earn the same

5 operating profit in absolute dollars in the base

6 case as they do in the standards case in the year

7 after the standard goes into effect.

8 The least severe markup scenario for

9 manufacturers is the flat markup scenario since

10 manufacturers are able to fully pass onto their

11 consumers the additional costs due to standards.

12 The most severe markup scenario for manufacturers is

13 the preservation of operating profit markup scenario

14 since in this markup scenario manufacturers are not

15 able to fully pass through the additional cost due

16 to the standards thereby reducing manufacturers

17 profit compared to the flat markup scenario.

18 The INPV results for the GSFL

19 manufacturers are shown on this slide. The top

20 table displays the results of the flat markup

21 scenario which represents the least severe impact to

22 manufacturers. And the bottom table displays the
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1 results of the preservation of operating profit

2 markup scenario which represents the most severe

3 impact to manufacturers. And TSL5 is the TSL that

4 is proposed for this NOPR.

5 MR. BROOKMAN: Keith Cook?

6 MR. K. COOK: Keith Cook with Philips. I

7 think there is a third scenario that also needs to

8 be analyzed. And that is a loss of profitability.

9 It is not just flat or maintaining but the third

10 scenario is the fact that we just can't recover from

11 these increased costs.

12 MR. BROOKMAN: Mike Rivest?

13 MR. RIVEST: Would that be because of an

14 erosion of margin or what would be the mechanism or

15 is it because of a loss of good, better, best? What

16 would be going on in the market that would explain?

17 MR. K. COOK: Yeah. First off this is the

18 total commoditization now of our market. So you

19 don't have any way to differentiate your product

20 from anybody else. So it is pure price now. And

21 the second problem is the fact that you've already

22 established the pricing level today and now to
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1 increase the cost it is hard to justify that there

2 is a justification that allows you to increase it.

3 So you go into these big boxes, the Home Depots, the

4 WalMarts, they are not going to accept the higher

5 price. You've already got it at a contract level;

6 they are going to want to maintain that. And so

7 with increased cost there is going to be a profit

8 erosion on this.

9 MR. BROOKMAN: Thank you Keith.

10 MR. H. COOK: The INPV results for IRL

11 manufacturers are shown on this slide. The format

12 is the same as the previous slide where the top

13 table displays the results of the flat markup

14 scenario and the bottom table display the results of

15 the preservation of operation profit markup

16 scenario. And again TSL1 is the TSL that is

17 proposed for this NOPR.

18 MR. BROOKMAN: Joe, do you want to

19 comment?

20 MR. HOWLEY: The manufacturers just noting

21 how hugely negative this impact is on a percentage

22 basis for the manufacturers and to counter with how
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1 little energy savings was projected before this

2 certainly is not a good equation for the

3 manufacturers or I think even for DOE for a

4 rulemaking, this product line.

5 MR. BROOKMAN: Thank you.

6 MR. H. COOK: Any further comments?

7 MR. BROOKMAN: Andrew DeLaski?

8 MR. DeLASKI: They're also I just want to

9 understand how this analysis matches up with some of

10 the earlier analysis we heard about today. So there

11 is also markups assumed in for example the NIA and

12 the LCC, so which of these scenarios is used for the

13 LCC and the NIA?

14 MR. H. COOK: This is -- it is the flat

15 markup.

16 MR. DeLASKI: Okay. And so the LCC

17 assumes that the margins that are being earned today

18 will continue to be earned in the future? And you

19 know what is driving the difference in impacts here?

20 There are clearly the assumptions about the size of

21 the investments and fluorescent manufacturing is

22 what needs to happen to make the GSFL more efficient
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1 is addition of a lot of materials but not

2 necessarily a change in manufacturing process. So

3 what you assume about cost pass through of those

4 incremental costs is going to drive your results.

5 Whereas IRL manufacturing to change the technology

6 could require significant capital tooling changes

7 and you have a very significant drop in shipments in

8 IRL, more so than in GSFL. So you are building a

9 capacity and that capacity is immediately

10 underutilized.

11 MR. GATTO: Dave Gatto, Westinghouse

12 Lighting. I just want to point out that it is an

13 incremental efficiency increase. It isn't actually

14 in the case of GSFL an incremental increase in

15 material cost. I would agree that the physical

16 equipment costs to convert are not there but I think

17 the point that Joe and Keith have been trying to

18 make and you know Charlie this is a little bit in

19 response to you, it is not that we can't make a more

20 efficient GSFL. It is that the amount of material

21 and cost associated with that is skewed, the

22 percentage of cost increase to the percentage of
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1 efficiency increase are 40 to two. So it is

2 important to point out that the incremental piece

3 there is the energy efficiency --

4 MR. BROOKMAN: Right.

5 MR. GATTO: -- not the actual cost to

6 produce the lamp.

7 MR. RIVEST: Right. And that is a

8 consumer story, it is not so much a manufacturer's

9 story. Right because your investment --

10 MR. GATTO: I don't -- I am sorry. I

11 don't know that I agree with that. I think that is

12 kind of where Keith was. If it is an issue for the

13 consumer it is --

14 MR. RIVEST: No.

15 MR. GATTO: -- manufacturer.

16 MR. RIVEST: I understand that but in the

17 IRL you are asked to invest up front --

18 MR. GATTO: Yes.

19 MR. RIVEST: -- in tooling. Here you're

20 only -- you are investing in materials. So your --

21 there is a shorter time -- your investment is

22 shorter duration and you can more easily change your
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1 inventory than completely retooling your factory.

2 And so the risk is greater in IRL.

3 MR. GATTO: I appreciate that. No and I

4 do

5 --

6 MR. RIVEST: If you could pass through

7 those costs in GSFL to the consumer --

8 MR. GATTO: That is the key right there.

9 MR. RIVEST: -- you'd be making off really

10 well; right?

11 MR. GATTO: If. And the if is we've

12 already seen it. The if isn't there. You saw it

13 with the price spikes that we experienced with the

14 effective date of the last rulemaking there is a

15 pretty flat curve there of consumer both commercial

16 and residential acceptance of higher price for

17 initial first cost. And I am not saying that if you

18 waited long enough when no one else was left and

19 people had no lights and I mean that, I mean that is

20 kind of the extreme you have to take when consumers

21 have literally no light other than candles then they

22 are going to pay whatever it costs obviously if they
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1 can afford to do so. What I think that gets missed

2 in this analysis sometimes is that gap of time can

3 be disruptive to manufacturing, to the economy and

4 to the consumers. And we just think it is important

5 to point out. And I am not disagreeing with you at

6 all Mike that it is definitely a shorter recovery if

7 you could pass along. I just don't think -- I think

8 we've been clear in our comments I just don't want

9 to miss this opportunity to make it clear that it is

10 longer than you think.

11 MR. BROOKMAN: So just to clarify that was

12 Dave speaking last and the back and forth was Dave

13 and Mike Rivest, Dave and Mike Rivest back and

14 forth. Now Eric Montgomery has a comment. Eric you

15 have the floor. You need to unmute your phone.

16 Eric you have a comment. Please speak. We are not

17 hearing you. There is a little bit of garbled signal

18 but you are not coming through. Eric sorry --

19 MS. CALLAHAN: Could you ask Eric to email

20 me the question?

21 MR. BROOKMAN: Yes. Eric Susan suggests

22 you just email her the question and she will ask it.
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1 And then also David Nesting has a comment.

2 This would be the test where we figure out

3 whether the software is failing or the individual.

4 MR. NESTING: There we go. I am unmuted.

5 I think one of the things that might be missing in

6 this as we talk about -- can you hear me all right?

7 MR. BROOKMAN: Yes, you are good.

8 MR. NESTING: Okay. Is that some of the

9 impact on manufacturers right now is focused solely

10 on the lamp manufacturer part. What is missing is

11 that although these lamps are going to use a lot

12 more REO we don't just put REO in lamps. We put

13 phosphor in lamps. And so the fact that we have 5%

14 of the margin using the very best phosphors that

15 money can buy in the world doesn't mean you can make

16 the other 95% of your product with the same

17 material.

18 MR. K. COOK: Can you explain that further

19 Dave?

20 MR. BROOKMAN: Yeah. I didn't quite get

21 that, Dave?

22 MR. NESTING: Yeah. I mean what we are
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1 looking at is that right now we are moving to super

2 T8s and the fact is that under the current standard,

3 the phosphor, yeah it is still vitry along side, it

4 is still landed phosphate, all those things are

5 still true but the phosphor that we use for the so6 called super T8 and the phosphor that we use for the

7 80 color is not the same supplier and it is not the

8 same quality. So to say well why don't you just

9 make everything with that material that we found

10 from one supplier somewhere for all of the

11 manufacturers that work in the U.S. market is more

12 of a challenge. You are looking at investments on

13 REO processing and phosphor making which for example

14 those we have divested that part of the business in

15 2006.

16 MR. BROOKMAN: Eric, do you want to give

17 it another try, see if you can. You got it?

18 Yes, Mike Rivest.

19 MR. RIVEST: This is a supply chain issue.

20 They are not investing here because they are buying

21 the phosphors but the phosphors have to be made by

22 someone. So that investment has really shifted to
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1 the suppliers. So it is a little bit like the

2 amorphous transformers, those who -- yeah.

3 MR. BROOKMAN: Okay. So thanks for that

4 interpretation.

5 Eric Montgomery do you want to try again

6 to join the conversation? Maybe you have already

7 emailed Susan. Not yet? Give it another try.

8 Nope. Okay.

9 MR. H. COOK: Moving on?

10 MR. BROOKMAN: Yes.

11 MR. H. COOK: One of the criteria that DOE

12 looks at is the impact of standards on small

13 businesses. To be considered a small business for

14 this rulemaking the Small Business Administration or

15 SBA sets a limit of 1000 total employees or less for

16 these companies. DOE used publicly available

17 information to identify potential small businesses.

18 Also during interviews DOE asked manufacturers if

19 they are aware of any potential small businesses in

20 their markets. After refining the list of potential

21 small businesses based on DOE's initial research DOE

22 directly contacted the remaining potential small
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1 businesses to determine if they met SBA's definition

2 of a small business. DOE found 21 potential GSFL

3 small businesses and 15 potential IRL small

4 businesses.

5 All small businesses DOE identified were

6 not the original manufacturers of the GSFLs or IRLs

7 they sold nor did they own or operate the equipment

8 used to produce their lamps. Therefore DOE does not

9 estimate small business would face any capital

10 investments due to the proposed standards. However

11 most small businesses will face additional testing

12 and certification costs due to the standards. Also

13 some small businesses that control their product

14 specifications for their lamps would face additional

15 R&D and engineering costs to redesign the lamps that

16 do not meet the proposed standards. Since small

17 business have lower sales volumes than large

18 manufacturers these product conversion costs are

19 spread out over fewer units which cause the product

20 conversion costs to be significantly higher as a

21 percentage of revenue compared to large

22 manufacturers.
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1 Based on DOE's analysis some small

2 businesses might choose to invest in other areas of

3 their lighting business instead of making the

4 necessary investments to continue producing GSFLs

5 and IRLs that meet the proposed standards.

6 Therefore some small businesses might exit the GSFL

7 or IRL markets to pursue other lighting products as

8 a result of the proposed standards.

9 At this time DOE seeks comment on the

10 potential impact to GSFL and IRL small businesses at

11 the proposed standards. So issue 36.

12 MR. BROOKMAN: No comments here?

13 MR. DeLASKI: I am trying to figure out

14 who -- what kind of business. Is this a -- so this

15 is a company that is buying lamps from someone else

16 and then -- basically they are almost like a

17 wholesaler or it is a private labeler.

18 MR. H. COOK: Private labeler, yes.

19 MR. DeLASKI: Okay.

20 MR. BROOKMAN: Anything else?

21 MR. DeLASKI: So under their own label or

22 under a say True Value or something like that?
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1 MR. H. COOK: Yes.

2 MR. BROOKMAN: Alex.

3 MR. BOESENBERG: Alex Boesenberg at NEMA.

4 An example Andrew is I know of one company that

5 sources tubes and end caps and crimps the end caps

6 on the tubes in the United States. They are a U.S.

7 manufacturer.

8 MR. BROOKMAN: Okay. Joe?

9 MR. HOWLEY: My comment is that this is

10 pushing to very high technology levels in many

11 cases. And there has got to be problems created with

12 these small manufacturers trying to access this

13 technology. I know it seems like you reached out to

14 many of them. You weren't able to get a lot of

15 responses but I think the natural assumption is you

16 are going to greatly disrupt the market and their

17 ability to provide these products when you are

18 talking about these small manufacturers. There is

19 going to be I think without too much speculation a

20 negative effect on that particular part of the

21 market.

22 MR. BROOKMAN: Hayden why don't you cue
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1 the next comment boxes?

2 MR. H. COOK: So here are several issue

3 comment box. Some of them were kind of discussed.

4 Some weren't. The first comment box DOE seeks

5 comment on its use of 1.52 as the distribution chain

6 markup for the GSFL and IRL industries. This would

7 be from the manufacturer to the end user.

8 I can just read through these and if you

9 want to comment on it.

10 In the second issue box, issue 24, DOE

11 seeks comment on the $6.1 million industry product

12 conversion cost and the $65.4 million industry

13 capital conversion cost estimates for IRL

14 manufacturers to comply with the proposed IRL

15 standards.

16 And the last issue box is DOE seeks

17 comment on the potential domestic manufacturing

18 employment impact to GSFL and IRL manufacturers as a

19 result of the proposed standards.

20 Start with any of those three.

21 MR. BROOKMAN: Joe, do you -- no. Mike

22 Rivest.
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1 MR. RIVEST: Mike Rivest. I'd like to add

2 following up on our previous conversations about

3 ability to pass through costs. If there were any

4 analogies or any situations from which we can learn

5 what happened, for example, when rare earth

6 phosphors costs more and that created a greater cost

7 for you, were you able to pass any of those costs

8 through to your customers. So we are looking at

9 price elasticity but from an industry wide where

10 everyone had a higher cost to see if you were able

11 to pass a portion or all of those costs through.

12 That would be very helpful --

13 MR. BROOKMAN: Garry Fernstrom.

14 MR. RIVEST: -- in creating new scenarios.

15 MR. FERNSTROM: So Mike this is Garry for

16 the California IOUs. I think an additional

17 important dimension of your request for information

18 has to do with the transiency of the supply cost

19 increase. So this would be a relatively long term

20 effect. It might result in a different opportunity

21 to pass costs along than a shorter term effect. So

22 as examples might be provided they should include
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1 some consideration of that dimension.

2 MR. RIVEST: Absolutely. Maybe there were

3 other costs that were longer term, like recycling

4 costs or I don't know -- you are in a better

5 position than I to come up with examples.

6 MR. BROOKMAN: Keith?

7 MR. K. COOK: On issue 24 I guess I don't

8 understand those conversion costs because the market

9 is changing so rapidly to LED I don't know why

10 anybody would invest in IRLs because they'll end up

11 with hung conversion costs that they aren't going to

12 be able to recover.

13 MR. HOWLEY: This is Joe. That was going

14 to be my comment.

15 MR. RIVEST: Because you have to.

16 MR. HOWLEY: Mike on your comment I think

17 you could speculate that a portion of the cost was

18 attempted to be passed on by industry would probably

19 be the best assumption with that one. On this one I

20 agree with Keith that consider what you are asking

21 the industry to do. You are asking us to invest an

22 enormous amount of money as an industry right when
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1 this market is -- LEDs are coming in in waves and

2 investing all that money in a technology that is

3 sure to shrink in sales. It is a huge ask to ask an

4 industry to do that. And you have to understand

5 what a huge risk that the Department of Energy is

6 taking to ask an industry to do this kind of thing.

7 I mean these are high risk games because the costs

8 are very large. And the risks of industry being

9 able to do this or wanting to do this right as the

10 market is converting it is -- the timing couldn't be

11 worse. So it is not a good situation what is being

12 proposed here.

13 MR. BROOKMAN: What about comments on

14 issue box 26 direct domestic manufacturing impact?

15 MR. HOWLEY: Again I mean a lot of the

16 halogen type products are yet still made in the U.S.

17 Of course some are made outside. Some are -- but a

18 big portion is made in the U.S. And if these

19 investments have to be made to keep that

20 manufacturing here it puts it at risk, it puts

21 manufacturing employment at risk. And if it shifts

22 to LED a lot of these products are imported and it
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1 shifts manufacturing labor out of this country. And

2 this may hasten it; a regulation that is this

3 severe. That would be my comment.

4 MR. BROOKMAN: Okay. Andrew DeLaski?

5 MR. DeLASKI: I don't know the relative --

6 you know in fairness a lot of LEDs are made

7 domestically too. There is LED manufacturing

8 happening domestically so there is a mixture on both

9 of domestic and foreign manufacturing in terms of

10 LEDs and incandescent reflectors.

11 MR. HOWLEY: Right. But --

12 MR. BROOKMAN: Okay. Additional comments

13 here?

14 Okay.

15 MR. H. COOK: The next slide is also a few

16 more issues for comment. In the first box DOE seeks

17 comment on the compliance cost of any regulations

18 GSFL or IRL manufacturers must make to product other

19 lighting products especially if those lighting

20 products -- if those regulations take place three

21 years before or after 2017.

22 And the second box is DOE requests comment
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1 on whether GSFL manufacturers would potentially

2 increase the amount of mercury used in GSFLs in

3 order to comply with the proposed GSFL standards?

4 MR. BROOKMAN: Joe?

5 MR. HOWLEY: It should not have a big

6 impact on mercury use.

7 MR. BROOKMAN: Regulatory burden? Other

8 regulatory impacts that you'd like to note for the

9 record?

10 MR. H. COOK: And any other requests for

11 comments on any other aspects of the MIA at this

12 time?

13 MR. BROOKMAN: Keith?

14 MR. K. COOK: Well since these are already

15 covered products I don't see where there is any

16 additional change from where we are today.

17 MR. BROOKMAN: Okay.

18 MR. H. COOK: Next Karina will talk about

19 some of the other downstream analyses.

20 DR. GARBESI: So thanks. This is Karina

21 Garbesi from LBNL. DOE conducts a number of

22 standardized, what we call downstream, analyses.
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1 The first of these analyses, the emission analysis,

2 takes the output from the national energy savings

3 modeling that is done as part of the NIA and here

4 you can see the results of the emissions analysis

5 that are done for GSFLs. Basically DOE quantifies

6 the cumulative emissions reductions that could

7 result from amended standards, and in so doing it

8 accounts for the upstream emissions from the power

9 plant fuel cycle as well. You can see the

10 cumulative emission here calculated for GSFLs.

11 We've highlighted TSL5, the proposed standard level.

12 Note that the units for the six chemical species

13 that are considered are different, as shown on the

14 left hand column there. So you can see that DOE

15 estimates at TSL5 that there would be emissions

16 reductions of 170 million metric tons of carbon

17 dioxide, 210,000 English short tons of NOx, .32 tons

18 of mercury, 2.8 thousand tons of nitrous oxide,

19 730,000 tons of methane and 250,000 tons of sulfur

20 dioxide. And then the same analysis with the same

21 units are repeated here, in this case for the

22 savings in emissions associated with IRLs at TSL1,
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1 the only TSL considered. As you can see, they are

2 much smaller. We won't go through all of the

3 numbers again here.

4 DOE also monetizes the value of the

5 emissions reductions. DOE uses the most recent

6 social costs of carbon values that are generated by

7 the

8 Interagency Working Group on the Social

9 Cost of Carbon in its analysis. The social cost of

10 carbon includes damages associated with agricultural

11 productivity, human health effects, property damage

12 from sea level rise, and other ecosystem effects, as

13 well as other impacts. You can see in the middle of

14 the slide there the range of values that the

15 agencies have agreed to use in the impact analysis.

16 Basically these are the result of combining three

17 separate impact assessment models, and all of which

18 generate a distribution of impacts, and then they

19 combine these and take the average value from those

20 three models for three different discount rates:

21 assuming a 5% discount rate, a 3% discount rate, and

22 a 2.5% discount rate. And those average values are
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1 the first three numbers there: 11.8 dollars per ton,

2 and mid range value of 39.7 dollars per ton is

3 considered the reference value, and 61.2 dollars per

4 ton is the high value. And then there is sort of a

5 high high which is the 95th percentile value at the

6 3% discount rate. The Working Group encourages use

7 of all of those values in considering the possible

8 impacts. The social cost of carbon is modeled to

9 increase over time.

10 And DOE also monetizes NOx emission

11 reductions that could result from the standards. It

12 considers a range of values, in this analysis it

13 uses $2,639 per short ton.

14 In terms of the results of that analysis

15 you can see in the four data columns the spread of

16 values from lowest on the left to highest on the

17 right. I'll just discuss the reported values for

18 TSL5. The units there are in millions of dollars,

19 so somewhere between $1.3 billion at the low end and

20 $17 billion at the high end is the estimated value

21 of cumulative emission reductions for the whole

22 analysis period. And then you can see the same
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1 plots essentially repeated for IRLs; in this case

2 there are much smaller savings because of the lower

3 energy savings but potential between $6.1 and $75

4 million in 2012 dollars.

5 So issues for comment on that one: DOE is

6 soliciting input on the SCC values and in particular

7 those in the later years 2050 and beyond.

8 MR. BROOKMAN: No comments here. Okay.

9 DR. GARBESI: Okay. We will assume there

10 are no comments.

11 DOE also conducts a utility impact

12 analysis. Again these are based on the projected

13 energy savings at the different TSLs. It uses a

14 modified version of the National Energy modeling

15 system to calculate the impacts on the installed

16 capacity and on the electricity generation per year.

17 The results of that analysis are reported in Chapter

18 16, sorry 18 -- it is

19 16.

20 And we also conduct an employment impact

21 analysis. This is distinct from the employment

22 impacts in the industry itself, which is reported in
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1 the MIA. This is really economy wide impacts

2 resulting from the change in spending flows across

3 different sectors of the economy as a result of the

4 proposed standards. We use a model called ImSET

5 that accounts for 187 different sectors of the

6 economy. It accounts for equipment and energy

7 expenditure changes that were developed and shown in

8 the energy savings analysis. And it gives output in

9 numbers of jobs, a projected range in the numbers of

10 jobs, either gained or lost as a result of

11 standards. You can find the results of that in

12 Chapter 17.

13 And then, last, we also do a regulatory

14 impact analysis, which for some completely

15 inexplicable reason actually calculates the impact

16 of the non-regulatory alternatives and then compares

17 them to what one would get from amended standards,

18 mandatory amended standards. In this analysis DOE

19 considered five policy alternatives to mandatory

20 standards, and then compared those to the base case

21 of no new regulatory action. So those five policy

22 alternatives included consumer rebates, consumer tax
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1 credits, manufacturer tax credits, voluntary

2 efficiency targets, and bulk government purchases.

3 And again the output of the analysis is in NES and

4 NPV for those non-regulatory alternatives, which are

5 then compared in their potential impact to

6 standards. And the results of that analysis are in

7 Chapter 18.

8 MR. BROOKMAN: Alex Boesenberg?

9 MR. BOESENBERG: Alex Boesenberg, NEMA. I

10 would like to ask a question about ImSETS, Karina.

11 Does ImSET or maybe it is somewhere else in the

12 employment analysis is there any consideration given

13 to the type of job gained or lost in terms of its --

14 I am not sure what to call it, associated affects or

15 trickle down affects depending on characteristic

16 behaviors or social behaviors within a sector and to

17 help explain my poor question, explain it such as

18 evidenced by the heavy investment by the State of

19 North Carolina in the Research Triangle Park area to

20 bring technology jobs in and the belief and the

21 publication of numerous claims by the state that it

22 has improved the quality of that area because people
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1 in tech jobs also encourage their kids to do more

2 after school activities or want to go to the big box

3 store and buy more gadgets and they can do that

4 because they are in a more educated or more

5 productive job. Is there any weighting given to

6 different jobs or is it just straight numbers?

7 DR. GARBESI: There are probably other

8 people who are more expert in ImSET than I am here.

9 I believe the answer to that is no, that it is

10 really just looking at kind of flow of money through

11 the sectors and the labor intensiveness of the

12 different sectors and calculating the change in the

13 numbers of jobs.

14 MR. BOESENBERG: Thank you. That is what

15 I've also found. I was hoping you'd have a

16 different answer.

17 DR. GARBESI: Do you have a better

18 understanding of that?

19 MR. BOSENBERG: Alex Boesenberg again. It

20 is just I think if we are going to spend time on

21 social costs of carbon its worth these social costs

22 of jobs. I am sorry I don't have an answer or data
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1 to submit but if we undertake one, we should

2 undertake the other.

3 MR. BROOKMAN: Okay. Let's go to the

4 proposed standard.

5 DR. GARBESI: So Aisha Husain from

6 Navigant will take over here.

7 MS. HUSAIN: So the next few slides are

8 just the summary of the standards being proposed

9 today for GSFLs and IRLs. This basically summarizes

10 the proposed standard for GSFLs which is TSL5 and

11 the associated efficacy levels.

12 And this shows the proposed standard for

13 IRLs which is TSL1 and the associated efficacy

14 levels.

15 And then just in summary of the proposed

16 rule and its impacts the products, this just shows

17 that so for the products shipped over a 30 year

18 analysis period it results in energy savings of 3.5

19 quads for GSFLs at the proposed standard level of

20 TSL5 and .013 quads for IRLs at TSL1. The NPV for

21 product shipped is 3.1 billion at 7% discount rate

22 and 8.1 billion at 3% discount rate for GSFLs. It
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1 is .18 billion at 7% discount rate and .28 billion

2 at 3% discount rate for IRLs over the 30 year

3 analysis period.

4 And I think that is about it. I don't

5 know if you want to --

6 MR. BROOKMAN: And so as we promised at

7 the outset an opportunity for anybody that wishes to

8 make concluding remarks.

9 Joe it looks like you want to make a

10 concluding remark.

11 MR. HOWLEY: No. My only concluding

12 remark is that I appreciate the ability to discuss

13 this rulemaking today. And I believe that some of

14 the levels being proposed as you have heard are very

15 high and represent problems, challenges, pain,

16 however you want to describe it for the industry.

17 We will be providing some more written comments to

18 provide more information on this. Thank you.

19 MR. BROOKMAN: Thanks Joe.

20 MS. HUSAIN: Just wanted to also note the

21 June 30 comment period close date.

22 MR. BROOKMAN: Additional final comments?
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1 Andrew DeLaski?

2 MR. DeLASKI: I just want to echo my

3 opening remarks which is that we strongly support

4 the proposed rule particularly for GSFL and that the

5 savings are very large on a national basis and I

6 really appreciate the engagement from the industry

7 on the sort of helping us all to develop a better

8 understanding of the facts on the ground and of the

9 consultant in DOE who I think have done a tremendous

10 job in this docket to develop a very strong record.

11 So I think I look forward to seeing a final rule in

12 a timely way, one that will be similar to the

13 proposed rule. Thank you.

14 MR. BROOKMAN: Thanks to all of you and do

15 you wish to --

16 MS. deBUTTS: This is Lucy deButts. I

17 just wanted to say thank you again to everyone. It

18 was a very informative meeting. And as a few of you

19 mentioned there is information going to be provided

20 to us which will be helpful to finalize analysis and

21 our comment period ends on the 30th. So thanks

22 everyone for coming.
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1 MR. BROOKMAN: Garry Fernstrom?

2 MR. FERNSTROM: Garry for the California

3 IOUs. I'd just like to say for the record we

4 support Andrew's comments. Thank you.

5 MR. BROOKMAN: Thank you.

6 (WHEREUPON, the meeting was

7 adjourned.)

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7 proceeding using the Court Reporter's notes and 

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$

$.18 178:7

$.28 178:8

$1.3 237:19

$17 237:20

$2,639 237:13

$3.1 177:5

$6.1 229:11 238:3

$65.4 229:12

$75 238:3

$8.1 177:6

0

013 242:20

1

1 1:12 3:7 34:4

60:2 61:7,8 62:7

66:4,9 86:19

1.0 200:20

1.15 200:19,20

1.52 229:5

1/4 185:1 186:19

1:30 155:20 156:5

10 30:15,16

10% 81:10 82:1,6

83:5 93:19,20

104:19 107:9

109:17 130:14

148:19 161:17

197:3 199:15

10:30 4:9

10:45 7:6

100 70:15

100% 91:5

1000 1:14 105:19

225:15

102% 94:10

103 139:2

105% 94:10

1070 104:7

108% 94:10

11 136:15 179:1

11.8 237:1

11:00 102:16

103:4

1120 105:5

115 11:18

1170 107:10

12 8:21,22 33:20

57:3 112:14

119:2 136:15

179:1 213:22

214:1

12:30 155:19

120

35:13,16,17,21

41:17 43:22

44:3 122:22

123:8

1200 107:16

125 103:18

13 29:4 138:22

13/1000 178:7

130

35:13,15,16,18,

19 36:1,2 37:7

41:5,17

43:13,21 44:3

54:12 122:22

123:3,9,10

130s 87:18

1400 139:5 140:15

15 93:21 102:17

136:16

147:13,15

151:10 226:3

15% 41:6,7,14

122:19,21

123:10 206:4

15.5% 122:20

1500 104:8

105:8,16

16 93:21 106:1

152:5 238:18,19

1614-1 1:11

17 239:12

17% 93:22 152:5

17.8 104:7

170 177:1 235:16

18 27:2 238:18

240:7 243:1

18.5 105:1,6

187 239:5

1939 174:11

1970 78:3

1975 21:3

1992 16:19 19:5

21:2

2

2 59:22 81:4 85:20

86:20

2% 100:11,13

2.5 35:9,10

36:9,17 103:18

2.5% 236:22

2.8 235:18

20 103:4 108:3

118:6,8 163:9

20% 134:18

2006 224:15

2009 13:22 14:11

21:11,12 48:22

209:15

2010 179:11

2011 21:20,21

22:18 80:20

130:18 136:11

179:11

2012 21:16,17

22:11 181:17

238:4

2013 21:22 22:22

179:16 180:16

181:19,20

2014 1:12 3:7 23:5

2017 23:11 156:21

233:21

2030 17:5

2046 156:21

205 26:14,15,21

2050 238:7

20585 1:15

21 89:7,10

118:5,10 226:2

210,000 177:2

235:17

2200 139:2

23 14:10

24 188:21 229:10

231:7

25 66:22 94:22

171:9 204:5

25% 134:19

250,000 235:19

2500 105:2,8
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26 232:14

27 120:7

27% 203:16

28 22:21 60:21

66:21 94:22

171:8 204:5

243:1

29% 135:2 138:20

141:2,5

2-foot 19:21,22

24:4 34:1 45:5

57:8 59:18 65:6

99:19 100:2,15

3

3% 100:15 177:6

178:8 236:21

237:6 242:22

243:2

3.1 126:2 242:21

3.5 176:21 242:18

3.94 134:21

3:00 7:15

30 10:10 94:21,22

137:18 156:20

169:10 170:9

176:2 203:18

242:17 243:2,21

30% 93:14 161:21

201:12

202:16,22

203:6,15,17

3000 106:2

30s 45:2

30th 244:21

31 102:2

32 77:6 102:7

171:8 197:1

204:12 235:17

33% 134:12

35 173:1

36 227:11

39 84:6

39.7 237:2

4

4 24:5 81:4 82:13

84:21 99:6,7

101:11,18

148:22 149:9

161:18 175:6

4.2 126:3

40 26:14,21 220:1

40% 52:14 203:10

4000 106:2

4100 100:9

4200 105:6,9

429.27 30:17

430 30:15

44 103:8

4500 33:4,5,6 57:7

99:20

4-foot 24:3 61:15

68:5 80:22

81:13 85:22

99:21 100:1,11

149:5 150:14

161:14 163:1

175:6

5

5 82:16 84:22

5% 100:12,14

130:15 135:3

137:17 138:17

184:13 212:8

223:13 236:21

5.1% 136:20

5.2% 136:21

5/8 60:2 61:7,8

62:7 66:4,9

5/8th 34:4

50 17:5 203:4,9

50% 92:15

203:17,18

5000 100:9 101:12

50s 174:9

55 44:4 104:22

105:3 111:19

594 93:13

5A 109:11 120:11

5C 119:4

6

6 3:21 82:20 99:7

101:12

6% 93:17

100:1,13

101:11,14

6.2 120:7

6.3% 136:20

60 44:2,3 104:4

111:18 137:16

204:11

60% 203:5

60PAR 118:4

60s 174:9

61.2 237:3

65 16:14 121:19

6500 100:9 101:13

7

7 100:19

7% 161:2

177:5,14 178:7

242:21 243:1

70 200:18

700 25:22

730,000 235:19

78 200:20

8

8 150:4

8% 101:12

8.1 242:22

8.5% 205:20

80 224:7

80,000 72:9

800 107:15

85% 130:13

144:3,11

861 136:9

88 200:20

89 87:8,9,11

91:3,10

8-foot 24:4 57:17

100:12,13

151:19 154:22

167:20

9

9 114:12

9% 128:9

9.6% 154:17

90 115:19

213:14,21 214:1

90% 95:1 112:3

90.1 145:4
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90+ 214:2

92 198:18

92.4 86:6,22

95:21,22

95 11:17

95% 94:9 212:9

223:16

95th 237:5

963 107:10

980 105:1

A

ability 86:5

119:19

180:11,22 182:6

228:17 230:3

243:12

able 8:14,16 18:4

24:21 36:21

37:6 42:8 43:14

64:6 65:11

66:11 113:7

117:7 139:10

180:17 189:16

193:2 215:10,15

228:14 230:7,10

231:12 232:9

absolute 215:5

absolutely 69:8

75:16 91:15

183:20 231:2

absorb 43:14

absorbs 34:19

academic 123:15

accelerate 183:2

accept 217:4

acceptable 43:15

73:6 105:17,18

115:17

acceptance

221:16

accepted 59:11

access 228:12

accessible 8:10

accordance 30:14

according 158:14

account 27:21

64:5,7 78:13

84:8,18 88:21

89:1 97:17

99:18 100:5

133:19 138:9

183:12 200:3

accounted 180:8

accounting 82:8

176:7

accounts 138:3

235:8 239:5,6

accrue 176:2

accumulate

151:13

accuracy 82:17

113:22

accurate 11:14,19

112:10,20

accurately 86:6

achievable 132:20

133:2

achieve 178:2

189:16

achieved 14:1

132:18 157:1

159:13 177:3,17

achieves 82:4

achieving 48:7

acknowledge

55:13 128:4

acknowledged

43:21

acknowledges

182:8

across 14:20

22:10 78:7

119:19 133:20

137:22 139:4,6

148:22

149:12,20 150:4

151:19 152:6,10

239:2

Act 21:1,2

action 239:21

actively 31:10

activities 241:2

actual 67:16 90:7

128:22 184:11

220:5

actuality 127:10

actually 4:5 11:21

36:8 40:19

41:17 46:16,17

55:6 61:3

87:17,22 89:2

93:2,19 94:15

121:17 123:6

143:19 144:8

145:17 161:5

163:6 169:7

182:12 186:7

190:18 192:18

198:7 203:8

205:4 210:20

219:13 239:15

add 79:11 146:20

168:13 190:21

230:1

added 81:17

128:9 210:19

adder 41:6

addition 28:22

134:21 176:15

188:6 219:1

additional 12:20

20:9,16 21:8,14

24:21 25:4,6

29:17 31:15

44:20 56:3

67:21 72:22

98:19,21 102:1

120:22 122:15

123:13 124:18

128:9,12,18

143:2 147:2

153:16 155:17

173:1 185:2,15

191:9 210:12,17

211:2,11

215:11,15

226:11,14

230:16 233:12

234:16 243:22

Additionally

120:17

address 11:1 16:9

17:6 19:17,19

20:7 28:17 29:1

30:3 52:9 62:14

66:17,20 114:13

addressed 79:1

210:9

addressing

16:11,19,20

112:10

adequate 83:22

adequately 114:8

adjourned 245:7
Capital Reporting Company

GSFLIRL Meeting 05-01-2014

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www.CapitalReportingCompany.com © 2014

adjust 200:2

adjusted 84:8

85:5 113:11

120:6

adjustments 80:7

84:19 148:17

Administration

225:14

adopt 21:7

adopted 21:14

23:9

advantages 49:2

adverse 32:9,10

46:7

adversely 102:5

123:22

advise 67:8 202:2

AEO 136:10

205:13

AEO's 205:10

aesthetic 67:9

Affairs 5:8

affect 41:14 102:9

124:4 180:7

184:3

affected 70:8

102:6 124:1

affects 106:9

240:14,15

afford 73:3,7

171:9 222:1

afternoon 176:19

against 32:6 45:12

84:17

age 83:14 159:20

agencies 236:15

agenda 3:21

6:21,22

ages 73:19

aging 83:6,8

144:16

ago 138:22 175:1

agreed 236:15

agricultural

236:10

ahead 94:9 106:18

123:16 143:15

184:6 214:11

aimed 26:1

air 8:4

Aisha 2:4 6:1

31:17,20 66:2,3

118:15,16

172:11,22

175:4,5 242:5

Alex 2:8 5:7

12:6,7 14:4

37:18,19

39:19,20 40:17

48:17 54:17,18

60:15,16 61:21

62:18 63:4

71:22 72:1

73:13 75:4,5

97:18,19 173:9

181:6 189:22

190:1 228:2,3

240:8,9 241:19

Alliance 6:13 78:1

allow 121:9

127:10

allowable 83:20

allowed 152:21

allowing 12:9

allows 133:19

158:16 161:8

192:6,7 217:2

alone 180:12

already 3:21

15:21 16:10

20:21 25:7

29:13 40:3

42:18 47:9 49:5

50:5,8 52:4

55:22 66:11

80:14 84:16

93:13 102:16

140:15 164:10

174:18 183:11

186:1,3 187:4

192:15 200:12

209:19 211:1

212:2,3,15

216:21 217:5

221:12 225:6

234:14

alternative

178:14,18,21

179:18 183:16

184:13 185:2

187:18,21 189:7

191:21 205:7,15

alternatives 114:9

239:16,19,22

240:4

altogether 139:3

am 4:17 5:7,14

6:7,21 9:18

31:21 38:16,19

43:8 46:21

48:16 54:7 56:8

60:18 62:5

70:4,7,12,13

72:17 74:3,4

84:6 86:18

88:12 90:6

94:3,5 95:17

96:2 97:1 99:5

102:12 103:10

108:6 109:22

110:11 111:16

116:9 126:7

128:1 137:15

138:8 139:9,11

140:22 141:1

142:10 144:6

145:21 146:4

151:1 152:3

153:22 156:12

160:19 164:17

165:6 170:10

171:13,15

172:3,9 181:5

182:18

187:12,13

203:14 210:16

211:16

212:1,3,13,15,2

1 213:15 220:10

221:17 222:5

223:4 227:13

240:14 241:8,22

246:4

amended

21:2,7,13

207:20

209:12,19,22

235:7 239:17,18

American 152:4

among 67:12

158:13

amongst 115:9

amorphous 225:2

amount 14:21

29:5 60:9

69:8,9,11 73:18

169:5 171:1

180:18 186:7

187:10 189:15

190:4 191:6

193:6 210:19

211:3,11 212:11
Capital Reporting Company

GSFLIRL Meeting 05-01-2014

Page 5

(866) 448 - DEPO

www.CapitalReportingCompany.com © 2014

213:2 219:20

231:22 234:2

amounts 181:13

analogies 230:4

analogous 194:14

analyses 7:14

21:22 26:18

129:17 131:16

133:10,14 147:8

156:15,16

160:11

178:15,18 205:7

234:19,22 235:1

analysis

7:4,5,8,10,11

9:13 13:2

22:2,19 23:9,18

25:8 26:18

29:21 31:19,22

32:1,13 34:7

38:11 40:6

45:8,11,14

47:22 54:11

56:6,9,18

57:2,16 58:11

59:4 60:6 63:7

64:1,3,9,16,22

73:5 75:19

76:12 79:2,21

80:8 81:17

82:10 86:15

92:12 97:8,16

99:11 100:7,20

101:20 103:14

106:2,4,6,8

109:2,12

112:1,3,8,9

115:8 116:13,21

120:9 129:6

130:11,20

131:21 132:20

133:2,13

135:7,20

136:18,22

137:4,18

138:2,3,9,10,12,

19 141:3 145:13

146:1

147:4,5,10,13

148:4 151:11

152:16

153:10,20

154:3,10,12,13

155:4,10

156:10,11,19,20

,22 157:8,17,21

158:1,6,7

159:7,11,14,17

160:9,10,18,22

161:1,4,7,21

162:5 165:6,13

166:8,16,19

167:4 170:6,14

171:17,20

173:22 174:2

175:12,18,21,22

176:2,15,22

177:13,20

178:3,11,16,18

179:14,18

182:14

184:3,13,16,21

185:2,3

187:6,21

188:18,22

189:5,7,12

190:7

191:2,15,20,21

192:9 195:22

196:5,8 200:9

205:8,9,17

206:9,13,16

208:7,11,17

218:9,10 222:2

227:1

235:1,4,20

236:9,15

237:12,14,22

238:12,17,21

239:8,14,18

240:3,6,12

242:18 243:3

244:20

analyst 163:13

analytical 57:5

103:16

analyze 9:22

56:13 61:17

72:12 88:13

111:9 141:20

196:11

analyzed 40:11

41:3 56:22 57:6

58:9 61:10,12

65:1 80:9,17

81:3,6,17 100:7

120:5 125:9

132:7 134:3,16

135:4 151:7

182:11 214:14

216:8

analyzing 112:19

and/or 24:22

Andres 5:18

Andrew 2:5

13:15,16 27:3

28:9 50:14

52:21 58:18

61:20 65:7

66:18,19 85:3

107:1 112:22

114:15 115:2

145:19 146:14

165:4 177:10

186:17,21 218:7

228:4 233:4

244:1

Andrew's 20:14

54:10 245:4

annual 17:1,3

133:20

134:1,8,10

147:6 177:16

208:8

ANSI 57:21 58:14

59:4,9 84:15

124:15 128:21

204:8

answer 40:13 73:7

89:2,3 138:8

152:20 164:8

193:2 214:7

241:9,16,22

answered 85:2

anybody 114:13

139:9 140:11

201:1 216:20

231:10 243:7

anyone 7:1 79:12

152:22 180:2

210:7

anything 76:21

146:22 185:15

227:20

anytime 72:17

anyway 39:7 40:6

apparently 4:14

appeared 18:9

appears 65:10

appendix 30:16

109:11 119:4,8

120:11

apples 95:20 99:1

204:16

appliance 5:18

13:17 70:11

145:16

application 27:9
Capital Reporting Company

GSFLIRL Meeting 05-01-2014

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www.CapitalReportingCompany.com © 2014

60:3 66:5

115:20 117:21

133:22 168:6

190:3

applications

25:18

27:6,13,16

33:17 63:12

66:6 80:12

125:10 157:15

159:9,10

168:1,3 170:12

192:20 196:4

199:16 203:8

205:18

applied 127:13

130:13 136:9

146:15 170:2

applies 26:5,9

apply 94:5 99:13

120:18 127:13

139:6 140:17

170:5

applying 49:2

apportions 158:12

appreciate 15:13

42:12 43:5

55:11 73:13

143:1 221:3

243:12 244:6

approach 36:12

49:4,10 94:6

95:7 107:20

131:1,5,10

147:19 148:3

approaches

121:21

appropriate 30:21

100:2,16

112:17,20 128:8

131:11 142:15

200:8 212:18

approximately

132:16 136:14

147:15

April 22:1 23:1

architectural

170:21

area 20:5 39:15

53:7 83:16,18

109:1 116:17

117:17 211:8

240:19,22

areas 227:2

aren't 16:18

40:13,16 98:19

102:11,20

159:15 167:14

189:20 231:11

argon 47:7

198:1,3,22

202:10

argue 41:21

77:15,16

arguing 76:7

argument 39:21

42:18 164:2

182:19

arguments 17:14

arms 28:13

arrangements

131:10

ASAP 20:13

ASHRAE 137:22

145:4,21

aside 111:3

aspect 174:6

197:11

aspects 234:11

assess 135:7 207:4

assessed 45:12

128:7 134:5

135:1

assessing 186:5

assessment 31:19

32:2 139:12

192:2 236:17

Assessments 7:4

associate 4:22

associated 80:3

119:17 120:3

127:8 134:14

219:21 235:22

236:10 240:14

242:11,13

Association 5:9

assume 89:22

148:16 150:16

171:18 187:22

219:3 238:9

assumed 53:1

58:5 134:12,18

144:3 159:22

166:19 175:13

179:19 185:4

196:5 218:11

assumes 134:16

160:11 191:2

206:4 218:17

assuming 170:9

194:5 200:5

236:21

assumption 102:3

123:20 126:16

129:16 144:2

158:1 162:20

164:11

166:15,22

171:16 188:18

189:12 190:14

196:2 204:21

205:16 228:15

231:19

assumptions

134:11 147:4

159:4 160:4

173:4,6

178:16,17,19

191:16 192:11

195:21 205:15

206:8 218:20

assure 11:10

118:21

attempt 38:11

62:19 76:1

108:22 179:21

attempted 231:18

attention 88:10

attenuated 162:1

attenuates 159:12

attractive 184:5

attributes 51:17

102:8 124:3

audible 96:22

authorized 21:5

automated 188:20

availability 48:6

126:8 174:19

175:1 180:12

181:21 192:19

199:15

available 18:1

27:10,12,18

38:1,4,5,8

40:13,15,16

42:15 46:3,20

48:3,11 51:5,9

52:16 57:15,22

58:7 63:3 79:6
Capital Reporting Company

GSFLIRL Meeting 05-01-2014

Page 7

(866) 448 - DEPO

www.CapitalReportingCompany.com © 2014

80:2,6,10 99:19

104:18 105:13

107:21 109:7

110:13

113:14,17

120:2,5 121:5

122:3 126:2

139:8,13

140:10,15 163:9

180:20 182:1

187:11

189:18,19 190:8

191:7 192:15

195:14 198:6

208:7 225:16

Avenue 1:14

average 99:22

130:11

134:1,13,19

136:8 147:14

148:9 149:9,17

150:1,10 151:22

152:6,13 162:15

179:18 201:14

236:19,22

averages 137:10

avoid 12:16 39:11

75:1

avoided 177:8

aware 88:11

102:20 163:17

179:5 196:3

225:19

Awareness 5:19

13:17

away 92:16

209:20 210:1

awful 139:10

B

bad 131:20

203:13

badge 102:18

155:21

bag 17:14

balanced 73:1

ballast 14:13,21

80:17,20,21

81:1,2,5,6,7,8,1

1,14,16,21,22

82:4,14 93:20

95:3,5,6 97:5,15

130:17,18

134:13,16

136:7,11,13

143:6,8,9

144:22 146:4,5

147:14

148:12,15

149:15 150:8

151:11 159:22

160:2 164:13

190:8,19 191:12

192:21

195:13,18

196:19,21

197:2,4,7,8

199:7,14,19

200:1,2,9,15,17

201:2,3 203:6

205:2,5

ballasts 81:4,11

159:18 190:19

195:1,19,20

204:22

Ballo 2:4 5:20

12:21,22 26:22

27:1 84:4,5

Baltimore 3:10

bar 44:15

barber 67:5

barely 52:5

barriers 123:2

base 59:10 70:6

118:7 161:15

162:6,16 168:22

169:4,5 176:6

187:6,8,22

188:5,7,10

191:8 194:17

195:2 196:20

198:1 215:1,5

239:20

based 15:9 18:9

19:22 22:13

25:2 32:15

34:7,9 47:13

51:9 56:17

57:19 79:6 83:9

84:13,19

89:7,21 90:16

91:16 103:20

116:15 119:15

120:12

130:6,10,12

134:15 147:13

148:9 149:9,18

151:11 158:7

164:6 172:2

180:16 189:4

196:7,16 198:3

201:11 214:3

225:21 227:1

238:12

baseline

56:14,16,20

57:11,12

58:5,8,16

68:2,4,22

82:2,3,6 103:21

104:9,13,19,20,

21 105:8 107:9

109:18 111:12

119:14 133:12

135:17 136:1

147:6,10

148:12,19

149:15 173:17

175:7 185:4,7

188:7

baselines 57:17,21

58:9 68:9 81:10

94:4

basic 30:13,14

208:4

basically 17:12,13

29:19 163:13

173:19 227:16

235:5 236:16

242:9

basing 126:15

147:5,9

basis 15:5 57:10

213:8 217:22

244:5

bathrooms 102:21

bathtub 174:14

beam 116:2

beat 43:3

become 42:15

47:11 117:18

161:19 198:6

becomes 92:13

164:16 178:1

begin 13:20

beginning 9:19

63:11 174:11

behalf 83:13

behave 117:13

173:12

behaviors 240:16

behind 29:12

behold 39:10

belief 240:20
Capital Reporting Company

GSFLIRL Meeting 05-01-2014

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(866) 448 - DEPO

www.CapitalReportingCompany.com © 2014

believe 8:17

17:7,11,18

20:1,6 48:3 61:1

72:4 78:16 79:5

101:16 103:8

111:7 112:9

114:9 117:1

121:9,15,20

122:2 141:3,8

152:18 163:5

172:6 182:2

186:16 241:9

243:13

beneficial 83:15

benefit 15:7 75:18

177:9

benefits 15:12

132:7 152:22

Berkeley 6:8

156:13

best 52:11,12

70:17 96:12

216:15 223:14

231:19

better 15:16 18:19

19:11,14,16

20:4 52:11,12

62:4,19 71:2

79:7 97:2,13

110:1,7 118:2

196:11 202:5

216:15 231:4

241:17 244:7

beyond 55:4

115:7 166:20

238:7

bias 78:6

89:11,12,19

bigger 183:17

194:14

biggest 180:14

183:1

bill 17:1,3

billion 17:2,3

177:5,6 178:8

237:19,20

242:21,22 243:1

billions 15:1

bin 110:14

bipin 24:3,5 68:5

81:1,14 86:1

99:21 100:2,12

148:22 149:5,10

161:14 163:1

Bipins 161:19

bit 13:1 23:14

54:18 64:1,21

65:9 84:10

101:5 110:3

113:1 116:5,6

126:1 142:20

158:2 168:4

175:10 184:16

197:22 204:4,20

211:3,4 219:18

222:17 225:1

blue 160:20 189:4

bluebook 130:5

Boesenberg 2:8

5:7 12:6,7

37:18,19 38:20

39:19,20

60:15,16 61:8

62:1,12,18 63:4

71:22 72:1

75:5,15 97:9,19

189:22

190:1,10,20

191:13,22 193:9

228:3 240:8,9

241:14,19

BOESENGBERG

191:5

bold 25:19

BOSENBERG

5:7 241:19

bottom 96:2

215:22 217:14

box 10:6 59:13

63:17 84:21,22

229:3,4,10,16

232:14

233:16,22 241:2

boxes 10:3 84:2

147:22 217:3

229:1

BP 107:12

BR 16:15

39:10,11

BR30 115:16

116:1,4

121:14,15,20

break 7:5

102:15,17 130:1

156:6

Brian 2:3 6:7

96:20,21 112:1

138:11

156:11,13

173:9,16

brief 6:21

briefly 170:1

177:11 206:21

bright 93:18 94:3

167:18

brighter 93:20,21

bring 7:19 27:3

59:18 60:1

132:15 240:20

broader 27:20

broadest 13:7

Brookman 2:2

3:2,9 4:13 5:6

6:9,14,17 8:22

10:18 12:3,18

13:14 20:8,15

26:22 28:2,8

29:17 30:1

31:15 34:5,12

36:6 37:3,18

38:14 39:1,19

40:9 42:10,22

44:19 45:6 46:8

47:19 48:15

49:8,20

50:13,20

51:14,19 52:8

53:4,18

54:2,5,7,14 56:2

58:18 59:13

60:15 61:18,20

62:3,14,16

63:8,15,21

64:19 65:7

66:1,15 67:20

68:12 69:22

71:5,21 73:11

74:2,10 75:4

76:16 77:19

79:10,16,22

83:1,11 84:2,21

85:3,18 86:13

88:17 90:14

91:21 92:18,22

93:4 95:14

96:4,20

97:3,10,12,18

99:5 100:22

101:22 102:14

103:6,11

104:11,14

105:10

106:17,21

109:21 110:7,22
Capital Reporting Company

GSFLIRL Meeting 05-01-2014

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(866) 448 - DEPO

www.CapitalReportingCompany.com © 2014

112:5,22

114:4,11

115:2,12 117:22

118:13 119:11

121:2 122:13

123:5,13,18

124:6 125:3

126:20 127:2,4

128:2,13

129:3,8,12,18

130:21 131:2,13

132:3 137:14

138:5,15 139:17

140:1,5,19

142:5,22 143:14

144:4,12,14,18

145:10 146:2,12

147:1,17,21

148:6

150:11,20,22

152:8,14

153:14,18

155:1,3,17

156:8 163:3,11

164:18 165:4

167:5 169:9,20

171:10

172:11,13,15,21

175:3 177:10,15

180:2 181:1,4

182:15 183:19

184:6 185:14,18

186:17,21

187:14 188:15

189:22 192:22

193:12

194:3,7,12

195:4 196:13

198:15 199:11

200:10

201:19,21

202:19 204:2,18

211:13,22

213:4,9,21

214:4,7,10

216:5,12

217:9,18

218:5,7 220:4

222:11,21

223:7,20 224:16

225:3,10

227:12,20

228:2,8,22

229:21 230:13

231:6 232:13

233:4,12

234:4,7,13,17

238:8 240:8

242:3

243:6,19,22

244:14 245:1,5

brought 59:20

build 212:22

213:1

building 1:15 3:8

33:11 94:8 95:4

97:16 102:20

103:2 133:21

137:1,7,8

139:12 145:2,20

154:7 155:21

188:19,22 219:8

buildings 137:21

builds 13:22

built 169:1

bulb 13:6 114:2

144:8

bulbs 43:18

bulk 240:2

bumps 189:17

bunch 124:21

burden 48:4

234:7

burdens 132:7

Bureau 136:12

burn 105:19

106:1

burner 124:12

125:6,7

127:7,14 128:11

burners 126:16

127:8

burnt 144:8

business 38:1

46:18 98:13,18

207:8 224:14

225:13,14

226:2,9,17

227:3,14

businesses 131:7

225:13,17,19,21

226:1,3,4,5,11,1

3 227:2,6,10

Butler 2:3 5:21

buy 17:22 18:4

43:17 72:15

76:11 77:5

124:20 131:19

145:14 193:3,6

223:15 241:3

buyers 15:19

buying 72:13

115:1 182:19

224:20 227:15

C

cafeteria 155:22

calculate

136:12,17

238:15

calculated 58:1

133:15 134:15

136:3,8,13,19

143:21 154:17

235:10

calculates

135:18,21

239:15

calculating

134:21 241:12

calculation 64:8

137:5 176:18

calculations 70:6

154:9

California

4:18,20,22

10:21 17:9

20:12 28:4 31:2

39:2 63:9,12

70:1 83:3,13,19

93:6 95:4 129:4

131:4 137:20

138:7 188:21

199:13,17

230:16 245:2

Callahan 2:5 5:16

33:22 34:7 46:9

47:3,9 59:16

61:7 62:15 63:1

66:7 74:11

144:21 145:9

146:3,16 222:19

candidate

24:10,15

candles 171:1

221:21

capability 40:21

capacity 32:16

159:8 188:20

189:3,8,15

207:11 219:9

238:16

capital 209:13,16

219:6 226:9
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229:13

caps 228:5

capsules 35:8

capture 80:18

captured 174:3

capturing 166:11

carbon 235:16

236:6,9,10

237:8 241:21

care 77:7 92:8

careful 44:13

65:18

carefully 68:14

157:7 201:1

Carolina 240:19

carry 98:4 181:18

case 17:11 42:15

51:3 58:8 79:8

99:17 116:5

126:7 156:21

160:14 161:15

162:6,8,14,15,1

6 163:2 164:11

176:6 182:6

185:5,8,10

186:4 187:6,8

188:1,6,7,10

189:1

191:7,8,9,18

192:17 193:8

194:17,18 195:2

196:19,20,21

213:8 215:1,6

219:14 235:21

238:1 239:20

cases 27:7 43:19

65:21 94:15

106:6 112:13

127:20,22

151:22 152:12

154:19 161:13

188:1,6 196:22

203:10,14 213:5

228:11

cash 207:16,18

208:1,14 214:20

catalog 58:13,21

59:1 82:17

84:14,16

85:9,11 99:22

101:8 108:8,12

120:1,3

catalogs 18:21

59:8

categories 18:22

60:21 101:20

category

16:4,8,20

18:11,13,15,16

20:2,6 32:18

36:9 60:1

61:3,10,13 72:5

104:13 105:13

106:3 115:15

cathode

204:12,13,17

cause 162:22

167:1 169:4

188:19 197:6

209:4 210:1

226:19

causing 167:8

211:10

CBECS 133:18

137:3

CCE 89:6 90:2

91:17,18,19

CCT 22:9 32:22

57:7 99:18

100:5,6,8,9

101:5

CCTs 33:1,3,4,5

68:4 99:20

ceiling 33:17

167:20,21,22

168:1 171:1

cell 8:6

census 133:20

137:2 139:4

center 87:20

centers 122:7

central 86:20

certain 21:4 22:15

24:2 25:9,17

43:11 44:8 47:4

53:8,11 55:5

56:13 83:21

86:6 109:7

112:13 134:11

135:1 160:12

171:7

certainly 9:14

28:4 51:1 65:5

117:2,5 168:19

192:9 202:11

218:2

CERTIFICATE

246:1

certification

82:18 84:9,18

85:6,12,15

88:19 89:1

95:18

108:4,13,16,18

110:15 226:12

certified 11:7

30:11 88:20

89:20

certify 246:4

CFR 30:6,15,16

chain 224:19

229:5

challenge 98:4

164:3 224:12

challenges 243:15

chance 99:6

change 69:10

129:1 134:17

146:21 163:10

164:5,7

165:9,20 167:2

186:7,10 197:3

219:2,5 220:22

234:16 239:2

241:12

changed 111:13

changes 54:22

79:14 124:13

194:17 219:6

239:7

changing 15:5

161:10 193:21

194:20 201:5

231:9

channel 130:4,13

channels 130:7

131:9

Chapter 238:17

239:12 240:7

Chapters 179:1

characteristic

240:15

characteristics

58:4,6 68:3

81:16 102:5

109:18 111:12

123:22 134:15

characterization
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133:11,18 137:3

characterize

141:22

Charlie 2:9 6:12

20:3 74:5

77:19,22 110:22

111:1 131:13,14

138:15,16

139:17

140:5,19,22

141:10 142:2,9

146:12,13 147:1

182:15,16,17

183:20

187:14,15

193:12,14

202:19,20

211:13,15

219:18

chart 52:2 159:7

177:16 179:3

198:19

charts 178:9

check 140:4

172:12

checked 6:20

chemical 235:12

cherry 98:12,13

CHERYL

246:4,15

chime 181:19

China 92:8 209:7

Chinese 209:8

choice 4:1 15:19

16:2,12 78:19

115:20 157:11

158:3,11,12

162:21 164:13

197:6,8

choices 97:6,14

115:9 188:5

201:4

choose 81:19

94:11 196:6

227:2

chooses 77:2,7

103:14

choosing 187:9

chose 205:4

chosen 57:10

103:19 148:18

CIOUs 118:22

circline 24:19

circuit 41:18

142:18

cite 30:5

claim 38:9

claims 199:2

240:21

clarification 12:1

26:1 46:10 99:4

129:10 201:7

clarify 25:15

64:20 128:4

204:19 222:11

clarifying 25:18

class 32:14,18,20

33:8,14,21

34:16 35:1,12

36:5 37:14

56:15 57:8

58:1,7,9 65:6

72:5 74:16

76:18 77:15,16

81:3 82:10,12

100:8,12 103:19

104:1,4 119:20

132:10,14,19

133:8

149:3,5,10

154:21,22

158:20

162:11,22

165:16,17 173:2

classes 21:4

32:3,15,19

34:6,9 44:21

56:12,13,22

57:3,5,7,9,14,18

65:1 77:10 81:5

82:8 99:12,14

103:15,16

122:17,18

132:15 133:1,5

148:10

158:13,14,17

161:9 162:2,5

166:21

classifications

117:15

clear 70:4 193:15

222:8,9

clearly 50:2

152:22 172:6

193:3 202:3

218:20

close 4:15 112:3

142:11,20 182:3

189:20 243:21

closely 118:17

126:14

closer 141:6

closing 7:18 9:19

CO2 177:1

coated 71:15

coating 34:18

46:13 127:20

210:21

coatings 48:20

119:18 120:18

Cobalt 173:10,20

code 145:4,20,21

146:18

codes 95:4 97:16

145:2,8 188:19

coefficient 120:1

coffee 102:22

cold 80:12 169:17

colleague 56:5

102:13

color 32:21,22

51:18 54:22

224:7

column 59:6

85:20 235:14

columns 237:15

combination

14:12,15 55:10

132:20

combinations

47:16 97:6,15

combine 236:19

combined 14:1

combining 236:16

comes 165:7 170:4

coming 48:12

69:1,21 74:4

222:18 232:1

244:22

comment 4:2,8,12

10:9 23:8 29:4

42:12,22 45:2

49:22 53:6

59:13 61:17

63:16 68:9

76:20 79:16

82:13,16,20
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83:9,16

84:2,21,22

86:1,10 92:19

93:1,6 94:13,18

99:6 100:19

101:21 102:3,7

104:9 105:7,11

106:18 107:1

108:9,20 118:19

120:8 123:1,20

124:2,7,9

126:21 127:5

128:4,11 131:22

141:11 143:20

144:1

147:5,9,12,18,2

2 150:12 162:19

167:6 168:10

169:21 171:11

173:4,5 175:15

180:2 185:12,16

187:2 195:17

196:10,16

197:12 206:7

207:2 213:10

217:19

222:14,16 223:1

227:9 228:9

229:1,3,4,5,9,11

,17 231:14,16

233:3,16,17,22

238:5 243:21

244:21

commented 60:19

commenters

112:16

commenting

137:15

comments

9:5,7,16

10:2,4,5,11,12,1

5 12:15,20

13:18 17:10

20:9,14,16

23:5,7 28:14

29:17 31:15

34:14 37:2

38:3,13

44:14,20 45:3

52:4 53:14

55:15 56:3

58:16 59:14

60:18 62:20

65:5 67:21 83:3

85:19 94:2

100:22 101:3,21

102:1,12

111:12,15

114:12 116:16

118:22 119:8

122:11,12,15

123:13

129:15,18

130:21 137:12

139:19 143:2,12

145:7 147:2,3

148:5 153:8,16

155:3,15,17

173:1 175:18

181:8 184:9

188:16 196:7

210:7 218:6

222:8 227:12

232:13 233:12

234:11 238:8,10

243:17,22 245:4

commercial

14:6,7,14 15:3

48:6 55:3 93:11

105:16,17,22

106:5,12 114:18

115:6 117:12

121:6 123:4

131:16,18 135:3

136:15,19

137:17 138:18

139:12 142:15

144:7,10 147:8

149:6 152:16

153:20 154:17

155:9,12 181:14

205:20 206:2

209:22 221:15

commercially

46:3 48:3 51:9

57:15,22 58:6

80:2 99:19

104:18 107:21

109:7 110:12

113:14,17

117:16 120:2

commoditization

216:18

common 44:8

57:13,22 58:6

95:7 103:21

104:2 117:3

commonly 80:21

83:17 117:15,16

126:5

compact 125:6

companies 67:13

209:8 225:16

company

4:20,21,22

227:15 228:4

comparable 175:8

compare 64:4

compared 14:10

35:17 84:17

99:19 100:8

215:17 226:21

239:20 240:5

compares 239:16

comparing 99:22

188:7 204:16

comparison 99:15

compatibility

63:13 192:20

compelling 42:20

competes 116:4

complaints 67:4

complete 8:2 13:5

112:4 187:5

246:9

completed 21:9

completely 40:18

41:19 73:13

91:11 107:14

163:17 221:1

239:14

complexity 12:11

compliance 21:15

23:10 80:6 82:9

84:8 95:19

110:18 120:5

207:13 233:17

compliant 91:11

98:3 185:22

complications

142:18

complies 89:5

comply 110:5

119:19 120:14

209:14 229:14

234:3

component 161:7

components 130:1

135:13

composition

47:18 48:21

compositions 47:5

comprehended

183:21

comprehensive
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49:17

comprised 203:2

computer 48:1

computes 157:14

concept 113:20

concern 18:18

39:3,13,18 43:5

59:19 61:16

63:10 66:8 72:4

78:12,21

92:2,17 179:7

182:10 186:13

concerned 11:3

19:1 78:2 85:21

86:18 174:20

180:6 209:1,11

concerning

208:22

concerns 9:15

60:19 169:11

concession 72:7

concise 8:3

concludes 29:19

concluding

243:8,10,11

conclusions 34:9

116:15 149:4

conditions 40:8

194:20

conduct 21:5

38:10 238:20

conducted 9:13

29:21 135:9

145:6 178:14

206:17,21

207:22

208:10,16

conducts 234:21

238:11

confident

202:17,18

configuration

143:12

confirm 125:4

confirmed 26:19

100:16

confused 96:2

211:16

Congress 19:4

conscious 98:8

consequence

44:12 70:22

consequences

117:20

conservation 1:9

3:4 9:12

21:1,2,3 23:15

34:10 132:11,14

135:9

consider 17:16

23:16 25:5

94:13 107:18

109:14 115:8

121:8 143:17

144:10 145:8

151:6 186:2

196:9 205:1

231:20

consideration

7:22 25:12

85:12 99:16

119:15 167:17

231:1 240:12

considerations

73:1

considered 17:17

24:18 39:16

76:19 95:2,3

109:6 110:3

111:14 114:8

118:20 119:3

135:22 146:6

153:7 166:21

175:17

205:12,21 206:5

225:13 235:13

236:1 237:3

239:19

considering

17:8,11

25:14,18 28:21

40:4 109:12

137:19 141:7

237:7

considers 24:7

135:12 237:12

consistent 22:10

constant 179:15

constrained

212:20

constraint 33:7

51:4,6 151:10

constraints 34:2

75:21

construction

143:10 145:1

148:16 157:18

consultant 244:9

Consulting

6:2,4,6 31:21

37:9 66:4

consumed 69:9

consumer 4:1

51:16 55:3,4

72:15,22 77:2,7

81:18 105:15

114:18,22

115:8,21 116:3

121:6,8,22

135:8 154:13

156:18 157:11

158:3,11,12,15

176:1,9 177:7

220:8,13

221:7,15 239:22

consumers 15:22

16:2 17:2,21

35:13 43:11,16

53:12 64:6

66:10 72:8 73:3

93:22 97:7,14

102:10 114:17

115:14,22 122:4

124:5 154:3,5

157:4 158:17

161:8 162:21

164:9 176:11

177:22 182:2

187:7,8 188:3

189:16 196:5,9

204:21 209:19

215:11 221:20

222:4

consumer's 115:5

135:10

Consumers 43:17

consumes 73:18

consumption

14:8,9 25:1 36:3

64:12 73:19,20

82:3 133:12

134:8

165:10,11,13

166:3,7,10,14

176:5 180:10

193:5

contacted 225:22

contain 89:17

153:19

content 20:17
Capital Reporting Company

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context 60:17 72:3

continue 20:1

101:3 163:8

175:19 198:15

212:5 218:18

227:4

continued 17:18

179:17

continuing 168:15

198:17

contract 217:5

contractors

199:17

control 138:3

145:14 188:20

189:9,12 226:13

controlled 193:16

209:7

controls 135:4

141:13,17

145:3,6 146:8

189:2,3,4 190:4

191:2,3,17,20

192:4,15

194:4,16,21,22

198:20,21

199:4,5

conundrum 61:12

conversation

52:21 53:3

167:7 225:6

conversations 8:7

202:21 230:2

converse 61:4

conversion 121:1

183:22

226:18,20

229:12,13

231:8,11

convert 212:9

219:16

converting 232:10

converts 180:9

Cook 2:4,7 5:10

6:11 37:5,10,17

49:8,9 52:8,9

53:18,19 54:3,9

83:1,2 90:14

91:22 93:5

123:15 129:9

137:15 142:2

144:15 148:2

163:4 164:19

169:10 174:17

180:5 183:20

192:13

206:12,14 212:6

213:5 214:6,12

216:5,6,17

217:10 218:6,14

223:18 225:9,11

227:18 228:1

229:2 231:7

233:15

234:10,14,18

cool 71:9

copies 88:12

correct 29:14

60:17 70:9

141:2 165:15

166:5 193:18

194:8 246:9

correctly 44:16

125:9 190:2

correlated 32:21

corresponding

23:17 133:7

corresponds 10:7

132:11 134:19

149:2,13,21

150:5 151:21

152:11

corroborated

195:22

cost 7:8 52:14

53:1 55:1,4

72:11,13 73:4

75:18,22

76:2,5,13

106:10 120:14

133:10

135:10,13,14,15

145:13,17,20

146:10,20 157:5

158:9,10 162:20

164:6 169:4,5

170:2,4,19

171:22 172:6,7

176:8 186:15

187:3 211:1

215:3,15

217:1,7

219:3,15,21,22

220:5 221:17

229:12,13

230:6,10,18

231:17 233:17

236:9 237:8

costly 36:1

costs 76:15 79:3

98:21 121:1

134:5 136:7,13

146:15 158:15

169:1 171:19

176:12 188:4

204:17 215:2,11

216:11 219:4,16

221:7,22

226:12,15,18,20

230:3,6,7,11,21

231:3,4,8,11

232:7 236:6

241:21

Counsel's 5:22

count 165:8

counted 165:7

counter 168:12

217:22

country 43:12

88:3 138:1

163:9 233:1

couple 9:9 14:18

15:8,10 22:5

95:12 138:21

197:14 198:9

201:11

coupled 80:5

160:1

coupling 190:9

courier 10:13

course 4:7 8:5

9:19 10:13,14

15:20 22:11

114:3 161:22

165:2 174:11

184:1 232:17

Court 246:5,7

cover 17:1 24:1

57:1 184:9

coverage 23:22

24:8 25:4 26:7,8

covered 7:20

16:14,19 17:9

18:11,13,14

19:1 24:19,20

25:7,9 32:15

59:22 102:16

107:17

112:12,15

114:21 115:7

123:6 176:19

185:14 234:15

covering 19:22
Capital Reporting Company

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CR 213:21

crafted 201:1

create 38:18 75:2

77:10 117:14

created 42:14

47:22 208:13

228:11 230:6

creates 36:19,20

101:7

creating 15:5

16:16 39:6

230:14

credit 182:14

192:2 199:8

creditable 11:11

credits 240:1

CRI 19:4,5,8

27:4,13,19 29:2

49:15 58:4 68:4

213:14 214:1,2

crimps 228:5

criteria 32:6,11

45:12 104:17

109:19,20

111:11,13

113:2,9,10,12,1

4 225:11

critical 117:18

173:13

crucial 15:11

CSL 107:4

CSU 17:4

cue 228:22

culminating 7:14

cumulative

160:13,15,17

161:6 177:18

235:6,10 237:21

curious 46:21

70:21 171:15

213:15

current 22:6 40:1

48:22 52:2

100:17 167:3

181:14 188:18

195:18 202:4,6

224:2

currently 24:1

60:7 124:17

132:13 211:20

curve 53:1,2 98:6

158:7 160:9

161:4 221:15

curves 159:21

customers 67:12

152:17 230:8

cut 54:15 186:18

cycle 7:8 21:18

76:13 133:10

134:5 176:8

235:9

cycles 21:5,10

72:13

Cymbalsky 2:2

3:12,13 30:2,3

31:9 38:14,15

51:19,20 52:19

138:21

D

D.C 3:8

damage 236:11

damages 236:10

dampening

183:14

danger 55:22

darker 57:6

103:19

data 9:21 20:3

75:8 79:12,18

80:6 82:18 83:6

84:17,18

85:6,9,11,13,15

87:1 120:2,5

129:6 133:18

136:9 137:4,5

139:8,11,12,15

140:4,8,14,16,1

7

141:12,14,20,21

142:10 154:4,5

163:7 237:15

241:22

database 11:2,12

86:18 87:1

88:14,19

89:4,9,17 90:7

95:18,21 96:8

108:18 140:10

date 23:8,10

207:13 221:14

243:21 246:15

Dave 2:7 5:12

43:1,2

54:5,14,16

140:5,19,21

143:1 144:4,5

145:10,11

152:2,8,20

170:15 181:4,5

219:11

222:12,13

223:19,21

David 2:10 223:1

day 3:14 6:19 7:17

10:22 68:18

106:1 156:4

189:9

days 71:9 138:21

DC 1:15

dead 43:3 97:1

deadline 29:8

deal 43:14 44:7

dealing 201:15

dealt 83:15 173:6

debutts 6:16 9:3

20:19 28:1

29:14,18 31:17

140:2,13 153:9

244:16

deButts 2:3 6:16

8:19 140:3

244:16

decade 15:10

decades 14:18

December 23:4,11

decide 25:5

decided 98:12

decision 38:2 51:7

98:8,13,18

153:6,11,13

170:19

175:12,14

199:10

declared 30:12

decline 33:3

declines 162:11

declining 212:13

decrease

122:19,20

168:11 174:7

184:22

decreasing

83:5,19 174:7

defer 172:3

defining 26:4
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definitely 53:21

68:20 111:14

145:7 222:6

definition 24:13

25:15,21,22

26:3,9,10,12

27:2,8,20

28:5,18,22

226:1

definitions 28:17

delaski 5:18 13:16

28:10 29:16

50:15 51:2,10

58:19 59:1

61:19,21

62:5,21 63:2

65:8 85:1,4,14

113:1,4 114:15

115:4 145:19

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188:9 218:8,16

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233:5 244:2

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61:20 65:7

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112:22 114:15

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186:17,22 218:7

233:4 244:1

delaying 210:3

demand

157:10,14,15,20

158:3,13 159:16

162:17 183:14

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212:17 213:2

demands 159:6

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113:21

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78:11

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79:12

department 1:14

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12:8 13:8,11

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71:11

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designing 49:5

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109:2

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detailed 28:14

63:7 118:19

details 148:4

determination 7:7

32:14 129:20

172:5

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24:9 32:2 57:20

80:4,7 100:10

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178:15 191:16

202:14 226:1

determined 25:8

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determines 24:14

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137:6

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45:19

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163:18,21 175:9

176:4,5 177:13

197:1,8 218:19

differences 45:4

79:19 100:7,10
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different 13:9

33:1,9,11,16

34:3,6,8,20 36:8

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differentiate

117:5,10 216:19

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116:19 117:2

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117:8

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distributor

130:14
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distributors 130:9

131:9 181:17

182:1

divert 210:1

diverted 83:21

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32:14 33:2,7,13

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242:5

dramatic 116:1

172:18

dramatically

152:18
Capital Reporting Company

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draw 88:9

drawn 34:10 90:8

drifted 181:7

drive 87:21 88:3

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219:4

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170:18

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drops 161:2

duck 4:9

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164:14

195:7,11,15

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214:2

duration 220:22

during 8:4 10:22

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earlier 22:17 26:7

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244:2

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24:17

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242:11,13

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54:22 174:8

efficiency

14:17,20 15:10

18:1,3 35:5 40:4

41:11,14 44:6

50:12 53:2,10

55:18 60:22
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67:18 70:21

78:1 79:7

107:18 121:18

122:10 163:18

164:2,20 165:3

169:14 186:2

219:13 220:1,3

240:2

efficient 15:20

16:3,13,14,18

35:20,22 36:22

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effort 103:16

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else 89:14 92:8

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28:19

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204:14 206:1,3

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238:3,13,14

239:6,8 242:18

enforce 31:10

enforcement 30:9

89:22

90:2,5,17,19
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engagement 244:6

engineer 130:2

engineering 7:4

32:12 45:14

47:22 53:1

56:6,9,11 57:2

59:4,10 62:6

64:1,3,9 103:14

129:17 226:15

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231:22

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159:11

entirety 16:6

envelope 125:8

environments

115:17

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99:20

equation 22:14

38:21 89:22

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119:21 120:1

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equipment

93:15,19

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178:1 219:16

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establish 80:4

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everything 52:1

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116:10 224:9

evidence 37:22

evidenced 240:18

exacerbated

36:16

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exactly 77:3 92:1

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examining 23:19

example 15:8 47:6

48:12 50:6 64:6

68:5 74:21

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119:18 127:18

159:21 165:8

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218:11 224:13

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excursion 173:17

174:4

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27:22

exempted 13:3

19:4,19,20

39:9,15 40:18

exemption 18:6

41:1

exemptions 25:19

exist 38:17 42:13

55:20 81:21

121:11 211:18

212:2,15

existence 77:14

78:8

existent 183:4

existing 26:13
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50:18 57:16

58:3 89:5

125:16 184:2

185:7

exists 79:8 90:11

126:12

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expand 93:10

122:5 127:16

expanding 24:7

expect 71:7 78:22

95:21 168:15

169:7 172:1

expected 31:7,14

59:12 159:5

expects 154:15

expenditure 239:7

expense 53:22

expenses 136:18

expensive 69:14

76:3 106:15

161:19 178:1

experience 144:18

experienced

221:13

expert 241:8

expertise 48:20

experts 63:5

explain 50:11

63:22 84:10

109:5 123:7

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240:17

explained 84:15

124:10

explaining 152:4

explanation 62:19

explored 205:15

expressed 136:1

expressing 62:22

extend 115:6

extending 25:3

extent 50:5,12

189:15 192:5

198:4 201:1

externality 167:9

extra 72:2

74:7,16,22

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extracting 176:8

extreme 86:7

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F

face 4:15 115:3

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38:12 49:10

55:16

64:6,10,14 92:2

96:15 98:6

107:4 122:8

123:11 137:19

163:8 169:11

190:6 191:10

192:16

216:10,21

223:13 224:2

factor 33:8,14

35:2,12 76:2

77:9 99:18

100:4,11 101:14

123:10 124:9

128:7,8 148:12

149:15 184:17

190:19

191:14,18

194:16 195:13

196:19,21

197:4,7,8

200:2,16

factoring 190:4

factors

23:15,17,19

32:21 34:16

81:12 99:13

100:16 101:3,5

119:16 175:16

192:9 196:18

197:3 199:14,19

200:17

factory 221:1

facts 62:22 244:8

fail 11:15 182:21

failed 72:14

157:19 158:19

failing 223:3

fails 143:5

failure 143:5,6,8

144:22 148:15

fairly 106:13,14

107:18 112:10

116:3 160:18

fairness 233:6

fall 24:12 55:2

fashion 139:13

faster 12:17

favor 78:13

favored 83:7

feasibility 42:19

feasible 24:17

32:7 45:20 46:6

48:5 56:21 92:3

features 32:17

51:16 102:8

124:3

February 21:22

22:21

fed 158:11

federal 10:6,8

207:11

feedback 8:12

57:19 109:19

130:19 183:17

feeds 158:9

feel 17:14 74:14

86:2 109:17

111:11 189:10

Fernstrom 2:8

4:17,18

10:19,20

20:10,11 28:2,3

31:1,12 39:1,2

63:8,9 69:22

70:1,20

83:11,12 93:9

96:5,6 99:2

109:21,22 110:9

114:4,6 117:22

118:1 119:10

129:3,4 131:3,4

138:6,7,13

199:11,12 201:6

230:13,15

245:1,2

Fernstrom's 30:4

fewer 162:16

188:9 226:19

field 67:10
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figure 145:22

204:14 223:2

227:13

figuring 203:11

fill 46:19

47:2,5,16,17

48:21 186:1

fills 46:20

filtered 154:4

final 20:7 21:10

23:3,5,12 29:6

79:16 80:4 82:7

99:6 114:12

120:4 175:15

184:12 188:16

191:17 207:9

243:22 244:11

finalize 10:11

208:18 244:20

finally 23:10

33:13 56:21

finding 65:4 101:9

findings 25:3

126:15

finds 37:12

fine 98:1 184:8

finish 12:13

184:11

finished 54:7

182:16

finishes 175:20,21

first 9:2,7 20:19

21:9 36:18

42:12 48:15

56:12 57:1 73:4

75:6 81:22 86:2

135:13 143:4

154:20 158:9,15

162:19,20 164:8

171:16 172:6,7

173:18 206:20

208:6,22 216:17

221:17 229:4

233:16 235:1

237:1

fit 33:10

125:12,14,15,16

,17 126:17

128:21 129:2

fitted 161:5

fitting 124:12

127:6

five 8:20 24:20

42:4 102:15

126:6,10 128:18

239:19,21

fix 44:10

fixed 69:9 166:19

189:9 191:20

193:7 199:6,7

201:4

fixture 125:13

126:8,9

128:17,20 129:1

139:3

141:4,18,19

143:10 164:4

202:8

fixtures 35:3

125:10,14,16

129:2 139:2,5

flat 163:7,8

180:19

214:16,21

215:9,17,20

216:9 217:13

218:14 221:15

flood 118:8,10

floor 102:22

171:11 222:15

flow 29:21

207:16,18

208:2,14 241:10

flows 214:20

239:2

fluctuation

213:20

fluctuations

213:17

fluorescent 1:10

3:6 11:4 13:22

24:1,8,11,13,18

25:6,16,22 29:3

47:6 68:19

69:2,18 72:3,9

73:2,8,17 74:1

80:16 83:18

130:16 131:6

141:7,16 159:18

174:11,21

210:14 218:21

focus 8:5 52:21

57:4 103:15

164:22

focused 223:9

focusing 183:18

folded 13:4

folks 76:15 96:9

103:11 202:22

211:17

foot 24:5 60:1

83:20 148:22

149:10 150:4

161:19 171:1

175:7

footprints 33:11

force 169:13

forcing 180:20

fore 7:19

forecast 157:12

foreclose 13:7

foregoing/

attached 246:8

foreign 233:9

forever 65:15

forewarning

12:19

format 217:11

Forrestal 1:15 3:7

102:19

forth 86:17 87:4,7

210:13

222:12,14

forward 14:16

138:19 152:21

166:18 172:19

244:11

fossil 176:9

foul 38:19

fraction 111:17,19

157:19,20

160:12 162:1

164:15 170:4,12

188:19 189:2,8

190:16 193:21

195:18 196:5

203:19 204:22

205:3,4

fractional 173:21

fractions 164:17

framework 21:20

22:17 181:9

205:18

frankly 28:12

48:19

free 164:6,7
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frequency

163:20,21 164:1

204:9,11

front 115:3

220:17

FSC 190:21

fuel 176:8 235:9

fuels 176:9

fulfill 162:17

full 39:11 51:5

60:6,13 62:8

65:2,20 67:14

68:7 80:9 81:21

176:8 192:8

193:4 197:14

198:22 202:4

204:6

fully 128:4 200:14

209:16

215:10,15

function 119:21

159:20 160:21

161:3,5 180:7

196:3

fundamental

61:14,15

furthermore 38:7

162:13

future 95:22

136:10 160:1

166:16 178:19

195:20 218:18

G

gadgets 241:3

gain 25:10

197:12,13,18

198:9

gained 239:10

240:13

games 232:7

gap 222:2

garages 115:19

Garbesi 2:3 79:17

173:3,5

194:11,13 201:7

202:16

234:20,21 238:9

241:7,17 242:5

garbled 222:17

Garry 2:8 4:17

10:19,20

20:10,11 28:2,3

30:4 31:1

39:1,2,21 43:5

63:8,9 69:22

70:1,20 71:7

83:11,12 93:8

96:5,6 97:20

99:2 109:21,22

114:4,6 117:22

129:3,4 131:3,4

138:5,7

199:11,12

230:13,15

245:1,2

Garry's 18:18

97:20 131:22

gas 4:19,21,22

46:19 47:2,5,17

48:21 67:7

178:20 186:1

gases 47:16

gather 208:12

gathering 20:4

Gatto 2:7 5:12

43:2 54:6,15,16

140:22 141:9

142:8 144:5

145:11 152:2

153:3 170:15

181:2,5,6,22

219:11

220:5,10,15,18

221:3,8,11

GE 5:14,15 48:17

61:9 66:19

68:13 70:2,13

73:13 86:14

118:4 143:16

198:16 210:10

general 1:10 3:5

5:21 11:8 13:21

19:6,9,15,19

24:10,13 25:15

27:5,16 29:2

52:17 56:10

76:5 83:16,18

84:13 101:2

103:14 105:12

115:15 155:8

174:20

generalizations

12:16

generally 48:11

63:11 85:11

87:10 105:15

149:7,8,22

150:7,9 171:22

188:13

generate 67:12

236:18

generated 69:17

236:6

generation 238:16

generous 90:1,3

geometries 33:9

34:3 59:22

60:12

Gerke 2:3 6:7

96:21

97:4,11,13

138:11

156:12,13

164:8,15

165:15,19

166:1,5,15

167:3 169:21

172:3 175:11

177:16 184:8

186:9,16

187:5,20

188:3,11,14,17

190:6,11

191:1,6,15

192:5 193:2,18

194:2,8

195:10,12,16

204:19

gets 64:12 95:19

96:17 139:14

165:7 222:1

getting 62:4 67:11

88:14,18 92:1

96:16 144:19

151:13 180:13

191:9 202:4

211:16

GFSLs 18:17

given 13:1,6 98:9

119:20 177:12

240:12 241:5

gives 10:10 34:20

189:11 190:13

239:8

giving 62:21

182:13 183:15

glad 67:15

gone 43:16 52:12

87:22

gotten 204:20
Capital Reporting Company

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gouging 182:22

government

207:16 240:2

grab 17:14

grade 52:16

Great 93:1 106:19

107:1 124:8

185:19

greater 26:14

33:3,6 35:9 36:9

103:18 104:20

138:9 221:2

230:6

greatly 228:16

green 57:6 103:19

189:4

GRIM 207:17

208:18

GRIMs 214:20

gross 214:17,22

ground 102:16,22

244:8

group 36:11

143:17,21 144:2

154:3 160:4

171:13 236:8

237:6

grouped 184:8

groups 154:16,18

grow 161:20

growing 20:2

115:4 157:20

grown 162:3

grows 161:16

188:22 189:4,15

growth 20:5

160:15,17 191:2

195:19

198:20,21

205:11,13

GSFL 16:7

21:14,19 22:4,8

46:12 48:19

54:20 55:17

57:1 59:3 68:9

69:3 82:8,15

99:7 102:6

129:16 132:22

137:6 142:14,17

147:8,13

148:10,14 154:6

156:19 157:15

159:10 162:2

177:21 178:3

179:7,9 189:14

195:18 208:22

209:1,4,10

214:16,20

215:18 218:22

219:8,14,20

221:7 226:2

227:6,10

229:6,18 233:18

234:1,3 244:4

GSFL-IRL 3:18

GSFLs 9:12

21:4,8,13 22:6,7

23:20,22 32:20

33:21 45:10,15

47:2 50:17 51:3

56:11 57:4,12

58:8,13,17 74:7

82:21 100:21

102:9 129:22

131:11

132:10,15

134:2,7,12,17

142:20 143:7

147:11 155:13

157:12

159:6,8,13

160:14,20

207:5,21

209:3,20 212:6

226:6 227:4

234:2 235:5,10

242:9,10,19,22

guarantee 18:4

guess 46:19 59:17

89:22 108:6

124:18 146:10

165:6 168:10

174:5 177:12

196:16 231:7

guesstimate

196:15

guide 208:12

guy 92:12

guys 62:1 94:20

181:19

gymnasiums

168:2

H

half 17:2,3 69:18

126:4 128:10,12

hall 103:1

hallway 102:21

Halo 42:15

halogen 41:11

44:2 104:5

118:6,8,10

121:12,16

125:6,7 181:10

232:16

halo-phosphate

71:9

hand 8:13 17:13

102:12 116:6

198:19 206:11

235:14

happen 163:5

179:22 197:22

218:22

happened 43:7

182:12 230:5

happens 18:5 53:8

67:6 87:2

hard 8:9 40:5

168:17,18

196:14 202:13

203:11 217:1

harder 65:17

182:8 202:7

harm 38:18

harsh 115:17

hasten 233:2

haven't 7:20

125:22 171:20

182:16

having 12:8 49:12

77:16 83:8

109:15 116:20

145:15 179:4

181:17 192:6

Hayden 2:4 6:11

206:12,14

228:22

head 103:3

193:11,13

headed 175:1

health 32:10

236:11

hear 8:14,16 50:1

92:20,21 94:1

96:20 106:20

125:20 127:1

156:11 185:17

190:2 223:6

heard 52:3,7
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90:9,15 96:9

185:21 204:4

218:10 243:14

hearing 38:19

54:17 170:11

172:19 211:16

212:13 222:17

heat 204:12,13,17

heavier 142:16

heavily 71:14

heavy 240:18

hedges 183:11

height 167:21,22

171:1

heights 167:20

held 22:1 90:4,5

help 9:22 15:19

20:4 62:6 110:9

181:7 240:17

helpful 45:5 52:20

79:15 118:14

119:9 122:14

131:3 170:13

230:12 244:20

helping 244:7

hereby 246:4

hermetically

122:8 127:19

Hertz 204:11

Hey 140:22

Hi 31:20 92:21

103:9 118:16

150:13 202:20

206:14

high 14:19

19:4,5,8 24:4,5

27:4,13,19 29:1

33:15,17 40:21

41:2 44:6

57:10,17,18

61:5 68:18

77:13 82:11

86:9 87:2

100:13,14

101:5,12,16,19

103:20 107:13

120:10 121:4

130:9 138:21

149:12 151:19

163:20,22

168:1,2

174:13,19,21

204:9 205:13

228:10 232:7

237:4,5,20

243:15

higher 11:21

17:8,12,16,17

35:18 41:6,7

42:5 46:13,20

49:3 52:6,15

53:9,10,15

54:21 64:11

68:8 69:5 71:10

79:14 81:11

86:21 89:14

98:22 107:3

108:22 109:12

133:12 144:11

167:17

169:6,14,19

171:18 172:8

175:10 177:7

180:21 182:13

184:1 186:12

187:7,9,10,18,2

1,22 188:8,13

190:4,12,16

193:4 195:14

197:15 201:15

202:3 209:10

211:19 217:4

221:16 226:20

230:10

highest 173:19

174:1 177:3

237:16

highlighted

235:11

highly 48:20

166:17

hinging 213:19

HIR 104:22

105:3,4 118:4

hire 145:15

historical 160:20

184:20

historically

179:13

history 20:22

173:11,15

hit 98:10

hits 98:1

hold 40:7

71:13,15 187:13

holding 21:21

holing 76:8

home 141:9 217:3

homeowner

131:19

homeowners

141:8

homes 131:7

hop 61:21

hope 20:2 28:13

hopefully 46:22

hoping 4:1,5

139:10 241:15

horse 43:3

hotter 46:15

hour 70:15 72:9

hours 104:8

105:2,6,8,9,16,1

9 106:1,2,13

133:15,17,20

134:2,10 136:14

137:11 147:7,16

151:12,13 154:8

160:3 191:4

203:3,4,17,19

house 140:15

housekeeping

8:18

houses 139:2,5

housing 126:9,12

housings 126:17

Howley 2:6 5:15

36:6,7 40:9,10

53:4,5 61:9

71:5,6 76:16,20

85:18,19

101:1,2

104:11,12

105:10,11

112:6,7 115:13

117:1 121:2,3

122:7 125:4

130:22 147:18

152:14,15

155:6,14

167:5,6 174:5

196:14 200:11

201:20

202:1,3,18

217:20 228:9

231:13,16

232:15 233:11

234:5 243:11

huge 94:7 164:3
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203:18 232:3,5

hugely 217:21

Hum 195:15

human 236:11

hung 231:11

Husain 2:4 6:1

31:17,20

34:11,13 37:4

45:1,7 47:2,4,13

51:8 56:4 66:3

118:16

172:12,14 175:5

242:5,7 243:20

I

I'd 10:21 60:1

72:15 73:14

112:3 113:1

118:3 183:8

199:13 230:1

245:3

ID 156:1

idea 131:20

ideally 19:17

ideas 116:16

117:17

identical 30:17

31:4 93:15

123:9

identification

107:3

identified 32:5

45:9,16,21 47:4

56:12,17,18,19

57:14 63:6 68:6

100:5 104:15

107:4 120:9

126:9 226:5

identify 24:21

32:3 38:11 76:1

80:20 82:18

207:5 225:17

identifying 26:1

107:21 119:13

I'll 158:1 202:2

237:17

illumination

199:21 200:7

I'm 46:10 70:20

78:12 109:4

171:13 182:17

187:1

immediate 60:9

189:16 192:7,8

immediately

140:9 190:13

191:11 219:9

impact

7:10,11,13,14

33:12 55:4 71:8

78:4 138:10

156:10,15,22

175:20,22

176:15

178:15,19

179:17

184:12,21 185:1

186:5,6,10,15

189:6,11,13

191:16 203:20

205:8,22

206:5,13,16

207:6,7,12,15,1

7 215:21 216:3

217:21 223:9

225:12 227:10

229:18 232:14

234:6 236:15,17

238:11,20

239:14,15 240:5

impacts 32:9,10

33:19 46:7

64:3,8 134:5

135:8 154:6

156:17 183:3

205:14 206:22

207:4,20

208:2,15 218:19

234:8 236:13,18

237:8 238:15,22

239:1 242:16

implying 51:22

important 14:17

43:4 55:16

107:18 109:17

111:11 181:12

182:7 220:2

222:4 230:17

imported 232:22

impossible 42:5,9

65:18 78:16

212:4

impractical 41:19

improve 32:4 45:9

50:12 53:21

81:12

improved 104:5,6

105:3,4 107:17

109:1 240:22

improvement

14:9,10 15:13

107:22 109:6

211:5

improvements

14:1 15:3 55:8

improving 65:14

170:13

ImSET 239:4

240:11 241:8

ImSETS 240:10

inaccurate 12:17

inadvertently

95:11

inaudible 28:11

incandescent 1:11

3:6 13:3 15:14

16:4,14 18:5

26:10 39:8

233:10

inch 34:4 60:2,12

61:7 62:7

inches 35:10

66:5,6 103:18

126:2,3,4

include 22:14

24:3 37:16

44:13 45:3

55:14 78:14

141:12,13 142:2

145:2 170:3

230:22

included 49:16

145:13 151:7

154:4 165:2

181:9 184:3

239:22

includes 37:14

69:12,14 143:7

177:8 236:10

including 13:12

19:7 51:3 76:21

82:17 109:13

119:1,16 120:10

133:17 183:6

inclusion 25:6

income

154:3,12,14

incorporate 79:20

increase 41:10

60:9 66:14

73:19 93:17,22

98:14 121:17
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122:21 123:10

162:7 168:14,20

172:7 176:12

184:18,21 209:5

210:14,16

212:11,16

213:3,14 215:1

217:1,2

219:13,14,22

220:1 230:19

234:2 237:9

increased 36:3

47:18 70:21

125:8 151:15

165:12 174:8

190:3 209:3

216:11 217:7

increases 55:4

68:21 157:5

increasing 35:14

41:14 83:4,7,14

95:11 188:19

190:11,17

193:21 209:1

increasingly 11:6

164:16

incremental

171:19,22 172:7

186:15 187:3

210:18 211:4

219:4,13,14

220:2

incrementally

64:4 69:20

increments 109:8

199:15,20 200:3

201:5

incur 98:20

incursion 159:4

162:12

Independence

1:14

index 179:8

indicate 31:5

indicated 88:2

101:17 135:12

indication

86:19,21

indifferent 76:22

indirect 167:22

170:22

individual 98:18

223:3

individually

134:22

individuals 8:20

indoor 116:4

induce 76:11

industrial 134:3

136:16,20 147:8

149:6

industries 229:6

industry 19:10

46:15 59:11

69:16 96:9

101:4 172:17

173:7 182:3

207:18 208:9,15

229:11,12 230:9

231:18,21,22

232:4,6,8

238:22 243:16

244:6

inefficient 16:16

inexplicable

239:15

infeasible 76:18

information 6:20

9:21 10:15

12:12 80:20

84:13,14 88:13

119:6

120:9,13,17,21

125:21

126:15,18

130:17 163:6

208:8,12,17

225:17 230:17

243:18 244:19

informative

244:18

infrared 119:18

infringement

55:10

inherent 47:12

78:6 192:3

inherently 204:6

initial 58:2,13

63:5 70:5,15

73:21 80:4,8

84:16 93:14

95:1 108:8,12

151:15 221:17

225:21

initially 84:14

initiated 21:18

input 80:19

133:15

134:9,12,14

158:3 159:1

195:17 238:6

inputs 136:5

154:8 208:1,18

INPV 207:19

215:18 217:10

insert 172:21

installation

135:14 136:7,13

145:13,16,17

192:4 199:6,7

201:4

installations

143:11 200:1

installed 35:3

124:17 143:8

159:8 176:12

238:15

instance 109:16

193:20 213:6

instances 42:13

instant 81:2

instead 137:7

203:17 227:3

institutions

154:14

insulated 27:14

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184:18

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241:11

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168:8 170:10,13

interesting 77:21

78:2

Interestingly

189:13

internet 130:10,15

interpret 31:13

52:5

interpretation
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225:4

interpreted 61:2

interpreting

38:16 91:13

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124:11 207:22

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4:14

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209:13,16

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226:10 227:4

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Investor 4:18

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John 2:2 3:12

15:21 30:1

31:2,9 38:14,15

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25:11,16

26:2,15 27:4,22

29:2 33:3,4,5

34:2,3,22

35:2,5,7,9,10,13
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36:3,8,10,14,17,

21 37:7,13

38:11

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221:14 222:12

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LEDs 4:3 15:22

157:22

159:4,5,9,12

160:14 162:12

164:14

166:17,18

178:12 209:21
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legally 29:10

90:16

legislative 29:8

length 33:8,11

124:19 125:3

128:22

lengths 24:20

126:2 163:16

less 33:5 35:10,22

36:1,17,22

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level 41:5,20 42:1

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178:5 179:16

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190:12,14 193:7

200:15 201:15

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176:3 177:4

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41:13,14,19

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70:3,11,22

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72:3,9,15,21

73:5,8,17,22

74:1,7,16,19,22

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104:8,20

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160:6 162:15

170:19 175:14

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68:11 69:17

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94:9,10,16

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lighting

5:1,11,13,14,15

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188:20 189:3,8

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limit 8:6,11 26:12

175:17 225:15

limitations 121:10

122:6

limited 77:13

limits 25:12 41:2

107:11 122:9

127:9
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154:5,22

166:4,8,10

167:13 218:4

linear 11:3 24:19

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210:15

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64:1,21 65:8

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101:5 107:2

110:1,3 113:1

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218:1 219:18

222:17 225:1

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logic 40:7 52:2

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long 27:11

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71:16,17

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loosely 141:16

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macro 78:4

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maintain 43:15
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109:17 111:11

113:8 217:6

maintaining

81:19 202:7

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239:18,19

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90:13

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7:11

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220:15 223:10

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manufacturers

14:19 19:7,8

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5:9

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117:14 121:5,8

123:12,17

126:8,12 128:22

132:13 133:17

134:4 137:3

155:8,9 157:22

159:5,11 160:15

161:11,15,17,21

,22 162:12

166:7,9,18

168:16 169:13

177:22 181:14

183:6,17 185:5

200:21

216:16,18

224:11

228:16,21 231:8

232:1,10

marketed 25:17

26:4 27:2,5,8,16

marketing

19:8,15 30:18

marketplace

17:21 18:2 28:6

44:9 74:13

78:18 79:6

121:17 183:11

markets 43:17

106:7 117:13

209:22 225:20

227:7

markup

214:13,14,17,18

,19,21,22

215:4,8,9,12,13,

14,17,20 216:2

217:13,15

218:15 229:6

markups 218:11

match 199:20

200:6

matches 218:9

material 46:14

168:14 180:13

210:22 212:11

219:15,20

223:17 224:9

materials 48:10

69:13,14 173:13

178:19 182:21

183:13 209:5

213:3 219:1

220:20

matter 59:21 77:9

123:16 125:13
Capital Reporting Company

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179:7 186:12

202:11

matters 96:13

mature 160:16

Maureen 2:2 6:5

56:5,8 151:5

max 36:12 41:3,5

55:8 82:16

84:22 87:20

88:1 99:7 110:6

114:8 117:19

119:20 120:8

123:8 132:22

133:4

maxed 187:4

maximizing 51:22

maximum 41:7

49:6 50:5 56:20

88:7 132:17,19

133:1 177:9

may 1:12 3:7,14

24:1 25:10,11

37:15 39:6,17

43:6

61:13,14,16

64:6 86:19,20

96:10,11 126:5

172:5 175:16,17

183:20 184:4

185:14 203:5

204:20 210:20

211:2,3 233:2

maybe 12:17 13:1

69:17 93:21

101:6 108:1

112:1 141:4

152:19 197:15

225:6 231:2

240:11

mcgaraghan

92:21 93:1,5

95:15 106:19,22

108:6,9,15,19

110:11 124:8

125:19 128:1,3

150:13,21

151:1,16 171:12

172:17

185:16,19

186:14,18

213:11 214:1,9

McGaraghan 2:9

5:1 92:18

106:17 111:5

124:6 150:11

171:10 185:20

213:10

McGaraghan's

97:5

mean 31:13 54:15

69:7

70:3,5,7,10,16,1

7 71:1 73:21

81:9 82:1,5 85:4

91:11,13

92:10,16 96:9

98:7 111:2,17

123:15 166:13

201:16 221:19

223:15,22

232:7,15

means 30:20 48:7

84:15 92:15

104:5 105:4

136:11 161:11

167:18 168:4

203:10

measure 32:22

86:6 89:14

124:21 204:11

measured 67:19

90:7 204:12,13

measurement

86:5 87:5,6

88:16 89:19

90:11

measurements

70:16 86:17

measures 185:10

measuring

163:19,20

mechanism

216:14

MECS 133:18

137:3

medium 24:3 68:5

80:22 81:13

85:22 99:21

100:1,12 118:7

130:8 148:22

149:5,10

161:14,19 163:1

meet 24:10 26:9

35:21 36:21

42:5 48:21

49:12 50:19

51:12 52:2

54:11 58:2

60:22 62:8 65:2

88:6 91:6,14

92:6,14 124:15

181:15 185:7

209:10

211:20,21 212:6

226:16 227:5

meeting 1:9 3:4,5

4:11 8:3,5 9:11

12:9 21:21

22:1,19,21 23:6

25:8 30:8,10,20

49:18 51:15

75:1,17 85:10

114:7 244:18

245:6

meetings 4:10

8:10

megatons 17:5

members 20:13

75:7 101:4

mention 70:12

118:3 196:1

mentioned 16:10

27:4 36:14

50:4,6,10 66:4

107:2 108:21

109:3 121:13

127:19 160:5,7

161:4 196:17

244:19

MEPS 91:2

mercury 69:14

234:2,6 235:18

mess 203:12

met 157:16 226:1

metered 139:1,6

metering 139:1

140:17

methane 235:19

methodology

56:10 82:14,21

84:22 100:20

129:16 130:20

137:13 208:19

metric 177:1

207:19 235:16

MIA 206:16,19,20

207:1,3,9,10,22

208:5,19 214:14

234:11 239:1

MIAs 214:16

Michael 2:4,9

92:18,19

106:17,18

124:6,7 128:13
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150:11,12,20

171:10,11

172:15 213:10

214:7

microphone 62:13

97:11 140:21

microphones 4:14

mid 181:16 237:2

midday 7:9

middle 236:13

mid-morning 7:5

midpoint 179:20

midyear 182:2

migrate 76:4

77:17

migration 36:2

39:14 75:3

mike 4:22 6:10

42:10,11

47:19,20

50:16,20 51:14

52:20 63:18,20

74:3,6 79:2

88:17 95:17

96:7 97:4 110:9

111:4 113:18

115:3 116:18

153:9,15,18

185:20 216:12

222:6,13 224:18

229:21 230:1,15

231:16

Mike's 187:1

millimeters

126:6,11 128:19

million 177:1

229:11,12

235:16 238:4

millions 237:18

mind 52:3 114:19

mined 209:7

mini 24:5

minimally 185:22

minimum 14:11

80:5 91:2,19

92:11,14

98:11,17 120:4

minus 136:2

minute 102:17

minutes 102:15

misremembering

172:9

miss 222:9

missed 43:7,20

222:1

missing 223:5,10

mistake 17:7

mitigating 76:1

mix 126:4

mixture 233:8

model 30:13,14

36:20 48:1,2

57:13,20 103:22

108:22 136:6

143:4 158:16

160:21 161:1

170:7 173:14

174:10 179:16

183:5,22 195:9

199:9 205:6

207:16,17,18

208:2 239:4

modeled 36:13

57:17 58:5

161:5 165:22

166:12 168:11

171:14 172:20

200:13 237:8

modeling 4:1,5

166:11,16 206:3

235:3 238:14

models 81:8

236:17,20

moderate 205:14

Modernization

7:12

modest 15:15

160:18 184:13

185:1,9 189:14

205:14

modestly 161:16

modifications

25:14 28:21

modified 17:19,22

18:7,10,15

34:17 122:20

123:3 124:15

238:14

module

157:10,11,14

158:4,5,9,11,12

159:1 160:7

modules 157:9

mom 131:18

moment 91:17

111:4 153:11

170:9

monetization

176:16

monetized 177:8

monetizes 236:4

237:10

money 15:4,5

223:15 231:22

232:2 241:10

Montgomery 2:10

49:21 126:21

127:1,3,5,18

128:16 222:14

225:5

month 138:22

139:9 140:10

months 29:9

morning 3:3,11

4:17 5:2 6:20

56:7 185:22

mostly 152:16

MOTGOMERY

50:3

motivator 94:7

move 19:16 20:16

23:21 31:16

45:7 53:1,7

57:11 67:21,22

87:12,14

99:5,10 122:15

129:13,19 171:8

195:5

movement 194:16

moving 4:3 7:3,9

26:6 79:10

114:2

166:3,7,10

183:5 184:15

214:10 224:1

225:9

MR16s 119:2

muddled 204:20

multi-photon

45:17

multiple 38:22

81:1

multiplier 134:20

mute 8:11

myself 83:15
Capital Reporting Company

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N

nation 156:17

national 5:8 6:8

7:10 14:8 64:3,8

73:15 77:3

98:17 137:9

138:10

156:10,13,14,21

,22 165:9,16

166:13

175:20,22

176:3,15,20

178:6 184:22

186:19 190:21

195:8 196:18

205:8,22 206:3

235:2 238:14

244:5

nation's 69:7

natural 168:5

228:15

nature 16:1

106:11 128:6

Navigant

6:1,3,5,11 20:1

31:18,21 37:6,8

40:12 42:11

56:8 66:3 72:12

103:10 112:9,18

141:5 142:12

151:5 172:4

182:7 206:15

242:6

nearly 157:22

159:11 161:21

necessarily 78:15

79:5 131:11

182:19 203:19

212:18 219:2

necessary 18:8

49:18 72:18

80:8 84:19

120:6 209:10

227:4

negative 106:9

148:11 149:8,16

150:7,16

151:8,22

152:1,19

153:1,5

154:11,12,20

155:1 165:11

177:22 217:21

228:20

negatively 94:1

NEMA 12:7 37:19

39:20 44:14

60:16 63:4 72:1

75:5 88:12

97:19 116:15

182:17 190:2

228:3 240:9

NEMA's 140:11

neodymium 34:18

NES 132:17 133:1

185:9 206:2,6

240:3

Nesting 2:10

223:1,4,8,22

net 66:13,14 157:3

176:1,10

177:9,18 207:18

Nevertheless 38:4

newer 125:11

NIA 130:12

133:14 135:5

138:2 218:11,13

235:3

nitrous 235:18

nominal 59:6,8

171:8

non 183:4

none 37:22

non-efficacious

78:20

non-general 25:17

non-hermetically

127:22

non-modified

34:21

non-profit 154:16

non-regulatory

239:16 240:4

nonrepresentative

122:18

Nope 225:8

NOPR 3:18 16:6

22:2,22 23:2

26:18 29:6,20

55:12 57:16

80:8 81:17

82:10 84:12

100:6 107:5

124:22

125:1,5,10

130:10 137:4

156:15 165:3

182:9 206:18

208:10 216:4

217:17

nor 226:7

normal 87:3

88:5,22

normally 5:1

North 240:19

Northwest 6:12

20:3 77:22

Notably 177:6

note 9:3 12:10

14:17 58:10

61:9 118:17

162:9 181:12

234:8 235:12

243:20

noted 29:8 119:1

209:6

notes 157:6 246:7

nothing 69:8

174:21

notice 1:9 3:4

10:6,8 22:20,22

23:3 174:9

213:13

noting 217:20

notion 213:1

notwithstanding

111:2

NOx 177:2 235:17

237:10

NPV 132:17,19

177:4,7,14,22

178:7,8,13

185:1,9 187:2

205:14 240:4

242:20

numerous 240:21

O

O&M 158:10,15

obligated 90:16

obligates 98:20

obligation 13:5

observation 62:22

86:16

obtain 69:13

obtained 86:11

obviously 29:5
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72:19 125:12

221:22

occur 143:11

164:9

176:6,13,17

186:11

occurred 166:20

183:8 208:6

occurring 193:22

occurs 143:22

144:3 177:9,20

178:13

October 21:21

179:16 180:16

odd 62:10

offer 4:7 7:1 25:11

33:1,9,16

offered 25:9

offering 35:3

offers 17:22 18:3

Office 5:22

official 185:12

officially 55:15

offset 188:13

189:21 198:14

offsets 189:18

199:1

offshore 92:3

96:10

oh 112:5 128:14

201:21

okay 3:2 9:3,9

20:8,15,18,19

28:1,8 29:18

30:1

31:12,15,16,17

34:11 36:11

44:19,22 45:7

49:20 50:13

52:18 54:2,14

56:2,4 61:18

62:17 63:15,22

66:1,15

67:20,22 68:19

74:15 79:22

87:10 89:6

95:14 99:2,9,10

102:11 103:13

104:14 106:11

108:6,19 114:11

119:12 123:18

126:20 128:13

129:3,19 132:3

140:5,13 142:22

144:12 146:16

147:1,3,20

151:16,18 155:3

163:19 165:4

166:22 172:14

173:3 174:5

175:3 186:14,21

187:12 188:15

190:20

191:13,22 194:9

195:4,5 198:18

199:11 200:11

201:6 202:1

204:18 211:6,13

213:9 214:4

218:16 223:8

225:3,8 227:19

228:8

233:4,12,14

234:17 238:8,9

242:3

old 125:12

older 84:1

on/off 142:18

ones 45:13 203:12

212:19

onto 215:10

Onward 20:18

oops 44:17

open 39:4 88:10

opening 7:2

9:8,18 10:17,18

12:4 20:21

28:11 244:3

operate 35:13

75:22 80:16

81:4 116:8

127:10 163:22

194:21 195:1

203:6 226:7

operated 41:16,17

43:22 44:2,3

67:18 134:7

operating 106:13

118:5,6,8,10

133:15,17,20

134:1,10

135:11,15

137:11 147:7,16

151:12,13 154:8

188:4 201:13

214:18

215:3,5,13

216:1

operation 76:14

116:15 168:22

217:15

operator 94:8

opportunities

28:16 54:21

opportunity

7:1,18 9:18 17:6

28:15 55:17

94:22 95:9

222:9 230:20

243:7

oppose 165:1

opposed 3:16

66:13

opposite 40:19

41:1 62:11

103:1

optical 35:4

164:21

optimize 46:17

52:7

optimizing 52:1

option 15:22 16:3

32:7 47:11 61:5

81:18 94:8,12

151:2 186:2

196:9

options 15:20

16:17 17:21

32:3,5,11,12

35:6

45:8,11,13,16,2

2 46:11 48:2

50:5 55:1 56:18

65:12,13 72:21

115:5,9 119:16

158:10

oranges 204:16

order 10:2 17:2

24:9 49:1 80:18

91:4 119:6

146:3 200:3,6

201:12 203:1

209:14 234:3

organizations

154:16

original 226:6

originally 41:3

OSRAM 5:16

33:22 46:9

59:17 74:11

118:7,9 144:21
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others 125:17

171:7 175:19

182:5 195:11

213:7

ought 8:13,16

28:5

outages 181:21

182:1

outcome 49:11

62:10,11 122:2

146:22 152:19

178:16

outcomes 121:22

outdoor 115:16,17

118:8,10

outdoors 33:18

outline 22:16

outlined 10:5

84:11

output 24:4,5,6

33:15 57:17,18

58:2,14 80:19

81:9,20

82:1,5,11 84:16

100:13,14

104:7,19,22

105:5 108:12

113:9 148:19

149:12,20

151:19 154:21

161:18 163:2

196:22 197:5,17

207:17 235:2

239:8 240:3

outputs 175:7

outset 12:5,20

13:18 243:7

outside 107:13

109:16 114:20

232:17

outstanding 13:5

overall 14:9 72:11

98:6 129:15

176:14 190:22

203:5 212:12

overreaching

167:16

overview 20:20

29:19 206:20

214:13

Owned 4:18 10:21

owner 94:8

owning 135:10

oxide 235:18

oxides

179:5,13,19

P

Pacific 4:19

package 33:14,18

113:6,11,15,16

146:9

packages 33:16

113:20 127:7

169:16

packet 6:19 20:17

pain 243:15

pair 81:8

paired 81:1

pairs 100:5

paper 88:10 89:12

par 44:2 76:6

PAR20 36:16,17

124:17,19

125:11,12

127:13 129:10

PAR20s 115:22

125:5 128:5

PAR30 36:10,21

107:16 121:10

122:6 127:12,13

PAR30s

115:21,22 117:5

121:13,16 122:9

PAR38

36:10,13,20

41:4 45:2

104:4,22 105:3

107:6,8 110:15

111:18,19

115:19

118:5,7,9

121:11 152:17

PAR38s 115:16

117:7 122:8

127:19

parameter 99:16

paraphrasing

84:7

pardon 112:5

Park 240:19

partially 61:11

participants 8:8

particular 13:21

61:3 68:10

85:22 88:21

95:4 115:11

137:1 147:4,12

153:11 161:10

162:22 196:8

228:20 238:6

particularly 3:19

11:3 33:8

79:12,14 85:20

95:11 181:3,14

244:4

pass 11:15 56:4

155:22 167:10

215:10,15 219:3

221:6 222:7

230:3,7,11,21

passed 32:11

231:18

passes 11:17

past 14:15 101:15

110:20

124:17,20 125:6

patented 46:22

patents 47:14

48:10 55:10

path 48:14 175:2

pathway 50:9

pathways 50:11

55:9

patient 77:20

pause 210:6

pay 72:17 73:5

221:22

payback 106:14

133:14 134:6

135:6 136:3

184:3

paybacks

106:11,14

payer 15:4

payers 15:2

peak 173:17

penalty 18:1,3

people 76:11

77:17 94:15

121:19 131:19

138:17 152:4

164:15 182:20

183:2,10

190:6,8,14
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191:9 198:4,11

205:3,5 221:19

240:22 241:8

per 11:14,18 22:8

83:19 86:3,4

104:8 105:1,6

108:3

118:5,6,9,10

141:18 171:2

210:17 211:7

237:1,2,3,13

238:16

perceived 32:22

percent 14:10

42:5 44:4 87:7

89:13,16

128:10,12 169:5

177:13 196:9

197:2,15

198:9,10 199:20

200:21 201:5

205:21 206:3

percentage 135:2

143:21 144:11

171:4 193:16

197:19

198:11,13

214:22 217:21

219:22 226:21

percentages 132:1

142:12

percentile 237:5

perfect 69:15

perform 59:12

91:4 169:17

178:17 202:5

performance

32:17 49:7

51:11 70:15

91:3 96:19

98:11,14

102:4,5 107:3

108:22

123:21,22

203:13 205:2

performed 112:9

179:17 185:3

performing 84:20

107:13 118:2

212:3

performs 96:15

perhaps 12:12

28:17 89:14

116:16 121:21

168:2

period 10:9 15:10

23:8 73:6

133:14 135:7,20

136:3,18 137:18

147:4,5,10,13

151:11,14

156:20

157:17,21

158:1,6

159:7,11,14,17

160:9,18

161:1,22 162:3

165:13 176:2,22

177:21 178:3,11

180:17 181:10

189:1,5 206:9

237:22 242:18

243:3,21 244:21

periods 134:6

person 86:15

personal 98:13

personally 75:1

83:15

personnel 30:22

perspective

46:15,21 135:10

ph 34:18

phase 45:19

208:6,11,15

phases 208:5,9

Philips 5:10 37:5

91:22 118:5

144:15 148:2

163:4 174:17

216:6

philosophical

42:7

philosophically

41:21

phone 5:3 8:15

49:22 92:19

126:22 222:15

phones 8:6

phosphate 224:4

phosphor 42:16

132:16 223:13

224:3,5,6,13

phosphors 45:17

69:12 71:13

74:20 174:19,22

179:9 213:15

223:14 224:21

230:6

photometry

204:9,17

phrased 63:10

physical 33:7 34:2

124:13 219:15

physically 67:1

physics 101:10

pick 77:7 95:8

98:12,13 156:9

182:5

picked 196:22

picking 4:6

picks 146:19

picture 194:14

piece 14:7 15:11

220:2

Pierce 2:2 6:3

37:8,12

103:9,10,13

104:15

108:4,8,12,17

109:10

111:7,10,22

113:3,13 119:13

122:5,16 123:19

125:1,18 127:16

129:14,19 132:4

138:2,10,14

139:18,22

143:3,19 144:13

145:5 147:3,20

148:7 150:19

151:8,17 152:9

153:22

155:2,11,16

places 95:8 115:19

plan 30:16 38:17

plans 57:4

plant 235:9

play 69:1

pleasant 3:18

please 4:10 8:1

9:22 54:13

64:19 66:2

67:14 102:18

103:12 124:7

139:20 150:12

194:12 195:6

222:16

plenty 73:3

plot 162:9

plots 162:10 238:1
Capital Reporting Company

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plus 86:17 118:4

point 3:20 10:22

13:1 16:1 31:5

34:1 37:22

39:22 41:22

42:12 43:16

45:20 50:16

53:19 54:19

55:5 56:16

60:1,20 75:21

87:1 88:9 90:22

92:1,9 96:7 99:3

101:10 102:15

109:11 114:15

155:19 158:16

161:2 162:1

170:18

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220:2 222:5

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63:16 79:2

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154:15

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230:11 231:17

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149:7,10,17,18

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205:22 206:5

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131:8

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52:14,17 55:1

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214:16,17

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previously 160:5

210:6

price 7:6 53:1

129:20

130:11,14,15
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135:14 136:10

137:16 145:3

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158:5,8 159:1,2

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180:22

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18:2 26:5 28:6

31:8 32:15

39:15 55:2

74:12 88:4

90:18 101:13

107:3,12,13

108:16 109:7,9
Capital Reporting Company

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110:13,17,19

111:3,4

112:11,19

114:21

115:7,15,18

116:8

117:13,15,20

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122:3 132:13

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211:19,20

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232:16,22

233:19,20

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52:16

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216:8

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81:2,14

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205:11

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110:19 111:3

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23:3,13 240:21

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27:10,12,18

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Q

quad 178:7

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240:22
Capital Reporting Company

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quantifies 235:5

quantitative

207:19

quantities 87:4

209:9

quantity 12:12

50:8

question 11:1

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reasonable 29:5

94:16 130:22

131:5 144:11

147:19 211:8

reasonableness
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162:20

reasons 17:20

46:5 48:10

64:15 72:10

112:21 168:12

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65:11,13,16,21

66:10,12,21,22

68:6 69:11

70:22 75:19

76:14 80:11,14

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70:3 73:16

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176:16,22 177:2

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reductions 17:4

235:6,16 236:5

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191:2,18 198:19

204:8,9,17

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reflector 1:11 3:6

13:3 15:14

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Register 10:6,8

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relamped 160:3

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143:18,22 144:3

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171:17

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7:2,18 9:18,20

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28:11 243:8

244:3

remember 42:16

55:2 145:12

172:5
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www.CapitalReportingCompany.com © 2014

remind 73:14

reminder 155:20

remove 43:10

53:8

removing 53:12

renovate 190:18

renovation 143:10

145:1 146:6,7

148:16

164:3,7,10

renovations

137:21 157:18

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224:13

repeat 63:19

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179:22

repeated

181:21,22

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replace 60:8 66:11

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replaced 93:14

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72:14 79:4

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104:16,21 105:2

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157:19 159:16

193:15 199:21

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replacements

148:11,14

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199:18,22 200:8

report 11:22

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140:6,7,8

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11:2,5,9,14

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Reporter 246:5

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56:13,15

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requirement 40:3

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110:5 171:6

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48:22 49:13,19

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researched 126:8

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117:16

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84:3 94:1 96:22

97:4,20 125:2

128:3 169:21,22

185:6 194:19

responding 23:5

70:12 187:7
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response 75:6,21

93:9 109:5

110:1 115:13

161:9 219:19

responses 118:19

228:15

responsive 63:16

rest 21:12 170:6

restrained 143:11

restrict 203:21

result 9:13 24:15

26:16 36:2

64:11 93:7 95:5

98:22 100:17

134:10 151:3

161:13 162:4

165:21 169:18

180:11 227:8

229:19 230:20

235:7 236:16

237:11 239:3,10

resulted 181:22

resulting 82:22

239:2

results 25:1 34:22

56:22 82:2,15

100:20 122:18

129:16 133:13

135:22 139:6

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174:2 176:14

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215:18,20 216:1

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219:4 235:4

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239:11 240:6

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resume 103:4,6

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retail 60:3 66:5

116:7 130:15

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retailer 27:6

retailers 60:7

105:22 130:10

retooling 221:1

retrofit 93:16

94:2,7 164:10

175:13

199:16,17

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retrofitable

163:15

retrofits 158:19

return 39:18

174:13 211:1

revenue 226:21

reverse 130:2

review 6:22 22:4

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reviewed 45:11

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rider 13:6,12

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Rivest 2:4

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63:18,19,20,22

74:3,6,7,15

75:11 76:10,17

77:11 88:17,18

89:20 90:4,9,15

91:5,8,12,16

95:17 113:18

114:5 116:18

153:2,6,17,18,1

9 216:12,13

220:7,14,16,19

221:6,9 222:13

224:18,19

229:22 230:1,14

231:2,15

rock 17:11

rolled 3:22

room 8:12,14,16

30:22 52:6

66:20 73:14

139:4 141:19

156:2 213:12

roughly 164:1

RS 136:11

rule 3:5 9:22

12:11 13:21

15:18 16:22

17:9,16 20:7

21:10,11,12,13

23:3,5,12 29:6,9

38:3 40:6 76:6

80:20 89:6

130:18 136:11

152:5 159:13

167:10 189:17

191:14 196:12

209:15 242:16

244:4,11,13

rulemaking 1:9

9:17 10:9

13:4,5,13 19:17

20:20

21:5,10,18

22:16 23:19,22

24:7 26:8,20

36:18 40:17

43:8 48:22 49:1

60:11 66:13

70:14 79:1 86:2

87:7 88:3

91:18,19 107:15

119:3 127:11

132:6 160:10

167:8 168:18

185:11 192:2

197:9 204:10

205:19 206:1,10

207:13 208:20

218:4 221:14

225:14 243:13

rulemakings

59:20

rules 16:5 146:4

198:6

ruling 112:19

run 46:14 47:22

60:12

running 3:16 77:6

169:2 203:18

runs 156:21

S

sacrificed 51:17

safety 32:10

salability 42:2

sale 209:9

sales 78:19 137:10

154:9 213:14

226:17 232:3

sample 89:10
Capital Reporting Company

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samples 87:3

sampling 30:16

89:10

San 4:21

Sarah 2:3 5:21

satisfied 159:6

save 64:10 94:16

95:1 151:3

saver 169:14,15

199:4

savers 192:18

saves 95:10

saving 44:6 66:22

67:16

94:9,11,12

150:15

savings 14:3

15:15,17 16:21

17:2,3 19:12

24:16 25:2,11

26:17 38:9,21

43:20 64:8

66:14 67:17

69:7 72:11

73:15 77:1,3,8

78:14 81:13,19

82:4 94:6

106:10 122:1

134:22 136:1

148:9,11,13

149:6,8,9,16,17,

18,22 150:1,7,9

151:3,8,14,21

152:12

154:9,11,18,20

157:1,4 159:13

165:8,12,16

167:12

170:19,20

176:1,4,11,20

177:17,20

178:2,7 184:22

186:19

187:11,17

188:12

189:17,18,19

190:5,7,13,17,2

1,22

191:7,10,11

192:2,3,7,8

195:8 196:19

197:8,13

198:2,7 200:13

201:10,13

203:1,5,15,16,2

0 204:14 206:1

210:4 218:1

235:2,22

238:2,3,13

239:8 242:18

244:5

saw 181:8 221:12

SBA 225:15

SBA's 226:1

scale 113:7 160:5

162:9

scaled 56:21

61:10,13 109:8

122:17

scaling 61:14

99:11,13,17,18

100:4,11,16,20

101:3,4,14

113:15,20

123:10 124:9

128:7,8

scarcity 48:10

SCC 238:6

scenario 81:15

94:1 135:1

150:15 189:10

193:16 194:10

200:16

214:17,18,19,21

215:4,8,9,12,13,

14,17,21

216:2,7,10

217:14,16

scenarios 52:11

93:7 94:6,14

95:3 134:6

149:1,13,21

150:5,7,8

151:20 152:11

205:13

214:13,14

218:12 230:14

schedule 22:17

29:11

school 241:2

scope 23:21 25:3

26:6,8

scrap 69:11

screen 31:19

49:18 64:15

screened 45:18

46:1,2,11 96:17

screening 7:4

32:1,6,11

45:8,10,12

48:12 52:22

56:18

sea 236:12

sealed 122:8

127:19,22

seats 103:11

second 21:18 22:4

64:17 75:21

82:4 108:2

113:16 143:6

154:21 181:2

206:21 207:5

209:11 216:21

229:10 233:22

secondly 108:1

199:22

section 3:21 29:19

31:16 50:22

136:20

sections 30:6

72:20

sector 106:16

116:7 117:11,12

134:2,3,4

135:3,4

136:15,16,19

137:17

138:18,20

147:8,15 149:7

150:18

151:4,7,9

152:18 206:2

240:16

sectors 116:8,22

117:21 131:17

132:2 148:22

149:6,12,20

150:4 151:20

152:10 239:3,5

241:11,12

security 156:1

seeing 27:4 65:15

165:11 244:11

seek 12:1

seeking

120:13,17,21

207:2 210:18

seeks 162:19

195:17 227:9

229:4,11,16

233:16

seem 38:6

93:17,22 101:5
Capital Reporting Company

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110:2,4

seemed 113:11

seems 40:14 86:7

113:4 130:22

131:5 144:11

147:18 168:12

172:18 182:22

186:6 228:13

seen 13:2 19:6

34:8 47:14

173:18 182:3

221:12

segment 115:21

116:4

segments 116:14

segregation

131:21

select 81:8 199:19

selected 50:18

56:12,14 58:17

68:1 81:11

86:22 104:10,21

132:9

selection 98:14

200:17

selections 81:21

sell 41:20 90:16

117:10,11

selling 129:22

sells 92:7

sending 96:11

sense 33:10,16

38:9 40:2 76:9

189:11

sensitivity 134:6

145:6 158:15

173:21 174:2

sensors 139:3

sent 96:13 138:21

140:7

sentiment 172:18

separate 30:8,9,20

32:17 55:16

75:8 77:15

114:17 131:16

155:11 170:7

199:10

212:15,21

236:17

September 21:19

22:18

series 25:22 44:20

173:11,20

serious 19:11

serve 154:14

service 1:10 3:5

13:21

19:6,15,19

24:13 25:15

29:2,3 69:3

174:21

sets 133:19 225:15

setting 13:8 23:15

32:20 33:8,14

34:16 35:2,12

65:19 74:15

99:3 132:11

settings 93:11

settled 103:12

seven 23:16 89:7

several 14:15 50:4

87:6 119:16

143:3 229:2

severe 36:21

215:8,12,21

216:2 233:3

shape 33:9,12

62:9 99:17,19

114:2 124:13

129:1 178:12

shaped 99:20

100:15

shapes 24:18

110:14

share 8:3 24:22

25:10 75:7

77:12 134:4

161:16,18

166:18

shares 161:11

sharply 159:12

shift 15:9 74:22

161:19 163:1

167:2,9

171:5,14

172:2,10,18

178:12 183:3

187:8,16,17

195:3 198:21

199:2

shifted 154:19

188:4 224:22

shifting 161:14

175:17 198:4

209:19

shifts 178:21

183:6 188:5

195:12,13

232:21 233:1

shipment 97:16

112:1 130:12

148:9 163:6

195:18 205:9

shipments 3:22

7:10 97:8

111:18 139:16

149:9,18

156:10,14,19,20

157:1,2,8,12,16

158:22

160:13,16,17

161:6

162:5,7,11,13,1

6 166:12 175:21

212:12 219:7

shipped 242:17,21

shipping 92:5

shop 102:22

short 41:18 42:1

78:4,6,11,20

79:3 213:17

235:17 237:13

shortage 182:4

211:11

shortages 183:8

shorten 41:13

shortening 185:6

shorter 77:4

105:13

220:21,22 222:6

230:21

shortly 5:3

showing 83:6

160:19 164:17

165:12

shown 23:18 24:2

25:12,19 26:11

46:1 57:5

103:17,19

108:13,14 120:6

159:21 161:3

179:10 215:19

217:11 235:13

239:7

shows 36:4 116:22

134:1 135:10

141:14 148:21

149:11,19 150:3
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151:18 152:9

159:7 163:7

177:16 198:20

242:12,16

shrink 232:3

shrinking 177:21

shut 180:21

sidebar 8:7

sign 154:18

signal 222:17

signals 161:10

significant 24:15

26:17 52:14

60:19 71:7,12

116:7 162:21

185:8 219:6,7

significantly

71:10 137:22

209:5 226:20

silent 8:6

similar 26:4 36:7

58:5 60:21 68:4

171:13 178:12

180:1 244:12

similarly 5:4

35:16 100:4

173:12

simple 53:22

123:7 136:3

141:10 164:6

simplistic 204:1

simply 11:15 42:6

43:17 55:20

125:12 129:5

142:18 159:14

164:12 166:16

171:8 177:21

187:20

191:1,10,15

197:9

simulate 48:1

single 35:19 77:16

87:13 125:5

142:3,6 184:9

singular 49:11

sits 87:20

situation 40:18,20

65:14

87:3,14,19

126:19 232:11

situations 143:7

230:4

six 24:1 34:3

45:11 60:11

66:5 235:12

six-foot 24:20

size 125:6,9 127:9

218:20

sketched 29:7,13

skew 98:6

skewed 92:7

106:6 219:21

skews 142:16

skimming 109:4

slack 90:19

182:5,6

slide 10:16 23:14

24:3 25:20

26:11 27:2

28:19 29:4,20

64:22 84:6 93:3

94:18 95:13,16

101:6 107:1

108:2 124:10

137:16 145:12

157:8 169:22

184:11 198:17

208:4,20 210:9

214:12 215:19

217:11,12

233:15 236:14

slides 9:1,7,9 22:5

132:5 148:7

178:22 184:9

206:19 207:7

242:7

sliding 37:15 43:6

44:16 75:12

100:17

slightly 48:18

197:10

slim 154:22

slimline 24:4

100:13 150:4

small 26:15 35:2

68:21 87:3

89:10 107:12

122:21 123:2

124:9,12,16

127:6 131:7,17

134:4 154:16

162:3 164:16

170:16 171:4

181:12,13

196:7,11 200:3

203:21 204:22

205:6 207:8

211:11

225:12,13,14,17

,19,21,22

226:2,3,5,9,11,1

3,16 227:1,6,10

228:12,18

smaller 35:3

36:14,15

127:7,9 128:5

164:21 191:8

205:4 236:2

238:2

smooth 202:12

so-called 16:9

social 177:9

236:6,8,9 237:8

240:16 241:21

socket

141:15,17,18

software 8:13

223:3

sold 96:14 105:14

114:22 115:18

116:8 124:17,20

126:5 150:17

165:14 188:9

226:7

solely 223:9

soliciting 238:6

solid 17:11

183:2,3,6,9,16

Solutions 3:9 5:4

somebody 89:14

97:22 98:16

108:21

somehow 213:18

someone 50:11

98:8,12 170:21

171:5 197:6

224:22 227:15

somewhat 106:6

somewhere

27:12,17 124:22

224:10 237:19

240:11

sorry 9:19 37:4

48:17 54:8,15

62:1,12 70:12

140:22 173:5

181:5 220:10

222:18 238:18

241:22
Capital Reporting Company

GSFLIRL Meeting 05-01-2014

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sort 27:14 36:12

45:4 65:19 67:5

79:5 94:5 97:22

106:7 182:9

237:4 244:7

sorting 92:4 96:11

sought 68:3

sounded 51:21

171:16

sounds 85:5

101:15 201:14

204:1

source 16:1 195:8

sources 10:14

133:16,19 137:5

201:11 228:5

Southern 4:20,21

space 95:10

126:11

spaces 83:22

spacing 34:4 60:2

71:19 148:17

span 56:19

speak 8:1,15 50:2

62:12 76:15

124:7 127:2,3

150:12 222:16

speaking 98:7

181:4 222:12

specialized 19:14

specialty 19:5

26:15

species 235:12

specific 10:4 35:4

64:22 66:6

110:21 111:10

118:11,18

119:1,17 126:18

137:5 147:11

195:16 201:3

213:16

specifically 11:12

33:14 35:8

90:18 107:7

145:8 210:9

specification

212:7

specifications

11:8 226:14

specificity 86:8

specifics 208:20

specified 24:12

spectrum

17:19,22

18:7,10,15

22:13 34:17,21

103:17

122:19,20 123:3

speculate 231:17

speculation

228:19

spend 241:20

spending 37:10

239:2

spike 168:19

173:18

179:10,20,21

184:20

spiked 183:7

184:17

spikes 43:13

173:20 221:13

spread 87:9

226:19 237:15

spreadsheets

208:14

square 83:20

squeeze 125:7

stability 101:7

202:7

stable 179:13

stage 22:3 29:20

64:16 158:16

stakeholders

57:20

stand 6:9 55:22

standard 7:7,16

11:16 13:22

14:3,13 15:6,18

16:2 17:19 18:7

19:2,4,13 24:5

32:18 33:15

34:21 35:19,21

38:5,7,8,10,18

39:6 40:21

41:2,4,7

42:14,19 44:6

48:11 51:11

52:2,5 57:16,18

58:3 74:17,18

75:1,14 76:5,7

77:2,13 100:14

103:17 112:13

113:22 115:1

119:20 122:19

127:11 132:5

135:16,22 136:2

146:19 149:20

154:21 157:2,5

160:10 161:18

162:7 163:1

172:8 175:7

176:3,21

177:4,5 178:5,6

181:15 186:5,7

187:11,17 188:1

192:6,7,14

205:16 206:22

215:2,7 224:2

235:11

242:4,10,12,19

standardized

234:22

standards 1:9 3:4

5:19 9:12

13:8,17

14:1,2,11,15

15:8,11

16:19,22 18:21

21:4,6,7,13,14,1

5,16,17,19

22:4,6,8,10,12

23:9,16,20

24:1,10,14,16

25:2,11

26:13,20 31:11

36:11 44:15

57:3 75:17 99:4

100:18 111:6,21

116:12,20

124:15

132:11,14 135:9

145:22 161:12

162:8,14,15

163:2 167:1

169:14,19

171:18,19

176:6,13 180:21

181:16 184:5

185:8 188:6

191:7 192:18

194:18 195:2

196:21

207:4,8,15,20

208:3,22

209:2,4,10,12,1

9,22 211:21

215:6,11,16

225:12

226:10,12,16

227:5,8,11

229:15,19 234:3

235:7 237:11

239:4,11,17,18,
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20 240:6 242:8

standpoint 43:21

72:15 73:20

86:12 96:18

97:21 101:10

164:21

Star 11:10

start 3:3,11 4:13

6:19 22:7 56:5

69:19 81:2,14

92:17 114:1

156:4 169:2

182:22 183:9,12

197:22 229:20

started 56:9 85:9

starting 21:15

23:22 128:8

174:18

starts 69:21

177:22

state 20:13 58:19

60:17 130:7,14

131:9 137:2,16

154:7 173:22

183:2,3,6,9,16

240:18,21

stated 22:17 25:7

27:10 57:2

64:16 83:4

118:18 144:17

153:10 169:11

209:18

statement 12:14

30:5 37:20

55:12 66:21

97:20,22 124:19

144:7 190:3

193:10 196:17

199:14

statements 7:2 9:8

12:4

states 92:6 95:8

96:14 133:21

141:22 171:7

194:7 228:6

stating 27:9

statistical 86:12

87:5

statistically

142:21

Statistics 136:12

stay 95:1 140:20

210:22

stays 189:9

steady 73:18

173:22 194:7

step 14:16 47:21

64:17 98:5

180:6

stepped 66:20

steps 9:16 98:19

Stevens 2:9 6:12

77:19,21,22

110:22

111:1,8,16

112:2 131:13,14

138:16 139:21

140:7,14 141:12

142:4,6

146:12,13,14,17

182:15,16,17

187:15 188:2,12

193:12,14,19

194:5,9

202:19,20

211:14,15

212:1,10

stick 29:11

stock 139:12

159:8,18 188:22

stop 197:16

202:14

stopping 155:19

store 241:3

stores 60:4 130:9

131:18

story 220:8,9

straight 241:6

strand 209:13

strategies 107:15

strategy 213:18

stray 114:3

striation 67:3

striations 80:13

strikes 113:9

striking 161:13

162:8

string 74:4

stringency 74:18

striving 170:21

strong 68:16,20

113:12 244:10

stronger 13:9

161:20

strongly 13:20

16:5 160:15

178:10 244:3

struck 15:17

165:6

structure 37:14

208:4

structured 64:2

stuck 95:17

studied 119:17

stuff 156:3 183:8

sub 154:3

subgroup 207:8

sub-group 153:20

154:13 155:4,7

subgroups 207:6

sub-groups 154:2

subject 22:2 50:3

111:5,20 115:1

195:2

submit 9:6 10:15

38:12 114:21

242:1

submitted 10:12

23:7 38:3 126:3

Subpart 30:15

subsequent

173:20

subset 107:12

substantial 19:3

25:1 77:12

209:13

substantially

161:20

substantiate

129:6

substantiated

12:1 17:15

substitute 111:19

115:21 121:14

substitutes 56:17

68:1,2,7,10

105:9 109:16

114:20 119:14

sub-sub-group

155:10

subtract 170:5

subtracts 135:20

sudden 92:9,11
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Sue 5:16 66:4

sufficient 76:11

sufficiently 7:20

suggest 28:19

30:20 44:11

112:3,12 142:11

145:14 167:15

177:12 196:20

suggested 15:21

93:7 173:8,10

suggesting 34:5

44:10 94:3,5

114:17 116:9,19

141:1

suggestion 131:15

204:5

suggests 18:15

27:11 222:21

sulfur 235:19

summarily 114:10

summarizes 162:4

242:9

summary 13:18

140:8 176:14

242:8,15

super 36:12

224:1,6

supervised 156:3

supplier 224:7,10

suppliers 182:21

225:1

supply

180:11,20,22

182:9,21 213:17

224:19 230:18

support 13:20

14:22 16:6

20:14 22:20

69:17 131:22

244:3 245:4

supporting 15:3

suppose 42:6

sure 62:2 63:13

72:2 73:1,10

84:11 88:12

102:18 109:10

110:11 131:6

138:8

139:11,14,21

152:3 157:7

187:12 232:3

240:14

survey 75:8

140:14,16

surveyed 139:5

survive 60:5

Susan 2:5 33:22

34:12 46:8,9

59:15,16 60:18

61:2 62:16 66:7

74:10,11

144:20,21 146:2

222:21 225:7

susceptibility 67:7

susceptible 67:3

SW 1:14

swings 179:22

switch 142:3,7

158:17 161:9

163:14 174:20

switches 141:10

switching 164:9

166:20 173:2

189:3 191:3

208:19

Sylvania 5:17

34:1 46:10

59:17 74:12

118:7,9 144:22

system 14:21

67:14 81:9

82:1,5 93:13,20

134:9,11,14

148:20 183:18

199:21 200:7,14

206:3 238:15

systems 18:18

73:4 80:18

81:7,16

82:14,15 99:7

134:7,9 148:18

182:18 188:21

193:16,22

199:18 200:5

201:13

T

T12s 213:14

T5 57:17,18 82:11

100:14

149:12,20

154:21 161:14

163:15 165:11

166:4

167:7,15,17,21

168:4,5

171:14,19 175:7

192:17

T5s 42:16

161:16,20 162:7

163:2,6,8,18,19,

22 164:20

165:10,13

170:10 172:9

T8 163:14 165:11

166:4,6

167:7,15,19

168:4,5

171:14,18

175:6,10 224:6

T8s

163:1,19,20,22

165:2,10 167:20

168:11 170:10

172:7 224:2

table 13:10 23:18

25:13 33:20

36:4 48:9

58:10,15 68:6

80:22 81:13,15

82:7,10 94:20

103:17 120:7

134:1 148:21

149:11,19 150:3

151:18 152:9

171:21 178:4

215:20,22

217:13,14

tables 94:21 133:6

tail 86:21 87:22

taking 42:7 78:13

87:3 98:20

183:12 192:2

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targets 240:2
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task 83:17,21

85:15

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throughout 10:2
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78:5 157:21

174:1 211:6

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161:18 162:6
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usually 34:17

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217:5

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