Appliances & Commercial Equipment Standards: Fluorescent and Incandescent Lamps Public Meeting Page 1 of 2

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## Fluorescent and Incandescent

Lamps PublicMeeting for Test ProcedureNOPRand Energy ConservationStandard ANOPR DATE: March 10-11, 2008 TIME: 9:00 a.m. - 5:00 p.m. ET LOCATION: U.S. Department of Energy

1000 Independence Avenue, SW Room 8E-089 Washington, DC 20585 Purpose: The Department of Energy (DOE) held an informal public meeting that covered the test procedure Notice of Proposed Rulemaking (NOPR) for general service fluorescent, incandescent reflector, and general service incandescent lamps and the energy conservation standard Advance Notice of Proposed Rulemaking (ANOPR) for general service fluorescent lamps and incandescent reflector lamps. This public meeting gave DOE an opportunity to present its proposals in the test procedure NOPR, the methodology analyses prepared for the energy conservation standard ANOPR, and to respond to stakeholder's questions. The meeting also enabled DOE to outline its plans for the remaining energy conservation standard analyses and to seek input from stakeholders on its planned methodologies, assumptions, and data sources. The agenda for the public meeting first covered the test procedure NOPR and then the energy conservation standard ANOPR, continuing on the following day, March 11, 2008. For more information, please visit the Energy Conservation Standard ANOPR and Test Procedure NOPR webpages. The following documents are available as Adobe Acrobat PDFs. Download Acrobat Reader. 

### Meeting Materials • Notice of Proposed Rulemaking and Notice of Public Meeting, Federal Register, March 13, 2008 (PDF 250 KB) • Advance Notice of Proposed Rulemaking and Notice of Public Meeting,Federal Register, March 13, 2008(PDF 1.4 MB) • Presentations: Test Procedure NOPR (PDF 162 KB) ECS ANOPR Scope of Coverage (PDF 134 KB)

http://www.eere.energy.gov/buildings/appliance_standards/residential/lampsanopr_mtg.html 5/29/2008Appliances & Commercial Equipment Standards: Fluorescent and Incandescent Lamps Public Meeting Page 2 of 2

ECS ANOPRRulemakingOverview (PDF 91 KB) ECS ANOPREngineeringAnalysis (PDF 452 KB) ECS ANOPR Life-Cycle Cost Analysis (PDF 131 KB) ECS ANOPRNational ImpactAnalysis (PDF 134 KB) ECS ANOPR NOPR Analysisand Next Steps(PDF 148 KB) ECS ANOPR Closing (PDF 38 KB) ® Transcripts: Public MeetingTranscript, March 10, 2008 (PDF 1.1 MB) Public MeetingTranscript, March 11, 2008 (PDF 281 KB)

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http://www.eere.energy.gov/buildings/appliance-standards/residential/lamps_anopr_intg.html 5/29/2008UNITED STATES DEPARTMENT OF ENERGY PUBLIC MEETING ON TEST PROCEDURES FOR GENERAL SERVICE FLUORESCENT LAMPS, INCANDESCENT REFLECTOR LAMPS, AND

GENERAL SERVICE INCANDESCENT LAMPS

AND ENERGY CONSERVATION STANDARDS FOR GENERAL SERVICE FLUORESCENT LAMPS AND INCANDESCENT REFLECTOR LAMPS

U.S. Department of Energy

Room 8E-089 1000 Independence Avenue, Southwest

Washington, D.C. Monday, March 10, 2008

9:00 a.m. Participants DOUG BROOKMAN, Facilitator LINDA GRAVES Department of Energy

STEVE NADEL American Council for an Energy Efficient Economy RON LEWIS Department of Energy

GARY FERNSTROM Pacific Gas and Electric MICHAEL SCHOLAND Navigant Consulting, Inc.

CONAN O'ROURKE Lighting Research Center

JOE HOWLEY GE Consumer and Industrial

MAHIMA GUPTA Navigant Consulting, Inc.

ANDREW DELASKI Appliance Standards Awareness Project 1

EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064Participants (Continued)

PAM HORNER Osram Sylvania NEMA Lamp Section

PAUL WALITSKY The Industrial Ecology Company, LLC

MIKE RIVEST Navigant Consulting, Inc. JEFF HARRIS Alliance to Save Energy

SUSAN ANDERSON Osram Sylvania KEITH COOK Philips Lighting

TOM ECKMAN Northwest Power and Conservation Council

DIANA BURK Navigant Consulting, Inc. DAIN HANSEN National Electric Manufacturers Association ERIC STAS Department of Energy FRANCINE PINTO Department of Energy 2

EXECUTIVE COURT REPORTERS, INC.

(301) 565-00643 A G E N D A AGENDA ITEM: PAGE: Welcome 5 Linda Graves Opening Remarks, Introductions and Agenda Review 6 Doug Brookman Test Procedure Overview 13 Michael Scholand Comments from Participants Regarding the Test 15 Procedure NOPR

(None) Test Procedures 16 Michael Scholand Conan O'Rourke Energy Conservation Standard Overview 52 Mahima Gupta Comments from Participants Regarding the Energy 54 Conservation Standard ANOPR Andrew Delaski Appliance Standards Awareness Project Scope of Coverage 60 Michael Scholand Engineering Analysis 75 Mahima Gupta Conan O'Rourke

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(301) 565-0064AGENDA ITEM: A G E N D A 4

PAGE: Afternoon Session Engineering Analysis (Continued) 111 Conan O'Rourke Mahima Gupta Life-cycle Cost Analysis and Payback Period 191 Analysis

Diana Burk National Impact Analysis 241 Mahima Gupta Closing Remarks 299 Ron Lewis Adjourn

EXECUTIVE COURT REPORTERS, INC. (301) 565-00645 1 P R O C E E D I N G S 2 9:20 a.m. 3 Welcome 4 Linda Graves 5 MS. GRAVES: Good morning. Welcome to the 6 Department of Energy. I'm Linda Graves. I'm the 7 leader of the Standards Lighting Team. I'm here with 8 my boss, representatives of general counsel and policy, 9 and a team of energy consultants. It's a high-energy 10 group from Navigant Consulting, Rensselaer Polytechnics 11 Lighting Research Center, and OnLocation, and they will 12 be doing the presentations. They have quite a list of 13 issues that they'd like your input. 14 We're doing this as a doubleheader. We're 15 doing a combined meeting with the test procedures on 16 incandescent, fluorescent, and reflector lamps, 17 followed by the standards on fluorescent lamps and 18 reflector lamps. We've asked our esteemed facilitator 19 to be flexible as we work through the agenda so we can 20 cover the material in a way that will meet everyone's 21 needs. 22 As you know, the Energy Independence 23 Securities Act had a large impact on the team. We were 24 on the homestretch of being ready to go forward with 25 these rulemakings, and our team has really done yeoman

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(301) 565-00646 1 effort to incorporate all the changes very quickly. 2 For those of you who participated in the 3 framework document meeting, you'll recognize that the 4 scope has changed. We very much appreciate the impact 5 you gave us at that meeting and look forward to your 6 input and participation in this meeting today. 7 With that, I'm going to turn it over to our 8 facilitator, Doug Brookman. 9 Opening Remarks, Introductions, and Agenda Review 10 Doug Brockman 11 (PowerPoint presentation.) 12 MR. BROOKMAN: Thank you. It's our tradition 13 to ask that each person introduce him- or herself, so 14 I'm going to start and go around the room. Your name 15 and organizational affiliation, please. 16 (Introductions.) 17 MR. BROOKMAN: I guess that's all that's with 18 us. We expect more people will be joining us. 19 Probably, they're trying to clear through security. 20 I think all of you received a packet of 21 information as you walked in the door. The top of the 22 packet is the agenda for today, followed by a colorful 23 packet of slides that you'll be seeing as the day 24 proceeds, the PowerPoint presentation, as well as some 25 issues that have been identified for stakeholder EXECUTIVE COURT REPORTERS, INC.

(301) 565-00647 1 comment. 2 As Linda said, this is both the test 3 procedure meeting and also the standards meeting for 4 general service fluorescent lamps and incandescent 5 reflector lamps. So we're going to be covering both of 6 those in the span of these two days. 7 I'm going to take a quick spin through the 8 agenda. I am now finishing the first substantive block 9 that you see there, 9:05 to 9:15. Following that, 10 we're going to have a brief test procedure overview. 11 Immediately following that overview there's an 12 opportunity for each of you that wishes to do so to 13 make brief overview comments. Any issues that are 14 especially of concern to you, issues you want to flag 15 for the Department's consideration, that would be a 16 good time to do it. But, they should be brief. 17 Following that, we will have a summary 18 presentation on test procedures. We'll take a break 19 mid morning, round about 11:15 or so, and then, 20 following that, we'll have an Energy Conservation 21 Standard Overview and then get additional comments from 22 participants regarding the Energy Conservation Standard 23 ANOPR. We'll break for lunch round about noonish, 24 12:15. 25 Following that, when we return from a lunch, EXECUTIVE COURT REPORTERS, INC.

(301) 565-00648 1 a summary on scope of coverage, a mid afternoon break, 2 and then close out the day with engineering analysis. 3 And then you'll see, round about 3:45 this afternoon, 4 there's an opportunity again for anybody that wishes to 5 make comments that you don't think have been covered 6 sufficiently or at all. That would be a time for you 7 to raise additional issues. We'll adjourn today round 8 about 4 o'clock. 9 Let me say, as we're going through the agenda 10 today there's quite a bit of content. We'll be going 11 as efficiently and effectively through it as we can. 12 We don't want to diminish anyone's opportunity to speak 13 and comment. However, if we have the opportunity -- 14 we'll keep it moving along, is the bottom line. 15 So I'm asking each of you to speak up and be 16 assertive, and I'll be trying to recognize individuals 17 by name and queue you to be speaking. The Department 18 of Energy and I don't believe in wasting anybody's 19 time, so we'll go as rapidly through this and not 20 diminish the effectiveness of this meeting. 21 Steve Nadel, before I finish the agenda 22 review? 23 MR. NADEL: Yes. I was wondering, based on 24 some past experience, whether potentially things might 25 go well we can try to do this in one day. If we have EXECUTIVE COURT REPORTERS, INC.

(301) 565-00649 1 to go to 5 o'clock or something. 2 MR. BROOKMAN: Ron Lewis, do you want to 3 speak? 4 MR. LEWIS: We're going to deal with the 5 standards and the test procedures over the two days. 6 There are people that expected it to go into tomorrow 7 and some of them aren't even here yet. So I don't 8 expect we're going to get both of them done in one day. 9 MR. NADEL: Okay. Some of us can't come 10 tomorrow, but I guess we'll just proceed. I'm just 11 saying let's let the discussion proceed and if we can 12 cover more, is there a problem with that. 13 MR. LEWIS: If we finish -- there's a lot to 14 do. I would be surprised. But I think there were some 15 people that couldn't make it today that were going to 16 try to make it tomorrow and catch the end. 17 MR. FERNSTROM: I guess I would add, there 18 were some of us that saw in the notice that this was 19 going to be a one-day meeting, too, and we believed 20 that. 21 MR. LEWIS: Well, if we finish, but I don't 22 want to rush it and compress it trying to finish it in 23 one day if that's not the natural ending. That's. I 24 guess, my point, was not trying to just hurry things 25 only to complete it in one day. EXECUTIVE COURT REPORTERS, INC.

(301) 565-006410 1 MR. BROOKMAN: So one thing I have -- 2 MR. FERNSTROM: I'm sorry. I thought I 3 understood you to say absolutely not. 4 MR. LEWIS: Yeah. No, that was not my 5 intent. 6 MR. BROOKMAN: One thing that I haven't 7 covered yet because I'm still doing the agenda review 8 is some basic ground rules. We do hope that you'll say 9 your name for the record as we proceed so that our 10 court reporter here can get it straight. So that was 11 Steve Nadel, Ron Lewis, and then followed by Gary in 12 that, and followed again by Ron Lewis. 13 So the bottom line, Ron, is however far we 14 can get today, that's okay. 15 MR. LEWIS: Yes. I just don't want to rush 16 it and not cover the things with the focus being to end 17 it today. 18 MR. BROOKMAN: Let me offer a hypothetical. 19 If we got through everything today, would we come back 20 tomorrow? 21 MR. LEWIS: You can if you want. 22 (Laughter.) 23 MR. BROOKMAN: No, for real, because there 24 may be some people that maybe are going to show up 25 tomorrow. EXECUTIVE COURT REPORTERS, INC. (301) 565-006411 1 MR. LEWIS: We'll make arrangements if we do 2 complete everything, but I was under the impression 3 that we had so much content and there were some people 4 that said that they couldn't make it for the first day 5 and would try to make it for the second. 6 MR. BROOKMAN: We have a lot of content here. 7 We don't want to diminish anybody's capacity to 8 comment. 9 Okay. We appreciate these comments along 10 these lines. So then we'll go as quickly as we can, 11 and having said that, if we don't get it all done 12 today, then we'll resume tomorrow at 9 a.m. as we did 13 today. We'll observe basically the same format, and 14 we'll cover some of the material that we covered today 15 briefly. 16 So you can see the Energy Conservation 17 Standard Overview at 9:15. Round about 9:30 we go to 18 Life-cycle Cost Analysis. We'll take a break mid 19 morning. Then we'll go to National Impact Analysis. 20 We'll break for lunch, and then discussion of other 21 issues, talk about the NOPR analyses, and then talk 22 about next steps and closing remarks. If this schedule 23 holds, we'll adjourn tomorrow at about 3:30 or so. 24 So that's the general plan. Questions and 25 comments on that? EXECUTIVE COURT REPORTERS, INC.

(301) 565-006412 1 (No response.) 2 MR. BROOKMAN: There's frequently a slide for 3 ground rules, but I didn't see it in there. 4 MR. SCHOLAND: Sorry, Doug. 5 MR. BROOKMAN: That's okay. 6 MR. SCHOLAND: It's in the ANOPR stack. 7 MR. BROOKMAN: So I'm going to ask simply 8 that you speak one at a time and also say your name for 9 the record. Listen as an ally. Keep the focus here. 10 That is, please turn off your cell phones, put them on 11 vibrate, whatever. And if you have to have a sidebar 12 conversation, you'll notice the acoustics in this room 13 are very good. 14 (Laughter.) 15 MR. BROOKMAN: We can hear you. And it will 16 be disruptive if you're involved in a lengthy sidebar 17 conversation. So please don't do that. Please keep 18 the focus here. 19 I hope this is an opportunity for you to 20 pursue the issues that matter to you today. Let's 21 seize this opportunity today and make this a useful day 22 of dialogue for you and for the Department. 23 Okay. So that's all that I would say at the 24 outset. I think the first item on the agenda is then 25 to have a test procedure overview. Michael Scholand. EXECUTIVE COURT REPORTERS, INC.

(301) 565-006413 1 MR. SCHOLAND: That's right. Thanks, Doug. 2 Test Procedure Overview 3 Michael Scholand 4 (PowerPoint presentation.) 5 MR. SCHOLAND: Mike Scholand from Navigant 6 Consulting. I'm going to walk you through some of the 7 slides here on the test procedure notice of proposed 8 rulemaking that the Department issued a couple of weeks9 ago. My colleague Conan O'Rourke and I will be tag10 teaming this presentation because it is, after all, the 11 Monday morning after the hour has changed and it's a 12 little hard to have one person do them all. It might 13 put you to sleep. 14 So, what is the purpose of today's meeting. 15 Okay. We have four goals for today that we outline 16 here on Slide Number 2: to present the Department's 17 proposed test procedure for fluorescent and 18 incandescent lamps, to seek comment from participants 19 on the proposal, to discuss specific issues relating to 20 that proposal, and finally, to discuss next steps in 21 this rulemaking. 22 Let's review the schedule for the test 23 procedure. The NOPR, as I mentioned, was issued by the 24 Department on February 21st, 2008. The public meeting 25 we're holding today. Comments on the NOPR from EXECUTIVE COURT REPORTERS, INC.

(301) 565-006414 1 interested parties we're going to be recording. As 2 Doug has mentioned, a court reporter is here today. 3 All your comments that you make about the notice of 4 proposed rule will be recorded in the transcript for 5 today's meeting, and there is also a 75-day comment 6 period for written comments which you can supply to the 7 Department. 8 I just want to confirm, Linda. The notice of 9 proposed rulemaking will be published on Wednesday; is 10 that what the Federal Register said? 11 MS. GRAVES: The 13th. 12 MR. SCHOLAND: The 13th? Okay. So that's 13 Thursday? It's Thursday. So the 75 days will start 14 from the 13th. I think that puts us sometime in May, 15 towards the end of May. 16 DOE obviously reviews and considers all 17 comments, and finally, there will be a final rule 18 published. That final rule for the test procedure will 19 be published either on the same day or before the 20 notice of proposed rulemaking for the Energy 21 Conservation Standard, which is the second presentation 22 we'll be going with today. 23 I want to briefly walk you through the 24 outline for the test procedure presentation before we 25 open up the floor for any opening statements. We have EXECUTIVE COURT REPORTERS, INC.

(301) 565-006415 1 eight issues we're going to be discussing this morning, 2 Conan and myself. The first is updates to the test3 procedure references. Then we'll talk about high4 frequency fluorescent ballasts. We'll talk about 5 rounding fluorescent lamp efficacy. We'll talk about 6 the measurement of correlated color temperature. We'll 7 talk about general service fluorescent lamp basic model 8 definition. 9 Conan will discuss the reference ballast 10 settings for added fluorescent lamp coverage, and we'll 11 discuss test procedures for general service 12 incandescent lamps and off mode and standby mode energy 13 consumption. So these are the eight issues we'll be 14 talking about this morning in this set of slides. 15 Let's just stop here and open up for any 16 comments or issues or opening statements from any 17 stakeholders here on the test procedure. 18 Comments from Participants Regarding the Test Procedure 19 NOPR 20 MR. BROOKMAN: This is an opportunity for 21 anybody that wishes to say anything briefly that they'd 22 like to call out and call attention to. 23 (No response.) 24 MR. BROOKMAN: I see no comments, then, at 25 this time. Okay. EXECUTIVE COURT REPORTERS, INC.

(301) 565-006416 1 2 3 4 Test Procedures Michael Scholand and Conan O'Rourke (PowerPoint presentation.) MR. SCHOLAND: Okay. Great. Moving right 5 along, let's walk through some background on the 6 regulatory history for the test procedure. As you all 7 know, fluorescent and incandescent lamps were added to 8 EPCA by the Energy Policy Act of 1992 and DOE 9 established a final rule for that test procedure in May 10 of 1997. That established test procedures for 11 incandescent and fluorescent lamps, including compact 12 fluorescent lamps. The test procedure incorporated by 13 reference several ANSI and IESNA -- that's the 14 Illuminating Engineering Society of North America -- 15 industry standards. 16 Then, in August of 2005, Congress passed the 17 Energy Policy Act of 2005, and DOE codified a test 18 procedure final rule in December of that year which 19 established the Energy Star Version 2.0 for medium 20 screw-base compact fluorescent lamps as the test method 21 for CFLs. 22 Finally, the Energy Independence and Security 23 Act of 2007 established energy conservation standards 24 for general service incandescent lamps and it also 25 directed DOE to incorporate a measure of standby mode EXECUTIVE COURT REPORTERS, INC.

(301) 565-006417 1 and off mode energy consumption in its test procedures. 2 That's kind of the regulatory overview for 3 the context. Are there any questions at this point? 4 MR. BROCKMAN: I wasn't clear because I was 5 trying to be brief earlier. The format, as you can 6 see, is that there's rather detailed information in 7 these slides. After a few of the slides, then there's 8 an actual opportunity for each person to comment as you 9 wish. So you could just find the spot that's most 10 relevant for you and make your comments. 11 MR. SCHOLAND: Okay. No questions on this 12 regulatory history? Then I'll hand it over to Conan. 13 MR. O'ROURKE: Thank you, Michael. The first 14 thing we're going to go over is updates to the test 15 procedures, the references in particular. 16 We've looked at the references for the 17 existing ANSI standards that were lamp standards and 18 during this process we -- it's been identified that 19 these standards have been updated and also compiled 20 differently. The first row here is showing the 21 previous ANSI standards from 1991 have been 22 consolidated for double-ended lamps into C78.81 and for 23 single-ended lamps for C78.901. 24 Also, the test method for electrical 25 measurements of fluorescent lamps has also been updated EXECUTIVE COURT REPORTERS, INC.

(301) 565-006418 1 to the 1997 version, and the reference ballast ANSI 2 standard has also been updated to the 2002. Some of 3 these standards show up in the definitions of cold 4 temperature fluorescent lamp and fluorescent lamp, the 5 first row in particular, and also rated wattage refers 6 to them. Parts of the CFR that deal with references 7 and also the test procedure itself will reflect these 8 updated standards. 9 IESNA and the CIE standards have also been 10 addressed. LM-9, which deals with electrical and 11 photometric measurements of fluorescent lamps, has been 12 updated to a 1999 version. LM-45, which deals with the 13 measurements of incandescent lamps, has been updated to 14 the 2000 version. It was previously LM-16, which had 15 been withdrawn. It was no longer part of the IES 16 procedures. And also, an update to CIE 13.2. It has 17 been corrected to 13.3, which is dealing with the 18 color-rendering properties of light. This does affect 19 the definition of colored fluorescent lamp and also 20 would be addressed and referenced in the test procedure 21 section in Appendix R. 22 Any questions on those test procedures at 23 all? 24 25 (No response.) MR. O'ROURKE: I'm going to continue on to EXECUTIVE COURT REPORTERS, INC.

(301) 565-006419 1 talk about the medium base compact fluorescent lamp. 2 In the 1997 rule, they had established test procedures 3 for CFLs in Appendix R and it had referred to LM-66. 4 But in EPACT 2005 it had been updated to Version 2.0 of 5 the Energy Star specification for CFLs. So to prevent 6 any conflict being suggested that LM-66 be removed 7 as a reference in the test procedures. 8 At this point the Department is seeking 9 comment on the proposed test procedures and the 10 reference updates, specifically whether these updates 11 to the standards would introduce any additional testing 12 burden or measurement of lamp efficacy. 13 MR. BROOKMAN: So you can see what the 14 Department has wanted to incorporate by reference and 15 otherwise, and you can see the items that they've 16 wanted to not incorporate as well. So, comments on 17 those, please. Yes. 18 MR. HOWLEY: Joe Howley, making comments on 19 behalf of the NEMA Lamp Technical Section. The 20 chairman of the technical section could not make it. 21 His flight was canceled, and so I'll be making these on 22 his behalf and the behalf of the NEMA Lamp Technical 23 Committee. 24 Regarding the subject of incorporated 25 industry standards by reference, NEMA agrees with the EXECUTIVE COURT REPORTERS, INC.

(301) 565-006420 1 DOE proposal to update the incorporated industry 2 standards by reference to current editions as noted in 3 the NOPR. This is consistent with NEMA's earlier 4 proposal to the DOE, and as further noted by the 5 Department, such an updating would maintain the desired 6 consistency, accuracy, and in some cases reduce 7 potential errors. 8 NEMA appreciates the update of fluorescent 9 and incandescent lamp test procedures as proposed in10 the NOPR and would incorporate all of the most up-to11 date industry standards and practices. 12 However, regarding the subject of IESNA LM9- 13 99, NEMA does not agree from a technical point of view 14 with DOE contention that provisions contained in IESNA 15 LM9-99 would require the Department to amend the energy 16 conservation standards for fluorescent lamps to take 17 self-absorption provisions of LM9 into account. NEMA 18 will provide more detailed written comments on this 19 subject. 20 NEMA notes that under substitution method21 calibration conditions no separately determined self22 absorption factor, or SAF, is required since self23 absorption correction is inherent in the substitution 24 calibration process. An SAF is required when the 25 measured lamps are different in physical size and shape EXECUTIVE COURT REPORTERS, INC.

(301) 565-006421 1 from the standard sources used for calibration, not the 2 substitution method. 3 The premise that the addition of the SAF 4 increases measurements by 5 to 10 percent and that it 5 would therefore be the basis for revised DOE energy 6 efficiency requirements is not correct. We further 7 recommend that since the DOE is not an expert in such 8 matters that the Department involve a photometric 9 measurement expert at NIST, such as Yoshi Ono, since 10 NIST is responsible for government lamp calibration 11 methods, is a well-respected participant on photometric 12 standard bodies, and is the primary source of luminous 13 flex calibration sources in the U.S. 14 We further note that the Department made use 15 of the NIST expertise during the development of certain 16 provisions of the 1997 final rule test procedures for 17 lamps and strongly urge DOE to solicit NIST assistance 18 in this particular subject. Thank you. 19 MR. BROOKMAN: Thank you. Thanks very much. 20 Yes, Gary. Yes, will you hand that down to him? 21 MR. FERNSTROM: Gary Fernstrom, Pacific Gas 22 and Electric Company. Just one quick comment. We see 23 light-emitting diodes coming onto the lighting scene 24 quickly. Is there a provision or thought about test 25 methods for LEDs or will they fit into some of these EXECUTIVE COURT REPORTERS, INC.

(301) 565-006422 1 tests? 2 The reason I ask the question is because LEDs 3 will have drivers or the equivalent of ballasts, and 4 I'm not sure whether incandescent test standards or 5 fluorescent ones or other ones would be the appropriate 6 test standard. 7 MR. BROOKMAN: I'm looking at this side of 8 the room first. Is that appropriate? Ron Lewis. 9 MR. LEWIS: Thanks for the input, but I think 10 with the schedule that we're under to get this done and 11 to have things definitive, I don't think the time 12 allows for it right now. I agree that as LEDs and 13 solid state lighting becomes more of a factor we're 14 going to have to have test methodologies for that. But 15 right now, to get this out, I think that we're going to 16 keep it in the spirit existing. 17 MR. FERNSTROM: Okay. So I wasn't suggesting 18 that something new be added, but I was just looking for 19 a clarification as to whether the group felt that 20 separate test methods would be required or if these 21 would be applicable. 22 MR. BROOKMAN: Michael Scholand. 23 MR. SCHOLAND: Mike Scholand from Navigant 24 Consulting. I can give you -- outside of the scope, 25 first of all, of this rulemaking, this is about EXECUTIVE COURT REPORTERS, INC.

(301) 565-006423 1 fluorescent lamps and incandescent, as you understand. 2 In Ron's office there is a program to support the 3 development of -- increasing the efficiency, the 4 efficacy of light-emitting diodes and to look at 5 standardization for test methods and representation of 6 efficacies. It's being run by a gentleman by the name 7 of Jim Broderick. 8 He has, under contract, Pacific Northwest 9 National Laboratories and their lighting team, and they 10 are drafting an IESNA test methodology for testing 11 white light-emitting LED devices. I think that would 12 be the better context for that. 13 MR. FERNSTROM: Okay. So you answered my 14 question. It's not the intention that any of these 15 test procedures be used for LEDs. 16 MR. SCHOLAND: No, not at all. 17 MR. FERNSTROM: Thank you. 18 MR. BROOKMAN: Thank you. Thanks for the 19 query. Other comments or questions on this segment of 20 the standards that are anticipated and incorporated by 21 reference or not incorporated by reference? 22 (No response.) 23 MR. BROOKMAN: Okay. Conan. 24 MR. O'ROURKE: Thank you, Doug. The next 25 section is going to be a discussion of high frequency EXECUTIVE COURT REPORTERS, INC.

(301) 565-006424 1 fluorescent ballast testing. In the first slide, 2 Department procedures require that they be tested using 3 low frequency. That's been the standard method for 4 testing fluorescent lamps. But the recent addition of 5 update to ANSI C82.3 does incorporate now a reference 6 ballast for high frequency operation. 7 By continuing to test the fluorescent lamps 8 on low-frequency ballasts when possible, DOE ensures 9 that there is consistent and repeatable efficiency 10 measurements. ANSI provides only high frequency 11 reference ballast settings for several lamps, so in 12 that case DOE would propose using a high frequency 13 reference ballast for those lamps only. 14 The second slide, referring for high 15 frequency fluorescent ballast testing. The Department 16 realizes that the market is shifting towards high 17 frequency ballasts which would operate the lamps at 18 high frequency. So future industry trends may provide 19 input in whether they should shift the test procedures 20 over to high frequency operation measurement 21 capabilities. 22 In such a case, the Department may be willing 23 to amend its procedures by choosing the ratings for 24 either high frequency or low frequency, and then you 25 could use one to scale the other when the case may be. EXECUTIVE COURT REPORTERS, INC.

(301) 565-006425 1 So the Department is seeking comment on 2 whether they should limit its testing to low frequency 3 ballasts at this time. 4 MR. BROOKMAN: Joe, do you have a comment? 5 Joe. 6 MR. HOWLEY: I think NEMA generally agrees 7 but the technical committee will be providing written 8 comments on this. 9 MR. BROOKMAN: Thank you. 10 MR. O'ROURKE: Thank you. Next we turn it 11 back over to Michael. 12 MR. FERNSTROM: One more comment? 13 MR. SCHOLAND: Sure. Go ahead. 14 MR. FERNSTROM: Gary Fernstrom, PG&E. We 15 believe that ballast testing should not be limited to 16 low frequency and high frequency should be considered 17 as well. 18 MR. BROOKMAN: Thank you. Any additional 19 comments on that point? I see none. 20 MR. SCHOLAND: Okay. Mike Scholand here 21 continuing on Slide 15. Thanks, Conan. Let's now 22 discuss the rounding of fluorescent lamp efficacy. 23 Lamp efficacy is defined in the Code of 24 Federal Regulations as the ratio of measured lamp lumen 25 output in lumens to the measured lamp electrical power EXECUTIVE COURT REPORTERS, INC.

(301) 565-006426 1 input in watts rounded to the nearest whole number in 2 units of lumens per watt. 3 So for fluorescent lamps, lamp efficacy is 4 rounded off to the nearest lumen per watt. For 5 incandescent reflector lamps, it's rounded to the 6 nearest tenth of a lumen per watt. 7 The DOE believes that the accuracy of 8 efficacy measurements is crucial in order to maximize 9 energy savings under the Department's regulations. DOE 10 therefore is proposing to revise the fluorescent lamp 11 test procedure such that all efficacy measurements for 12 fluorescent lamps be rounded to the nearest tenth of a 13 lumen per watt. 14 This proposal is consistent with DOE's 15 approach in the May '97 final rule regarding the 16 rounding practice required for the calculation of 17 incandescent reflector lamp efficacy. In that rule, 18 DOE stated that IRL lamp efficacy should be rounded to 19 the nearest tenth of a lumen per watt in order to 20 retain the significant figures in the EPCA standard for 21 IRL. 22 DOE notes that the average lamp efficacy for 23 general service fluorescent lamps, as listed in EPCA, 24 are specified to the nearest tenth of a lumen per watt. 25 Finally, the proposed revision to the EXECUTIVE COURT REPORTERS, INC.

(301) 565-006427 1 efficacy rounding practice for general service 2 fluorescent lamps does not alter the method for taking 3 the test measurements but only the calculation of lamp 4 efficacy itself. 5 DOE seeks comment on whether fluorescent lamp 6 efficacy should be calculated to the nearest tenth of a 7 lumen per watt. 8 MR. BROOKMAN: Joe. 9 MR. HOWLEY: Joe Howley. The lamp 10 manufacturers have found no issue with rounding to the 11 nearest whole number. Has been the case since 1997. 12 However, they're taking this proposal into 13 consideration and will provide further written 14 comments. 15 MR. BROOKMAN: Thank you. 16 MR. SCHOLAND: Steve. 17 MR. NADEL: Yes. We support use of tenths. 18 As we use the data, oftentimes the rounding is a 19 judgment call to try to draw a clean standard. I think 20 the tenths will make it much easier to do. 21 MR. BROOKMAN: Thank you. 22 MR. SCHOLAND: Okay. Thank you. Any other 23 comments on Issue Number 3? 24 (No response.) 25 MR. SCHOLAND: Okay. Now let's discuss the EXECUTIVE COURT REPORTERS, INC.

(301) 565-006428 1 measurement and calculation of correlated color 2 temperature. The Department uses correlated color 3 temperature for two purposes. The first one is, DOE 4 uses the metric to define a colored fluorescent lamp 5 and a colored incandescent lamp, both of which types 6 are excluded from regulation. 7 The second purpose is a kind of proposed 8 purpose which is relating to the energy conservation 9 standard advance notice of proposed rule we'll be 10 discussing later today. That is, DOE is considering to 11 establish product classes for fluorescent lamps in part 12 around correlated color temperature. 13 So now let's look at correlated color 14 temperature for fluorescent lamps. The existing test 15 procedures for fluorescent and incandescent lamps in 16 the Code of Federal Regulations do not provide guidance 17 or methodologies for determining or calculating 18 correlated color temperature. DOE therefore proposes 19 to incorporate by reference IESNA LM9-1999 to determine 20 CCT for fluorescent lamps. 21 DOE does not believe the adoption of this 22 standard imposes excessive burden on manufacturers 23 because they already use this method to calculate 24 chromaticity coordinates to report on the CCT for their 25 product catalogues and marketing literature. EXECUTIVE COURT REPORTERS, INC.

(301) 565-006429 1 DOE proposes to amend the definition of 2 colored fluorescent lamp in the notice of proposed 3 rulemaking to include references to IESNA LM9-1999. 4 DOE seeks comment on the proposed 5 incorporation by reference of the industry standard 6 LM9-1999, the title of which is IESNA Approved Method 7 for the Electrical and Photometric Measurement of 8 Fluorescent Lamps, for measuring and determining CCT 9 for fluorescent lamps. 10 Joe. 11 MR. HOWLEY: The NEMA agrees that LM9-1999 is 12 appropriate as both a test procedure and as a means to 13 determine fluorescent lamp CCT. Thank you. 14 MR. SCHOLAND: Great. 15 MR. BROOKMAN: Additional comments? 16 (No response.) 17 MR. SCHOLAND: Okay. Slide 20. The Energy 18 Independence and Security Act of 2007 introduced a new 19 definition to the statute for colored incandescent 20 lamp. The definition is shown here on the screen, and 21 essentially it says a colored incandescent lamp is in 22 part an incandescent lamp with a correlated color 23 temperature less than 2,500 Kelvin or greater than 24 4,600 Kelvin where the correlated color temperature is 25 computed according to the Journal of Optical Society of EXECUTIVE COURT REPORTERS, INC.

(301) 565-006430 1 America, Volume 58, pages 1528 to 1595 (1986). We have 2 noted that that, we think, is a typographical error in 3 the statute, that it should be 1968. 4 EISA 2007 gives a precise reference which DOE 5 proposes to incorporate into its incandescent test 6 procedure in this notice of proposed rulemaking. DOE 7 does not consider this action to be unduly burdensome 8 as no manufacturer is required to determine the CCT of 9 their incandescent lamps unless they're classifying 10 them as colored incandescent lamps, at which point they 11 would not be subject to standards. 12 Are there any questions on the CCT for 13 colored incandescent lamps? Okay. 14 MR. BROOKMAN: Joe. 15 MR. HOWLEY: NEMA will be providing written 16 comments. 17 MR. SCHOLAND: Okay. Thank you, Joe. Now 18 let's discuss the definition of basic model for a 19 general service fluorescent lamp. As mentioned 20 earlier, in the energy conservation standards ANOPR 21 we'll be discussing later today DOE is considering 22 separate product classes for fluorescent lamps based on 23 correlated color temperature. 24 If a standard were to be set based on CCT 25 product classes, manufacturers would need to test and EXECUTIVE COURT REPORTERS, INC.

(301) 565-006431 1 report on a basic model for each of those product 2 classes. A basic model involves identifying a lamp or 3 class of lamps which do not have any differentiating 4 electrical, physical, or functional features that 5 affect efficacy. 6 In the 1997 final rule, DOE defined basic 7 model for general service fluorescent lamps as 8 including all lamps with essentially identical light 9 output, power input, and luminous efficacy regardless 10 of their CCT. This last part of the definition would 11 not make sense if DOE chooses to establish product 12 classes based on CCT. 13 Therefore, DOE is proposing in this notice of 14 proposed rulemaking to amend the definition of basic 15 model for general service fluorescent lamps to require 16 that lamps have similar CCTs. 17 DOE seeks comment on its proposal that all 18 general service fluorescent lamps that are considered 19 to be in the same basic model must have similar 20 correlated color temperatures. 21 MR. BROOKMAN: Joe. 22 MR. HOWLEY: Yes. With regard to this 23 subject, the definition of basic model of a general 24 service fluorescent lamp such that all general service 25 fluorescent lamps are considered to be the same basic EXECUTIVE COURT REPORTERS, INC.

(301) 565-006432 1 model will have similar -- okay. Regarding this 2 subject, will have similar correlated color 3 temperatures. NEMA has some concerns with this 4 proposal. 5 Today the industry uses CCTs as a nominal 6 designation and not as a primary designation of the 7 general service fluorescent color. While NEMA is not 8 opposed to considering the addition of CCT to the 9 definition of general service fluorescent lamp basic 10 model, a suitable test tolerance factor would need to 11 be developed. 12 Further, NEMA notes specifically that the 13 language proposed by DOE requiring tested CCT to be 14 rounded to the nearest unit, one unit out of several 15 thousand is not technically meaningful and indicates a 16 false level of precision and reproducibility. 17 NEMA will accordingly comment in more detail 18 on this subject in written form, and including a 19 possible alternative proposal to DOE for consideration. 20 NEMA does agree with DOE that maintaining 21 determination of color rendering index rounded to the 22 nearest unit is fully appropriate. Thank you. 23 MR. BROOKMAN: I know your technical expert 24 is not here, but are you able to send a signal to the 25 Department of what kind of alternative you might EXECUTIVE COURT REPORTERS, INC.

(301) 565-006433 1 suggest? 2 MR. HOWLEY: No, I'm -- at this time I'm not 3 able to comment further on that. 4 MR. BROOKMAN: Okay, okay. I thought I'd 5 try. 6 7 8 MR. HOWLEY: Okay. (Laughter.) MR. BROOKMAN: Steve Nadel. 9 MR. NADEL: Yes. I'm trying to understand 10 what you mean by "similar." If I understand correctly, 11 in the past we've used the same general model whether 12 it's, you know, a 3,000 Kelvin, a 3,500, or a 4,100. 13 Those are all the same basic model. This whole thing 14 is being introduced to get at the call them 5,000 15 degree Kelvin lamps. 16 Does that mean we're just going to have 17 demarcation between basic models, everything from, you 18 know, under 4,500 up to 29, 28, whatever it is, as one 19 classification and everything else is another? Or, are 20 you going to suggest that the 3,000 versus 3,500 versus 21 4,100 each be separate basic models, each subject to 22 testing? 23 MR. BROOKMAN: Mike Scholand. 24 MR. SCHOLAND: Mike Scholand from Navigant. 25 Thanks, Doug, and Steve, for that question. It forces EXECUTIVE COURT REPORTERS, INC.

(301) 565-006434 1 us to clarify this ambiguous statement. I guess the 2 issue is the old version of the definition of basic 3 model for general service fluorescent lamp required 4 that -- basically does not allow you to have different 5 basic models according to correlated color temperature. 6 We cannot define at this point in our 7 proposal, because DOE is also discussing the 8 possibility in the ANOPR of establishing product 9 classes around correlated color temperature, and it -- 10 you know, depending on comment and discussion, it could 11 establish two classes, as was NEMA's proposal on the 12 framework document, or it might establish multiple 13 classes of CCT. 14 DOE cannot prescribe those now, and so rather 15 than create ranges that don't make sense in this 16 definition, using the term "similar" CCTs lets you go 17 far enough to say that, yes, CCT matters in the 18 definition of basic matter. But in the energy 19 conservation standard you will actually be setting the 20 product classes. You will be setting a lumen-per-watt 21 requirement for those product classes, however many 22 bins of CCTs that you have. And, manufacturers will 23 have one basic model for each of those. 24 So the ranges of CCT will be established in 25 the energy conservation standards rulemaking, but in EXECUTIVE COURT REPORTERS, INC.

(301) 565-006435 1 the test procedure we simply want to modify this term 2 "basic model" to show that CCT matters. 3 Does that answer your question? 4 MR. NADEL: I think it does. If I understood 5 correctly, you are saying your intent is to draw 6 boundaries based on the final product classes in the 7 product rule. 8 MR. SCHOLAND: Correct. Yes. 9 MR. BROCKMAN: Joe. 10 MR. HOWLEY: Just one more comment to that 11 effect. To the extent that we end up with regulations 12 that cover higher color temperatures, it's clear that 13 as you get higher and higher in color temperature a 14 different product class would be needed as they have 15 different efficiencies at higher CCTs. So we would 16 agree that if this was extended to higher ranges there 17 would have to be different classes considered. I 18 realize that's for the ANOPR more than this. 19 MR. SCHOLAND: Thank you, Joe. Again, the 20 Department does not want to say what those are now. It 21 simply wants to recognize that language saying 22 regardless of CCT in the definition of basic model 23 can't be used if the Department is going to use CCT as 24 a product class differentiator in the standard. That's 25 what this amendment is trying to do. Okay? Conan. EXECUTIVE COURT REPORTERS, INC.

(301) 565-006436 1 MR. O'ROURKE: Thank you, Michael. The next 2 section we're going to be discussing, reference ballast 3 settings for added fluorescent lamp coverage. 4 The Department proposes adopting reference 5 ballast settings for regulated lamps that do not yet 6 have ANSI-approved references in C78.81 (2005) and 7 C78.901 (2005). These additional lamps are often lower 8 wattage lamps that replace lamps that are already part 9 of the ANSI standards. The Department has derived each 10 of these settings based on those lamps. For example, a 11 four-foot T-8 lamp, reference settings were derived 12 from the 32-watt, four-foot T-8 rapid-start lamp. 13 These additional lamps would require14 reference ballast settings and include several four15 foot lamps and also two-foot U-shape lamps that have 16 lower wattage that have been introduced to the market. 17 For example, the 28-watt, four-foot T8 medium bi-pin 18 lamp. 19 Lamps which the Department is considering 20 expanding its fluorescent coverage to in the ANOPR 21 preliminary determination and several of these lamps 22 which it does not currently plan to extend coverage to 23 on this rulemaking, such as the VHO and fluorescent 24 lamps and T5 lamps. The Department proposes setting 25 these lamps to avoid need of reopening of test EXECUTIVE COURT REPORTERS, INC.

(301) 565-006437 1 procedures in the future if coverage does get extended 2 to cover these lamps. 3 Looking at the proposed reference ballast 4 settings, the first category is for four-foot medium 5 bi-pin lamps, and these would be for lamps that are on 6 the market today but aren't listed specifically in the 7 ASNI C78.81. We're proposing the reference ballast 8 settings for T12 and T10 lamps would have a voltage of 9 236 bolts, 0.430 amps, and 439 ohms. For the T8 lamp, 10 it would be 300 volts, 0.265 amps, and 10 ohms. 11 For the two-foot U-shaped lamp that's not 12 contained in ANSI C78.901, for the T12 it would be the 13 236 volts with 0.430 amps and 439 ohms, and the T8 lamp 14 would be 300 volts, 0.265 amps, and 910 ohms. 15 For the eight-foot single-in slimline lamps 16 that are not listed in C78.81, for the T12 lamps we 17 would look at 625 volts, 0.425 amps, and 1,280 ohms. 18 The T8 lamps would be 625 volts, 0.260 amps, and 1,960 19 ohms. 20 For the eight-foot recessed double-contact 21 high-output lamps not listed in ANSI C78.81, for the 22 T12 it would be 400 volts, 0.8 amps, and 415 ohms. For 23 the T8 lamp, we would be using 450 volts, 0.395 amps, 24 and 595 ohms. 25 Then continuing on for the eight-foot very EXECUTIVE COURT REPORTERS, INC.

(301) 565-006438 1 high output lamps that wouldn't be listed in the ANSI 2 C78.81 -- yeah, Steve? 3 MR. NADEL: Yeah, I think it's easier for us 4 to look at the slides than have you read them. 5 MR. O'ROURKE: That's fine. I didn't know if 6 it was anything you would have wanted to go over 7 specifically as a point, so I at least wanted to make 8 sure that I covered them. 9 MR. BROOKMAN: It's useful to have a good 10 portion of this in the record as well. 11 MR. NADEL: Okay. 12 MR. BROOKMAN: Okay. There's a utility in 13 this. 14 MR. O'ROURKE: For the T12 lamp, it would be 15 400 volts, 1.5 amps, and 215 ohms. 16 Normal and high-output lamps, nominal length 17 of four feet, not listed. For the T5 we're listing 329 18 volts, 0.17 amps, and 950 ohms. For the high-outputs, 19 it would be 235 volts, 0.46 amps, and 255 ohms. 20 For reference ballast settings for the T5, 21 should the Department extend coverage to the T5s or 22 other lengths other than four-foot nominal, the 23 Department would establish reference ballast settings 24 to derive what these reference ballast settings should 25 be from the IEC standard. The Department would EXECUTIVE COURT REPORTERS, INC.

(301) 565-006439 1 determine the appropriate lamp replacements that exist 2 in industry market and use the corresponding reference 3 ballasts or the lamps that fall into that category. 4 So the Department is seeking comments on 5 proposed reference ballast settings. 6 MR. BROOKMAN: Joe. 7 MR. HOWLEY: A comment from the NEMA 8 Technical Committee on this issue. Regarding the 9 subject of adopting test procedures for lamps that have 10 not yet been covered or regulated by DOE solely for the 11 purpose of expediting the test procedure NOPR process, 12 NEMA is strongly opposed to this concept, particularly 13 where there is a lack of appropriate consensus industry 14 referenced ballast test settings. 15 NEMA understands the need to establish 16 reference test circuits for fluorescent lamps covered 17 by the final rule. However, NEMA strongly urges DOE to 18 accept that it is of paramount important to first 19 establish which new lamp types will be covered and to 20 subsequently then establish technically relevant 21 reference ballast settings and possible other test 22 conditions for those lamp types. 23 There will always be lamp innovations that 24 precede standardization. This is normal and a natural 25 part of the innovation cycle. NEMA is concerned that EXECUTIVE COURT REPORTERS, INC.

(301) 565-006440 1 establishing new, generic, mandatory reference ballast 2 settings that must arbitrarily be applied to new, 3 unanticipated lamp types could also prevent the4 commercialization of otherwise viable new energy5 efficient lamp designs, especially for lamps that might 6 only be intended for high-frequency, dimming, or 7 controllable operation. 8 Fundamentally, this concept is about the 9 freedom to innovate new general service fluorescent 10 lamp designs without being constrained by reference 11 circuits that relate to old ballast designs or 12 operating points. NEMA will propose in more detail how 13 such situations can be suitably handled for the 14 regulatory process. Thank you. 15 MR. BROOKMAN: Any follow-on questions? That 16 was a lot. No? Okay. Ron Lewis. 17 MR. LEWIS: We are in a situation where it's 18 been the tradition -- I think it goes back to the 19 process rule time -- of trying to have the test 20 procedures completed about the time that we have the 21 NOPR for the standards done. That's been historically 22 how it's been handled. 23 We also have the situation that once these 24 are put through to a final rule, published, and have an 25 effective date, then they have to endure for a time EXECUTIVE COURT REPORTERS, INC.

(301) 565-006441 1 period. So we're trying to be forward-looking without 2 inhibiting creativity or innovation, but also realizing 3 by the time this gets passed and has an effective date 4 and all the rest that our opportunity will be a while 5 before we can encompass new devices into it. 6 So to the degree that you can look forward 7 and give us input, that's helpful for that. We want 8 sustainability. We want to impact those products even 9 if they may be in the early stages of coming into 10 practical and commercial use. 11 There are time ingredients here that are 12 against us, so we're trying to reach out and get our 13 arms around some of those things. So to the point that 14 you can give us some direction and input on things that 15 might be in the works, that would be helpful. 16 MR. HOWLEY: Okay. NEMA will provide some 17 more written comments and ideas that will help in this 18 area. Thanks, Ron. 19 MR. BROOKMAN: Thank you. Steve Nadel. 20 MR. NADEL: In the spirit that this is a 21 workshop and I'm trying to understand things, I have a 22 question for NEMA. If I understand the DOE proposal, 23 they have some specific values for a whole bunch of 24 classes that they're proposing to cover in the ANOPR 25 and then they are also proposing settings for two EXECUTIVE COURT REPORTERS, INC.

(301) 565-006442 1 categories that they are not presently covering in the 2 ANOPR, the VHOs and the T5s. 3 I was wondering; Joe, you mentioned that some 4 of these values are not well determined. I wondered 5 whether that applies to both categories or whether that 6 really applies more to the T5 category because the VHO 7 has been around for ages. 8 MR. BROOKMAN: Joe. 9 MR. HOWLEY: With regard to new products, 10 yeah, it would -- I think they're looking at products 11 where there's no standards set, which is a different 12 issue than the VHO products, which have been around for 13 quite a while. 14 MR. BROOKMAN: Thank you. Final comments on 15 this subject? 16 (No response.) 17 MR. SCHOLAND: You can sit down, Conan. I'll 18 take the last view. Thank you very much, Conan. 19 The last two sections I'm going to start by 20 discussing the test procedures for general service 21 incandescent lamps. As you're all aware, the Energy 22 Independence and Security Act of 2007 established 23 energy conservation standards for general service 24 incandescent lamps, and DOE does have a limited test 25 procedure in the Code of Federal Regulations today EXECUTIVE COURT REPORTERS, INC.

(301) 565-006443 1 which is primarily for labeling for the Federal Trade 2 Commission. 3 Therefore, in this NOPR DOE is proposing to 4 amend that test procedure to specify the units to be 5 tested. That's the first one. Second, to define basic 6 model for general service incandescent lamp. And 7 finally, to provide a method for calculating the GSIL, 8 the general service incandescent lamp, annual energy 9 consumption and efficacy. 10 Now, because of the similarity in technology 11 between the general service incandescent lamps and 12 incandescent reflector lamps, DOE is proposing that the 13 above additions to the general service incandescent 14 lamp test procedure be implemented in the same manner 15 as the existing IRL test procedure. So DOE's proposal 16 is basically consistent with what's there for reflector 17 lamps. 18 DOE is seeking comment on this proposed 19 addition to the general service incandescent lamp test 20 procedure. Any comments? 21 MR. BROOKMAN: Joe. 22 MR. HOWLEY: Yes. Regarding the subject of 23 testing for general service incandescent lamps, NEMA 24 basically agrees with the DOE plan to insert language 25 for test procedures in a manner that would be EXECUTIVE COURT REPORTERS, INC.

(301) 565-006444 1 consistent with the IRL procedures. 2 However, NEMA will strongly suggest in its 3 written comments that to mitigate the additional 4 burdens presented to industry by an additional new set 5 of 12 months' reporting provisions, the DOE should do 6 away with the existing antiquated pre-production 7 notification requirement for all covered lamp types. 8 NEMA does not believe the pre-production notification 9 has proven useful to the Department or adds value to 10 the public. 11 This provision requires the assignment of 12 industry resources to undertake a superfluous activity 13 since the post-12 month production provision ensures 14 that production lamps are complying with the minimum 15 efficiency requirements. 16 In addition, NEMA is aware the Department and 17 its contractors are in the process of developing a 18 modern electronic compliance database that will not 19 easily lend itself to automating the old pre-production 20 notification. NEMA contends that the public interest 21 would not be jeopardized by this simplification while 22 it would eliminate a non-useful burden on industry. 23 NEMA contends that the elimination of the 24 pre-production requirements would be in keeping with 25 federal guidelines aimed at minimizing burdensome EXECUTIVE COURT REPORTERS, INC.

(301) 565-006445 1 requirements. If DOE desires the industry maintain 2 evidence of compliance before launching a new product, 3 such a variation of this provision would be acceptable 4 as it would still put industry in the position of 5 needing to demonstrate initial minimum efficacy 6 compliance upon request before production commenced. 7 Lastly, it is not clear to NEMA how DOE will 8 implement the reporting aspects of its new lamp rules 9 in a non-burdensome manner. This is a matter of 10 primary importance to the industry since it involves 11 real resources, cost, and time. It is NEMA's 12 contention that existing basic models that will 13 continue to meet new minimum efficiency standards that 14 might be adopted under the federal rule for the 15 companion ANOPR should not have to be retested by 16 industry or re-reported unless industry wishes to do so 17 in a voluntary manner.18 In addition, to further promote non19 burdensome reporting requirements, NEMA strongly 20 encourages DOE to ensure that its electronic compliance 21 submission system is fully operational prior to the 22 need for industry to submit any reporting data that 23 would be necessary under new provisions of the ANOPR. 24 NEMA also reiterates its request discussed 25 previously to eliminate the pre-launch reporting EXECUTIVE COURT REPORTERS, INC.

(301) 565-006446 1 requirements that are contained in the current 2 reporting requirements. Instead manufacturers should 3 be required to maintain proof of compliance prior to 4 the production for sale and then to follow up after 12 5 months of electronically reported test data. 6 NEMA urges DOE to ensure that as part of its 7 transition to new lamp requirements that it would be8 advisable for the Department to implement an easy-to9 understand Web-based educational resource that will10 explain to all NEMA manufacturers, in particular non11 NEMA manufacturers (sic) or importers, how to ensure 12 compliance. Thank you. 13 MR. BROOKMAN: Thank you. Other comments 14 related to this section? 15 (No response.) 16 MR. SCHOLAND: Okay. 17 MR. BROOKMAN: Okay. 18 MR. SCHOLAND: Hearing none, the final 19 section of the test procedure is the off mode and 20 standby mode -- excuse me. Go ahead. 21 MR. FERNSTROM: If we could -- 22 MR. BROOKMAN: Gary, please. 23 MR. FERNSTROM: -- go back to No. 7 just 24 briefly. This is Gary Fernstrom from Pacific Gas and 25 Electric Company. We would encourage DOE to define the EXECUTIVE COURT REPORTERS, INC.

(301) 565-006447 1 basic model general service incandescent lamp broadly 2 so that a full range of correlated color temperatures 3 are included. That is to say so that higher color 4 temperature incandescent lamps are included and not 5 excluded. 6 MR. SCHOLAND: Okay. Gary, I don't know if 7 you're aware. The greater than 4,600 Kelvin is 8 considered colored incandescent and less than -- is it 9 2,600 I believe -- is colored. So within that band it 10 includes incandescent, halogen, and halogen infrared 11 technologies. 12 MR. FERNSTROM: That's precisely the point 13 that I'm getting at. We would encourage DOE to 14 consider a broader range because we're concerned that 15 lamps just above the upper limit would not be tested or 16 regulated in any way. 17 MR. SCHOLAND: Okay. 18 MR. BROOKMAN: Any other comments on this 19 point? 20 MR. SCHOLAND: I just would like to go back 21 to Slide 20 for Gary's information. EISA 2007 22 introduced a definition for colored incandescent lamp. 23 This is part of the statute which says correlated 24 color temperature less than 2,500 Kelvin or greater 25 than 4,600 Kelvin where correlated color temperature is EXECUTIVE COURT REPORTERS, INC.

(301) 565-006448 1 computed according to the journal methodology. 2 DOE would not be able to include correlated 3 color temperatures outside of this range, Gary, without 4 a statutory amendment. 5 MR. FERNSTROM: Okay. Thanks for the 6 clarification. The general concern that we have, not 7 withstanding the regulatory mandate here, is that 8 loopholes will be found and products will be developed 9 just outside the limits and therefore will continue to 10 be non-regulated. 11 MR. BROOKMAN: Thanks for that clarification. 12 MR. SCHOLAND: Thank you. Okay. Back to 13 Slide 31, the off mode and standby mode. 14 In Section 310.3 of EISA 2007, Congress 15 directed the Department to amend its test procedures to 16 incorporate a measure of off mode and standby mode 17 energy consumption if feasible. DOE believes that for 18 general service fluorescent lamps, incandescent 19 reflector lamps, and general service incandescent 20 lamps, none of these lamp types employ a standby mode 21 or off mode. 22 If the lamp must be disconnected from the 23 main power source in order for it to provide no active 24 mode function -- that is, emitting light -- and if the 25 light is disconnected from the main power source, the EXECUTIVE COURT REPORTERS, INC.

(301) 565-006449 1 lamp does not satisfy the requirement of operating in 2 standby mode or off mode. This is according to the 3 statutory definitions of these three different modes: 4 active mode, standby mode, and off mode. 5 DOE therefore believes that all covered 6 products that meet the definitions of general service 7 fluorescent lamps, incandescent reflector lamps, and 8 general service incandescent lamps are single-function 9 products and do not offer any secondary user-oriented 10 or protective functions. 11 DOE seeks comment on its proposal to not 12 incorporate a measure of off mode and standby mode 13 energy consumption in its test procedures for these 14 three lamp types. Discussion, please. 15 MR. BROOKMAN: Joe. 16 MR. HOWLEY: Yes. Regarding the subject of 17 off mode and standby mode energy consumption, NEMA 18 agrees with DOE conclusions that provisions do not 19 technically apply to the covered lamps and accordingly 20 there is no need to expand the lamp test procedure to 21 incorporate measurements for either off mode or standby 22 mode. Thank you. 23 MR. BROOKMAN: Additional comments? Gary. 24 MR. FERNSTROM: Hi. Gary Fernstrom, Pacific 25 Gas and Electric Company. We're beginning to see some EXECUTIVE COURT REPORTERS, INC.

(301) 565-006450 1 compact fluorescent lamps that contain integral control 2 in them so that they can be turned on and off either 3 through a power line carrier or wirelessly. So the 4 question is, how would these lamps be dealt with? They 5 would presumably be outside of the scope of this 6 regulation. 7 MR. SCHOLAND: That is correct, Gary. 8 Compact fluorescent lamps are outside of the scope of 9 this test procedure. 10 MR. FERNSTROM: Means that it's an 11 incandescent test procedure. 12 MR. SCHOLAND: Well, the test procedure is 13 addressing general service fluorescent lamps, 14 incandescent reflector lamps, and general service 15 incandescent lamps. So compact fluorescent lamp are 16 another category that's just beyond the scope of -- 17 sorry. 18 MR. FERNSTROM: Thank you. 19 MR. SCHOLAND: Thank you for the comment. 20 Other comments on this issue? 21 (No response) 22 MR. SCHOLAND: So the last slide here is how 23 to submit comments. This is also -- you will see it in 24 the notice of proposed rulemaking when it's published 25 on Thursday of this week, on the 13th. This also gives EXECUTIVE COURT REPORTERS, INC.

(301) 565-006451 1 you the e-mail address, how to submit written comments, 2 courier comments. 3 The comment period. Again, it's 75 days 4 after the date of publication in the Federal Register, 5 and I believe it's around May 28th or 29th. Don't 6 quote me on that, but you'll see it in the notice and 7 Linda will be sending an e-mail to all the stakeholders 8 on the distribution list once the notices are9 published. So you will get the actual date in that e10 mail. 11 Any other comments or questions or discussion 12 points on test procedure? 13 (No response.) 14 MR. SCHOLAND: No? Great. 15 MR. BROOKMAN: So we have a choice to make. 16 We're scheduled -- at this point on the agenda we are 17 allowed to take a break. However, we've only been at 18 this for a little more than an hour, so we can keep 19 plugging ahead if you wish, also. What's your 20 preference? Let's keep going. 21 Okay. So then we're moving on to Energy 22 Conservation Standard Overview. 23 MR. SCHOLAND: Mimi? 24 MR. BROOKMAN: And then in about, maybe, a 25 half an hour or so we will take a break and get a cup EXECUTIVE COURT REPORTERS, INC.

(301) 565-006452 1 of coffee and the like. 2 Energy Conservation Standard Overview 3 Mahima Gupta 4 (PowerPoint presentation.) 5 MS. GUPTA: Hi. My name is Mimi Gupta. I'm 6 going to be starting off our discussion on the energy 7 conservation standards for general service fluorescent 8 lamps and incandescent reflector lamps ANOPR. Today 9 I'd just like to give you a brief overview of the 10 rulemaking and what we'll be talking about in the 11 upcoming day or days. 12 The purpose of this public meeting is to 13 present the methodologies and characterize the results 14 for the analyses completed to date, to discuss specific 15 issues related to each analysis, to seek input from 16 attendees on methodologies, assumptions, and on data 17 sources, and to describe some of the upcoming analyses 18 and next steps. 19 The Energy Policy and Conservation Act, or 20 EPCA, directs DOE to consider seven factors when 21 setting energy conservation standards, and this slide 22 shows the seven factors and the corresponding analyses 23 done in the rulemaking that address those seven 24 factors. 25 This slide shows the different analyses, part EXECUTIVE COURT REPORTERS, INC.

(301) 565-006453 1 of the ANOPR, advance notice of proposed rulemaking, 2 that we'll be discussing in the upcoming presentations. 3 The Department has completed a market and technology 4 assessment and a screening analysis, which feed into 5 the engineering analysis. The engineering analysis, in 6 conjunction with the product price determination and 7 energy use characterization, serve as inputs into the 8 life-cycle cost analysis and national impact analysis. 9 In addition to discussing these ANOPR 10 analyses, we'll also be discussing today the DOE's 11 preliminary determination on expanding its scope of 12 coverage to additional general service fluorescent 13 lamps. 14 After a period of comment after the ANOPR, 15 the next step in the rulemaking process is the notice 16 of proposed rulemaking, or NOPR. This slide shows the 17 different analyses done in the NOPR. First, the ANOPR 18 analyses are revised. Trial standard levels are 19 established. The Department conducts an LCC subgroup 20 analysis, a manufacturer utility and employment impact 21 analysis, an environmental assessment, and a regulatory 22 impact analysis. 23 Throughout the presentations you'll see that 24 we highlight several issues for comment. These issues 25 for comment are in a handout in your packet. Several EXECUTIVE COURT REPORTERS, INC.

(301) 565-006454 1 issues for comment have issue numbers beside them which 2 correspond to the last section of the ANOPR, the issues 3 that we highlight in the ANOPR notice. Some issues 4 don't have issue numbers on them, but we welcome 5 comments on all issues we raise as well as any other 6 issues stakeholders would like to talk about. 7 Finally, I'd just like to say that 8 participants are invited to provide summary comments or 9 statements and they're invited to raise any additional 10 issues for discussion today, and that the ANOPR comment 11 period will be closing 30 days after publication in the 12 Federal Register. As Mike said, the ANOPR is scheduled 13 to be published on March 13th, and so that would mean 14 the comment period would close on April 12th, 2008. 15 I think we're opening it up for any opening 16 statements. Right, Doug? 17 MR. BROOKMAN: Yes. So, as reflected in the 18 agenda, any summary comments, overview comments at this 19 time would be welcome. Andrew Delaski. 20 Comments from Participants Regarding the Energy 21 Conservation Standard ANOPR 22 MR. DELASKI: Sure. First of all, I 23 apologize for being late this morning. Delta has some 24 liability problems with their planes this morning. So 25 I'm glad to be here. I want to make just a couple of EXECUTIVE COURT REPORTERS, INC.

(301) 565-006455 1 comments as to -- to respond to the Department's 2 publication of the ANOPR before the rulemaking. 3 One is, I want to just take a moment to 4 provide a little bit of context. I was struck last 5 week with the President at the Renewal Energy 6 Conference of Washington last week. There was an issue 7 of a fact sheet by the White House, and that fact sheet 8 gave prominent mention to appliance standards in the 9 fact sheet. I think the context of this rulemaking is 10 incredibly important. 11 In the fact sheet, which is entitled 12 "Increasing Our Energy Security and Confronting Climate 13 Change" issued by the White House last Wednesday -- 14 I'll just quote from it -- "In December President Bush 15 signed the Energy Independence and Security Act of 16 2007, which responded to his 20 In 10 challenge in last 17 year's State of the Union Address to improve 18 efficiency." It mentions fuel economy standards, it 19 mentions renewables, and then it goes on to about 20 appliance standards. 21 "The lighting efficiency mandate will improve 22 lighting efficiency by more than 70 percent by 2020." 23 We were just talking about the tests for general 24 service lamps. I think it's worth taking a second to 25 mention the leadership of Chairman Bingaman, Bingle, EXECUTIVE COURT REPORTERS, INC.

(301) 565-006456 1 Baucher, Markey, and Congresswoman Harmon in 2 accomplishing the general service lamp standard that 3 was enacted in EISA but also to acknowledge the 4 leadership of the industry: General Electric, of 5 Sylvania, of Philips, and putting the lighting 6 standards effectively on the table. It was an enormous 7 step forward made possible through the leadership of 8 Philips, GE, and Sylvania, as well as the members of 9 Congress that made that standard happen. 10 Also, the fact sheet goes on to talk about -- 11 it says, "The appliance efficiency mandate sets over 45 12 new standards for appliances." Now, I'm not quite sure 13 how the math got worked out there. I count 10. 14 (Laughter.) 15 MR. DELASKI: But I suppose if you count all 16 the additional requirements for future rulemakings that 17 are embedded in EISA that it might very well count out 18 to 45. 19 So I think that's just an important context 20 to have the White House come out with a fact sheet. 21 It's a big pat on the back, I think, for the 22 Department, acknowledgment of the work that's going on 23 at the Department to set efficiency standards and to 24 advance them as one of the cornerstones of how this 25 administration views how energy efficiency fits into an EXECUTIVE COURT REPORTERS, INC.

(301) 565-006457 1 overall energy policy. 2 I want to congratulate DOE on this particular 3 rulemaking because I know it must have been a big lift 4 to go from having a rulemaking which covered three 5 product categories, broadly speaking. To take out the 6 general service lamps must have been -- as I read 7 through the ANOPR and the technical support documents, 8 I just thought, my gosh, where did all the general 9 service lamp stuff go. 10 So it must have been a big technical lift to 11 get all that out of there, so congratulations for 12 accomplishing that. What I expect and hope is we will 13 be able to keep on your schedule for a final rule 14 according to the published schedule, which I think will 15 be a challenge still. 16 This rulemaking, and my last point I want to 17 make, is a critically important rulemaking in the scope 18 of the overall set of things the Department is now 19 tackling, the 30-odd rulemakings. I think Ron told me 20 35 at one point. There are huge savings at stake in 21 this particular rulemaking. 22 On the ANOPR analysis published by DOE, if 23 you look at the levels that are the max -- that meet 24 the legal criteria of maximum level of cost effective 25 savings, for general service fluorescent lamps the EXECUTIVE COURT REPORTERS, INC.

(301) 565-006458 1 current analysis shows a potential savings of 16 quads 2 at a net present value of $54 billion using the 3 3 percent discount rate. For the incandescent reflector 4 lamps, 2.4 quads and $15 billion NPV. 5 So these two together are approaching 20 6 quads of potential energy savings that are cost 7 effective based on the analysis published by DOE at a 8 net present value of $70 billion. It's a big 9 rulemaking. 10 To put that in a little bit of context, I 11 think many people in this room are familiar with the 12 CR17 rulemaking for air conditioners, which was at the 13 time one of the most important rulemakings the 14 Department ever completed. The total savings from that 15 rulemaking estimated by DOE was 4.2 quads. The NPV was 16 a billion bucks. We're talking about energy savings 17 that are on the order of four to five times greater 18 than the CR13 rule with a net present value on the 19 order of 70 times greater according to the Department's 20 analysis published. 21 So it's an extraordinarily important 22 rulemaking. There's a lot of analysis ahead of us, a 23 lot of discussion ahead of us. I think the Department 24 has done a very effective job and a very thorough 25 analysis. We will of course have some points that we EXECUTIVE COURT REPORTERS, INC.

(301) 565-006459 1 want to discuss and comment on, but I think it really 2 has laid the groundwork for what could be an enormously 3 important rulemaking by the Department. So, thank you. 4 MR. BROOKMAN: Thank you, Andrew. Additional 5 overview comments at this time, summary comments? 6 (No response.) 7 MR. BROOKMAN: I see no more. Okay. Mimi. 8 MS. GUPTA: Okay. So I think Mike Scholand 9 will be talking about the Scope of Coverage section of 10 the ANOPR. 11 MR. BROOKMAN: Ron Lewis, please. 12 MR. LEWIS: While Michael is getting ready, 13 the word "lift" has a significant meaning on this in 14 that this ANOPR was almost completely done, written, 15 including the incandescent lamps, general service 16 incandescent lamps, and we had to lift it out, extract 17 it, and redo the analysis. This team has done an 18 incredible job of trying to handle in stride the change 19 in the legislation, which outwardly could appear like 20 it reduced our effort, but because we were so far along 21 with things, trying to then go back and rewrite it and 22 take into stride the EISA 2007 legislation. 23 Before you came in this morning, and I was a 24 little bit short with it, we wanted to leave time. 25 There was a lot of confusion in our minds as we were EXECUTIVE COURT REPORTERS, INC.

(301) 565-006460 1 trying to integrate a whole lot of things and get this 2 done right. We wanted to leave room for everybody and 3 get all the comment and make sure we clarified 4 everything that we possibly could because there was so 5 much confusion around this. 6 So we had left two days to handle all this. 7 We're ahead of schedule, which is great, but I wanted 8 to make sure everybody had the chance to give their 9 comment. Because of the confusion that we experienced 10 with trying to redo everything and look at definitions 11 and all kinds of things that changed, that we didn't 12 rush through it, that we handled it as comprehensively 13 as possible. 14 So we thank you for your input, and that word 15 "lift" meant a little bit different to us, as "extract 16 and redo." 17 MR. BROCKMAN: I also thought the "lift" 18 meant quantity. Quantity, yes. Okay. Michael 19 Scholand. 20 Scope of Coverage 21 Michael Scholand 22 (PowerPoint presentation.) 23 MR. SCHOLAND: Thank you, Doug. Mike 24 Scholand here from Navigant Consulting. I'm going to 25 talk us through now the Scope of Coverage section of EXECUTIVE COURT REPORTERS, INC.

(301) 565-006461 1 the advance notice of proposed rulemaking. This 2 section addresses the scope of coverage for additional 3 general service fluorescent lamps. 4 As we had discussed earlier, the Energy 5 Independence and Security Act changed the scope of 6 coverage in this rulemaking. First and foremost, it 7 established energy conservation standards for general 8 service incandescent lamps. Therefore, those lamps are 9 no longer part of the standards rulemaking. 10 It amended Section 42 U.S. Code 6295(I)(5) to 11 remove the Department's authority to consider coverage 12 of additional general service incandescent lamps. So 13 in the framework document DOE had contemplated looking 14 at both additional general service fluorescent lamps 15 and additional general service incandescent lamps. 16 Following EISA, the incandescent portion of that was 17 removed. Incandescent reflector lamps are part of the 18 definition of general service incandescent lamps, 19 therefore no additional incandescent reflector lamps 20 are considered in this scope of coverage for this 21 rulemaking. 22 Next, it modified the EPCA definitions for 23 general service fluorescent lamps and incandescent 24 reflector lamps, bringing additional lamps under DOE's 25 authority, which were then added to the scope of the EXECUTIVE COURT REPORTERS, INC.

(301) 565-006462 1 rule. 2 So, any questions or comments on that? 3 Steve, you have a puzzled look on your face. 4 MR. BROOKMAN: Steve Nadel. 5 MR. NADEL: Yeah. I have to go back to the 6 wording of the EISA language, but as someone who was 7 intimately involved in this, I don't recall any 8 discussion about removing DOE's authority to consider 9 other product classes. It may have removed the 10 obligation to say DOE must do it, but I don't believe, 11 and I need to check back the legal language, that it 12 removed the authority for DOE to be able to change 13 coverage. 14 MR. BROOKMAN: Pam. 15 MS. HORNER: Pam Horner with Osram Sylvania. 16 Just one note, that whenever I speak for the remainder 17 of this it will be on behalf of the NEMA Lamp Section. 18 So when I say NEMA, I mean the Lamp Section. 19 Just a point of clarification, please, 20 because it will affect a comment I have to make later. 21 Does what you just said, Michael, mean that PAR 20 22 lamps are not covered under this ANOPR? 23 MR. SCHOLAND: PAR 20 lamps are not covered? 24 I believe they are covered. I think they're -- 25 MS. HORNER: You said additional coverage, EXECUTIVE COURT REPORTERS, INC.

(301) 565-006463 1 and so my question is, EISA specifically brought in 2 smaller -- I think this is where Steve was headed -- 3 smaller diameter lamps. 4 MR. SCHOLAND: Correct. 5 MS. HORNER: Including the PAR 20 type. 6 MR. SCHOLAND: Yes. 7 MS. HORNER: So it will simply affect our 8 comments, so I would like some clarification as to 9 whether you think these are or are not covered by the 10 candidate standard lamps. 11 MR. SCHOLAND: I do have a slide on this, 12 Pam, coming up, and they are covered because the 13 modifications made by EISA, which is my third bullet on 14 this slide, EPCA modified the definitions of GSFL and 15 IRL. One of those modifications was to change the 16 lower threshold diameter from two and three-quarters 17 inch to two and one-quarter inch, which is essentially 18 an R18. 19 MS. HORNER: Thank you. 20 MR. SCHOLAND: So an R20 or a PAR 20 would be 21 covered now, but not by action of the Department. 22 That's what I was -- this scope of coverage that I'm 23 discussing here is in the context of DOE, although the 24 first set of slides I'm going to talk about are EISA 25 impacts. EXECUTIVE COURT REPORTERS, INC. (301) 565-006464 1 Do we have another question? 2 MR. BROOKMAN: Yes. Please say your name for 3 the record. 4 MR. WALITSKY: Paul Walitsky, Industrial 5 Ecology. So, under that definition, a PAR 16 lamp 6 would not be covered, then? 7 MR. SCHOLAND: Correct. The PAR 16 is not 8 covered. 9 MR. BROOKMAN: Thank you. 10 MR. SCHOLAND: Okay. So now let's discuss 11 the EISA 2007 change to the definition of general 12 service fluorescent lamp. Here you can see the 13 definition of general service fluorescent lamp is on 14 the screen, Slide Number 3. You'll notice in bold 15 VIII, lamps with a color rendering index greater than 16 or equal to 87. Prior to passage of the legislation 17 that had said 82. 18 So a change was made to the statutory 19 definition of general service fluorescent lamp, which 20 is part of the scope, that DOE is looked at additional 21 fluorescent lamps, and it raised the CRI from 82 to 87, 22 which brought many more lamps into the Department's 23 purview of consideration for this scope. 24 Okay. And, how did the definition change the 25 scope of coverage for incandescent reflector lamps, EXECUTIVE COURT REPORTERS, INC.

(301) 565-006465 1 which we were just getting to. Thanks, Pam. 2 Slide 4. In bold here you will see the 3 changes. Basically, the coverage now includes ER, 4 which is ellipsoidal reflector, BR, for bulge 5 reflector, and BPAR, for blown parabolic aluminized 6 reflector, or similar bulb shapes. So that provision 7 was added. 8 And then, finally, the diameter provision we 9 were just discussing, diameters exceeding two and a10 quarter inches. That previously two and three11 quarters. 12 So what this in essence means is that 13 previously ER and BR shapes were excluded. Now they 14 are included in the definition. And then the diameter 15 has been made to a smaller size. 16 There are some specific exclusions here which 17 I mention in the bottom bullet. Basically, EISA 18 included exemptions for ER30, BR30, BR40, and ER40 19 lamps rated at 50 watts and less, and it also excluded 20 BR30, BR40, and ER40 lamps rated at 65 watts. And it 21 excluded R20 lamps rated at 45 watts or less. Those 22 are statutory exclusions and they were introduced by 23 the Energy Independence and Security Act of 2007. 24 Okay. Next slide. Any questions on this 25 before I move on? Does that clarify it? EXECUTIVE COURT REPORTERS, INC.

(301) 565-006466 1 (No response.) 2 MR. SCHOLAND: Okay. Now I'll discuss how 3 EISA modified the definition of colored incandescent 4 lamp. EISA introduced a new definition for colored 5 incandescent lamps as follows. Colored incandescent 6 lamp means an incandescent lamp designated and marketed 7 as a colored lamp that has 8 1) A color rendering index of less than 50, 9 as determined according to the test method given in the 10 CIE Publication 13.3 (1995), or 11 2) A CCT, a correlated color temperature, of 12 less than 2,500 Kelvin or greater than 4,600 Kelvin 13 where the CCT is computed according to the Journal of 14 Optical Society of America article. The citation here 15 says 1968, but again in the provision -- in the 16 statutory language it's 1986 and we believe that is a 17 typographical error. 18 So essentially, the new definition of colored 19 incandescent lamp removes the exclusion of neodymium 20 incandescent reflector lamps from regulation. DOE 21 therefore considers standards for these lamps by 22 creating a separate product class for modified spectrum 23 incandescent reflector lamps. 24 Okay. So this is the last slide. This 25 summarizes all the changes that EISA imposed on the EXECUTIVE COURT REPORTERS, INC.

(301) 565-006467 1 scope of coverage of product that we were considering 2 in the advance notice of proposed rulemaking. Are 3 there any questions on these slides on EISA impacts? 4 Okay. 5 MR. BROOKMAN: Yes. Steve Nadel. The new 6 definition effectively removes the exclusion of the 7 "neo-deo-nium." 8 MR. SCHOLAND: Neodymium. 9 MR. BROOKMAN: Thank you. Steve Nadel. 10 MR. NADEL: Right. You've mentioned a couple 11 of times that you consider the reference to this 12 Journal of Optical Society article a mistake. 13 MR. SCHOLAND: Yes. 14 MR. NADEL: I would encourage the Department 15 to let the congressional committees know what you 16 believe to be the mistake because I know they're 17 working on a technical correction package now. 18 MR. BROOKMAN: Thank you. 19 MR. SCHOLAND: Ron is making a note. Let the 20 record show. 21 (Laughter.) 22 MR. BROOKMAN: Okay. 23 MR. SCHOLAND: Okay. So, Slide 6, Expansion 24 of Scope of Coverage. We have an extraction here of 25 Paragraph 6295(I)(5), where it reads, "The Secretary EXECUTIVE COURT REPORTERS, INC.

(301) 565-006468 1 shall initiate a rulemaking procedure to determine if 2 the standards in effect for fluorescent lamps should be 3 amended so that they would be applicable to additional 4 general service fluorescent lamps." 5 A question was raised earlier about the 6 modification to this paragraph. This used to say "and 7 general service incandescent lamps," but following EISA 8 that provision was removed. So DOE is now working 9 under this revised expansion of scope of coverage, 10 considering additional general service fluorescent 11 lamps, and we have the schedule in a table here on the 12 slide just to show you that at this stage of the 13 advance notice of proposed rulemaking DOE is providing 14 its preliminary determination of scope. 15 Based on the comments and feedback it gets 16 today and in written comments, DOE will propose a 17 determination of scope in conjunction with the notice 18 of proposed rulemaking. And then based on comments it 19 gets at that point in the rulemaking process, it will 20 take those back and consider and then issue a final 21 determination of scope at the final rule stage. 22 So, okay. So, what are the criteria that DOE 23 is using when selecting fluorescent lamps for coverage. 24 DOE considered four main criteria, outlined here and 25 discussed in more detail in the ANOPR, which is EXECUTIVE COURT REPORTERS, INC.

(301) 565-006469 1 published. The first, obviously, the statutory 2 definition of general service fluorescent lamps. 3 Second is the potential energy savings of those lamps. 4 Third, lamps whose shipments may not be high volume 5 but have the potential to grow, such as they may become 6 a substitute for regulated lamps, and then finally, 7 potential for a standard to meet two remaining 8 statutory criteria, which are technologically feasible 9 and economically justified. 10 So, are there any questions on the scope of 11 coverage criteria the Department used? 12 (No response.) 13 MR. SCHOLAND: Okay. On the next slide we 14 show the additional general service fluorescent lamps 15 in DOE's preliminary determination of scope. There's 16 three lamps identified here: four-foot -- these are 17 additional general service fluorescent lamps DOE is 18 preliminarily determining to include in its scope of 19 coverage and therefore regulation. Four-foot medium 20 bi-pin lamps with wattages greater than or equal to 25 21 watts and less than 28 watts. Right now that threshold 22 cuts off at 28 watts, so this would bring into 23 inclusion wattages of 25. It would be the lower 24 threshold. 25 For the eight-foot recessed double-contact, EXECUTIVE COURT REPORTERS, INC.

(301) 565-006470 1 rapid-start, high-output lamps, ones that are not 2 defined in ANSI C78.1 (1991). An example of this would 3 be an 86-watt T8 high-output lamp with a 400 milliamp 4 and high frequency operation. 5 And then the third group is eight-foot,6 single-pin, instant start, rapid -- excuse me. Eight7 foot, single-pin, instant start, slimline lamps with a 8 rated wattage greater than or equal to 52 watts that 9 are not defined in ANSI C78.3 (1991). An example here 10 would be a 59-watt T8 single-pin lamp. 11 In the next slide there's a visual 12 representation of how these lamps fit into DOE's scope 13 of coverage. The yellow boxes on this slide represent 14 the lamps that DOE has already covered and is 15 regulating. The purple boxes represent the additional 16 general service fluorescent lamps that are proposed for 17 coverage. 18 Okay. Finally, on the next slide I briefly 19 discuss the fluorescent lamps DOE considered but is not 20 presently planning to cover. These lamps are T5 21 miniature bi-pin lamps. The reason DOE has -- DOE 22 discusses, again, in more detail in the ANOPR its 23 rationale behind not proposing to cover these lamps at 24 this time. I just summarize them here. 25 For T5 miniature bi-pin, basically there is a EXECUTIVE COURT REPORTERS, INC.

(301) 565-006471 1 lower potential for per-unit energy savings because 2 these lamp types already represent a more efficacious 3 product. Second, they represent a small market share. 4 Thirdly, regulation of these lamps may slow adoption 5 of these higher efficacy products. 6 For the very high output, the VHO lamps, 7 although there may be potential for relatively large 8 per-unit energy savings, research indicates they have a 9 small and decreasing market share. 10 Finally, for fluorescent lamps with alternate 11 lengths, diameters, base types, and shapes, DOE 12 believes that these other lamps constitute a small 13 market share with little potential to grow. 14 In Slide 11, DOE invites comment on its 15 consideration of expansion of scope of coverage for 16 general service fluorescent lamps. 17 MR. BROOKMAN: Pam. 18 MS. HORNER: Pam Horner, speaking on behalf 19 of the NEMA Lamp Section. Regarding products to be 20 covered by DOE, as we noted in the previous discussion, 21 the testing procedure NOPR does reference some 22 suggestions for test procedures for T5 lamps. 23 NEMA is considering support that DOE cover T5 24 lamps. We have not yet achieved a consensus on this, 25 and it will be in our written comments. But it would EXECUTIVE COURT REPORTERS, INC.

(301) 565-006472 1 be for those specifically used for general 2 illumination, and we would like to tell you why we are 3 considering this amongst ourselves right now. 4 It is, in particular, to prevent the 5 introduction of less efficient T5 lamps, namely those 6 that contain halophosphor, into the U.S. market. We 7 would oppose any kind of standards for T5 lamps that 8 would remove any of the existing high efficiency or 9 high efficacy T5 lamps. 10 Additionally, in summary, we do agree with 11 the DOE on the following coverage points. The 25-watt, 12 four-foot, medium bi-pin lamps, T8 and T12s, are 13 suitable candidates to consider for coverage. T8 14 eight-foot RDC HO lamps should be considered for 15 coverage. The eight-foot, single-pin, slimline lamps 16 greater than 52 watts should be covered and its 17 corollary, the T8 eight-foot, single-pin, slimline 18 lamps less than 52 watts shouldn't be. 19 MR. BROOKMAN: Should not be? 20 MS. HORNER: Right. It was implicit. VHO 21 lamps should not be covered. We are in agreement with 22 you. We are also in agreement that lamps with 23 alternate lengths, diameters, bases, or shapes, or a 24 combination thereof, should not be covered except 25 perhaps in the exception I noted that we are EXECUTIVE COURT REPORTERS, INC.

(301) 565-006473 1 considering regarding T5s per our comment. 2 We do want to make one point, that when the 3 original analysis was done for fluorescent lamps DOE 4 suggested that it does not need to expand coverage of 5 two-foot, medium, bi-pin, U-shape lamps with wattages 6 less than 28 watts and that was because there weren't 7 any. Now there are. 8 MR. SCHOLAND: All right. 9 MS. HORNER: So we would like to suggest that 10 that is a suitable candidate to bring under. In other 11 words, the 25-watt U-bend corresponding lamp. Thank 12 you. 13 MR. BROOKMAN: Thank you. Additional 14 comments on scope of coverage issues? Steve Nadel. 15 MR. NADEL: Yeah, let me say, we are still 16 looking at all of these things. I would say we 17 generally tend to agree with what NEMA said. We were 18 also looking at the U-bend and wondering whether 25 19 made sense. We are still looking at the 52 watt limit 20 for the eight-foot. If I understand, there are some 50 21 and 51 watt products. We haven't had a chance to look 22 at them yet and whether they are niche and couldn't be 23 used. 24 We also were interested in covering the T5 25 for the reason that Pam said, although we would take it EXECUTIVE COURT REPORTERS, INC.

(301) 565-006474 1 a step farther and say that DOE should analyze 2 opportunities for T5. We are not in any way suggesting 3 at this point we want standards to be set, but we would 4 like to see an analysis, you know, to see are there 5 opportunities. We recognize that the existing T5 6 products are relatively efficient. 7 The one other comment I would make, and 8 perhaps I should know this, is if it's medium -- under 9 your standard, if it's a medium bi-pin base, regardless 10 of whether it's T8, T5, T10, T-whatever, it is covered, 11 right? 12 MR. SCHOLAND: The way the Department is 13 proposing product classes in this notice, medium bi-pin 14 would all be grouped, but T5 is not medium bi-pin. T5 15 is miniature. 16 MR. NADEL: Right. That's the point I was 17 making. I know there had at various points been a T10 18 lamp. I just wanted to make sure they would be covered 19 and that they do not provide a potential loophole. 20 MR. SCHOLAND: In the four-foot length -- 21 MR. NADEL: Yes. 22 MR. SCHOLAND: -- medium bi-pin T10s are 23 included. 24 MR. BROOKMAN: Thank you. Additional 25 comments on scope of coverage? EXECUTIVE COURT REPORTERS, INC.

(301) 565-006475 1 (No response.) 2 MR. BROOKMAN: Okay. The next segment on the 3 agenda is fairly extensive and lengthy. It's almost 11 4 o'clock. I'm going to suggest we take a break now. 5 It's five 'til. I'd like to resume at 10 minutes 6 after. So, 11:10 we'll resume. Please wear your 7 badges while you're in the building. 8 (Brief recess.) 9 MR. BROOKMAN: Okay. Thank you for coming 10 back so we can resume on time. We left off with the 11 engineering analysis and Mimi. 12 Engineering Analysis 13 Mahima Gupta and Conan O'Rourke 14 (PowerPoint presentation.) 15 MS. GUPTA: All right. So I'll be starting 16 off our discussion on the analyses for the ANOPR by 17 talking about the market and technology assessment, the 18 screening analysis, the engineering analysis, and the 19 product price determination. These four analyses serve 20 as foundational analyses for the life-cycle cost 21 analysis and national impact analysis, which we'll be 22 discussing further on in the day and maybe tomorrow. 23 More detail on these analyses can be found in the ANOPR 24 Technical Support Document in Chapters 3 through 6. 25 So in the market and technology assessment, EXECUTIVE COURT REPORTERS, INC.

(301) 565-006476 1 DOE characterizes the fluorescent and incandescent 2 reflector lamp market and industry, it identifies 3 several measures to improve efficacy, called technology 4 options, and it establishes product classes for general 5 service fluorescent lamps and incandescent reflector 6 lamps. 7 The screening analysis then takes the 8 technology options developed in the market and 9 technology assessment and screens several of them out 10 based on four EPCA criteria, and the resulting 11 technology options are then called design options. 12 The design options are fed into the 13 engineering analysis, where DOE identifies baseline 14 lamps or lamp and ballast systems and their higher 15 efficacy alternatives. In the product price 16 determination, DOE establishes end user prices for the 17 lamps and ballasts identified in the engineering 18 analysis. 19 So, as I just said, one of the major outputs 20 of the market and technology assessment is product 21 classes. I'm going to start off by talking about 22 general service fluorescent lamp product classes, and 23 then I'll go on to talk more about incandescent 24 reflector lamp product classes. 25 EPCA established standards for eight EXECUTIVE COURT REPORTERS, INC.

(301) 565-006477 1 different categories of fluorescent lamps by lamp type 2 -- namely, four-foot medium bi-pin, two-foot U-shaped,3 eight-foot slimline, and eight-foot, recessed, double4 contact, high output -- and two wattage bins within 5 those lamp types. For each one of those lamp 6 categories EPCA established a minimum average lamp 7 efficacy standard and a minimum CRI standard. 8 First, I'm going to talk about the product 9 classes in the ANOPR as they relate to the minimum 10 average lamp efficacy standard, and then I will address 11 the issue of minimum CRI standards. 12 So, to establish product classes, DOE based 13 its product classes on two criteria: one, the type of 14 energy used, and two, the capacity of the product or 15 other performance-related features that justify 16 different standard levels, such as features affecting 17 consumer utility. For both fluorescent lamps and 18 incandescent lamps, the type of energy used is 19 electricity, which is not very much of a 20 differentiating feature, so we focused on the second 21 one. Where we saw differences in end utility and 22 differences in efficacy we established a separate 23 product class. 24 So the resulting criteria that met that 25 description for fluorescent lamps were physical EXECUTIVE COURT REPORTERS, INC.

(301) 565-006478 1 constraints of the lamp, lumen package, and correlated 2 color temperature. DOE did not use lamp diameter, 3 ballast interoperability, and lamp wattage as criteria 4 on which to base separate product classes. 5 Now I'm going to talk a little bit about each 6 of these criteria in more detail. In terms of physical 7 constraints of lamps, the physical constraints of a 8 lamp refers to ability of a lamp to use a particular 9 fixture. DOE believes that the ability of a lamp to 10 use a particular fixture affects the utility of that 11 lamp. For example, lighting designers may feel that 12 certain fixtures are more appropriate for certain rooms 13 than other fixtures. 14 Because the efficacy of the product is also 15 affected by a fixture -- for example, four-foot lamps 16 and eight-foot lamps exhibit different efficacies -- 17 DOE feels that physical constraints of lamps is an 18 appropriate criteria on which to base its product 19 class.20 So the result of this would be that straight21 shape lamps and U-shape lamps would have different22 product classes, and four-foot length lamps and eight23 foot length lamps would have separate product classes. 24 A second criteria on which DOE will base its 25 general service fluorescent lamp product classes is EXECUTIVE COURT REPORTERS, INC.

(301) 565-006479 1 lumen package. Lumen package refers to the quantity of 2 light a lamp and ballast systems provides to the 3 consumer. DOE has noticed that there are in some cases 4 noticeable differences in lumen output between 5 different types of lamps. For example, eight-foot, 6 single-pin, slimline lamps and eight-foot, recessed, 7 double-contact, high output lamps have approximately a 8 50 percent difference in lumen output. DOE believes 9 that this affects the utility of those products. 10 In addition to having a substantial 11 difference in lumen output, these two lamps also show 12 an efficacy differential that can be as much as 10 13 percent between comparable slimline lamps and high 14 output lamps. 15 Therefore, given the differences in utility 16 and efficacies, DOE, in the ANOPR, establishes separate 17 product classes for eight-foot, single-pin, slimline 18 lamps and eight-foot, recessed, double-contact, high 19 output lamps. 20 Finally, the third criteria which DOE uses to 21 establish general service fluorescent lamp product 22 classes is correlated color temperature. Correlated 23 color temperature, or CCT, is a measure of the 24 perceived color of the white light emitted from the 25 lamp. DOE believes that it is a performance-related EXECUTIVE COURT REPORTERS, INC.

(301) 565-006480 1 feature that affects consumer utility. 2 In addition, DOE believes that CCT affects 3 the efficacy of the lamp as well. Higher CCT lamps 4 emit less radiation in the visible part of the 5 spectrum, resulting in relatively lower efficacies. 6 As you can see on this figure on the right, 7 its an example of average efficacies of four-foot, 8 medium, bi-pin lamps. You can see that the 4,100 9 Kelvin lamps exhibit on average higher efficacy than 10 the 6,500 K lamps. Given that information, DOE 11 considers setting separate efficacy standards for lamps 12 with CCT less than or equal to 4,500 K and lamps with 13 CCT greater than 4,500 K. 14 As I stated before, there are several 15 criteria on which DOE does not base its product classes 16 on for general service fluorescent lamps. DOE does not 17 subdivide product classes by lamp diameter. For 18 example, our T12 lamps are in the same product class as 19 our T8 lamps. DOE does not believe that these are 20 properties that affect lamp utility because right now 21 in manufacturer product literature and market trends we 22 see that T8 lamps are being offered as replacements for 23 T12 lamps. 24 In addition, as a related issue, DOE is not 25 subdividing product classes by ballast EXECUTIVE COURT REPORTERS, INC.

(301) 565-006481 1 interoperability. Using the same example, T8 lamps and 2 T12 lamps require different ballasts, but DOE is 3 treating them to be in the same product class. 4 DOE understands, though, given some standards 5 on T8 and T12 lamps may not allow T12 lamps to be 6 available in the market and that would require 7 replacement of the ballast, DOE takes those economics 8 of purchasing another ballast as a replacement into 9 account in its life-cycle cost and national impact 10 analyses, as we'll discuss later on today. 11 Finally, DOE does not subdivide product 12 classes by lamp wattage. For example, the 40-watt, 13 four-foot, medium, bi-pin T12 lamp and the 34-watt, 14 four-foot, medium, bi-pin T12 lamp are in the same 15 product class. This is because DOE doesn't believe 16 lamp wattage is a property that necessarily affects 17 lamp utility, and we see that by 34 watts being offered 18 as replacements for 40-watt lamps. 19 Now that I've touched on the criteria on 20 which DOE based its general service fluorescent lamp 21 product classes, I'd like to touch on the issue of the 22 CRI standard. As I said earlier, EPCA established CRI 23 requirements that depend on lamp wattage. They have 24 separate CRI requirements for higher wattage lamps and 25 for lower wattage lamps. EXECUTIVE COURT REPORTERS, INC.

(301) 565-006482 1 However, as I just stated, DOE is not 2 proposing -- or, is proposing to not subdivide its 3 product classes by lamp wattage. As you can see, that 4 creates a bit of a problem in how we want to deal with 5 the CRI standard as it exists right now in the product 6 class structure proposed in the ANOPR. 7 In addition, after the framework, 8 stakeholders submitted comments suggesting that DOE 9 change the CRI standard. Right now DOE believes that 10 it doesn't have the authority to change the CRI 11 standard. 12 So, DOE invites comment on the possible 13 approaches to handling the issue of CRI in the GSFL 14 efficacy standards. 15 MR. BROOKMAN: Pam. 16 MS. HORNER: Pam Horner, NEMA Lamp Section. 17 This is regarding Section 3(A)(2)(a)(2), specifically 18 the subject of other class-setting factors that were 19 not adopted. In principle, NEMA is interested in this 20 simplified approach. Simple is good. It excludes 21 certain factors that had been previously included, as 22 you mentioned, such as CRI, and we applaud any effort 23 to streamline and to simplify. 24 However, in our comments we wanted to give 25 you a heads-up that in our written comments we are EXECUTIVE COURT REPORTERS, INC.

(301) 565-006483 1 going to include some other factors for consideration 2 because there are some downsides to excluding these 3 factors. 4 For example, CRI. If you take a look ahead 5 and look at the Candidate Standard Level 1, one sees, 6 if you analyze it, that you could in effect have T12 7 halophosphor lamps that wouldn't meet the standard but 8 T8 halophosphor lamps that would. Now, what tool do 9 you use to ensure that the appropriate energy efficient 10 lamps remain in the market? 11 It is possible, and this is where we need a 12 little bit more time. It is possible that if you 13 carefully select an LPW you might be able to do that. 14 But another obvious tool is CRI. So we simply want to 15 give you a heads-up on that today, and we will include 16 far more detail in our written comments. 17 The other issue, of course, is lamp diameter. 18 I know many of us during the interview period 19 expressed an interest in showcasing lamp diameter and 20 analyzing lamp diameter for a lot of reasons. I'd just 21 like to say at this point, and we will say more in our 22 written comments, that DOE notes a 10 percent 23 differential between slimline and HO systems, for 24 example. So there are differences according to 25 operational types. EXECUTIVE COURT REPORTERS, INC.

(301) 565-006484 1 But there is at least that sort of 2 differential in the four-foot category between a T8 and 3 a T12. So, in other words, diameter matters. 4 So it is difficult; you're absolutely right. 5 And while we're fascinated with and appreciate the 6 efforts to streamline and understand the work that goes 7 into all of these analyses, I guess we're not so ready 8 to throw these out as considerations. Thank you. 9 MS. GUPTA: Thank you. 10 MR. BROOKMAN: Andrew Delaski. 11 MR. DELASKI: Clarifying question. I missed 12 your point about the 10 percent difference. What was 13 your -- 14 MS. HORNER: There can be 10 percent efficacy 15 differences based on diameter. And some of these truly 16 also relate to the very kinds of, ultimately, the 17 ballasts upon -- with which these are associated, 18 because T8 lamps today -- and everyone is nodding. We 19 know this. The T12 operate for the most part on 20 magnetic, the T8 on electronic. There are a lot of 21 differences here, so we're not ready to throw out 22 diameter as a consideration. Thank you. 23 MR. BROOKMAN: Thank you. Other comments on 24 the logic behind the class differentiation? 25 MS. GUPTA: Yeah, a couple more comments, or EXECUTIVE COURT REPORTERS, INC.

(301) 565-006485 1 request for comment are coming up on the next slide. 2 MR. BROOKMAN: Okay. Keep going, then? 3 MS. GUPTA: Yeah. So this slide just shows a 4 summary of the product class structure considered in 5 the ANOPR. As you can see here, we have separate 6 product classes for the four lamp types, and we create 7 product classes within each one of those lamp types for 8 lamps with CCT less than or equal to 4,500 K and lamps 9 with CCT greater than 4,500 K. 10 So here we ask for a few more detailed 11 comments, which Pam addressed some of them. So, DOE 12 invites general comments on the GSFL product classes. 13 Specifically, we invite comments on whether T12 and T8 14 lamps should be part of the same product class and also 15 on the CCT divider, whether there should be one, how 16 many there should be, and where the appropriate 17 dividers should be. 18 MR. BROOKMAN: Pam. Joe. 19 MR. HOWLEY: Yes, just a follow-up comment on 20 the T8 versus T12 product class divider for four-foot 21 lamps. NEMA feels that there really should be a 22 product class divider here. As the comment Pam made 23 before, and Andrew's follow-up question, we note that 24 when you're considering why you split into two 25 different products classes eight-foot slimline and EXECUTIVE COURT REPORTERS, INC.

(301) 565-006486 1 eight-foot high output, one of the reasons was there 2 was a difference of about 10 percent in efficiency 3 between those two types.4 So if that was a reason to split the eight5 foot high output and eight-foot slimline, certainly the 6 difference between T12 and T8 four-foot is even greater 7 than 10 percent. So if that represents a reasonable 8 rationale for splitting those two categories, certainly 9 that would still apply for the four-foot T8 and T12. 10 It's just there's a significant efficiency difference 11 between those two product classes and the four-foot 12 type. 13 MR. DELASKI: Just a follow-up to Joe. 14 MR. BROOKMAN: Yeah. Go ahead, Andrew, and 15 then to Mike Rivest. 16 MR. DELASKI: Just to be clear, the T8 is 10 17 percent more efficient; is that -- 18 MR. HOWLEY: At least. 19 MR. DELASKI: At least, in your catalogue, or 20 industry-wide generally. I just want to be clear on 21 what the comparison is. 22 MR. BROOKMAN: Okay. Mike Rivest. 23 MR. RIVEST: Yes. Mike Rivest. This is a 24 complicated issue, and this is an underlying theme of 25 this analysis, is that because this is a system this is EXECUTIVE COURT REPORTERS, INC.

(301) 565-006487 1 a more complicated analysis. We had a lot of internal 2 debates and questioning about the appropriate thing to 3 do. 4 What we did try to do is to provide an 5 analysis that, with what you will see, have multiple 6 baselines. Multiple baselines is a way of capturing 7 the separate impact, say, of T8s and T12s without 8 separating them into product classes. 9 I think ultimately the right thing to do 10 depends on your policy objective. Creating a product 11 class has an implication in terms of what standards you 12 can set. So by creating a product class for T12s and 13 creating an economic justification for a higher T12 14 standard, for example, that becomes constraining. 15 We'll see that as the analysis develops today. 16 So I'd like everyone to keep an open mind 17 about what the right thing to do is as you think 18 through the implications of the economic justification 19 at every step of the analysis, bearing in mind that 20 we've tried to give the best of both worlds on the 21 analysis, something that combines the effect yet very 22 simply would allow you to see the separate impacts of 23 each CSL on different baseline lamps. 24 MR. BROCKMAN: Ron Lewis. 25 MR. LEWIS: I'd also be interested in input EXECUTIVE COURT REPORTERS, INC.

(301) 565-006488 1 on slimline versus high output. Generally, a lighting 2 designer would not be using one as a replacement for 3 the other. They would be used for different 4 applications. Considerably different characteristics 5 of those lamps and the luminaires that would be using 6 them. 7 The T8 versus T12 as replacements one for the 8 other and how they're applied in looking at the 9 migration of one to another, how that fits into play. 10 I mean, they are the same dimension. The target lumen 11 packages or applications where they're used versus a 12 slimline, versus high output. Any clarification you 13 could give us there to help us would be appreciated. 14 MR. BROOKMAN: Joe. 15 MR. HOWLEY: I think the bottom line is, we 16 talked about constraints. I think it produces a 17 different constraint when you put the two product 18 classes together. Although it may be true they're used 19 in similar applications, they do need separate 20 ballasts, and there are more and more T8 fixtures made 21 today that are smaller, slimmer, that indeed will not 22 fit a T12 lamp. So there even are some differences 23 within the fixture types themselves between the two. 24 But the main constraint is we do not believe 25 it will ultimately be possible to set a lumen-per-watt EXECUTIVE COURT REPORTERS, INC.

(301) 565-006489 1 standard that makes sense for T12, that this same exact 2 standard makes sense for T8s. I think that is 3 ultimately a constraint that's going to be difficult to 4 get around, saying that one number would be equally 5 effective for both product classes. 6 Given that that is the key outcome of this 7 entire analysis, I think that produces an unworkable 8 final solution, to have one lumen-per-watt standard 9 cover both. I believe that you need two product 10 classes because you're going to end up with two 11 different lumens-per-watt number that make sense for 12 T12 and that would make sense for T8. Thank you. 13 MR. BROOKMAN: Thank you. Follow on with 14 Mike Rivest. Steve, I'm coming to you. Let's keep 15 this all contiguous here. Go ahead, Mike. 16 MR. RIVEST: Mike Rivest. The difficulty 17 might be to be able to establish a T12 standard at all 18 if it's a separate product class. That's my concern. 19 And you know, this is a policy issue. It's a legal 20 issue in terms of how the economic justification is 21 handled. 22 Just to give you my thinking on that, one of 23 the important analyses is the life-cycle cost analysis. 24 As we look at the consumer economics on those 25 consumers of T12 lamps, what are the implications of EXECUTIVE COURT REPORTERS, INC.

(301) 565-006490 1 increasing the efficacy requirement on the T12 lamp if 2 there is no low wattage option available. It would 3 mean that they would be paying more, getting more 4 light, but not saving energy. 5 So at the consumer level, the single consumer 6 level, we couldn't show an LCC saving of a T12 7 standard. We could show a net national energy savings 8 benefit of a T12 standard when one considers the 9 substitution effect of a higher cost T12 lamp migrating 10 more people towards the T8. 11 So here, because of the separate criteria for 12 consumer economics at the single level and the 13 aggregate impacts on the nation, we get this strange 14 situation that I haven't encountered in other rules 15 where we can't make an LCC case for T12, we can make a 16 national impact case. By combining the product 17 classes, it does constrain you to a single level, 18 that's true. 19 But as the presentation unfolds and we try to 20 present how that level would cut across the existing 21 products. You know, if we can work this problem 22 together I think is -- but what I just explained was 23 the rationale, or one of the rationales, for -- at 24 least for the moment looking at regulating them at the 25 same level. EXECUTIVE COURT REPORTERS, INC. (301) 565-006491 1 MR. BROOKMAN: Steve Nadel. 2 MR. NADEL: Yes. We strongly support what 3 DOE has done to combine these two classes, the medium 4 bi-pin, including the T8 and T12. They do compete in 5 the marketplace. People are making decisions. Gee, do 6 I want a T8 or a T12 fixture. Do I replace the ballast 7 or not. That's what happens in the marketplace. 8 What matters is, you know, there is very 9 large energy savings at stake here. If you start 10 splitting them up I think you may dramatically reduce 11 the potential energy savings, you know, by a factor of 12 two or more. So we see this as being a critical issue. 13 I would note that we have problems with the 14 argument that, gee, if efficacy varies we need to have 15 two standards. I don't see it that way at all. That 16 could be used to argue, gee, we need to maintain 17 separate product classes for almost any inefficient 18 product. I think what's much more important is not the 19 efficacy difference but the performance difference. In 20 this case, the high output lamp has a much higher light 21 output, and that is a performance difference. That I 22 support being a rationale for a separate class for HO, 23 but not the fact that it's an efficacy difference. 24 I would also note that, per the earlier 25 discussion, and this had to do with test procedures, EXECUTIVE COURT REPORTERS, INC.

(301) 565-006492 1 but it may make sense to have a T5 class as well. In 2 terms of CRI, my tendency is to think we probably don't 3 need it. But I agree with Pam; we should hold it in 4 reserve to see if that's going to be an important 5 differentiator. 6 As Pam was kind of alluding to, we don't -- 7 presently in the United States, as far as I know, there 8 is no halophosphor T8. We don't want to encourage 9 people to start introducing those products in order to 10 get around a standard. So if the efficacy doesn't 11 work, we should be open to CRI. 12 I don't recall anything in the law 13 prohibiting DOE from revising the CRI standard. So I 14 would encourage we keep it on the list of options even 15 if it is, maybe, not the primary thing. Hopefully LPW 16 will be an adequate differentiator. 17 MR. BROOKMAN: Mike Rivest. 18 MR. RIVEST: Again, CRI analytically proves 19 to be difficult because it's not something that -- 20 first of all, it's not an efficiency metric. The way 21 it correlates with efficiency is it tends to be a 22 positive correlation. So it's hard to analyze the 23 benefits of one or another CRI directly. 24 Now, maybe we just haven't captured it 25 correctly, but for the present time it's proved to be a EXECUTIVE COURT REPORTERS, INC.

(301) 565-006493 1 challenge to look at the differential impacts of one 2 pairing versus another pairing, say. 3 MR. BROOKMAN: Let's let Steve finish, and 4 then Andrew. 5 MR. NADEL: Right. And I'm not saying do 6 lots of analysis based on CRI. I agree. Hopefully 7 this will all work out. But because one of the 8 objectives as noted in the ANOPR is to prevent opening 9 up loopholes and we don't want to encourage the 10 introduction of products, you know, if an LPW doesn't 11 keep a T8 halophosphor product from being introduced, 12 adding a CRI to that standard may be an appropriate 13 one. 14 MR. BROOKMAN: Andrew Delaski. 15 MR. DELASKI: I think you've heard twice now 16 this morning that there are a couple of spots in this 17 analysis where your analysis may have nothing to say on 18 the topic but that are crucial to how the rulemaking 19 proceeds. I think this is something that comes up in 20 lighting that we don't see in other products. 21 It happened in 1992 in reaction to the EPACT 22 reflector lamp standards. I don't think anybody 23 analyzed what would happen if exempted lamps took 60 24 percent of the marketplace. California analyzed what 25 happens if vibration service lamps become ipso facto, a EXECUTIVE COURT REPORTERS, INC.

(301) 565-006494 1 conventional product in the marketplace. 2 So, as you noted, and I think it's on the 3 opening slide in the product class discussion, that we 4 have to watch out for loopholes here. We have to watch 5 out that if something has -- some of the little stuff 6 becomes the big stuff. It's a tiny piece of the 7 market. They are not even this big. I think Pam 8 indicated that the halophosphor T5 is nonexistent. You 9 can't analyze cost effectiveness because it doesn't 10 exist in the marketplace. 11 I think it is incumbent on the Department to 12 protect against the loss of energy savings that would 13 happen if these loopholes were to open up in response 14 to the Department's actions. That doesn't fit into 15 your analysis but it's still something you have to 16 protect against. 17 MR. RIVEST: I understand. 18 MR. DELASKI: Whether it's the T5 issue, 19 whether it's this issue, whether it's -- Pam mentioned 20 the U-bend lamps that didn't exist when you first 21 started this analysis. We could have lower wattage 22 lamps that don't exist today, below some of the levels 23 that you're looking at, that may or may not be a 24 problem in terms of energy savings that have to be part 25 of the Department's consideration in this rulemaking. EXECUTIVE COURT REPORTERS, INC.

(301) 565-006495 1 MR. BROOKMAN: Pam. 2 MS. HORNER: Pam Horner for the NEMA Lamp 3 Section. You've heard that a few times. I'd like to 4 comment, please, briefly on your last question 5 regarding correlated color temperature and update you 6 briefly on something that the NEMA Lamp Section is 7 doing. It goes back or is related to the revised 8 definition of colored fluorescent lamps. Are you with 9 me here? So it's related to your question. 10 We tend to agree with the revised definition, 11 but what it does -- and this whole thing, for everyone 12 here, if you don't know what I'm talking about, is if 13 you look at her previous slide, it has a distinction 14 made between lamps of less than or equal to 4,500 15 Kelvin, which would capture the main kinds of 16 correlated color temperatures that you find in the 17 market today for common application. It then gives a 18 second set of product classes for greater than 4,500 19 Kelvin. 20 This looks good, except something new has 21 happened in the market. That is that not only lamps of 22 great -- well, lamps of greater than 4,500 Kelvin, the 23 ones that look bluer, are now spreading out into higher 24 and higher numbers. Probably this was originally 25 intended to capture your 5,000 Kelvin lamps that are EXECUTIVE COURT REPORTERS, INC.

(301) 565-006496 1 becoming very common in utility rebate programs. Very 2 high interest in these lamps. 3 But what is happening in the market, and 4 we're here to tell you, is that even higher color 5 temperatures are entering the market not just for 6 special applications. The definition said why don't we 7 just say if it's for special applications, it's for 8 special applications and you market that way. But for 9 example, there's an 8,000 Kelvin lamp that is rapidly 10 becoming of interest in the market that could be used 11 for both specialty and general applications. 12 I mean, you could sort of not tell the truth 13 exactly on your packaging, I suppose, but that isn't 14 really an option. So, how do we deal with this trend? 15 Several months ago, our Technical Committee 16 set about getting the top phosphor scientists -- which 17 tend to live mainly in the big three lamp companies. 18 This was no small task -- to get them together under 19 the auspices of a NEMA Technical Section Taskforce to 20 examine the kinds of trends for higher-color 21 temperature lamps, knowing that this would come up and, 22 if asked, what would we say. 23 I wish we were ready today and we could have 24 a party or something, but unfortunately we are still 25 collecting how we would do this. But the initial EXECUTIVE COURT REPORTERS, INC.

(301) 565-006497 1 indication is that there should be a third break. 2 Like, these are okay, but we think there will have to 3 be something around 5,500, something of that nature. 4 Don't hold me to that, please, because we'll put it in 5 our comments. 6 But we wondered if DOE would be interested. 7 The minute we get all of our findings, would you be 8 interested in having a really nice technical summary of 9 what we analyzed and why, and we promise it would be 10 interesting? Okay. Because this is not a minor point. 11 It has to do with everything from machine speed to 12 coating thicknesses, to availability of phosphors, to 13 the different efficacies of different kinds of 14 phosphors. There seems to be a natural break that we 15 think will be helpful in your columnation. 16 I see some nods. I'm going to take that as a 17 yes. Thank you. 18 MR. BROOKMAN: Thank you. Yes, please. Your 19 name. 20 MR. WALITSKY: Paul Walitsky, Industrial 21 Ecology. What we found in Philips when I was active 22 there was that the further south we got in the country 23 the higher the color temperature went that people 24 preferred. So we were seeing, in the south and in 25 Mexico, in 98 percent of the sockets were daylight. EXECUTIVE COURT REPORTERS, INC.

(301) 565-006498 1 And it was a geographical spread as well as preference. 2 So that, I think, reinforces some of what Pam 3 may be getting to. The 5,000 K lamp was popular for a 4 while. We used to see 6,500 only for special printing 5 applications, but now it's getting into general 6 lighting. So they have moved exactly in those 7 directions. 8 MR. BROOKMAN: Thank you. So, Pam, thanks 9 for those remarks. Let me note for the record that DOE 10 would be very interested in receiving that kind of 11 detailed analysis to supplement their work. 12 Okay. So, any other comments, then, before 13 we return to Mimi? 14 (No response.) 15 MS. GUPTA: All right. So now that we've 16 discussed the general service fluorescent lamp product 17 classes I'd like to move on to the incandescent 18 reflector lamp product classes. EPCA set efficacy 19 standards for six different wattage bins for 20 incandescent reflector lamps. DOE believes that 21 wattage, though it affects efficacy, is not a measure 22 of utility and merely a measure of power. For example, 23 a high efficacy, 55-watt lamp can deliver the same 24 amount of light as a lower efficacy 75 watt lamp. 25 So if DOE were to maintain the wattage bins EXECUTIVE COURT REPORTERS, INC.

(301) 565-006499 1 as they exist in EPCA, DOE's analysis could not 2 consider the 55-watt lamp as a replacement for the 75- 3 watt lamp since they would be in separate product 4 classes. 5 Therefore, DOE establishes a product class 6 that encompasses the entire wattage range covered, 40 7 watts to 205 watts. To take into account the effect of 8 wattage on efficacy, DOE is proposing that the 9 candidate standard level for incandescent reflector 10 lamps would be an equation that depends on wattage. 11 So here you see an illustration of the EPCA 12 standards. It's a step-like standard. As you can see, 13 as lamp wattage increases, the efficacy standard 14 increases as well. You can also see here the form of 15 the ANOPR candidate standard levels for incandescent 16 reflector lamps. Similarly, as efficacy increases, or 17 as wattage increases, we have efficacy increasing. 18 DOE is establishing product classes by 19 modified spectrum for incandescent reflector lamps in 20 the ANOPR. As discussed earlier in the scope of 21 coverage section, EISA 2007, or the Energy Independence 22 and Security Act, defines a colored lamp such that some 23 incandescent reflector lamps -- for example, lamps 24 containing greater than 5 percent neodymium -- are no 25 longer excluded from energy conservation standards EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064100 I coverage. 2 These lamps may fall under the definition for 3 modified spectrum also incorporated by EISA, which 4 defines modified spectrum as a lamp that is not a 5 colored lamp and a lamp whose color point with 6 chromaticity coordinates lies below the black body 7 locus and at least four macadam steps from the color 8 point of a similar clear lamp. 9 DOE believes that modified spectrum IRL offer 10 different light output and therefore utility. Because 11 they absorb a portion of the visible spectrum, visible 12 light emission of the filament, they exhibit a reduced 13 efficacy. Therefore, DOE considers establishing a 14 separate product class for modified spectrum lamps. 15 This slide shows a summary of DOE's 16 incandescent reflector lamp product classes. We have 17 two product classes. Each one spans the full wattage 18 range. So you have one product class for standard 19 spectrum IRL and another product class for modified 20 spectrum IRL. 21 I'd like to open the floor for comment on the 22 IRL product classes. 23 MR. BROOKMAN: Pam. 24 MS. HORNER: Surprise. Pam Horner for the 25 NEMA Lamp Section. We like that smoothing formula. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064101 1 It's a very good idea, and we think the rationale was 2 very well thought out. 3 We do have one concern that we're going to 4 elaborate upon in our written comments that we would 5 like to give you, again, a little heads up on. In the 6 description of what one must do in order to get at the 7 difference between a modified spectrum lamp and a 8 standard spectrum lamp, it seems to us that the 9 responsibility for getting the correct baseline 10 efficacy falls to the manufacturer, which is rather 11 interesting. 12 In other words, you have a clear lens, then 13 you have to carefully take it off, put on the modified 14 spectrum lens, et cetera. The process, according to 15 the people who wear white lab coats in our company, 16 they find to be extremely complicated. 17 We are a little bit concerned about how it 18 might be enforced and verified the way it's written, so 19 we thought it would be an opportunity for us, too, if 20 we can have some improvements suggested in those areas. 21 We will provide those in writing. Thank you. 22 MR. BROOKMAN: Thank you. Thank you very 23 much. Additional comments on these IRL product classes 24 and the way they're described? Yes. 25 MR. FERNSTROM: Gary Fernstrom, PG&E. We EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064102 1 noticed that DOE in its Footnote 28 indicates the 2 modified spectrum lamps provide a unique utility to 3 customers in that they offer a different spectrum of 4 light from the typical incandescent lamp. However, we 5 think DOE's conclusion differs a little bit from the 6 LRC's conclusion having to do with the utility of these 7 lamps. We would like to see that further investigated. 8 We don't think that modified spectrum 9 incandescents offer very much utility consumers that 10 can't be better achieved through fluorescent or other 11 types of light sources. 12 MR. BROOKMAN: Thank you. Steve Nadel. 13 MR. NADEL: A question first, as I'm trying 14 to understand this. How do you define modified 15 spectrum? Where is the line between normal spectrum 16 and modified? Because, you know, there's the potential 17 to game this. Oh, I tweaked it, you know, to a minor 18 degree. 19 MS. GUPTA: Yeah. Well, EISA 2007 20 establishes a definition for a modified spectrum. 21 MR. FERNSTROM: Okay. So you would use that 22 definition. 23 MS. GUPTA: Yeah, we would have to. It's 24 actually that definition that incorporates the idea of 25 the clear lamp. So in order to get this break for a EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064103 1 modified spectrum, you would already have to do that 2 measurement between the clear lamp and the modified 3 spectrum lamp, referring back to Pam's point. 4 MR. BROOKMAN: Go ahead, Steve. 5 MR. NADEL: I guess, to make a comment, I'll 6 somewhat agree with Gary that we're not clear what the 7 extra utility is and how much of a benefit it is. 8 We're concerned that potentially this could result in 9 lost energy savings. So as part of any analysis -- 10 we'd recommend that DOE not make a decision but do an 11 analysis and see what the impacts are on energy saving 12 as part of this analysis before making a decision. 13 MR. BROOKMAN: Andrew Delaski. 14 MR. DELASKI: I'm curious if the Department 15 has any data at this point on what market share 16 modified spectrum reflectors have. 17 MS. GUPTA: No, we don't have any data at 18 this point. The only data we have is looking at 19 manufacturer product literature. We can see that there 20 are relatively lower numbers of incandescent reflector 21 lamps that are modified spectrum than there are general 22 service incandescent lamps, but we would appreciate any 23 data on that. 24 MR. DELASKI: Do you all have any NEMA 25 manufacturers or certain NEMA -- do you have any EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064104 1 information you can share on that at this time on what 2 your take is? 3 MR. HOWLEY: -- indicate it's a relatively 4 low percentage of the market. 5 MR. BROOKMAN: Joe says no specific data at 6 this time. 7 MR. FERNSTROM: Gary Fernstrom, PG&E. I'd 8 just like to point out that perhaps one way to 9 estimating market share without actually having that 10 information is looking at shelf space in retail. PG&E 11 noticed a significant shelf space in retail devoted to 12 modified spectrum lamps. 13 MR. BROOKMAN: Thank you. 14 MS. GUPTA: That includes modified spectrum 15 incandescent reflector lamps, also. Okay. 16 MR. BROOKMAN: Yes, Ron Lewis. 17 MR. LEWIS: If NEMA or anybody, if IES or 18 ANSI has a definition of what modified spectrum is, 19 even if we're looking at -- to my understanding, 20 everything is a filter. That's a deductive process as 21 opposed to additive. So, much like on the straight 22 line curves versus the step function, here this looks 23 like it's a continue -- anybody could do anything. 24 Where is that line as far as modified spectrum that 25 applies -- that's a deductive efficacy or the spectrum. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064105 1 In trying to get our arms around what is it 2 that we're dealing with here, it's not a discrete point 3 of a single step of this is modified spectrum. But, 4 what is the range or how do we get our arms around a 5 definition of modified spectrum for incandescent 6 reflector lamps specifically? 7 MR. BROOKMAN: Joe. 8 MR. HOWLEY: Yes, this is Joe Howley. There 9 is a definition of modified spectrum which was worked 10 out in the EISA law, and that is in there. It has to 11 do with changing the color point off the black body 12 curve a certain number of degrees to basically ensure 13 that a heavy amount of filtering was occurring, that 14 you were going after the modified spectrum result. 15 But otherwise, what you're proposing is 16 exactly correct. You would need two separate product 17 categories. Under the old rulemaking you'll note that 18 this product category was exempted. Under this 19 rulemaking, EISA basically takes away that exemption 20 but provides a definition. If these were to be further 21 regulated as you're proposing, there would definitely 22 need to be two product categories, as you're proposing, 23 one for clear lamps and one that, as you said, has a 24 filter on it removing the yellow part of the spectrum 25 and producing a lower lumen-per-watt level. So that EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064106 1 would need its own separate category, as you're 2 proposing. 3 So we're basically supporting your proposal. 4 There are some questions about how you might test for 5 that, but other than that, on the high level we support 6 your proposal to have two separate categories. 7 MR. BROOKMAN: Thank you. Jeff Harris. 8 MR. HARRIS: Jeff Harris, Alliance to Save 9 Energy. I wonder, Joe or somebody else from the 10 manufacturer side, if you can tell us anything about 11 the cost difference for modified spectrum reflector 12 lamps. Is it roughly the same magnitude as the cost 13 difference for the conventional GLS lamps? 14 MR. BROOKMAN: Hey, Joe, let's get it on the 15 record. Why don't you leave that mic on? 16 MR. HOWLEY: Essentially, the same glass is 17 used. So, yes, there would be a cost adder whether or 18 not you're forming it into an A-line bulb or you're 19 putting it into a reflector type bulb. You're using 20 the same kind of glass or same kind of coatings. But 21 the cost adders would still be there. 22 MR. BROOKMAN: Thank you. So, other comments 23 on this spectrum of issues? 24 (Laughter.) 25 MR. BROOKMAN: I see none. Okay. So let's EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064107 1 do two more slides and then we'll break for lunch. 2 MS. GUPTA: Okay. My colleague Conan 3 O'Rourke will talk a little bit about the screening 4 analysis next. 5 MR. O'ROURKE: Thank you, Mimi. In the 6 screening analysis, the Department goes through looking 7 at the different possibilities of the technology 8 options that were identified and whether they should or 9 should not be screened out and will later become design 10 options. The criteria they look at are technological 11 feasibility, the practicability to manufacture, 12 install, and service, as well as adverse impacts on 13 product utility or product availability, and also 14 looking at impacts on health or safety. 15 The design options that were at least 16 selected for consideration -- I'll read them -- for the 17 general service fluorescent lamps are high-emissive 18 electrode coatings, high efficiency lamp fill gas, high 19 efficiency phosphors, glass coatings, and high 20 efficiency lamp diameters. 21 For the incandescent reflector lamp design 22 options, they are the high temperature operation, 23 thinner filaments, efficient filament coiling, 24 efficient filament orientation, higher efficiency inert 25 fill gas, tungsten-halogen lamps, higher pressure EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064108 1 tungsten-halogen lamps, infrared glass coatings, and 2 high efficiency reflector coatings, as well as 3 efficient lamp placement. 4 Next, moving into the engineering analysis, 5 the purpose of the engineering analysis is to take the 6 -- 7 MR. RIVEST: Doug? 8 MR. BROOKMAN: Yes. 9 MR. RIVEST: This is probably a good place to 10 break. 11 MR. BROOKMAN: I was wondering. I thought so 12 as well. Comments on these last two slides, 17 and 18? 13 Yes, Pam. 14 MS. HORNER: Pam Horner with NEMA Lamp 15 Section. Regarding the technology assessment and 16 screening analyses that were performed, first, for 17 fluorescent, we agree. For incandescent reflector, we 18 agree in general with the technologies that were 19 considered for improved efficacy, as long as they apply 20 to 40-watt to 205-watt. It never said anywhere in here 21 that that remains the wattages that are regulated; is 22 that correct? Okay. So as long as that is the case, 23 then we're okay. 24 We also believe the DOE screened out the 25 appropriate ones and left a reasonable list. We have EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064109 1 some updated information for you, however, on one of 2 them that could become a caveat as we move forward in 3 trying to improve efficacy in the incandescent 4 reflector lamp. Again, it's nothing -- you can't count 5 on these things. Like Andrew says, things just keep 6 popping up. 7 We just learned, for example, that on certain 8 contracts for xenon gas -- xenon gas happens to be the 9 real reasonable next step up above krypton for the 10 improvement of efficacies in these certain lamp types, 11 especially in the halogen world. You talk about 12 limited supply and cost increase. It went up seven 13 times over the last three months in a recent contract 14 analysis we did. 15 For some reason there is a major shortage, so 16 there is a sudden concern about what would have been a 17 viable gas fill option. It's driving us crazy, 18 basically. We even learned that, just as an example, 19 one of the competitors for this is the federal 20 government and its space program. Now, we're not 21 saying that that's the only competitor for the 22 technology, but these things happen. 23 So we thought it would be useful for you to 24 know that even though the analysis was excellent these 25 sorts of things can happen and impact our future. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064110 1 MR. BROOKMAN: Thank you. Thanks for that 2 clarification. Other comments on the selected design 3 options featured on Slide 18? Steve Nadel. 4 MR. NADEL: Yes. One of the consultants 5 we're working with is looking at this list, and what I 6 heard from some preliminary results is we wonder 7 whether DOE may have cut out too many. I don't have 8 more particulars at this point, but we may be 9 commenting on that. 10 MR. BROOKMAN: Thank you. The sooner the 11 better, I'm certain. Yes. Additional or perhaps final 12 comments on these design options? 13 (No response.) 14 MR. BROOKMAN: Okay. So let's take lunch 15 ' 10 i f 12 now. It s mnutes a ter . 16 (Whereupon, at 12:10 p.m., the meeting was 17 recessed for lunch, to reconvene at 1:13 p.m., the same 18 day.)

EXECUTIVE COURT REPORTERS, INC. (301) 565-0064111 1 A F T E R N O O N S E S S I O N 2 1:13 p.m. 3 MR. BROCKMAN: A few people made it here late 4 because of delays and other kinds of things and didn't 5 get a chance to introduce themselves. I want to 6 provide that opportunity to anyone that didn't have a 7 chance to introduce him- or herself. Mark, I think you 8 were one. 9 MR. FRIEDRICHS: No, I introduced myself. 10 MR. BROCKMAN: Oh, you did. That's right, 11 you did. Okay. I guess maybe I'm mistaken. So then 12 that courtesy is now fulfilled. Conan. 13 Engineering Analysis (Continued) 14 MR. O'ROURKE: Thank you, Doug. I'll begin 15 our after-lunch discussion dealing with the engineering 16 analysis. The engineering analysis is used in 17 conjunction with the product price determination to 18 look at developing a relationship between energy -- 19 higher efficiency products and the cost of those higher 20 efficiency products. These two things, the engineering 21 analysis as well as the product price determination, 22 feed together into later analyses on life-cycle cost 23 and on the payback period analysis, as well as the 24 national impact analysis. 25 MR. BROCKMAN: We're on Slide 19, correct? EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064112 1 MR. O'ROURKE: Yeah. I just moved on to 20. 2 MR. BROOKMAN: Okay. 3 MR. O'ROURKE: So Slide 20 is meant to be a 4 summary of the main steps of the engineering analysis. 5 Choosing the representative product class. Here, 6 that's one which will be selected to be the engineering 7 and the life cost analysis. 8 Define the basic model. That basic model is 9 developing the characteristic models for each of the 10 representative product classes and service reference 11 points when we look at higher representative products 12 and candidate standard levels when we move on from 13 there. 14 Selecting the efficient substitutes. 15 Basically, looking at products that we gathered from 16 manufacturers' literature in developing a comprehensive 17 list of what is on the market. We looked at 18 substitutes that would maintain similar light output as 19 well as save energy. 20 Then, the next step is developing candidate 21 standard levels. These span the range of what kind of 22 meets energy standards today all the way up to what's 23 maximum technology feasible. 24 The last step is scaling the product classes 25 that weren't analyzed from the ones that were analyzed. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064113 1 That would be the last step. 2 So, representative product classes. The 3 Department selected a subset of the product classes, as 4 we showed earlier, of the eight that would be analyzed 5 for the engineering analysis and the life-cycle cost 6 analysis. The ones that were chosen were based on 7 highest volumes of shipment, ones that were common in8 the marketplace. The ones in particular are the four9 foot, medium, bi-pin with a correlated color10 temperature of less than or equal to 4,500; the eight11 foot, single-pin, slimline lamps also less than or 12 equal to 4,500; and finally, the eight-foot, recessed, 13 double-contact, high output, the same CCT requirement. 14 For incandescent reflector lamps, we looked 15 at standard spectrum lamps and scaled those findings to 16 the modified spectrum, which I'll discuss at the end. 17 Baseline models are developed from within the 18 representative product class. They're usually the ones 19 that would meet -- just bare minimum meet the existing 20 Energy Star energy standard. We selected the 21 particular attributes like light output, wattage, and 22 operating lifetimes that were typical for the most 23 common lamps for that baseline model. 24 It was mentioned earlier that there were 25 several different baselines for the product class, as EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064114 1 Mike Rivest tried to comment on, how to handle the 2 different lamp diameters within the same product class. 3 We'll talk about that as well. 4 So, going down just to describe what these5 baseline models are, we have the four-foot, medium, bi6 pin. We're looking at baselines of the 40-watt T12, 7 the 34-watt T12, and the 32-watt T8, with operating 8 lifetimes of 20,000 hours and a CCT of 4,100. That was 9 what was selected. We broke the phosphors up into 10 three different categories. In this case we're looking 11 at 700 series, which would be CRIs between 70 and 79. 12 We're also describing 600 series with CRIs between 60 13 and 69. 14 But I was just showing here that phosphors of 15 the 40-watt T12 and the 32-watt T8, their baseline 16 models are using 70 CRI lamps for 700 series, where the 17 34-watt T12 is using lamps with CRIs in the 60s. 18 For the eight-foot, single-pin, slimline, 19 we're looking at the 75-watt, the 60-watt T12s, and the 20 59-watt T8. The operating lifetimes here are 12,000 21 hours and 15,000 hours. The CCT is 4,100, and the 22 phosphors we're looking at here are also the 70s and 23 the 60 CRIs for this category as well.24 The last one here for the recessed double25 contact, we're looking at the 110-watt and the 95-watt EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064115 1 T12s, and we don't -- in this one we do not have a T8 2 baseline model because, based on the market data that 3 we got, the market is so small -- it's less than 5 4 percent -- that it wasn't considered for a baseline. 5 And operating lifetime here was 12,000 hours with 4,100 6 K and looking, again, at CRIs of 70s for the 110 and 7 60s for the 95-watt and the -- version. 8 So, once you have those baseline models, the 9 next step is looking at substitutes that you would get. 10 Here we're showing the table of these are all based on 11 commercially available product. These are just 12 examples of the four-foot medium bi-pin category. So 13 you see there are three different baselines there. The 14 first one in the first row, the T12, 40-watt, has a 15 rated efficacy of about 80 lumens per watt with a CRI 16 of about 70. 17 The other baseline is the T12 at 34 watts 18 with a 77.9 lumens per watt and a 62 CRI. The third 19 baseline is a T8 with 32 watts, 86.2 lumens per watt, 20 and CRI of 75. Then, all the remaining rows are 21 different, other representative products, substitutes 22 that you could have in those product classes. 23 Any questions on this table? 24 MR. BROOKMAN: Or other questions or comments 25 on the baseline models specified in 23, if you haven't EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064116 1 done so already? 2 (No response.) 3 MR. O'ROURKE: Now, the next step we're 4 looking at systems because when you're comparing a lamp 5 to a lamp they're going to operate in an application 6 with a ballast. So that's the approach that was taken 7 in our analyses for the engineering and for the LCC. 8 It considers both the reduced wattage lamps and equal 9 wattage lamps. 10 In the case of equal wattage lamps, if you 11 have a more efficient lamp for the same wattage, you're 12 going to have more light output, not necessarily energy 13 savings. So to deal with energy savings you can use a 14 lower ballast factor ballast to compensate. 15 We realize that the ballast does influence 16 the amount of light you're going to get and also the 17 system power in that case. We looked at them paired 18 with more than one ballast in some cases for that 19 system. 20 Systems were chosen to have similar mean 21 lumen outputs as a baseline model. Again, energy 22 savings of the baseline model could be obtained by 23 either having a more efficacious reduced wattage lamp 24 on the same ballast or have a more efficacious and same 25 -- reduced wattage lamp on a different ballast that EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064117 1 would operate the lamp at a lower power level. 2 I'm going to have a graph up here in a moment 3 so you can see how this plays out. 4 So, just to go into how the systems would 5 work, we look at the system mean light output as based 6 on the number of lamps per ballast times the ballast 7 factor times the mean light output of the lamps. An 8 example would be if you had a three-lamp ballast with a 9 0.9 ballast factor and the lamps were about 2,000 mean 10 lumens. Then the system lumens would be approximately 11 5,400 lumens, and that's what we would use kind of for 12 the system comparison. 13 System is dependent on the lamp wattage and 14 ballast factor. So as ballast factor decreases, the 15 system power would decrease as well. As the lamp 16 wattage decreases, it also reduces system power. 17 Here on Slide 27 we're looking at different 18 rated lamp wattages. As you reduce the wattage, you'll 19 see that there's a general shift up and to the left. 20 We're showing the rated lamp efficacy in lumens per 21 watt on the Y-axis. 22 The green arrows are meant to show changes in 23 lamp and ballast that would occur to take advantage of 24 these higher efficacious light sources and still try 25 and maintain light output. The yellow ones are showing EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064118 1 the change in lamp only or it could be also lamp and 2 ballast changes. We also have a green arrow up here 3 that shows a transition of where it would occur going 4 from T12 technologies to T8 technologies. 5 We're also showing here where all the 6 baselines are starting out at. So here's a 40-watt T12 7 baseline at about 80 lumens per watt. Here's a 34 8 baseline, about 78 lumens per watt, and also, the T8 9 baseline at about 86 lumens per watt. Yes. 10 MR. NADEL: You have a bunch of vertical 11 green arrows. Are those supposed to be green in those 12 cases or are those supposed to be yellow? 13 MR. O'ROURKE: They're meant to be green 14 because they have to be a lamp and ballast change. It 15 can't just be a lamp only. 16 MR. NADEL: It can't be? You're going from 17 like a T12 -- 18 MR. O'ROURKE: No, the vertical green are 19 just the same lamp type, the 32-watt T8. All I'm doing 20 is choosing a more efficacious 32-watt T8. But in 21 order for me to get energy savings, I have to be able 22 to reduce the system power by using a lower ballast 23 factor ballast. 24 MR. NADEL: Okay. 25 MR. O'ROURKE: I can't do it with the lamp EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064119 1 alone. 2 MR. NADEL: Okay. 3 MR. O'ROURKE: But I'd have to replace the 4 ballast. 5 MR. BROOKMAN: Gary. 6 MR. FERNSTROM: Conan, Gary Fernstrom from 7 PG&E. What you're doing is you're showing us on the 8 left-hand axis, though, the efficacy. So you could get 9 an improvement in efficacy just as well by increasing 10 the lumens and keeping the watts the same. 11 MR. O'ROURKE: Right. Well, what would 12 happen, when you compared the systems you would have a 13 much different comparison in the overall lighting. 14 Unless if you were trying to compensate by trying to 15 maintain about the same light output. 16 MR. FERNSTROM: All right. So this is for a 17 nominal light output, or a consistent light output. 18 MR. O'ROURKE: Well, the way that these ones 19 get these higher efficacies for the same power is by 20 providing more light. So you have to be able to, if 21 you want to still keep about the same amount of light 22 for the system, you're going to have to use a lower 23 ballast factor ballast. 24 MR. BROOKMAN: Jeff. 25 MR. HARRIS: Jeff Harris, Alliance to Save EXECUTIVE COURT REPORTERS, INC.

(301) 565-00641201 Energy. Did you look at any conversions from a three2 lamp to a two-lamp configuration in the same fixture? 3 MR. O'ROURKE: We didn't. You'll see a 4 little bit later our systems that we set, what we're 5 going to analyze for each baseline model. In some 6 cases it was a three-lamp ballast, in some cases it was 7 a two-lamp ballast. But at this time we have not taken 8 in going from different number of lamps and comparing 9 them to each other. 10 MR. FERNSTROM: So, Gary from PG&E again. I11 was surprised at that, too, because I think the two12 lamp might be more common. So, is there a reason why 13 you chose the ones you did? 14 MR. O'ROURKE: Only in that we believed at 15 the time they were the more common ones on the market. 16 I think it's also similar to what they did in the 2000 17 ballast rule as well. 18 MR. BROOKMAN: Mike Rivest, go ahead. 19 MR. RIVEST: Mike Rivest. So in terms of 20 selecting a representative system, one could have 21 chosen a two-lamp, three-lamp, or a four-lamp, or one 22 could have done the analysis with all three. You'll 23 see that as you try to anticipate what consumers will 24 do as they're faced with a more stringent standard, 25 there's already a very large range of choices that they EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064121 1 have to make. 2 So, to keep the analysis tractable, we 3 elected with the three-lamps because what we saw based 4 on the 2000 analysis was that the average lamps per 5 electronic ballast was like 2.85. Where does this 6 matter. It matters primarily where you have to incur a 7 cost of a ballast and divide the cost of that ballast 8 over a certain number of lamps for your fixed cost. So 9 if we would have taken a two-lamp system, we would have 10 been overstating the cost of the ballast, and if we had 11 taken a four-, we would have been understating it. 12 MR. FERNSTROM: Thank you. 13 MR. BROOKMAN: Thank you. I thought I saw 14 someone else with a comment or a question. No? Okay. 15 MR. O'ROURKE: Okay. Going on, looking at 16 the baseline systems, the four-foot, medium, bi-pin, 17 three-lamp system has -- for the T12, could be a 18 magnetic or electronic system -- or a 0.88 ballast 19 factor with electronic ballast, excuse me, and the T8 20 would be a 0.88 ballast factor, electronic ballast. 21 Additional systems we would look at would 22 look at other ballast factors for the T12 system and 23 also other ballast factors for the T8 allowing for low, 24 medium, and high ballast factors. 25 For the eight-foot system, along the same EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064122 1 lines, for the T12, the magnetic ballast or electronic 2 ballast with a 0.88 ballast factor, a T8 with a 0.88 3 ballast factor, electronic ballast. And, the number of 4 ballast factors available for these ballasts were a lot 5 less once you get up into this category of ballast for 6 the single-pins, so we don't have as many options to 7 choose from.8 Going to the eight-foot, recessed, double9 contact, we only have, again, the T12 lamp as the 10 baseline. We have an electronic ballast for that, and 11 we're looking at two other ballast factors of 0.9 and 12 0.89. We are using T8 even though it isn't enough of a 13 market for a baseline. We're looking at least from the 14 analytical side of what would the analysis look like if 15 you included the T8 system with a 0.81 ballast factor. 16 So in summary, for at least I should say 17 introducing the candidate standard levels, once we have 18 now got all our representative substitutes that we're 19 going to use to compare to our baseline models, now we 20 can start to look at developing candidate and standard 21 levels. These would usually have several different 22 design options. Primarily we looked at -- we've been 23 discussing the different phosphors, but they could also 24 have other ones as well. 25 So the phosphors we've mentioned were the 600 EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064123 1 series, which are typically halophosphor lamps with 2 CRIs between 60 and 69, and they are usually 3 accompanied with reduced wattage lamps. The 700 series 4 have a rare earth phosphor, usually in some combination 5 with a halophosphor, but the primary addition is the 6 rare earth phosphor. It does have a higher wattage 7 baseline and higher efficiency lamps. These lamps have 8 CRIs between 70 and 79. 9 The last category of 800 series uses a more 10 rare earth phosphor and even more efficient lamps with 11 CRIs between 80 and 89. 12 The other possible design options that are 13 listed here besides just the phosphors are the emissive 14 coatings, higher efficiency lamp gas fills, thicker 15 phosphor coatings, glass coatings, and higher 16 efficiency lamp diameters. In some cases, the 17 candidate standard levels that are suggested do 18 eliminate T12 lamps. 19 MR. BROOKMAN: Joe, go. 20 MR. HOWLEY: Yeah, I just had some questions 21 concerning the T12 systems used for the baseline. I 22 noticed that you are using either magnetic or 23 electronic for the four-foot and the eight-foot 24 slimline, but only using magnetic -- electronic for the 25 eight-foot high output T12. It just seems unusual EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064124 1 because most T12 systems, the overwhelming majority of 2 them, are used on magnetic systems only. with very few 3 of them being used in electronic. T8 is the other way, 4 where we recognize almost all T8 systems are run on 5 electronic ballasts, but almost all T12 systems are run 6 on magnetic ballasts because the driver there typically 7 is lowest first cost. 8 So in the contractor market, the contractor 9 either goes for the lowest first cost, which is T12 10 magnetic, or they go for most energy savings, which is 11 T8 and electronic. The middle market almost doesn't 12 i

ex st. 13 So the baseline, especially the one where you 14 only include the electronic on eight-foot high output, 15 it just seems not like a typical system, so an unusual 16 system. Do you know why magnetic was not considered 17 there? 18 MR. O'ROURKE: I'll let Mimi comment on that. 19 MS. GUPTA: Mimi Gupta. The reason why we 20 used for high outputs only electronic T12 systems is 21 because shipments from the 2000 ballast rule indicated 22 that most high output ballast shipments were 23 electronic. 24 MR. HOWLEY: For the new. But the vast 25 majority of the installed base is magnetic. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064125 1 MR. BROOKMAN: Mike Rivest. 2 MR. RIVEST: The LCC, what it's doing is it's 3 comparing the situation where there's no standards to 4 one where there is standards. So although the 5 installed base might be magnetic, the presumption is 6 that -- am I saying -- is this correct? 7 MS. GUPTA: (Off mic.) 8 MR. RIVEST: But we're talking about the LCC 9 here. 10 MR. BROOKMAN: Repeat that for the record, 11 please. Mimi, get up here. Say what the presumption 12 is again, please, Mimi? 13 MR. RIVEST: We're reacting to which? 14 MS. GUPTA: Right. So for four-foot medium 15 bi-pin and eight-foot single-pin slimline lamps, we 16 assume that the installed base is magnetic for T12 17 lamps and that purchases will be electronic. For HO 18 lamps, given the information from the 2000 ballast 19 rule, we assumed that the installed base of high 20 outputs were electronic. 21 MR. HOWLEY: That would be incorrect. 22 MS. GUPTA: Okay. All right. So if you have 23 any information about, like, the markets you have 24 magnetic and electronic in the high output market -- 25 MR. HOWLEY: Well, for years the T8 high EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064126 1 output was only sold on magnetic. The electronic came 2 in relatively recently in that particular product 3 category. Probably within the last five years or so. 4 But the vast majority of those products, baseline would 5 be electromagnetic. 6 MR. BROOKMAN: Please. Come to the 7 microphone and say your name for the record, please. 8 DOE welcomes any additional data here. 9 MS. ANDERSON: Susan Anderson with Osram 10 Sylvania. The other point is that one of the big 11 exceptions in the ballast rule is for the magnetic 12 minus 20 degree HO ballast, which is a very large 13 application for T12 HO lamps. So you're going to 14 continue to see those sold. Even new shipments will be 15 magnetic. 16 MR. BROOKMAN: I see. So, going back to you, 17 could you hazard a guess about how much of the 18 installed base is magnetic? 19 MS. ANDERSON: Ninety-nine. 20 MR. BROOKMAN: Ninety-nine? 21 MR. HOWLEY: A very high percentage would be 22 magnetic. 23 PARTICIPANT: It's only been in the last 24 couple years we even had an electronic T12 ballast. 25 MR. BROOKMAN: Okay. So thanks for that -- EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064127 1 thanks to all of you for that data. Gary. 2 MR. FERNSTROM: So, Gary Fernstrom, PG&E. 3 I'd just like to ask whether this is a marginal 4 analysis or an average or embedded analysis. You know, 5 for sure Joe is right, the majority of equipment out 6 there is magnetic now, but are we looking at the 7 embedded or should we be looking at current shipments. 8 MR. BROOKMAN: Yeah, yeah. 9 MR. HOWLEY: I think the rulemaking, though, 10 that she's pointing to didn't include a basic ballast 11 type because for whatever reason that rulemaking had 12 that product exempted. So it sounds like that 13 rulemaking simply missed or did not have that included. 14 So that's why you missed that entire product category. 15 MR. BROOKMAN: I'm not sure you heard Gary's 16 last question, which was about whether this analysis 17 should focus on the installed base or prospective 18 sales. 19 MS. GUPTA: I think we're looking at both 20 here. The national impact analysis is very dependent 21 on the installed base, and the LCC analysis is more 22 dependent on sales. But to some extent, it's dependent 23 on the systems that are installed right now because 24 when examining a lamp replacement, you have to take 25 into account what ballasts exist at that time. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064128 1 MR. BROOKMAN: Mike Rivest. 2 MR. RIVEST: I guess the one missing piece of 3 information for me is, is the magnetic ballast for 4 those systems going to be sold after the standard is in 5 place? They continue to exist. 6 MR. BROOKMAN: Pam, go ahead. 7 MS. HORNER: 2011. Isn't that the last year? 8 MS. ANDERSON: Yes, but -- 9 MS. HORNER: For replacement. 10 MR. BROOKMAN: So, 2011, and then to -- is it 11 Susan? 12 MS. ANDERSON: But one of the exceptions to 13 the ballast rule is the minus 20 degree magnetic 14 ballast for T12 HO. That's one of the largest markets 15 for T12 HO. So magnetic ballasts will continue to be 16 sold. 17 MS. HORNER: In that category. 18 MR. RIVEST: Okay. So there should be two 19 baselines. 20 MR. BROOKMAN: Yes, please. Pam. 21 MS. HORNER: Pam Horner, NEMA. Since we're 22 talking about electronic versus magnetic and this 23 slide, I think you would be well served to -- do you 24 see under four-foot, which is the first bullet. Under 25 that is baseline. And then what you have is T12 EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064129 1 systems, magnetic ballast or an electronic ballast. 2 Could you -- how can you have -- is that two baselines? 3 Because, again, taking the consideration we're talking 4 about that you're going to do installed base, 5 personally I can't even imagine a four-foot electronic 6 T12 being anything. 7 MR. BROOKMAN: Mimi. 8 MS. GUPTA: I think the answer to a lot of 9 these questions will become clearer when we talk about 10 the life-cycle cost analysis. The idea is that we have 11 one T12 -- for each baseline T12 lamp we might consider 12 the purchase of a new electronic ballast for new 13 construction. 14 I mean, I think these questions will become 15 more clear when we talk about how we structured the LCC 16 analysis, but we recognize in our analysis that most 17 T12 systems do have a magnetic ballast associated with 18 them. 19 MR. BROOKMAN: Do you recognize their 20 assertion that it's very, very small? One percent is, 21 I believe, what they said. 22 MS. GUPTA: Yeah. I mean, that's -- 23 MR. BROOKMAN: Okay. 24 MS. GUPTA: We definitely recognize that for 25 four-foot and eight-foot slimline in the analysis right EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064130 1 now, and we appreciate your comments regarding the high 2 output. 3 MR. BROOKMAN: Let's get any other comments 4 on this and then we'll hold off on the larger question 5 until we get to life-cycle cost. Go ahead. Then I'm 6 coming back to you. 7 MR. WALITSKY: Paul Walitsky, Industrial 8 Ecology. I just wanted to raise one issue on the 9 ballast. The voltage, 120 versus 277. Because there's 10 a difference in the efficiency on a universal ballast 11 that will cover 120 to 277 versus the individual. I 12 don't know what you took -- I presume you used 120 13 voltage, but I don't know. I think that would be worth 14 looking at as well. 15 MR. BROOKMAN: Do you know that? 16 MR. O'ROURKE: I'm not sure for this rule 17 here. I know that in an unrelated rule on ballasts 18 that is being taken into account. But for this I think 19 -- I'm not sure if there was a specific 120 or only 20 277. It might have just been selecting particular 21 systems in that case. But, thank you for that comment. 22 MR. BROOKMAN: Okay. Keith, go ahead. 23 MR. COOK: Keith Cook, Philips. Could we go 24 back to Slide 24 for just a second? I guess one 25 question I've got here is the baseline that was chosen EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064131 1 was always the minimum CRI for each class and it was 2 also the minimum lumens per watt for each class. So, 3 as a result, aren't we going to be led a little bit 4 astray from the fact that those are probably also the 5 lowest cost? And so when we look at total payback it 6 will be the most favorable when we do the comparison? 7 MR. O'ROURKE: Again, Mimi will be talking 8 about that when she does the LCC, but we're starting 9 out where the bottom of -- the lowest-performing 10 products are today. I mean, there already is an 11 existing energy standard in place that's even lower 12 than that. We're raising that bar up to where the 13 bottom of what's on the market today is and then seeing 14 how high above that you can go. 15 But the economic impact will be taken into 16 account, whether how much more expensive it is or that 17 you need to switch ballasts. That is taken into 18 account in the LCC, and she will go through that. 19 MR. BROOKMAN: Mike Rivest and then back to 20 Steve. 21 MR. RIVEST: What you said is correct. In 22 the LCC, we calculate the full life-cycle cost of every 23 lamp. So everything is referenced back to the least 24 efficient lamp when you look at the results. If you 25 want to compare, say, Lamp Number 5 with Lamp Number 4, EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064132 1 you would subtract the LCC of Lamp Number 5 from Lamp 2 Number 4. 3 If we had perfect information, we would know 4 the distribution of sales by efficacy, and then we 5 could provide you with the LCC for the distribution of 6 lamps is this much, for the whole class. But we don't 7 -- we barely have data separating out the 700 and 800 8 series. We certainly don't have data that would break 9 down 700 series into subgroups like that. 10 MR. BROOKMAN: Steve Nadel. 11 MR. RIVEST: In the national energy savings 12 model, however, we have a full matrix which we've 13 populated with assumptions about the market share of 14 each lamp-ballast combination and we calculate the full 15 energy savings over time based on that. When we talk 16 about it later, that's critical data that we need to 17 calculate the energy savings. So we'd be looking for 18 some guidance as to, you know, what weights to put onto 19 each of those ballast-lamp combinations. 20 MR. BROOKMAN: Steve Nadel. 21 MR. NADEL: Mike just said most of what I was 22 going to say. The national energy saving economic 23 analysis is critical. So if one combination has only a 24 one percent market share, it will only get a one 25 percent weighting and the more common ones will EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064133 1 dominate. 2 MR. BROOKMAN: Andrew, yes. 3 MR. DELASKI: Yeah. Mike, I wonder if you 4 could circle back to, then, you discussed about what 5 the baseline -- how it differs as you consider it for 6 the NIA and for the LCC. But then, what then -- if you 7 come back to the slide in front of us, which is -- in 8 front of me is Slide 28. 9 MR. O'ROURKE: Do you want to go to 28? 10 MR. RIVEST: Yeah. 11 MR. DELASKI: What are you trying to capture 12 with the baseline in this slide? What is the baseline 13 you're trying to show in the engineering analysis? 14 MR. RIVEST: All right. In the engineering 15 and the LCC what we're trying to determine is, in the 16 absence of a standard, what are the possibilities of 17 technologies that a consumer would select. Now, the 18 truth is -- and Mimi corrected me. I had my head on 19 wrong -- the ballasts are in place in 2012, the first 20 year of the standard. Therefore there are both people 21 with magnetic ballasts and some minute amount of people 22 with electronic T12s. 23 We're capturing the impacts on both of those 24 scenarios. So we call them both baselines because 25 that's a starting point for some people. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064134 1 MR. DELASKI: It's a stock baseline. 2 MR. RIVEST: It's a stock for ballasts, but 3 sales of the lamps are still feeding a certain ballast 4 which is in the stock. So that's where I was myself 5 getting confused. 6 MR. BROOKMAN: Mimi. 7 MS. GUPTA: Yeah, Mimi Gupta. So the 8 magnetic ballast represents a stock baseline for T12s. 9 The electronic ballast represents a shipment baseline 10 for T12s. 11 So if you were wanting to look at what are 12 the economic impacts of just replacing a lamp on an 13 existing system, then you assume that system has a 14 magnetic ballast. If you wanted to look at the impacts 15 of buying a whole new system, then you would assume 16 that that person would have bought an electronic system 17 because they can't buy a magnetic ballast anymore. 18 Does that make it at all clear? 19 20 21 22 because --MR. DELASKI: (Off mic.) MS. GUPTA: Excuse me? PARTICIPANT: No, they're not right now,

23 MS. GUPTA: But in 2012, because of the 24 ballast rulemaking, magnetic ballasts for four-foot 25 medium bi-pins won't be available. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064135 1 MR. BROOKMAN: Joe, go ahead. Joe, go. 2 MR. HOWLEY: Except one exception. The high 3 output magnetic ballasts. Again, kind of what we 4 missed here. They only regulated that from a low 5 baseline, basically an aluminum wire electromagnetic, 6 up to a high efficiency electromagnetic. So in that 7 case, that ballast will actually continue to exist, 8 which is why it's such a glaring missing component 9 here. 10 MR. RIVEST: We're with you on that one. 11 MR. BROOKMAN: Have we resolved this? I 12 think so. Okay. So, keep going. 13 MR. O'ROURKE: On Slide 30, we're showing a 14 table at least of the proposed candidate standard 15 levels, as to the columns there on the left, and 16 showing the associated efficacies with each candidate 17 standard level. There's also columns for the different 18 lamp types of T12, the 40-watt T12, the 34-watt T12, 19 and the 32-watt T8. 20 These would be the two baseline levels for 21 the T12s, the first row. And down here at the 700 22 series for Candidate Standard Level 2, that would be 23 the lowest candidate standard level baseline for the T8 24 system. 25 As I mentioned before this slide was that at EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064136 1 Candidate Standard Level 4 and 5 you start having that 2 only T8s can meet those higher candidate standard 3 levels. 4 As you progress down a given slide for a 5 given lamp type, you see the overall improvements are 6 happening through better phosphors but also other 7 improvements to the lamp that could gain those higher 8 efficacies with given phosphors. So we've named them: 9 the 700 series, improved 700 series; 800 series and 10 improved 800 series. 11 Any questions on this table? 12 (No response.) 13 MR. O'ROURKE: Okay. Thank you. So we're 14 going to start now talking about how these relate to 15 each one of the categories. Here is a four-foot medium 16 bi-pin, again showing a similar graph to what I showed 17 you before with the arrows on it, the yellow and green 18 arrows. 19 For now, we're showing where -- start off 20 with where the baselines are again for the 40-watt T12, 21 the 34-watt T12, and over to the 32-watt T8. The red 22 lines drawn here are showing the different candidate 23 standard levels. So CSL 1 is a little over 82, CSL 2 24 is about 85 lumens per watt, and up to 90 lumens per 25 watt for CSL 3, and a little above 92 for CSL 4, and EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064137 1 lastly, CSL 5 at a little over 95. 2 As you get up to these higher, the CSL 4 and 3 5, there are no longer any T12 lamps that would be able 4 to have a high enough efficacy to meet those 5 requirements. Questions? 6 MR. BROCKMAN: Keith. 7 MR. COOK: Keith Cook. When you established 8 these candidate standard levels, were these supposed to 9 be minimum values or nominal values? 10 MR. O'ROURKE: These were minimum, to be 11 within a given candidate standard level. 12 MR. COOK: That may end up being a problem 13 because it's based upon nominal value products, so. 14 MR. O'ROURKE: Yes. 15 MR. BROCKMAN: Mimi. 16 MS. GUPTA: I'm not sure if I totally 17 understand your question, but the candidate standard 18 levels were based on rated lamp efficacies, not the 19 nominal lamp efficacy. Is that what you were referring 20 to? 21 MR. O'ROURKE: The comment is the rating is 22 not a precise number. It has some tolerance about that 23 number, and some of those same -- 24 MR. COOK: Manufacturing tolerances that make 25 it a plus or minus, and typically those are -- EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064138 1 MR. BROOKMAN: Steve Nadel. 2 MR. NADEL: Yeah. Did DOE get data on actual 3 lumens per watt as opposed to just doing the 4 calculations from a catalogue? As I remember when we 5 first developed the EPACT '92 standards, we did get 6 some data and we looked at actual product rather than 7 just assuming it's all 48 or 34 or whatever. 8 MR. O'ROURKE: This is based on catalogue 9 data. The only exception is the wattages, where 10 appropriate, we're using the ANSI wattages of the lamp, 11 not the rated watts. For example, the 32-watt T8 ANSI 12 wattage is 32.5 watts. So we used the wattages for the 13 appropriate lamps that were listed in ANSI. 14 MR. BROOKMAN: Can you say generally how much 15 the variance is? 16 MR. COOK: It depends upon what the 17 particular criteria is. It varies. Probably by 18 manufacturer, too, because depending upon the processes 19 used in manufacturing itself. 20 MR. BROOKMAN: That was Keith. Yes, Joe. 21 MR. HOWLEY: Just to note here, there were 22 reporting requirements for the 1992 law. So there is 23 actual test reports on file with the DOE, and it may be 24 good to look at some of the actual reported data versus 25 the nominal or catalogue-rated data to get an idea if EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064139 1 these are practical or not based on the actual testing 2 of those lamps. 3 MR. BROOKMAN: Thank you. Thanks for that. 4 Tom Eckman. 5 MR. ECKMAN: Tom Eckman, Northwest Power and 6 Conservation Council. Since the analysis is an 7 incremental analysis, the real question is whether or 8 not there's a bias as you go up, whether the tolerance 9 band changes as you go up at each of these increments, 10 because you're looking at the prices of those and 11 whether or not this is a good representative of the 12 mean of each of those increments. 13 MR. RIVEST: I don't think the incremental 14 aspect of the analysis would be affected, but it might 15 be a question of then setting the standard, and a 16 standard that would be representative of those lamp 17 series. 18 MR. ECKMAN: I'm fine with going to the 19 tests. I think that's appropriate. But in terms of 20 whether there's a bias in this -- 21 MR. RIVEST: No, I don't think so. 22 MR. LEWIS: Doug. 23 MR. BROOKMAN: Yes, Ron Lewis. 24 MR. LEWIS: To Joe's point, in the reporting 25 by lamp manufacturers, I believe that in the EPACT '92 EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064140 1 there was a tolerance given that was allowable, that 2 you had to certify that you were within that tolerance. 3 And it was a rolling average over 12 years of 4 production or something. 5 PARTICIPANT: Twelve months. 6 (Laughter.) 7 MR. LEWIS: The report said 12 years. 8 MR. BROOKMAN: Hoping for the best, right? 9 (Laughter.) 10 MR. LEWIS: But it was already defined as 11 what the allowable tolerance was there. I remember 12 there was a lot of discussion over what that should be 13 and what the manufacturing tolerances were and the 14 reality factor versus just a rated. So I think that's 15 already -- 16 MR. O'ROURKE: That's correct. 17 MR. LEWIS: -- described, what the allowable 18 manufacturing tolerance was. So maybe we can even take 19 that into account. If you've lived with that since 20 1992 and have been certifying to that, there's probably 21 a hard number there of what a meaningful tolerance is, 22 rather than going through every piece of data since 23 that time. 24 MR. O'ROURKE: Right. An additional comment 25 to that is that that data would only be for lamps that EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064141 1 would have been covered at that time. It's not going 2 to be covering the lamps at the upper end here because 3 those lamps were not covered products at the time. 4 MR. HOWLEY: Right. But it will give you 5 some sense of the lower end of where things are at. 6 MR. BROOKMAN: The last comment from Conan 7 and then back to Joe. Okay. So now, then, any 8 additional comments? We're still on 31, as I recall. 9 (No response.) 10 MR. O'ROURKE: Going on to the eight-foot, 11 single-pin, slimline candidate standard levels, again 12 showing Candidate Standard Levels 1 through 5, with 13 zero representing at least the baseline product for the 14 75-watt system. The baseline for the 60-watt system is 15 at Candidate Standard Level 1, and the baseline 59-watt 16 is at Candidate Standard Level 3. Once you get to 4 17 and 5, again, there's no T12 system that can meet the 18 higher efficacy for those candidate standard levels. 19 The columns again show the progression of the 20 technology or design options to get those higher 21 efficacies. 22 Any questions on Slide 32? 23 (No response.) 24 MR. O'ROURKE: So the associated graph that25 goes with that, similar to the previous one for fourEXECUTIVE COURT REPORTERS, INC.

(301) 565-0064142 1 foot. You see the baselines for the 75-watt T12, then 2 the 60-watt T12, and the 59-watt T8. There's not as 3 much product available in these categories, so there's 4 a lot less dots to plot here. But there are some lower 5 wattage options at 59-watt -- at 57 watts as well. 6 Any comments on this slide? 7 (No response.) 8 MR. O'ROURKE: Okay. Continuing on to the 9 eight-foot, recessed, double-contact. This is, again, 10 covering the 110-watt T12 and the 95-watt T12. We're 11 not including a baseline lamp for the T8, but it is 12 included in the analysis. It's being included in the 13 analysis for the higher candidate standard level cases. 14 At Candidate Standard Level 2, at about 86 15 lumens per watt, the 110-watt lamp starts to fall out, 16 and at Candidate Standard Level 4 the 95-watt T12 lamp 17 falls out. 18 Any questions on this table? 19 (No response.) 20 MR. O'ROURKE: Okay. Lastly, the slide that 21 goes along with that showing the candidate standard 22 levels and the products, at least we found in the 23 catalogue. We didn't find any energy-saving versions 24 of the T8, so they're all within the same -- to take 25 advantage of those wattages, you'd have to use lower EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064143 1 ballast factor ballasts to maintain light output. And, 2 you have the 95 as energy-saving to the 110. 3 Okay. So, an example of what the -- did you 4 have a question, Mike? Okay. Going on to the next 5 slide, showing the systems results, we're taking -- 6 I've showed you the candidate standard levels for 7 lamps. I've described how we're going to take those 8 information for lamps and combine it with different 9 ballasts to create systems. This is just showing an 10 example of some of the results. 11 As Mimi mentioned, one scenario we're looking 12 at is if it's just a lamp replacement only. If you're 13 going, say, from a baseline product here to something 14 that has a higher efficacy -- so you take the 40-watt 15 T12 in the first row and you replace it on the same 16 system, same ballast, with a 34-watt, what is the 17 overall result. You can see that efficacy of the rated 18 lamp goes from 80 to 91.2. 19 Using -- actually, in this case we are using 20 a lowest ballast factor ballast, and we're looking at 21 the overall system mean lumens. Trying to keep them 22 approximate. There wasn't an attempt here to make them 23 identical. They're trying to stay within roughly 10 24 percent of what the baseline condition is. 25 Also, showing the other conditions. Here's a EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064144 1 T8 system and its baseline. You would be able to look 2 at changing to other technologies and seeing how 3 efficacy is impacted as well as different systems that 4 may be used. In this case, these are electronic 5 systems that could be compared to any of these 6 baselines to look at incremental change and the overall 7 impact on what the system mean light output would be 8 based on using those systems. 9 Any questions on this example? 10 (No response.) 11 MR. O'ROURKE: I see some looks. I just want 12 to make sure. Okay. Yes? 13 MR. HARRIS: Jeff Harris of Alliance. Within 14 what range do you consider the light output to be 15 equivalent? 16 MR. O'ROURKE: We were trying to keep them 17 within about 10 percent of what the baseline system 18 would provide. 19 Okay. So now we're looking for comments on 20 the selection of lamp ballast designs for the baseline 21 to max tech as well as the selection of the general 22 service fluorescent lamp candidate standard levels. 23 MR. BROOKMAN: So the relevant feature here 24 being the baseline to max tech, or at least that being 25 one relevant feature. Please, Pam. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064145 1 MS. HORNER: Pam Horner, NEMA Lamp Section. 2 We'd like to make a comment to give you a little bit of 3 insight into a manufacturer's mind and how we look at 4 the candidate standard levels, which is a bit -- it's 5 in addition to the energy savings potentials. I think 6 you can appreciate that we also have begun to look at 7 these in terms of what products would no longer qualify 8 and which products would remain in the market. 9 So for the record, and for your 10 entertainment, I thought it would be interesting for 11 you for me to give a very brief summary of those 12 products. It won't take long, but it will then maybe 13 make sense as to what we have to say about that. 14 So the proposed CSL 1 for fluorescent, which 15 right now is numbers. Our analysis shows that this 16 would eliminate halophosphor T12s. Think about this as 17 manufacturing also, okay, because we have to do that. 18 That's what we're paid to do here, right, today? While 19 continuing to allow 34-watt T12 700 series -- that's 20 your energy-saver type -- and your 40-watt T12 7- and 21 800 series. So there would be some T12s in the market 22 and all T8 would comply. 23 MR. BROOKMAN: Do you want to follow on 24 briefly? Use the microphone. 25 MS. GUPTA: Could you go to Slide 30, Conan? EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064146 1 MR. RIVEST: Actually, could you go to the 2 slide with the bars? 3 MS. HORNER: Don't you think that's hard to 4 read? 5 MR. RIVEST: Okay. Well, the other one. 6 (Laughter.) 7 MS. GUPTA: This is what, I guess, you would 8 be validating -- 9 MS. HORNER: Those are design options. Pam 10 Horner again. If a design option is what I'm 11 describing now, then -- I don't think so. 12 MR. NADEL: I think they are the same, but 13 you should check Candidate Standard Level 3 or 14 something just to make sure it pretty much includes -- 15 MS. HORNER: For example, Candidate Standard 16 3. What we see is that it would allow the 34-watt and 17 40-watt T12 enhanced 800. It's not just the 800. 18 MR. O'ROURKE: What we call "improved." 19 MS. HORNER: Yeah. Okay. And as we move 20 along, then we'd have -- at 4 we would eliminate T12. 21 Okay. And at 5, all we'd be left with in the market 22 would be 32-watt, 28-watt, and 25-watt highly improved 23 800 series. Does that correspond? 24 MR. O'ROURKE: Yeah. 25 MS. HORNER: Okay. So what our mindset is, EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064147 1 is that we would not only look at is this good for 2 energy savings but how do manufacturers change what 3 they do for a living, change over the lines, et cetera. 4 So you will know that our comments are going to have 5 to include what the impact upon us would be. We're not 6 ready today to say what that will be, but it certainly 7 will be in our written comments. 8 The other issue is that we need a little bit 9 of time to understand how -- if these are a reasonable 10 fit with the timing of the ballast rule. So, in other 11 words, as an example, if people are still allowed to 12 buy ballasts December 31st, 2010, or sometime in 2011, 13 that are magnetic for use, say, in their homes for T12 14 type lamps, in our minds is it reasonable to expect 15 that they should have some life out of those. 16 In other words, is it incumbent upon us as 17 lamp manufacturers to be able to provide lamps to them 18 for their newly purchased ballasts. To me, that's a -- 19 I don't know how you can characterize that solely as a 20 number. You know, what is the obligation of an 21 industry like ours to be able to continue to provide 22 lamps. 23 I'm not saying we are saying together, oh, 24 let's pick Number 3. But those are the sorts of things 25 that run through a manufacturer's mind beyond the EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064148 1 numbers, so I wanted to express that. 2 MR. BROOKMAN: Okay. Thank you. Thanks for 3 that illustration. Joe, please. 4 MR. HOWLEY: Joe. Also, I just wanted to 5 comment that within the efficacy numbers I think our 6 technical people are still looking at these numbers 7 based on actual test data to see if those indeed would 8 be the numbers we would suggest. We understand what 9 the objective is. We see that in the design options 10 for each ballast. But I know that we're looking at 11 those objectives versus those numbers and may have some 12 further comments on whether or not we feel those 13 numbers are the right numbers to hit those objectives. 14 So perhaps we'll have further clarifying 15 information in our written comments as well on that. 16 MR. BROOKMAN: Thank you. Okay. So, Conan, 17 take us back to where we were. 18 MR. O'ROURKE: On Slide 37? 19 MR. BROOKMAN: Yes. 20 MR. O'ROURKE: Any more -- 21 MR. BROOKMAN: So, final comments before we 22 move on to Slide 38? 23 (No response.) 24 MR. BROOKMAN: Okay. 25 MR. O'ROURKE: In Slide 38, we're now looking EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064149 1 at scaling to the other product classes that weren't 2 directly analyzed. So, looking at scaling from less 3 than 4,500 up to above 4,500, we looked at the products 4 that were on the market and we looked at the 6,500 K 5 and saw that they were approximately four to seven 6 percent lower than the 4,100 K. 7 So to avoid overly penalizing the current 8 products offered on the market, we considered adopting 9 the larger of the two scales as how much it could be 10 reduced by to seven percent. For example, if the 11 requirement was 82.4 lumens per watt for the four-foot 12 medium bi-pin of less than 4,500, if we picked one that 13 was greater than the requirement, it would be 76.6 14 lumens per watt. 15 Scaling to the other product classes for the 16 two-foot U-shaped lamp, we looked again at -- these are 17 ones less than 4,500. The efficacy differentials were 18 approximately three to six percent. Again, the similar 19 fashion of looking at the range. We used a maximum 20 allowed to six percent to do the scaling for these 21 products. 22 So the Department invites comments on these 23 methods used to scale products for above 4,500 and also 24 for the U-shaped. 25 MR. BROOKMAN: Steve Nadel. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064150 1 MR. NADEL: I was just curious if anybody, 2 either DOE or the manufacturers, have rough data on how 3 large a share of the market U-shaped are. Are they 4 pretty small these days? 5 MR. HOWLEY: Relatively. 6 MR. NADEL: I know they were big in the '90s, 7 but I haven't seen them that much since then. 8 MR. BROOKMAN: Joe. 9 MR. HOWLEY: This is Joe Howley. There's 10 been less and less use of the U shape. People seem to 11 be going more towards, if they want a two-by-two 12 fixture, even a two-foot T8 versus the U lamp. So 13 we're seeing that kind of fall out of favor somewhat. 14 Or what we call the high-lumen bi-ax. There's other 15 names as well. 16 (Laughter.) 17 MR. BROOKMAN: Thank you. So then, 18 additional comments on scaling? 19 (No response.) 20 MR. O'ROURKE: All righty. Moving on from 21 fluorescent to incandescent reflector lamps, going back 22 to baseline models, the Department has identified three 23 common lumen packages that represent the typical lamps 24 on the market for the standard spectrum incandescent 25 reflector lamps. These lamps are currently regulated EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064151 1 and would meet the requirements of the EPCA standard. 2 We're showing here on the table PAR 30s and 3 PAR 38 halogen lamps at 50, 75, and 90 watts with these 4 appropriate efficacies, 11.6, 14.0, and 14.6, and these 5 initial light outputs of 580, 1,050, and 1,310, and 6 associated lifetimes for those lamps. 7 Looking at substitutes for those lamps, the 8 Department chose substitutes to save energy and achieve 9 similar light output by increasing either the efficacy 10 or using a reduced wattage option. For example, using 11 a 50-watt -- looking at a 44-watt replacement to a 50- 12 watt lamp. 13 Wherever we could, we used commercially 14 available information, and in some cases we weren't 15 able to. We used modeling to help identify what those 16 would be. 17 And the ones that we -- the three basic 18 design options associated with the commercially 19 available ones were improved halogen, halogen infrared, 20 and improved halogen infrared. Those different 21 technologies also had the implication on lifetime of 22 3,000 hours or 4,000 hours. 23 The improved halogen and improved halogen IR 24 could be achieved using higher efficiency filaments, 25 filament coiling, filament configuration, capsule EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064152 1 design, higher pressure, or higher efficient reflector 2 coating. 3 As I mentioned for modeling, we used 4 commercially available lamps wherever we could but when 5 we couldn't we -- based on manufacturer's interviews 6 and technical literature, we -- used to develop models. 7 The model lamps that we used were these particular 8 ones of 14 lumens per watt, which would give you 44.3 9 watts for PAR 30. That would be a reduced wattage 10 equivalent of a 50-watt lamp. A 15 lumens-per-watt PAR 11 30, which could also be compared to the 50-watt lamp, 12 and a 66-watt, 19.8 lumens-per-watt PAR 38, which would 13 be a reduced wattage of a 90-watt. 14 So, looking at this graph, we're seeing 15 different lamp powers and we're seeing the different 16 baselines of the PAR 30 50-watt, PAR 38 75-watt, and 17 the PAR 38 90-watt. We're seeing that as you increase 18 the efficacies, then we have a shift in lower wattages 19 for those given technologies. 20 So the Department would invite comment on the 21 selection of the IRL designs from the baseline to the 22 max tech. 23 MR. BROOKMAN: Pam. 24 MS. HORNER: Pam Horner, NEMA Lamp Section. 25 Regarding the baseline, let me get this straight. For EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064153 this category you have selected a halogen lamp -- 2 MS. GUPTA: Yes. 3 MS. HORNER: -- as the baseline, not the BR30 4 or the BR40, even though the installed base and the 5 exemptions for those remain in place. 6 MR. BROOKMAN: Would you offer a different 7 rationale for -- would you say more about -- 8 MS. HORNER: I will get to that when he asks 9 the next question. I just wanted to make certain. I'm 10 building. Just as you are building your case, Conan, I 11 am building my rebuttal. 12 (Laughter.) 13 MS. HORNER: So I have understood that 14 correctly. 15 16 17 MR. BROOKMAN: Mimi. (Laughter.) MR. FERNSTROM: Pam, this is Gary from PG&E. 18 It's kind of hard to get this straight because that's 19 a curved lineup there. 20 MS. HORNER: I think that was a joke. 21 (Laughter.) 22 MS. GUPTA: Yes. We choose the halogen 23 technology as our baseline because even though EISA 24 2007 brought in BR and ER lamps, those will have to 25 meet the standard by the time 2012 comes around. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064154 1 MS. HORNER: Except for the exempted types. 2 MS. GUPTA: Except for the exempted types, 3 which this rulemaking doesn't cover, either. 4 MR. BROOKMAN: That's the key point, right? 5 MS. GUPTA: Right. Any incandescent 6 technology IRLS this rulemaking does not cover. 7 MS. HORNER: Oh, I understand that. 8 MR. BROOKMAN: Do you want to let -- do you 9 want to keep going or do you want to let -- 10 MS. HORNER: Yes, I have one more sentence. 11 MR. BROOKMAN: Keep going. No, we want you 12 to develop fully your -- 13 MS. HORNER: Yes. 14 MR. BROOKMAN: -- your rebuttal. 15 MS. HORNER: So the other sentence, then, is 16 that in that case, another -- shall I just put it this 17 way. Another way of looking at this is that since the 18 BR conundrum has entered and exited, and entered and 19 exited our lives throughout the world since 1992, it 20 would appear that BR has been cast aside to a safe 21 haven and now the DOE is looking at what they consider 22 to be remaining, and then from that remaining group has 23 selected something which they are considering a 24 baseline above which they would like to raise the bar. 25 Do I have that correct? EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064155

2 3 MR. RIVEST: Yes. MR. BROOKMAN: Mike Rivest. Yes. MS. HORNER: Fine. Then, when you come to 4 your next set of questions, I will comment. Thank you. 5 MR. BROOKMAN: Steve Nadel. 6 MR. NADEL: Just anticipating -- 7 MR. BROOKMAN: Wait a second. The suspense 8 is building here. 9 (Laughter.) 10 MR. BROOKMAN: Keep going, Steve. 11 MR. NADEL: Right. 12 MR. BROOKMAN: Anticipating, you said. 13 MR. NADEL: Because this rulemaking is not 14 looking at the 65 BRs, they're looking at alternatives 15 to those, but as I recall from reading the ANOPR, in 16 the national energy-saving model they do consider how 17 people will switch from these products to BRs. So 18 that's the place where I believe the case you're trying 19 to make may play out. 20 MR. BROOKMAN: Anticipating as you might. 21 MR. NADEL: Foreshadowing. 22 MR. BROOKMAN: There you go. Okay. So then, 23 back to you, Conan, if I'm not mistaken. 24 MR. O'ROURKE: No more comments on this? 25 We'll go now to discuss what the candidate standard EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064156 1 levels would look like for those products. 2 This was basically used to develop a 3 continuous equation to set the minimum efficacies 4 across these wattages. And the equations are shown in 5 this table for CSL 1. It's basically parallel varying 6 the constant in front of each one of them as you go to 7 the higher and higher candidate standard levels. They 8 would represent the design options, going from improved 9 halogen, to halogen IR, to improved halogen IR. 10 So here, Pam, to show where you were asking 11 about, where the baselines are representative to the 12 existing EPCA requirement today and where they fall 13 relative to those, and showing what the new CSLs would 14 -- CSL 1 and CSL 2 and CSL 3 for each of those 15 different design options. 16 So, the Department invites comments on 17 whether the IRL candidate standard levels represent the 18 appropriate technology across all wattages. 19 MR. BROOKMAN: Pam. 20 MS. HORNER: You anticipated. Pam Horner, 21 NEMA. So, first of all, regarding the formulas, again 22 we like the smoothing. That's a very good idea. And 23 not using a step function. But we would like to 24 comment, and will certainly comment in writing even 25 more, about these models. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064157 1 The lamp upon which CSL 1 is based -- did 2 everyone hear that? 3 (Laughter.) 4 MS. HORNER: -- shows a strong resemblance to 5 a known silver-coated PAR 38 halogen reflector lamp for 6 which only one company holds the patent, and the lamp 7 manufacturer that holds that patent is a NEMA member 8 and does approve of my going onward with this comment. 9 If this is the case, which we believe it is 10 because we do have the catalogue sheet upon which all 11 of these curves were based, then it would be, shall we 12 say, problematic for any other manufacturer to meet 13 that level. Since silver is the most efficient 14 reflector, no other materials can achieve this 15 reflectivity to our knowledge. So the one manufacturer 16 that is holding the patent has held the high ground. 17 So to establish a level that is an attempt to 18 improve the efficacy above a "standard" PAR 38 halogen 19 lamp has just made a one-manufacturer world. You may 20 not have known that. 21 CSL 2, which is based upon IR-coated halogen 22 capsules, appears to correspond very, very well with 23 products from many manufacturers in the market. One 24 could consider CSL 2 to be a level playing field. 25 There are other arguments against it, but it does have EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064158 1 that. 2 Now when you move to CSL 3, the same patent 3 issue applies because the improved reflector material 4 which has been used to create these formulas and those 5 lines is the silver-coated reflector. 6 The other comment that we would like to make 7 regarding these formulas regards something that you 8 have not included in your analyses, and that is lamp 9 diameter. The LPW formulas appear to apply to all 10 covered lamp diameters because there is nothing that 11 says otherwise. With the enactment of EISA, as we 12 discussed this morning, PAR 20 lamps are now covered. 13 We just established that the 40-watt through 205-watt 14 range is what is covered. 15 PAR 20 lamp optical systems are less 16 efficient than those of PAR 30 and PAR 38 by a 17 significant percentage. It's simply a matter of 18 geometry and size. 19 In our written comments we're going to 20 recommend that some percent reduction factor be applied 21 to these CSLs in order to account for that difference. 22 We have something in mind but have not settled on such 23 a percentage. 24 The other point I would like to make is that 25 if that is not done, all 50-watt PAR 20 lamps have just EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064159 1 been wiped out. 2 MR. BROOKMAN: Ron Lewis. 3 MR. LEWIS: If I could move us back to Slide 4 41. 5 MR. BROOKMAN: Is this the CFL -- is this the 6 equivalent of CSI here. 7 (Laughter.) 8 MR. LEWIS: The last bullet point, where it's 9 stated that there are different ways of meeting the 10 improved halogen and improved HIR with design options. 11 From what you're saying, is for two of those there is 12 only one way to meet those? None of these other 13 factors are options, whether they're in play right now 14 or not? 15 MR. BROOKMAN: Yeah, Pam. Please. 16 (Laughter.) 17 MS. HORNER: I'm waiting for permission. 18 What we're saying is that the most effective way of 19 improving the efficacy, and in fact the very line 20 that's been chosen was based upon that particular 21 technology. To use gas to do it won't get there. To 22 use a different material other than silver won't get 23 there. 24 MR. BROOKMAN: Steve Nadel. 25 MR. NADEL: I'm just trying to read your EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064160 1 parsing. To use other materials and the gas, will it 2 get you there? 3 (Laughter.) 4 MR. BROOKMAN: The and/or. 5 MS. HORNER: I can't answer that today, but 6 very specifically, I can't tell you, you know, some 7 magic combination of xenon or whatever. But I told you 8 the problems with xenon right now. 9 There are other problems, which I'm going to 10 introduce later, with this having to do with lamp life, 11 et cetera. But I'm saving that for the after-break. 12 (Laughter.) 13 MS. HORNER: But according to -- now I'm -- 14 if I may switch, I'm switching hats. I'm not speaking 15 as a NEMA person. I'm speaking as an Osram Sylvania 16 person. 17 Our incandescent and halogen engineering 18 staff, which is a considerable sized group, has 19 indicated to us that because of this patent they cannot 20 make a lamp that violates that -- or, that doesn't 21 violate it, excuse me, and that they cannot reach it 22 with known technologies. 23 Now, of course you can jump to CSL 2, which 24 I've already explained. Now we're just talking 25 technologies, and I haven't mentioned anything about EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064161 1 whether or not we think that's a good idea. All I'm 2 saying is that the facts are that the HIR level is the 3 level playing field. Easy for me to say. 4 MR. BROOKMAN: Okay. Andrew Delaski. 5 MR. DELASKI: When does the patent expire, 6 Pam? 7 (Laughter.) 8 MS. HORNER: I have a copy of it, but I don't 9 -- no, and it's a process patent, so it's not just the 10 application of silver to the reflector but it's also a 11 coating that prevents the silver from oxidizing both 12 during the manufacturing process and during use. I 13 don't know the expiration date of the patent. 14 MR. BROOKMAN: Joe, did you have a comment? 15 MR. HOWLEY: Just make one comment. I just 16 wanted to make it clear that it is not that the 17 manufacturers are supporting CSL 2. I'm not sure how 18 you interpreted Pam's comments, but that is not what we 19 are saying. 20 In fact, I think it's critical that we 21 provide consumers with options. The HIR technology 22 when you apply it to PAR lamps gets fairly expensive. 23 Although it might make sense for a retail application, 24 it probably does not make a lot of sense for consumer 25 applications. I think it's critical that we allow EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064162 1 consumers to have a cost effective alternative to use 2 in their homes as well. 3 So I think there are issues with all three 4 approaches and that whole area may have to be 5 reconsidered in terms of the levels. 6 MR. BROOKMAN: Steve Nadel. 7 MR. NADEL: You mentioned consumer 8 applications. My understanding is the majority of 9 consumer applications are using the BR lamp and not 10 these other products. 11 MR. HOWLEY: Both are used. 12 MR. DELASKI: This is Andrew Delaski. The 13 Department, I think, has -- done a good job on the LCC. 14 Look at that -- we'll get to that later, but that's -- 15 the option for the consumer includes 65-watt BR. A 16 person who wants to go to Home Depot and buy a 12-pack 17 for 20 bucks, it's still there. 18 MS. HORNER: This is Pam. Which means that 19 the BR could have been used as a baseline. 20 MR. BROOKMAN: Additional comments on this 21 subject? 22 (No response.) 23 MR. BROOKMAN: Okay. We've covered it 24 sufficiently? I think so. 25 MR. O'ROURKE: All right. Moving on to EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064163 1 modified spectrum. Looking at trying to scale to 2 modified spectrum and coming from the standard spectrum 3 lamps, looking at the products on the market, you're 4 seeing roughly anywhere from two to almost 30 percent 5 reduction in efficacy. The average is about 15. 6 So the Department recognizes that this may 7 have some distinct utility, but we're looking for a way 8 to establish a standard that both does not eliminate 9 modified spectrum lamps, which require a low efficacy 10 standard because of their distinct utility, and 11 acknowledges the range of spectrum modifications 12 possible for these different IRLs and their 13 corresponding efficacies. 14 So I will say a -- 15 MR. BROOKMAN: It looks like Gary -- 16 MR. FERNSTROM: Gary Fernstrom, PG&E. Conan, 17 a question. We talked earlier in the day about the 18 definition of the modified spectrum lamp. I think Joe 19 and maybe some others said it. It had to filter out 20 yellow light or -- by a certain number of macadam 21 circles from the black body of the radiation curve. 22 Does that definition apply to this entire -- 23 to the 29 percent range so as to say that, you know, we 24 can do that much filtering for a two percent reduction 25 or the same amount for a 29 percent reduction? EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064164 1 MR. O'ROURKE: We didn't have all the special 2 power distributions for these products, so we're trying 3 to base it on what they were marketing the product as 4 and how it performed. 5 MR. FERNSTROM: Okay. So just to be clear, 6 these products were marketed, that you looked at, as 7 modified spectrum lamps and therefore must have met the 8 definition. 9 MR. O'ROURKE: Well, they didn't necessarily 10 meet the definition because they're not necessarily at 11 this point compared to a clear lamp of the same exact 12 type to be able to look at that. Because it has a 13 requirement in there about how far it has to be from a 14 clear lamp with all the same technologies. 15 So we didn't have a clear lamp to compare it 16 to to see if it met that requirement. We're just 17 saying if you had the modified spectrum, what's its 18 efficacy compared to the best thing we could compare it 19 to to say how much it changed. 20 MR. BROOKMAN: Joe, go ahead. 21 MR. HOWLEY: I'd just like to comment that in 22 this particular market space right now there has been 23 no real definition of what one of these is. You have 24 manufacturers all over the board in terms of how 25 they're marketing them. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064165 1 But it's clear to us that something that only 2 provides a 2 percent reduction of lumens is not -- 3 would never meet this kind of definition. It would 4 simply not be able to move the color point that far. 5 Somebody that just has an extremely light coating on a 6 lamp and it's a marketing game in that particular case, 7 that is not a product that would meet this definition. 8 Nor, in the marketing world today, there is 9 no definition. So you can market a lamp however you 10 want. But those lamps, although they may exist, would 11 not be able to meet that definition or exist under the 12 new regulations. 13 MR. FERNSTROM: Okay. Well, then I'm really 14 confused. Because if, in some respects, we're going to 15 exempt modified spectrum lamps or apply a different 16 standard to them, are we defining the extent to which 17 they modify the spectrum? Because if we don't, you 18 know, if you don't modify the spectrum very much, it 19 would be, you know, really easy to come in with what 20 appears to be a lamp that meets the requirements but is 21 pretty efficient. 22 MR. O'ROURKE: This is Conan again. One of 23 the requirements that they do to say how much they 24 change it is it has to be more than a four-step macadam 25 ellipse away from a clear lamp. So that's saying it EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064166 1 has to change by that much. If it was within that, it 2 would be not a standard spectrum lamp. 3 MR. FERNSTROM: Thank you. 4 MR. BROOKMAN: Okay. Tom Eckman. 5 MR. ECKMAN: This data doesn't presume that 6 that's the case, the low end of that. I mean, you have 7 no idea -- 8 MR. O'ROURKE: Correct. 9 MR. ECKMAN: -- two to 29 percent. You just 10 said -- 11 MR. O'ROURKE: Correct. 12 MR. ECKMAN: -- it's indicative of whatever 13 is in the marketplace today, not the ones that actually 14 pass that test. 15 MR. O'ROURKE: That's correct. 16 MR. ECKMAN: So, you know, it's at best a 17 guess whether this is representative of what would pass 18 that test. 19 MR. BROOKMAN: Please. 20 MR. WALITSKY: Paul Walitsky. And then 21 what's going to happen is your average is going to go 22 up. If you illuminate the lower range ones, your 23 average in reduction may go to 20. I'm guessing. But 24 it's not going to stay at 15, which is, just 25 conveniently, the average between 2 and 29. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064167 1 MR. HOWLEY: That is correct. I agree with 2 Paul. Once you take all of the poor-performing lamps 3 out, you'll find the reduction in lumens from the lamps 4 that legitimately pass that definition would be higher. 5 It would probably be somewhere between 15 and 29 6 percent in actuality, not between two and 29 percent. 7 MR. BROOKMAN: That was Joe speaking. Tom, 8 do you have a follow-on comment? 9 MR. ECKMAN: If the criteria is the forced 10 macadam shift, then we ought to be representing that in 11 whatever offset there is. So to the extent that there 12 is some empirical basis for that which is a specific 13 test, it seems to me the data on that ought to be 14 looked at rather than just the catalogue data that 15 doesn't necessarily represent that. 16 MR. BROOKMAN: So, are there other comments 17 related to the other elements on Slide 46? 18 (No response.) 19 MR. BROOKMAN: No? Okay. 20 MR. O'ROURKE: Slide 47 is the last slide on 21 this topic and talks about a possible way to scale to 22 modified spectrum based on the light output of the 23 modified spectrum and the equivalent referenced clear 24 lamp, if you will, standard spectrum lamp. 25 So the reference standard would be equivalent EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064168 1 to the modified spectrum, say, except for the neodymium 2 coating or other additive that caused the lamp to emit 3 that light. You would basically look at the ratio of 4 the light outputs and multiply it by the candidate 5 standard level requirement for the standard spectrum. 6 That would create the new candidate standard level for 7 the modified spectrum. 8 So we're at -- again, this is a possible way. 9 We're looking for other input, so we're looking for 10 comments on this method for scaling from standard 11 spectrum to modified spectrum. 12 MR. HOWLEY: This is Joe. I think that's a 13 reasonable approach as long as you consider the true 14 modified spectrum lamps and not the products out there 15 that would not pass the definition. 16 MR. LEWIS: Doug? 17 MR. BROOKMAN: Yes. Ron Lewis. 18 MR. LEWIS: We were, in the latest 19 legislation, given approval, permission, authority to 20 not do ANOPRs anymore, and this is a perfect example of 21 where we still choose to have the interaction with 22 stakeholders and put out straw men where we're charged 23 to try to save energy and try to push things. We're 24 given some direction. We've got the spirit of where 25 they took the general service incandescent lamps and EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064169 1 things that they've done there have given us examples 2 of things. 3 In cases where we didn't have a definition of 4 the modified spectrum, there's no data in existence, 5 we're in this dialogue. How do we accomplish something 6 that is the best rule where it's considerate of the 7 impacts on manufacturers and it's considerate of saving 8 energy and all the rest. 9 We really are looking for the assist of what 10 is known. We're talking about all the things we don't 11 know, and because this hasn't been before there's not a 12 history to it. So to the degree that we can get 13 clarity of what is known and where we've got things or 14 methodologies where we can acquire data in a hurry to 15 help crisp this up and get more precise, we'd really 16 appreciate it. 17 MR. HOWLEY: Ron, this is Joe again. If you 18 wanted to borrow a page out of the EISA, the standards 19 for incandescent A-line lamps, the factor there used 20 was 25 percent, 25 percent reduction. We know with the 21 products that use the neodymium, which was a previous 22 exemption in the 1992 law, they really do cut the 23 yellow energy considerably, producing a dramatic 24 effect. But it is a 25 percent reduction using that 25 technology, and that is the technology that was EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064170 1 accepted by Congress for the A-line. 2 So if you're looking for a value to make this 3 simpler, that would be one approach, is to use the 4 value already given for the A-line lamps. 5 MR. LEWIS: In the spirit of four macadam 6 steps and in statements that have been made a couple 7 times about filtering out the yellow part of the 8 spectrum, is there anything that, with what's being 9 marketed today, where -- I think some of the comments 10 of comparing to eliminating the things that are just 11 token, that the reduction is just token, and the things 12 that are in that realm of the four macadam steps 13 reality. Is there anything that is a first order of 14 qualification that we can look at? 15 Since we don't have the bare glass lamps 16 versus the final product, is there anything that 17 discriminates easily between those that are token 18 versus those that are real, major -- 19 MR. HOWLEY: Well, you can look at the lamps 20 of the major lamp manufacturers who you know well. You 21 can look at their catalogue data if you're trying to 22 get some sense. There are a lot of other products out 23 there, in many cases from importer suppliers, that -- 24 who knows what they're -- how they're approaching it or 25 if it's just marketing. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064171 1 But I think if you look at the major 2 manufacturers' data, catalogue data, you'll get some 3 certainty that these products do meet this definition 4 because the NEMA manufacturers came up with that 5 definition. So we know that all of our products would 6 meet that definition. 7 Perhaps that's the subset you should be 8 looking at versus every single product you can find out 9 on the marketplace. 10 MR. BROOKMAN: Any final comments on Slide 11 47? 12 (No response.) 13 MR. O'ROURKE: All right. This might be a 14 convenient time to -- I don't know if we're going to 15 take a break this afternoon. 16 MR. BROOKMAN: We are at a point now where -- 17 MR. O'ROURKE: -- going to switch to product 18 price determination. 19 MR. BROOKMAN: Should we take a break now? 20 Let's take a break. 21 MR. LEWIS: And then everyone's going to come 22 back because Pam's got us waiting for Chapter 2. 23 (Laughter.) 24 MS. HORNER: If you like, I can tell you that 25 one right now. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064172 MR. LEWIS: No, no. We want everybody to 2 come back. 3 MR. BROOKMAN: Let's take a short break. 4 Let's try to do this in 10 minutes. Let's start at 10 5 'til three. Then we'll also be assessing at that point 6 how far we're going to get today and how much time 7 we'll need tomorrow. 8 (Brief recess.) 9 MR. BROOKMAN: So, at the break we were 10 discussing a couple of different things. A couple of 11 different things at the break. One was about the 12 remainder of the day today and tomorrow. Some people 13 have suggested that we should really go quickly. I've 14 heard from several people that they've said about what 15 they're prepared to say on some of these issues today 16 and maybe they don't have a lot more to say today given 17 their level of preparation. 18 I think also we've -- I've heard from DOE and 19 the contractor team that there's a heck of a lot more 20 slides possibly to go through. There's a question 21 about whether everybody in the room is in a position to 22 endure a hundred more slides. That's another question. 23 But irrespective, we anticipate that some 24 people that didn't make it today might make it 25 tomorrow, could very well make it tomorrow, so in the EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064173 1 event we did conclude things today, DOE would supply 2 representatives here to walk them through the material, 3 orient them, do whatever is necessary in this very room 4 tomorrow, right? Okay. So that's a certainty. 5 Now, Mike Scholand, your assessment was that 6 there's a whole lot of slides, a whole lot of content, 7 maybe it's not possible to get through this in the span 8 of even the next two hours if we stay 'til 5 o'clock. 9 MR. SCHOLAND: Just my personal view, Doug. 10 It's not necessarily the Department's. 11 (Laughter.) 12 MS. GUPTA: What a guy. 13 MR. BROOKMAN: If we did "presentation 14 light," noting that there are a hundred slides or 15 something left? 16 MS. GUPTA: Yeah, a hundred. 17 MR. BROOKMAN: If we did "presentation 18 light," do you think it's possible to get through this 19 in the span of the next two hours so that some of these 20 people that will not be with us tomorrow or wish to 21 travel after the end of the day today? Do you think we 22 could do that? Possibly. 23 MS. GUPTA: Maybe two and a half. 24 MR. BROOKMAN: I'm looking at Mike Rivest and 25 Ron Lewis and Linda Graves, all three here. For the EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064174 1 record this is, yes. 2 (Laughter.) 3 MR. RIVEST: This is Mike Rivest. I think 4 it's important to go over the ANOPR analysis sections, 5 and then there's the whole series of slides that talks 6 about the next round of analyses. That -- I know most 7 people in this room have heard that a hundred times. 8 So we can do those more quickly. 9 And, if needed, we can -- we'll be 10 interacting heavily with manufacturers during the 11 manufacturer impact analysis phase, and that's going to 12 start really quickly because of the delays in issuing 13 the ANOPR. So I'm sure we can have one-on-ones and if 14 there are any questions about subsequent analyses, we 15 can do that. 16 MR. BROOKMAN: And the actual NOPR slides, 17 that's further up yet, correct? 18 MR. RIVEST: No. They're part of this 19 package. 20 MR. BROOKMAN: Part of this package here. 21 Okay, fine. 22 MR. DELASKI: Doug? 23 MR. BROOKMAN: Yes. 24 MR. DELASKI: If I can just weigh in. 25 MR. BROOKMAN: Andrew. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064175 1 MR. DELASKI: I'm prepared to be here 2 tomorrow. My point of view, I don't want anybody to 3 feel like they need to go "light" because I'm learning 4 a lot today. 5 MR. BROOKMAN: Great. 6 MR. DELASKI: Other folks may want to get out 7 of here today, but I would appreciate people to keep 8 talking up because we're learning things. We're 9 hearing things from industry and things from the 10 Department about what their concerns are. I think 11 that's very valuable, so I encourage you not to go 12 "light." 13 MR. BROOKMAN: Okay. 14 MR. DELASKI: I think it's okay to go light 15 in terms of where -- what comes next, but. 16 MR. BROOKMAN: Yeah. Ron Lewis. 17 MR. LEWIS: We won't go backwards to the 18 thing that I mentioned before, but I did want to take a 19 minute to clear up. I'm not sure if everybody in the 20 room understands that the CSLs and our direction -- the 21 methodology we have to go through is, we have to 22 establish what is the max tech that's out there for a 23 product and work our way backwards from that to where 24 is that point that is both technologically feasible and 25 economically justified. But we start at the highest EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064176 1 level. We're commanded to do that, so we have to go 2 through all these things. 3 So one of the things that I was thinking we 4 could talk about some more but I think we're -- to move 5 along we'll look forward to it in your comments, is in 6 revisiting that Slide 41 on some of the things where 7 there was a problem of perhaps a -- 8 MR. BROOKMAN: Which is up here now. 9 MR. LEWIS: -- a patent or a single 10 manufacturer. There were several other different 11 design options and things of looking at. Since we've 12 got to start at the highest and stop at that level 13 that's technologically feasible and economically 14 justifiable through the analyses, what are those other 15 options that are at play. Are there other options. 16 We recognize you're on the record of one 17 option maybe being an impediment, but about the other 18 ones, reconsidering. Because we have to start there at 19 the high point and work down. So that would be very 20 helpful to us. 21 MR. BROOKMAN: Okay. So then, I guess, then, 22 the direction that I'm receiving is we're just going to 23 press on here. We'll be as efficient as we can. We'll 24 see where we end up. 25 So then, Mimi. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064177 MS. GUPTA: Okay. Did Pam want to follow up 2 on -- 3 MS. HORNER: The anticipated follow-up, 4 right? 5 MR. BROOKMAN: Please, Pam. 6 MS. HORNER: Pam Horner, NEMA. I guess these 7 indeed could be the last two sets of comments I make 8 today because we're really not prepared to comment on 9 the life-cycle analyses and all of the other analyses 10 because this is -- in two weeks this is what we've 11 done. 12 We wanted to make a point in the incandescent 13 reflector lamp area to make you aware of something that 14 has happened in the market. The topic is lamp life. 15 We understand that DOE does not include lamp life. 16 That is clear. But I think all of us in the room 17 understand that lamp life or the decision, say, to 18 manufacture a product that uses a filament, if one 19 chooses to make longer and longer lamp life products, 20 then given all other technologies being equal within 21 that product, the lumens per watt go down. It's just a 22 fact of physics. 23 So what we thought we would share with you is 24 something that has happened in the market recently. 25 There are some I'm just going to call them strategies EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064178 1 of some of the very large purchasers of these products.2 These strategies are to put into the market, say, one3 year, two-year, three-year, and four-year type life so 4 that, in their eyes, the consumer of these products 5 will have a choice. 6 We were just talking about this during the 7 break. The lamp life, whether we like it or not, is a 8 top consideration for consumers. So the people who buy 9 our lamps keep that in mind and in essence make a 10 demand on us, those of us who make these lamps, to 11 fulfill these. 12 We took a look at the curves, the CSL 1, 2, 13 3, and what happens is that at each level, even with 14 those, the four-year strategies that are out there, 15 which is about 6,000 hours, that sort of thing, will 16 not meet the level. 17 We either say retailers don't matter or their 18 analysis of what their customers want or need doesn't 19 matter. I mean, that's an option. 20 MR. BROOKMAN: These large retailers are the 21 ones that are requesting that industry come forward 22 with -- 23 MS. HORNER: Oh, yeah. Yeah. 24 MR. BROOKMAN: -- that life expectancy? 25 MS. HORNER: Yeah, I'm just laying it -- I'm EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064179 1 being very plain. I mean, it's simply a reality. I 2 don't know what to do about it yet, but this is fairly 3 recent, okay? 4 MR. BROOKMAN: Okay. 5 MS. HORNER: The other point is that -- I 6 would prefer to take off my NEMA hat right now and wear 7 my Osram Sylvania hat because I don't know that I'm 8 speaking for my colleagues. I think maybe I am, but I 9 don't know that. 10 When you use lumens per watt as the only 11 metric, which is what we have, and you step back and 12 take a look at what it is we're regulating, it becomes 13 veryclear to me that what's left in this incandescent 14 reflector lamp category and what we're talking about 15 here have now become -- the herd is a series of very 16 precise instruments now. They're not light sources 17 that give off the blob of light. 18 Instead, whether we think we can use optics 19 as a measure, whether we think we can legitimately take 20 a look at anything else, we have lumens per watt. 21 That's what we've got. These are lighting fixtures. 22 They're not fluorescent tubes or A-lamps. I'm just 23 saying, this is a fact and it's been a difficulty. Now 24 that difficulty is coming even more into play as 2008 25 is upon us. It's more so than in 1992 when we had some EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064180 1 blobs of light in the incandescent reflector lamp 2 world. 3 Now, whether you can use optics or not for 4 regulations, the fact is that the manufacturers have 5 improved their optics, have improved their shaping, 6 have improved the mounting direction of the filaments. 7 Thereby, through time -- you put a slide up there 8 about 11 lumens per watt as a baseline PAR 38. For a 9 lot of us, we maybe can't get to that patented level 10 but were pretty darn close through optical 11 improvements. 12 Do you see where I'm headed with this? It 13 can be done through some of those, maybe not to that 14 line level that you've shown. And it begs the question 15 for the future, you know, when I'm 90 and everyone else 16 in here is 70, I guess, or at least Joe. 17 (Laughter.) 18 MS. HORNER: At some point can we take a look 19 at application efficacy, which is a very brilliant idea 20 of the Lighting Research Center, one of your 21 consultants, to take a look at how these things are 22 used. 23 To close, I just wanted to give you a point. 24 If you take one of today's 50-watt PAR 30s, you can 25 take a look at the lumens per watt if you want to. In EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064181 1 our case, it's 13.2. But depending on whether you 2 shape and push those lumens in a skinny direction or a 3 fat direction, you're going to get a whole lot or very 4 little light on the task. 5 Probably the most dramatic example of this 6 about optics mattering and LPW not mattering when it 7 comes to what do incandescent reflector lamps do, is 8 the case of two non-regulated lamps, the compact 9 fluorescent reflector lamp and the MR16 low voltage 10 lamp. 11 If you take a 22-watt compact fluorescent 12 reflector lamp today and you stick it somewhere and you 13 aim it at something, from 10 feet away you're going to 14 get one foot candle. That baby is 43 lumens per watt. 15 The 20-watt MR16 is only 17 lumens per watt, but 16 depending on which beam configuration you choose, you 17 can get 50 foot candles in the middle. 18 What I'm telling you is this is a lighting 19 fixture, not really a lamp. The end. 20 MR. BROOKMAN: Okay. Thank you. Then let's 21 proceed. 22 MS. GUPTA: All right. So I'm going to go to 23 Slide 48 and talk a little bit about the product price 24 determination. So the purpose of the product price 25 determination is to establish end user prices for the EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064182 1 lamps and ballasts identified in the engineering 2 analysis. The analysis is based on available price 3 lists such as manufacturer price lists and state 4 procurement price lists. 5 So for each lamp, DOE developed three prices, 6 a low range, medium range, and high range price, in 7 order to represent the range of prices consumers 8 encounter in the marketplace. 9 The medium price is used as a reference price 10 in the LCC and is also used in the national impact 11 analysis, and the high and low range prices are used as 12 sensitivities in the LCC analysis. 13 In the product price determination, DOE also 14 developed a weighted average sales tax by region based 15 on data from Sales Tax Clearinghouse, and the national 16 average was calculated to be 6.9 percent. 17 So I'm going to talk a little bit about the 18 general service fluorescent lamp methodology for 19 establishing prices first. In researching the market, 20 DOE recognized that higher efficacy lamps or premium 21 lamps generally receive a higher markup or lower 22 discounts off of the blue book prices than lower 23 efficacy lamps. 24 However, in developing prices to be used in 25 the analyses, in order to reflect commoditization of EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064183 1 the market, DOE mirrored state procurement prices, 2 which reflect bulk purchases. In these state 3 procurement contracts we saw that those purchases 4 received a relatively fixed discount off of the blue 5 book prices over efficacies and wattages. So DOE 6 applied the same methodology in establishing their 7 high, low, and medium range prices. 8 The low price that DOE developed was 9 developed to be consistent with the state procurement 10 prices or high volume prices, and we applied a discount 11 to mimic those. The medium range price is consistent 12 with the discount provided by distributors for 13 commercial and institutional consumers, and a 13 14 percent contractor markup was then applied to these 15 prices. 16 The high price, representing the lowest 17 discount off of the blue book price, is consistent with 18 prices encountered by small quantity purchasers such as 19 Internet prices, and the 13 percent contractor markup 20 was added to these prices as well. 21 Here we see an example of some end user22 prices results for the 32-watt T8 four-foot medium bi23 pin lamps. As you can see here, we show a high, 24 medium, and low range price over which they span about 25 $2. As efficacy increases, you get an increase in end EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064184 1 user price. 2 So DOE requests feedback on the approach for 3 developing end user fluorescent lamp prices. 4 MR. BROCKMAN: Comments? I guess if you 5 thought this methodology was seriously flawed you would 6 say something; is that correct? Joe. 7 MR. HOWLEY: (Off mic.) 8 MR. BROCKMAN: Joe says it seems reasonable. 9 Thank you. It's nice to get affirmation on these 10 matters. It allows the Department to move forward. 11 Okay. 12 MR. RIVEST: That's about the highest level 13 of praise we ever get. 14 (Laughter.) 15 MR. BROOKMAN: That was Mike Rivest, for the 16 record. Okay. Mimi, keep going. 17 MS. GUPTA: Okay. So now I'll talk about how 18 we developed the incandescent reflector lamp prices. 19 For IRL, DOE used a similar methodology as it did with 20 fluorescent, namely developing discounts off of blue 21 book prices. In its research it did not observe a 22 significant variation of lamp prices, lamp wattage, and 23 therefore mirrored that phenomenon by applying the same 24 end user prices for, for example, the 75-watt PAR 38 25 lamp and the 90-watt PAR 38 lamp. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064185 1 However, DOE did notice a difference in lamp 2 prices between lower diameter and higher diameter 3 lamps, PAR 30 and PAR 38 lamps, and therefore it 4 developed separate end user prices for these lamps. 5 In developing the IRL prices, DOE noticed 6 that the PAR 38 market was a more developed market than 7 the PAR 30 market. Therefore, DOE, first of all, 8 discounts off of PAR 38 blue book prices and then used 9 the PAR 38 analysis as a guide to developing the PAR 30 10 lamp prices. 11 So, how did we develop the PAR 38 lamp 12 prices. Similar to fluorescent, we mirrored a fixed 13 discount off of the blue book prices, similar to the 14 state procurement contracts. When we developed the low 15 range price, we made those consistent with both 16 purchases found in state procurement. Medium range17 prices we developed to be consistent with shipment18 weighted average prices paid by consumers for commonly 19 available IRL. High range prices, which represented 20 the lowest discount off of the blue book, were made 21 consistent with prices encountered by small quantity 22 purchasers such as Internet prices. 23 So, as I said before, we based the PAR 30 24 price analysis on the results for the PAR 38 lamps. We 25 did this because we saw that the PAR 30 market seemed EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064186 1 less developed. To do this, DOE developed a modified 2 blue book price for PAR 30 lamps by applying the same 3 incremental differences between the incandescent lamps 4 and higher efficacy lamps from the PAR 38 lamps. 5 So, just as an illustration, DOE started off 6 with the incandescent technology equivalent of the PAR 7 38 lamp, which is the BR40 lamp, and developed the 8 incrementals from the incandescent to the halogen lamp 9 and used that same incremental to establish the PAR 30 10 blue book prices. We started off with the incandescent 11 just because we believe that to be the most high volume 12 lamp and commoditized lamp currently. 13 Then, once establishing these modified blue 14 book prices, DOE then applied the same discounts off of 15 the modified blue book prices as it used with the PAR 16 38 analysis to develop the low, medium, and high range 17 prices. 18 Here is an example of some of our IRL end 19 user price results. For the 75-watt PAR 38 baseline, 20 similar to GSFL, we show high range, medium range, and 21 low range. As you can see, as lamp efficacy increases, 22 end user price increases as well. 23 So DOE invites feedback on the IRL prices. 24 MR. BROOKMAN: Joe. 25 MR. HOWLEY: I was just going to say this EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064187 1 also seems like a reasonable approach. 2 (Laughter.) 3 MS. GUPTA: That's great. 4 MR. BROOKMAN: Jeff Harris. 5 MR. HARRIS: Jeff Harris. 6 MR. BROOKMAN: Get close to the microphone, 7 Jeff. 8 MR. HARRIS: How are you approaching the 9 differences in the enhanced spectrum -- modified 10 spectrum products we talked about earlier given this 11 broad range of apparent performance? 12 MS. GUPTA: Well, we don't directly analyze 13 modified spectrum lamps in the LCC and the NIA because 14 we assume that -- if the standard is established 15 correctly, we assume that the incremental energy 16 savings and the incremental prices in the modified 17 spectrum product class will be the same as the standard 18 spectrum product class and the impact should be 19 similar. Does that make sense? Okay. 20 MR. BROOKMAN: Steve Nadel. 21 MR. NADEL: I seem confused. I mean, 22 basically you're assuming you have the same, you know, 23 bare lamp and you add some filters to it, but the24 filters cost the same regardless of whether it's pre25 or post-standard. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064188 1 MS. GUPTA: Exactly. 2 MR. BROOKMAN: So, Slide 55. Slide 55 is an 3 invitation one more time for you to comment on these 4 five issues: product classes, standards for color 5 rendering index, selection of efficacious lamp 6 substitutes and candidate standard levels, scaling to 7 product classes not analyzed, and approaches for 8 establishing end user prices. I think we've touched on 9 these at least, if not covered them sufficiently. An 10 invitation to make final comments. 11 (No response.) 12 MS. GUPTA: Okay. 13 MR. BROOKMAN: Okay. 14 MS. GUPTA: Great, so. 15 MR. BROOKMAN: On to life-cycle cost 16 analysis. Yes, Gary. 17 MR. FERNSTROM: Gary Fernstrom, PG&E. I'd 18 just like to make an observation here. I find this 19 graph on page 54 to be very interesting. It shows a 20 range in retail price over on the right-hand side of 21 the graph from roughly $5 to $10. So that's a factor 22 of two. I can buy the product and pay twice as much 23 for exactly the same thing depending upon where I get 24 it. 25 On the other hand, the cost associated with EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064189 1 going from the least efficacious to the most 2 efficacious is $2 or $3. So I would be far better off 3 to be a wise shopper and get the best light bulb. 4 MS. GUPTA: You mean the best light bulb in 5 high volume; is that what you're saying? 6 MR. FERNSTROM: Well, even the way I shop, I 7 find this price range difference in retail. So I can 8 go to a big box hardware store and find a lamp for half 9 the price that I would at a small distributor. So I 10 think if we were all, you know, wise shoppers, we could 11 buy the best light bulbs and have them be less 12 expensive than if we just bought the worst light bulbs 13 at the wrong place. 14 MR. BROOKMAN: Mike Rivest. 15 MR. RIVEST: That's certainly true. A couple 16 of clarifying points, though. You know, the low end of 17 the range represents, I believe, the largest state 18 pricing. 19 MR. FERNSTROM: High volume. 20 MR. RIVEST: The high volume. So there's 21 that aspect. And then, we are not -- the price of the 22 19 lumen-per-watt lamp, if you try to buy it today you 23 will pay a lot more than that for it because the 24 discount on a base lamp is -- I'm going to make this up 25 -- is 60 percent off blue book and on the very high EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064190 1 efficiency product it might be 40 percent off blue 2 book. Here it's assuming constant 60. So we're 3 commoditizing a lot here. 4 MR. FERNSTROM: Yeah, that's a very good 5 observation. If I could even find the best product, 6 which a lot of times is just not available. 7 MR. BROOKMAN: Keith has a comment. 8 MR. COOK: Can you hear me? But that 9 analysis is exactly what's got us into problems today, 10 and that is the fact that everybody is looking at 11 initial cost and not life-cycle cost. It's led us 12 astray so many times that you look at that minimum 13 price. No matter how efficient it is, it still may not 14 be the best product over the long term because you have 15 to take into account how long the product lasts and 16 what the overall efficiency is of that product. 17 So, you know, we've got to get away from that 18 initial cost mentality. 19 MR. LEWIS: So, are you suggesting we should 20 consider life-cycle cost? 21 (Laughter.) 22 MR. BROOKMAN: The perfect segue, the perfect 23 segue. Diana Burk. 24 25 EXECUTIVE COURT REPORTERS, INC. (301) 565-00641 191

2 Life-cycle Cost Analysis and Payback Period Analysis 3 Diana Burk 4 (PowerPoint presentation.) 5 MS. BURK: Thanks for queuing me up. My name 6 is Diana Burk, and I'll be talking about the life-cycle 7 cost analysis. I'll also be talking about the energy 8 use characterization. 9 The energy use characterization is an 10 important analysis which feeds directly into the life11 cycle cost analysis. This analysis gives consumer 12 energy use by efficiency level. The life-cycle cost 13 analysis uses results from the energy use 14 characterization as well as the engineering and product 15 price determination, which gives you results of 16 efficiency with price. 17 So the purpose of the energy use 18 characterization is to develop energy consumption 19 estimates for those lamps or lamp and ballast systems 20 that we developed in the engineering analysis. The 21 purpose of the life-cycle cost analysis is to estimate 22 the amount of money a consumer will save by purchasing 23 a higher efficiency lamp. This estimate takes into 24 account both the first cost of purchasing the lamp as 25 well as the operating costs over the lifetime of that EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064192 1 lamp. 2 So there are two basic inputs to the energy 3 use characterization: operating hours and power of the 4 lamp or lamp and ballast system. For operating hours, 5 DOE developed a distribution of operating hours by 6 several variables: lamp type, sector, building type, 7 and region. Of course, by lamp type, DOE assumes that 8 incandescent reflector lamps will operate for different 9 annual operating hours than general service fluorescent 10 lamps. 11 DOE developed a distribution for these lamp 12 types in different sectors. For incandescent reflector 13 lamps, DOE developed a distribution for the 14 residential, commercial, and industrial sector, and for 15 fluorescent lamps in the commercial and industrial 16 sector. 17 The distribution of operating hours also 18 varies by building type. A certain lamp may have lower 19 operating hours in a vacant building versus a lamp 20 operating in an office. Operating hours will also vary 21 by the region of the country the lamp is located in. 22 DOE analyzes 13 regions, nine census divisions, or four 23 large states. 24 Power used in the energy use characterization 25 was developed in the engineering analysis. For EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064193 1 incandescent reflector lamps, it's simply the lamp 2 wattage, and for fluorescent lamps it's based on the 3 system power, which depends both on the lamp and the 4 ballast. 5 DOE developed operating hours for all three 6 sectors, as I stated earlier. To develop operating 7 hours in all three sectors, DOE used the 2002 U.S. 8 Lighting Market Characterization. This report was used 9 to develop an average operating hours by building type 10 and lamp type. DOE chose to develop the distribution 11 of operating hours by building type to represent the 12 average energy use of a lamp for a particular consumer 13 who would purchase lamps for the entire building. 14 DOE also used the Residential Energy 15 Consumption Survey. This report was used to develop 16 probability a certain building type resides in a 17 certain region of the country. 18 Using these two sources, DOE found that the 19 average operating hours of an incandescent reflector 20 lamp was 884 hours per year. Because the range of 21 operating hours by building type in the residential 22 sector was quite small, DOE also developed a 23 sensitivity for high and low operating hours by room 24 type. The high operating hours used was 1,210 hours 25 per year, which corresponds to a lamp operating in a EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064194 1 kitchen, and 183 hours per year, which corresponds to a 2 lamp operating in a closet. 3 (Laughter.) 4 MS. BURK: In the commercial sector, DOE also 5 used the 2002 U.S. Lighting Market Characterization. 6 Again, this report was used to develop an average 7 operating hours by building type and lamp type. In the 8 commercial sector, building types range from offices, 9 refrigerated warehouses, lodging, and food sales. DOE 10 also used the 2003 Commercial Building Energy 11 Consumption Survey. This gave the probability a 12 certain building type resides in one of nine census 13 divisions or four large states. 14 The operating hours for an average 15 incandescent reflector lamp was found to be 3,450 hours 16 per year, and the operating hours of an average 17 fluorescent lamp was found to be 3,435 hours per year. 18 This is a sample distribution of operating 19 hours in the commercial sector for fluorescent lamps. 20 As you can see, the highest probability of a 21 fluorescent lamp being located is an office, which is 22 number two. Approximately 18 percent of fluorescent 23 lamps are located in offices. The average operating 24 hours for a fluorescent lamp in an office is 25 approximately 3,700 hours per year. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064195 1 Finally, DOE developed operating hours for 2 the industrial sector. Again, DOE used the 2002 U.S. 3 Lighting Market Characterization. This time building 4 types ranged from printing and publishing to fabricated 5 metal products. 6 DOE also used the 2002 Manufacturer Energy 7 Consumption Survey, which gave the probability a 8 certain building type resides in the country. Because 9 the survey did not include information on the location 10 of those manufacturing facilities, DOE used information 11 from the 2007 census to determine the probability a 12 certain building type would reside in one of the nine 13 census divisions or four large states. 14 The average operating hours for an 15 incandescent reflector lamp in this analysis was found 16 to be 4,664 hours per year, and the average operating 17 hours for a fluorescent lamp was found to be 4,795 18 hours per year. 19 Finally, I'm going to open up the floor for 20 comment. DOE requests feedback on these average 21 operating hours and whether they're reasonable 22 estimations. 23 MR. BROCKMAN: So, both confirming the result 24 and also any comments about the methodology. 25 MS. HORNER: Dare we say it seems reasonable? EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064196 1 (Laughter.) 2 MR. BROOKMAN: Okay. I'm glad we captured 3 that on the record. Okay. Any other comments? Jeff 4 Harris. 5 MR. HARRIS: Yeah, I have a question. Jeff 6 Harris. As I recall, the Lighting Market Survey was 7 not a regionally differentiated one that was done in 8 2002. Do I remember wrong? 9 MS. BURK: No, that is correct. That is why 10 DOE used the Residential Energy Consumption Survey, 11 RECS, CBECS, Commercial Building Energy Consumption 12 Survey, and MECS, which gave the probability of 13 building types. The U.S. Lighting Market 14 Characterization gave the average operating hours for a 15 certain building type, but it did not say where those 16 building types were located, whereas RECS, MECS, and 17 CBECS gave the probability a certain building type 18 would be located in a certain region. 19 MR. HARRIS: Okay. I guess I understand 20 that. But in the residential sector, it seems to me 21 that, first of all, we're talking basically about 22 reflector lamps which are mostly likely to be in 23 ceiling fans and most likely to be in newer houses. 24 MS. BURK: Right. 25 MR. HARRIS: So there would tend to be a EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064197 1 concentration of those in the fast-growing regions, 2 which are the Southeast and Southwest. 3 MS. BURK: Right. 4 MR. HARRIS: And I would expect to see more 5 differentiation in lighting hours. 6 MS. BURK: Between in the different regions? 7 MR. HARRIS: Between the south and the north, 8 for example, than by building type. 9 MS. BURK: We did develop different 10 distributions by region. However, the U.S. Lighting 11 Market Characterization would only give you the 12 operating hours for like a single family attached 13 house. If there are more single family attached houses 14 in, say, the Northeast than the south, then you would 15 see that differentiation. But otherwise, you wouldn't. 16 MR. HARRIS: So you assumed different 17 operating hours by latitude? 18 MS. BURK: By building type. A mobile home 19 may have different operating hours than a person living 20 in a single family detached house. 21 MR. RIVEST: But a mobile home in -- 22 MR. BROOKMAN: Mike Rivest. 23 MR. RIVEST: But a mobile home up north would 24 have the same operating hours as a mobile home down 25 south. EXECUTIVE COURT REPORTERS, INC. (301) 565-0064198 1 MS. BURK: Right. A mobile home up north 2 would have the same operating -- 3 MR. RIVEST: But the number of mobile homes 4 would be greater in the south. 5 MR. HARRIS: I don't remember the exact 6 numbers, but it's my, again, vague recollection that 7 the overall residential lighting energy as a fraction 8 of total electricity from that study was lower than 9 we've seen in subsequent studies, especially regional 10 ones. 11 I'm going to turn to Tom Eckman in particular 12 because I recall that some more detailed work has been 13 done in the Northwest. If I recall, it showed more 14 lighting, but I don't know if it was by hours or by 15 connected load. 16 MR. BROOKMAN: Get to the mic, Tom. 17 MR. ECKMAN: Can you hear this? Because this 18 is pretty much what it's got to be. 19 Well, as I recall, one of the principal 20 reference studies in the Lighting Market 21 Characterization where we actually did have in situ 22 lighting loggers was done in Tacoma, which sits at 23 about the 46th Parallel. So it may be different than 24 the folks in southern California because it does get 25 dark there more often in the winter. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064199 1 But I think that there are only two metered 2 studies or two logged studies that were referred to in 3 that. The other one that I'm familiar with that was 4 done more recently was done and finished in '96. The 5 other one was done in California. It was pretty much 6 representative of all California. 7 When we compared the two averages, they were 8 a tenth of an hour per day different. So latitude 9 doesn't seem to have a major impact given sunny 10 California and rainy Tacoma. 11 MR. BROOKMAN: Would you confirm the building 12 type hypothesis? 13 MR. ECKMAN: The building type hypothesis, 14 you know, both of those were done as well. The metered 15 data that was done in California was across all three16 building types that you were looking at: single17 family, multi-family, and manufactured homes. The 18 Tacoma was only done in single-family, so I can't speak 19 to the variance there. 20 MR. BROOKMAN: Thank you. 21 MR. ECKMAN: But for new construction, the 22 power densities are much higher and the buildings are 23 much larger, and there's a higher prevalence of the can 24 lines where these things would go. We are doing now, 25 but it won't be ready for this study, we're going in EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064200 1 the field now with lighting loggers in those homes. 2 But because we're looking at 30 or 40 cans per home. 3 MR. BROOKMAN: Gary. 4 MR. RIVEST: Can I make an observation? This 5 product is unlike other products. If we're talking 6 about a clothes washer, we assume it lasts 14 years. 7 If it gets used twice as much, we assume it lasts 14 8 years anyway. Lighting, if this is good for 2,000 9 hours, it's good for 2,000 hours. 10 Now, the difference is that you may recover 11 your cash flow in the two years instead of one, but 12 that is a small difference. So operating hours is not 13 the driver it is in other analyses. 14 MR. BROOKMAN: Gary. 15 MR. FERNSTROM: Okay. Gary Fernstrom, PG&E. 16 Just one more observation about the can lights. New 17 homes have more can lights and they tend to be in rooms 18 that are occupied longer hours. So I think that 19 factors in also. You find the can lights in the 20 kitchens and living rooms, not in the closets. 21 MR. BROOKMAN: Okay. 22 MS. BURK: Shall I move on? 23 MR. BROOKMAN: Yeah. 24 MS. BURK: So, an additional input to the 25 energy use characterization is the power of the lamp or EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064201 1 lamp and ballast system selected in the engineering 2 analysis. As I stated earlier, for incandescent 3 reflector lamps the power is simply the wattage of the 4 lamp. But for fluorescent lamps, the system power 5 depends both on the lamp and the ballast it is operated 6 by. 7 DOE calculated the system power rating using 8 published catalogue data to estimate the system power 9 for a range of ballast factors with similar attributes. 10 For example, similar ballast efficacy factors, THD, 11 total harmonic distortion. 12 DOE developed a linear fit. This is an 13 example of a linear fit for a three-lamp, 32-watt, 14 four-foot T8 system with a normal ballast efficacy 15 factor and normal total harmonic distortion. 16 DOE invites comments on all the system power 17 ratings of the lamp and ballast systems analyzed in the 18 energy use characterization. 19 MR. BROOKMAN: Steve Nadel. 20 MR. NADEL: No, this seems reasonable. I 21 mean, it's a straight line function. The ballast 22 factor. 23 24 (Laughter.) MR. NADEL: Don't let this go to your head. 25 (Laughter.) EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064202 1 MR. BROOKMAN: Other comments? 2 (No response.) 3 MR. BROOKMAN: Okay. 4 MS. BURK: Okay. So now let's move on to the 5 life-cycle cost and the payback period analysis. As I 6 stated earlier, the purpose of the life-cycle cost and 7 payback period analysis is to estimate the life-cycle 8 cost savings and the payback period for higher 9 efficiency lamps compared to the baseline lamp.10 Here is a brief overview of the basic life11 cycle cost methodology. The life-cycle cost, or the 12 LCC, is the cost of owning and operating a piece of 13 equipment over its lifetime. The LCC is comprised of 14 first costs, shown here, the consumer price plus the 15 installation cost of installing the lamp or lamp and 16 ballast, and the operating expenses of that system over 17 the analysis period. This is discounted to present 18 value in the analysis. 19 The analysis of the LCC is done from the 20 perspective of the consumer, as opposed to the 21 manufacturing impact analysis, which is done from the 22 perspective of the manufacturer. 23 For transparency, this analysis tool is 24 implemented in Excel, which you can download from the 25 DOE website. It includes the ability to explore EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064203 1 certain sensitivities to key input variables in the 2 analysis. 3 The LCC results are expressed as the 4 difference between the life-cycle cost of the baseline 5 minus the lamp that meets the candidate standard level. 6 In addition to calculating the net life-cycle cost 7 impact of each candidate standard level, the life-cycle 8 cost analysis tool also shows the simple payback period 9 for each candidate standard level. 10 Later in this presentation I'll elaborate on 11 the life-cycle cost methodology for the lamps 12 rulemaking. 13 The approach taken in this analysis, DOE 14 makes, you know, several important decisions for this 15 analysis. This analysis only considers consumer 16 choices that save energy. For example, reduced wattage 17 lamps or lamp and ballast combinations that have 18 reduced system power. DOE does not consider those 19 options that do not save energy, however recognizes 20 that consumers may choose not to save energy when a 21 candidate standard level is applied. They can just 22 increase the light output of the product. DOE 23 considers these options in the national impact 24 analysis. 25 DOE recognizes that the event that triggers EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064204 1 the purchase of a lamp will affect the impacts of a 2 standard on the consumer. We will talk about these 3 events in more detail in the next slide. 4 DOE also recognizes that the lifetimes of 5 lamps may be different at different standard levels. 6 Therefore, DOE uses something called a residual value. 7 Again, we'll talk about this later. 8 Finally, it is important to note that in the 9 analysis DOE uses a distribution of several inputs. 10 For example, DOE uses a distribution of operating 11 hours, sales tax, and electricity prices. These inputs 12 are correlated in the analysis. For example, these 13 distributions are correlated by region. 14 Various events trigger the purchase of a 15 lamp. We'll go over these events generally here and 16 then go into more specifics in the slides to come. For 17 incandescent reflector lamps, there are basically two 18 events that might trigger the purchase of a lamp. This 19 is the event where a lamp fails and must be replaced, a 20 lamp failure event, or the new construction and 21 renovation event, where a building is being constructed 22 or renovated. 23 For fluorescent lamps, there are multiple 24 events. DOE analyzes five events for fluorescent 25 lamps. Of course, the first is the lamp failure event. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064205 1 A lamp fails and must be replaced. 2 The second is the standards induced retrofit 3 event. In this event, an increase in the efficacy 4 standard prompts end users to retrofit their lamps and 5 ballasts when in the base case they would have 6 otherwise only purchased a lamp. This event is 7 particularly salient at certain candidate standard 8 levels, Candidate Standard Levels 4 and 5, when a user 9 with a T12 system would no longer be able to purchase a 10 T12 lamp for that system and would be forced to 11 retrofit with a T8 system in the standards case. 12 The third event DOE analyzes is the event 13 when a ballast fails. Under this event, a consumer 14 must replace both their lamp and ballast in the base 15 and the standards case. 16 The fourth event is the event when a consumer 17 is planning to retrofit their building. In the case of 18 the standards, these consumers would be forced to 19 retrofit with a higher efficacy lamp when they wouldn't 20 have otherwise. 21 Finally, the fifth event is for those lamps 22 being purchased for a newly constructed building. In 23 this event, the lighting design can be new or 24 completely reconfigured. 25 As we talked about before, we analyzed the EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064206 1 economics on several baseline lamps, T12 and T8 2 baseline lamps, for certain product classes. DOE 3 recognizes that certain triggering events may be more 4 salient for T12 baseline lamps than they are for T8 5 baseline lamps. I'll go over the base case and the 6 standards case action for T12 baseline lamps here and 7 talk about the salient events for T8 baseline lamps in 8 the slide to come. 9 For the lamp failure event, the base case 10 action is simple: simply install a new T12 lamp. 11 However, in the standards case, the user can either 12 install a lower wattage, higher efficacy lamp and 13 maintain light output or they can install a new T12 or 14 T8 system. This would be an electronic system. 15 If the standard is set at Candidate Standard 16 Level 4 or 5, candidate standard levels which T12 lamps 17 would not be able to meet, many lamp purchases may be 18 made under the standards-induced retrofit events. In 19 this event, buildings who own T12 systems may replace 20 their systems before the lamps in their buildings 21 actually fail. Therefore, in the base case, the 22 buildings would replace a lamp halfway through the 23 analysis period, but in the standards case they would 24 purchase a T12 or T8 electronic ballast at the 25 beginning of the analysis period. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064207 1 A lamp may also be purchased under the 2 ballast failure event. Under this event, because the 3 magnetic T12 ballasts will no longer be available, a 4 base case action would be to install a T12 electronic 5 ballast, if one were to want to buy a T12 lamp. And in 6 the standards case, one would have to install either a 7 T12 or a T8 electronic lamp at a higher efficacy. 8 The fourth event is the ballast retrofit 9 event. DOE assumes that consumers of T12 lamps would 10 not retrofit with a T12 system. They would only 11 retrofit with a T8 system. Therefore, in the base case 12 consumers would install T8 electronic ballast lamps in 13 their existing buildings. However, in the standards 14 case, they would install a higher efficacy T12 or T8 15 lamp. 16 For the new construction and renovation 17 events, DOE assumes this is only applicable to the T12 18 high output systems. DOE assumes that new buildings19 are not being constructed using four-foot T12 or eight20 foot T12 single-pin slimline systems. In this case, a 21 user in the base case would install a new T12 high 22 output system, but in a standards case would install a 23 new T12 or T8 system where the light output is 24 maintained. 25 MR. BROOKMAN: Yes, Tom. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064208 1 MR. ECKMAN: I'm not quite clear how -- this 2 is Tom Eckman, Northwest Power and Conservation 3 Council. In the new construction and renovation cases, 4 I'm not quite clear; for those areas of the country 5 that have building codes that require maximum -- set 6 maximum lighting power densities, in many areas being 7 able to satisfy that, you just can't get there with a 8 T12 today, at least in our neck of the woods down in 9 California. 10 So the presumption that they could use that 11 as an option just isn't realistic. Now, there may be 12 areas of the country where that's possible, but a_fair 13 chunk of the country is covered by areas where that 14 option doesn't exist. 15 MR. BROOKMAN: Thank you. Yes, please, Paul. 16 MR. WALITSKY: Paul. If you've got to go to 17 an Energy Star or U.S. Green Building Council lead, you 18 can't use T12s, either. It won't work. You won't get 19 to the desired level on the Energy Star scale to get 20 your points. 21 MS. BURK: Is that it? For T8 lamps, DOE 22 assumes only three events are applicable: the lamp 23 failure, ballast failure, and new construction and 24 renovation events. For all three events DOE assumes 25 the user will install a T8 lamp in the base and EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064209 1 standards case. 2 Another important part of the life-cycle cost 3 analysis is the use of residual values. To compare the 4 life-cycle cost of two products, one must evaluate them 5 over the same period of time. This period of time must 6 be based on the lifetime of the product being 7 regulated. 8 For lamps, DOE recognizes that lifetimes may 9 vary at different candidate standard levels. To take 10 into account this variance, DOE uses something called a 11 residual value. This value prorates the value of the 12 remaining life of the lamp or ballast in the analysis. 13 So if one is estimating the residual value of 14 a $6, six-year lamp with a five-year analysis period, 15 at the end of the five-year analysis period a six-year 16 life lamp has one year of life left. So the residual 17 value would be one-sixth of the price of that lamp. 18 One-sixth of $6 would be $1. This $1 would be 19 discounted back to present value in the analysis from 20 the end of the analysis period. 21 The total life-cycle cost for a lamp that 22 lives longer than the analysis period is equal to the 23 installed cost of that lamp plus its operating costs 24 minus the residual value of that lamp. 25 DOE seeks comment on the use of residual EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064210 1 value and on other possible approaches to calculating 2 life-cycle cost for products with varying lifetimes. 3 MR. BROOKMAN: Yes, Gary. 4 MR. FERNSTROM: Gary Fernstrom, PG&E. This 5 is a little off the subject, but we talked about 6 ballasts earlier in fluorescent lighting systems and 7 the economics associated with them. Are ballasts 8 treated similarly in terms of their residual value when 9 T12 ballasts need to be replaced? 10 MS. BURK: Yes, they are. If-the analysis 11 period lasts, for example, five years and a fluorescent 12 lamp ballast, say, will last 15 years, then the 13 consumer actually pays for one-third of that ballast 14 for the life-cycle cost calculation. 15 MR. FERNSTROM: Thank you. 16 MR. BROOKMAN: Steve. 17 MR. NADEL: It seems like a reasonable 18 approach. It's much easier than trying to come up with 19 all sorts of permutations of different lamps and 20 ballast lives. 21 One question. What ballast life did you 22 assume? Is it in years or in hours? 23 MS. BURK: It is in hours, and we took it 24 from the 2000 ballast rule. I'll talk about it later, 25 but it's approximately 49,000 hours. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064211 1 MR. BROOKMAN: Paul. 2 MR. WALITSKY: The one point I -- 3 MR. BROOKMAN: Oh, you weren't done? 4 MR. WALITSKY: -- would mention is on lamp 5 maintenance values. As the lamp gets older, you're 6 getting out less light output. Would that come into 7 the residual value? 8 MS. BURK: In the life-cycle cost analysis 9 DOE does not include any maintenance costs for lamps. 10 However, it does take into account group and spot 11 replacements. So a group replacement would be 12 estimated 75 percent of the rated life and a spot would 13 be made at the end of the rated life. 14 MR. FERNSTROM: Gary Fernstrom, PG&E. Well, 15 if we want to carry that thinking one step further, 16 since there is a cost associated with disposal, is that 17 treated in the residual value? 18 MS. BURK: No. We do not take that into 19 account in the residual value. So I would assume that 20 the disposal of the lamp would be the same in the base 21 and the standards case, and so the life-cycle cost 22 savings, well, may be affected a little bit if the 23 lifetime is a lot shorter. 24 MR. BROOKMAN: Steve Nadel. 25 MR. NADEL: Yeah. You may want to look again EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064212 1 at the ballast life. As I recall, even in the last 2 ballast rulemaking there was a bunch of discussion and 3 that was perceived then to be a very conservative 4 value. 5 MS. BURK: Okay. 6 MR. BROOKMAN: Paul again. 7 MR. WALITSKY: Paul again. One comment on 8 recycling. Costs range anywhere now from five cents a 9 foot up to 10 cents a foot. It's come down somewhat 10 from the standard of 10 cents, but it's still -- a 11 four-foot lamp, your residual value is going to be 12 eaten up in the recycled foot. 13 MR. BROOKMAN: Okay. 14 MS. BURK: Thank you. 15 MR. BROOKMAN: Other comments on recycle -- 16 residual value? 17 (No response.) 18 MS. BURK: Okay. This diagram illustrates 19 the simple cash flow for one of the events, the T12 20 lamp failure event. The red arrow is the lamp 21 purchased. The green arrows are the operating 22 expenses, and the blue arrow is the residual value. 23 So in the base case, if you had a T12 lamp on 24 a magnetic ballast and it had a five-year service life, 25 the analysis period would be based on this five-year EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064213 1 service life. So, 2012. The consumer would purchase 2 the lamp. They would then have to pay operating 3 expenses at the end of each year throughout the 4 analysis period, which would end in 2017. 5 In the standards case, one would purchase a 6 reduced wattage T12 lamp on that same ballast. If that 7 lamp had a six-year service life, one would encounter a 8 residual value at the end of the analysis period. 9 The purchase price, of course, in 2012 may be 10 higher. The operating expenses throughout the analysis 11 period would be lower, and then you would see the 12 residual value, one-sixth of the lamp price at the end 13 of the analysis period, discounted back to present 14 value. 15 This is a draft concept of how we've 16 structured the life-cycle cost analysis. It may look 17 pretty confusing now. 18 (Laughter.) 19 MS. BURK: I will go over these inputs 20 generally here and talk about them in more detail in 21 the slides to come. 22 We've talked a bit about the installed cost, 23 where the main component is the lamp price. We'll talk 24 about the installed cost in the next slide, where we 25 also include installation costs in the life-cycle and EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064214 1 payback period analysis. 2 Operating costs are derived from energy 3 consumption and energy prices. I've talked about 4 energy consumption in the energy use characterization, 5 but we'll talk about energy prices in the slides to 6 come. 7 The operating cost over the analysis period 8 is calculated by discounting the operating cost and 9 taking into account the electricity price trends. 10 Again, I'll talk about discount rates and electricity 11 price trends in the slides to come. 12 The simple payback is the difference between 13 the total installed cost of the baseline and standards 14 case product divided by the annual electricity cost 15 between the baseline and the lamp that meets that same 16 candidate standard level. The life-cycle cost is the 17 addition of the total installed cost, the operating 18 expenses, And the replacement cost if the lamp dies 19 before the end of the analysis period. The residual 20 value is also taken into account. 21 For total installed cost, the total installed 22 cost of the lamp or lamp and ballast system is the 23 retail price plus the installation cost. The equipment 24 retail price is derived from the product price 25 determination. It's simply the sales tax times the end EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064215 1 user product price. 2 The installation costs represent the labor 3 necessary to install the lamp or lamp and ballast. For 4 labor times, DOE -- for fluorescent lamps, DOE used 5 information from the 2000 ballast rule. These labor 6 times depended on the lamp being installed. DOE also 7 used the weighted average group and spot labor time 8 rate. 9 For incandescent reflector lamps, DOE used 10 labor time estimates from the 2007 RS Means Electrical 11 Cost Data. In the residential sector, DOE assumes no 12 installation cost for incandescent reflector lamps. 13 MR. FERNSTROM: Gary Fernstrom, PG&E. This 14 is a small point, but shouldn't the equipment retail 15 price be the end user price plus sales tax? 16 MR. RIVEST: Yes. 17 MS. BURK: Yes. 18 MR. RIVEST: Sales tax rate. 19 MS. BURK: Yeah. It would be sales tax -- it 20 would be one plus the -- so if the sales tax was 6.9 21 percent, then the equipment retail price would be the 22 end user product price times one plus the 6.9 percent. 23 MR. FERNSTROM: So, to be picky, that's 24 mathematically incorrect. 25 (Laughter.) EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064216 1 MS. BURK: Fatally flawed. 2 (Laughter.) 3 MS. BURK: We did the calculation correct in 4 the spreadsheet. 5 (Laughter.) 6 MR. FERNSTROM: I had confidence you did the 7 calculation correctly. 8 MS. BURK: For labor rates, DOE assumed a 9 lamp was being replaced by a general maintenance 10 worker. DOE obtained the labor rate for this 11 maintenance worker from the U.S. Bureau of Labor 12 Statistics and found it to be $15.49 an hour. The 13 labor rate for the lamp and ballast replacement was 14 assumed to be an average of an electrician and 15 electrician's helper labor rate, and this was found to 16 be $53.88 an hour. 17 MR. BROOKMAN: I was wondering why that was 18 so low. Yes, Steve Nadel. 19 MR. NADEL: A comment on the electrician 20 rate. Yes, that makes sense for a smaller customer who 21 needs to hire an electrician, but a lot of large 22 customers will have electricians on staff and they're 23 not paying that. So you may want to -- again, it may 24 be Bureau of Labor Statistics or something, you know, 25 an on-staff electrician. I don't know what the, you EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064217 1 know, large versus small is, but, you know, some factor 2 to account for that. 3 MS. BURK: Okay. Any other comments? 4 MR. BROOKMAN: Keith. 5 MR. COOK: Sorry. On the replacement rate, 6 there's other factors in that also that aren't 7 accounted for. I don't know if it's worth going into, 8 but you know, you have to have forklifts and things 9 like that in order to get up into high bays and those 10 kind of places -- 11 MS. BURK: Right. 12 MR. COOK: -- for replacement. Those are not 13 cheap. 14 MS. BURK: Right. Well, DOE took into 15 account labor times from the data from the 2000 ballast 16 rule, which would include any forklifts needed to go up 17 to high bays. These do depend on lamp height, but if 18 you feel that they don't represent the actual labor 19 times, we'd welcome any comments. 20 MR. BROOKMAN: Steve Nadel. 21 MR. NADEL: Yes. I mean, in general, the 22 lamp has failed. You are going to have to get up there 23 anyway. So, do you need more forklift time. You know, 24 do you need to get a new forklift or something. I 25 think for the most part, if anything, the new lamps are EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064218 1 longer-lived and you have 24,000 replacing 20,000. 2 MS. BURK: Right. 3 MR. NADEL: I can't think of instances where 4 it's a shorter lamp life we're now using and therefore 5 you're going to need to change it more often. 6 MS. BURK: Right. You bring up a good point. 7 The only instances where installation costs really 8 matter is when the lifetime is different and one might 9 have to install a lamp more often in the base or 10 standards case than the other lamp. 11 MR. BROOKMAN: Okay. 12 MS. BURK: Okay. DOE understands that labor 13 times do not take into account new regulations from the 14 2005 National Electric Code. This code requires a 15 means for disconnecting luminaires installed indoors 16 and thus may affect the labor time to install 17 fluorescent lamp ballasts. This rule came into effect 18 in January of this year, so we welcome comments on how 19 this new requirement may affect labor times and labor 20 rates we're using in the analysis currently. 21 MR. BROOKMAN: Has industry estimated -- Joe. 22 MR. HOWLEY: Yes, Joe Howley. It definitely 23 would add a factor. You are correct in that the NEC 24 did add this new requirement that requires a 25 disconnect. In most cases, this disconnect is being EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064219 1 addressed through a separate in-line connector that now 2 they have to wire into the system. 3 So it would take some additional time. I 4 don't have an estimate of how long that would be, you 5 know, whether that would be 15 minutes, 30 minutes. I 6 can't imagine, it would be more than something in that 7 range. But you might, you know, at a minimum, my gut 8 feel is probably at least 15 minutes added, maybe a 9 quarter of an hour at the most to add that. 10 MR. BROOKMAN: Steve Nadel. 11 MR. NADEL: I'm curious because I'm not 12 familiar with this. Does this apply just to new 13 fixtures or if you have an existing fixture and a 14 ballast is being replaced do you have to -- does this 15 trigger that? Because we have relatively few new 16 fixtures. We have a lot of ballast replacements. 17 MR. HOWLEY: Right. I believe the code is if 18 you're doing a major retrofit you have to -- and you 19 have to pull a permit. That has to be changed. I 20 don't know how it affects individual fixtures. I could 21 go back and check that with their standards people. 22 MR. BROOKMAN: Keith, do you know how this 23 works? 24 MR. COOK: Yeah. It does affect fixtures for 25 field replacements, and so what the fixture EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064220 1 manufacturers are doing are actually shipping a 2 connector along with the fixture right now and then 3 it's field-installed. 4 MR. NADEL: Right. So my question was, does 5 it also affect ballast replacement. If you do not 6 replace the fixture, just replace the ballast -- 7 MR. COOK: No, it does not affect the ballast 8 right now. 9 MR. NADEL: Okay. Thank you. 10 MR. BROOKMAN: Yes, Paul. 11 MR. WALITSKY: Yeah, just from the real 12 world, we just relamped a school in Atlantic City. We 13 took about 20 minutes per fixture. And these were 14 ceilings about this height, and the local electrician 15 did it. He changed about -- about three fixtures an 16 hour is what he worked on. Just changing the ballast17 and changing the lamp. These were four-lamp and two18 lamp. 19 MR. BROOKMAN: Okay. 20 MR. WALITSKY: So that's current data right 21 from the field. 22 MS. BURK: Thank you. 23 MR. BROOKMAN: Great. Thank you. 24 MR. FERNSTROM: Gary Fernstrom, PG&E. Just a 25 clarification on that. I just heard that the EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064221 1 disconnect is shipped with the fixture. So, what's the 2 difference if I wire up a new fixture without a 3 disconnect or I wire up a new fixture with a 4 disconnect? Either way I'm connecting from the 5 building distribution system to the fixture. 6 (Pause.) 7 MR. BROOKMAN: We're not getting any response 8 to that. Ron Lewis. 9 MR. LEWIS: I think we're introducing an 10 element here that's not really in play, though, with 11 the fixtures. We're talking about ballasts and lamps. 12 I think the question was existing stock versus new. 13 So I don't want to have us chasing down roads to 14 collect a lot of data that we can't use. 15 It's a good point and I don't want to ever 16 cut off the conversation or input. I think in this 17 case the new fixtures and the disconnect in the 18 electrical code is for the luminaires, not for 19 replacing a ballast that's within the luminaire, 20 especially if it's only when it's a -- the same as most 21 of the other building codes. There are major retrofits 22 or renovations and new construction that are like half 23 or better, you know, a major thing where they need to 24 get a permit. We're talking about the majority of 25 replacements of lamps or ballasts are not going to fall EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064222 1 in that category. 2 So we can collect a lot of data and try to 3 introduce some artificial precision that's maybe not 4 going to lead us towards the efficacy standards that we 5 need to get to. 6 MR. HOWLEY: We can research this and get you 7 more specific data on exactly when it's required. It's 8 not real clear exactly in what cases it's required. We 9 have to research into this. 10 MR. BROOKMAN: Thanks, Joe. 11 MR. NADEL: Thank you. I understand the 12 relevance. 13 MR. BROOKMAN: Okay. 14 MS. BURK: Okay. Now let's talk about 15 electricity prices. The electricity prices DOE used in 16 this analysis were based on EIA Form 861. This form 17 provides the revenues of electricity sales for each 18 utility, what sector these revenues are based in, the 19 location of the utility, and the amount of customers 20 for that utility within each sector. 21 Based on this data, DOE developed electricity 22 prices for three sectors: the commercial, residential, 23 and the industrial sector, and for nine census 24 divisions in four large states. 25 In the life-cycle cost analysis, DOE used the EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064223 1 weighted average prices for the basic calculation and 2 the distribution in the Monte Carlo analysis. 3 MR. FERNSTROM: Gary from PG&E again. I wish 4 I see PG&E -- not PG&E but California at 9.9 cents. 5 Our average rates now are right around 14 cents. 6 MS. BURK: Okay. 7 MR. FERNSTROM: Across the board, all 8 sectors. 9 MS. BURK: This was based on 2007 data, but 10 if we get new data we can update these prices. 11 MR. FERNSTROM: Well, I can hardly believe 12 it's changed that much since then. 13 MR. COOK: I even thought the DOE-collected 14 data on the website showed 2007 California at 12.4 15 cents a kilowatt-hour. 16 PARTICIPANT: Could this be '06 data? 17 MS. BURK: I think it's EIA Form 861. Sorry. 18 I think it's 2005 data, actually. Yeah. It's the 19 most recent EIA form. If there's a new form that comes 20 out, we can update it -- 21 MR. FERNSTROM: Well, gee, electric prices 22 have gone up a lot, so I suggest you revisit this one. 23 MS. BURK: Okay. 24 MR. BROCKMAN: Steve. 25 MR. NADEL: Right. A better source may be I EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064224 1 think it's Electric Power Monthly that EIA publishes 2 every month. 3 MS. BURK: Okay. 4 MR. NADEL: The last time I looked at it, 5 they were already reporting some data, I think like 6 January 2008 or something. So you can do a 12-month 7 recent months and you'll be just a few months off. 8 MS. BURK: Okay. Great. 9 MR. BROOKMAN: Okay. 10 MS. BURK: All right. For electricity price 11 trends, DOE used information from EIA's Annual Energy 12 Outlook from 2007. DOE used the electricity price13 trends for both the reference high-growth and low14 growth cases. The reference cases used for the basic 15 calculation in the high-growth and low-growth are used 16 as sensitivities. This is an example of the trends 17 shown for each of the three sectors in each of the 18 three cases. 19 MR. FERNSTROM: So, Gary from PG&E again. I 20 don't think this stands the laugh. test. I mean, it 21 would show that in real terms electricity prices aren't 22 going to increase in the next 20 years. I think with 23 all the concern about carbon, you know, carbon trading 24 and so on, I don't think that this is at all realistic. 25 MR. BROOKMAN: Yes, Steve. Go ahead. It EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064225 1 would be helpful if you could say how you might modify 2 this. 3 MR. NADEL: Okay. Two comments. First, 4 clearly, you should use the most recent AEO. 5 MS. BURK: Right. 6 MR. NADEL: And the just partially released 7 AEO -- 8 MS. BURK: 2008. 9 MR. NADEL: -- 2008 revised shows a more 10 realistic trend. It still shows a modest decrease in 11 future prices, but it doesn't show the dramatic 12 decrease that's shown here. 13 MS. BURK: Right. 14 MR. NADEL: The other thing is you may want 15 to take a basket of other forecasts because EIA is 16 relatively unique in expecting significant price 17 declines in energy in future years compared to most 18 price forecasts. 19 MS. BURK: Okay. Thanks for your comment. 20 MR. FERNSTROM: So, just one more comment. 21 Gary from PG&E. I wish this were true. 22 (Laughter.) 23 MR. BROOKMAN: Does this fall in the category 24 of woefully inadequate? 25 (Laughter.) EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064226 1 MR. BROOKMAN: Sorry. Okay. 2 MS. BURK: All right. Now let's talk about 3 discount rates another input to the life-cycle cost 4 analysis. Just to remind you, discount rates are used 5 to bring operating costs and other costs, like residual 6 value or replacement costs, to present value in the 7 analysis. Discount rates are based on the finance cost 8 of raising funds to purchase products. It involves the 9 cost of any debt incurred to purchase the product or 10 the opportunity cost of any equity used to purchase the 11 product. 12 For the residential sector, DOE developed a 13 weighted average rate associated with household equity 14 and household debt. Equity ranged from savings bonds, 15 stocks, and CDs, and debt ranged from credit cards and 16 home equity loans. The primary source of data for this 17 analysis was the Federal Reserve Board Survey of 18 Consumer Finances. DOE looked at this source for a 19 range of years, from 1989 to 2004, to capture all the 20 economic cycles that may occur over a long period of 21 time. The average discount rate from these sources was 22 found to be 5.6 percent. 23 For the commercial sector, DOE based the 24 discount rates on the weighted average cost of capital 25 to a firm to obtain debt and equity financing. The EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064227 1 cost of equity was calculated using the Capital Asset 2 Pricing Model. The cost of debt was based on long-term 3 corporate bonds. The average commercial discount rate 4 was found to be 6.2 percent, and the average industrial 5 discount rate was found to be 7.5 percent. 6 MR. BROOKMAN: Comments? Since discount 7 rates are always an interesting subject. Comments on 8 these before we move on? 9 MR. NADEL: I think the risk premium has gone 10 up lately. 11 MR. BROOKMAN: Joe, comment? No? 12 MR. HOWLEY: Yeah, they're fine. 13 MR. BROOKMAN: They're fine? Yeah? 14 MR. HOWLEY: I mean, they vary all the time, 15 but they're reasonable. 16 MR. NADEL: This is Steve. I would note that 17 these are roughly in line with the -- first, this -- I 18 assume these are real discount rates, not nominal. 19 MS. BURK: Real, yeah. 20 MR. NADEL: These are roughly in the line 21 with what the utilities are using these days. Maybe 22 they're a little high, but roughly in line. 23 MR. BROOKMAN: Thank you. That's helpful. 24 Okay. 25 MS. BURK: Okay. Let me move on. So these EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064228 are other inputs to the life-cycle cost and payback 2 period analysis. DOE had to estimate lamp lifetime for 3 all of its products. For fluorescent lamps, DOE used 4 lamp lifetimes based on the manufacturing literature 5 based on a rated life for a three-hour start lamp. DOE 6 used a weighted average of group and spot relamping 7 rates where group replacements were made at 75 percent 8 of the rated life and spot replacements were made at 9 100 percent of the rated life, the end of the life of 10 the lamp. 11 For incandescent reflector lamps, DOE based 12 the lifetime on the manufacturing literature. 13 The ballast lifetime, as I said before, was 14 based on information from the 2000 ballast rule, which 15 was approximately 49,000 hours. Again, DOE assumed no 16 repair or maintenance costs. However, DOE does account 17 for lamp replacements in the analysis if the lamp dies 18 before the analysis period ends. 19 The analysis period, as I said before, is the 20 time span over which the life-cycle cost calculation is 21 calculated. It is based on the longest-lived lamp in a 22 baseline lamp in a product class. The analysis period 23 in years is equal to the life of the lamp in hours 24 divided by the annual operating hours of the lamp for a 25 given sector or building. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064229 1 So if a lamp were operating in a closet, it 2 may last 16 years. Then the analysis period would be 3 16 years. But if it were operated in a kitchen, it may 4 only last, say, two years, and the analysis period 5 would be two years. 6 MR. BROOKMAN: Tom Eckman. 7 MR. ECKMAN: Tom Eckman, Northwest Power and 8 Conservation. Just to clarify the statement that you 9 do include lamp replacement costs. So the operation 10 and maintenance cost of differential life lamps is 11 included so that the differential is present-valued in 12 there. 13 MS. BURK: Yes. 14 MR. DELASKI: Just to follow up on Tom's 15 question, I don't follow that because it says that 16 based on the longest-lived lamp in a product class. I 17 think you inserted longest-lived baseline. 18 MS. BURK: Right. That was a mistake in the 19 presentation. 20 MR. DELASKI: So it's the baseline lamp. 21 MS. BURK: It's the baseline lamp. 22 MR. DELASKI: So, if the replacement lamp 23 lasts longer -- 24 MS. BURK: Then you just use a residual 25 value, and there are no replacements within the EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064230 1 analysis period. But in some cases the analysis period 2 may last, say, for the eight-foot, single-pin, slimline 3 lamp, the eight-foot T8 lamp is 15,000 hours. It's the 4 longest-lived lamp in that product class. However, 5 some of the T12 lamps only last 12,000 hours. So then, 6 for those lamps, the lamp replacement would occur in 7 the analysis period because they would die before the 8 analysis period ends. 9 Does that answer your question? I'm sorry. 10 MR. DELASKI: It does, I think. But I think 11 the point that I wanted to raise is that the user who 12 has the longer-lived life is getting a benefit in the 13 sense that they have deferred that replacement for a 14 period of time. 15 MS. BURK: Right. 16 MR. DELASKI: And that's not captured in the 17 analysis, I don't think. 18 MS. GUPTA: It is, because you don't have to 19 -- 20 MR. BROOKMAN: Go ahead. Mimi, go ahead. 21 MS. GUPTA: It is, because the shorter-lived 22 lamp you have to purchase again. So you incur another 23 initial cost for that lamp. 24 MS. BURK: And then the residual value. And 25 that's discounted, so. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064231 1 MR. DELASKI: Then you count back -- 2 MS. BURK: Right. 3 MR. DELASKI: -- the residual value on the 4 baseline lamp which had been purchased -- 5 MS. BURK: Right. But the residual value 6 would occur at a later time, so there is an additional 7 cost of purchase to the shorter-lived lamp. Does that 8 make sense? 9 MR. BROOKMAN: Steve Nadel. 10 MR. RIVEST: It's all there. 11 MR. NADEL: Just a couple things to clarify 12 on fluorescent lamp life. I'm assuming you used a base 13 lamp, which might be a T12 or T8, which is going to be 14 somewhere around 20,000, but that many of the more 15 advanced-options have 24- or 30,000 and you just 16 prorate? 17 MS. BURK: Right. That is correct. 18 MR. NADEL: That's one question. The other 19 thing is, what did you do about ballasts and instant 20 start versus rapid start versus program start, which do 21 affect lamp life? 22 MS. BURK: We did not take that into account 23 in the analysis. However, if anybody can give us input 24 on how ballasts -- the operation of a ballast would 25 affect the lamp lifetime. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064232 1 MR. BROOKMAN: You would want a distribution 2 based on current ballast sales or something? 3 MS. BURK: Well, we would want how -- a rapid 4 start ballast may affect the lifetime versus an instant 5 start ballast of the lamp. 6 MR. HOWLEY: It's very difficult to analyze 7 because it gets to number of starts, which is 8 impossible to really have any accuracy with. So I 9 think the method that you used is probably reasonably 10 accurate for lifetimes based on these responses. 11 MR. BROOKMAN: Say it again loudly. It would 12 be accurate? 13 MR. HOWLEY: The method used appears to be 14 reasonably accurate for what you're doing in terms of 15 taking into account lifetimes. There are many, many 16 variables in the lifetime equation, is what you're 17 hearing here. You have to pick some kind of baseline 18 to analyze on. 19 MR. BROOKMAN: Okay. Steve, were you 20 finished? 21 MR. NADEL: No. It may well be more 22 complicated, and I agree with Joe. It's so complicated 23 it's not going to make much difference. I was just 24 curious what you had done, just trying to understand. 25 MR. BROOKMAN: Okay. Additional questions on EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064233 1 this point? 2 (No response.) 3 MR. BROOKMAN: Okay. 4 MS. BURK: All right. Thank you. Now let's 5 go on to a few of the results of the life-cycle cost 6 analysis. This table displays the results for one of 7 the baselines. Again, we analyzed several different 8 baselines within a product class. This is for the 34- 9 watt T12 baseline lamp, which is in the four-foot, 10 medium, bi-pin product class. The event analyzed shown 11 here is for the standards-induced retrofit event. 12 So in this event, the baseline system incurs 13 the cost of the lamp, but the standards case systems 14 incur the cost of both the lamp and the ballast. 15 In this scenario one can see that is not cost 16 effective to replace your magnetic T12 system with an 17 electronic T12 system when you wouldn't have had to 18 otherwise. But it would be cost effective to replace 19 your magnetic T12 system with an electronic T8 system - 20 - with certain electronic T8 systems. 21 The highest life-cycle cost savings for this 22 event occurs at Candidate Standard Level 5. There are 23 three energy-saving options at this event: the 32-watt 24 lamp, the 28-watt lamp, and the 25-watt lamp paired 25 with their respective ballasts. The most cost EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064234 1 effective option at CSL 5 is for the 28-watt lamp 2 paired with a 0.78 ballast factor ballast. uts reduction in mean lumen out d 3 Y p , ou o see a 4 approximately 1.3 percent less than that of the 5 baseline system. However, the life-cycle cost savings 6 is greater than 10 percent of the life-cycle cost of 7 the baseline system. 8 MR. RIVEST: Mike Rivest. Can you go back? 9 An important thing to point out here is that we're 10 presenting the results of a whole bunch of potential 11 choices at each efficiency level. When it comes time 12 to do the national impacts analysis, we have to put 13 weights and estimate what proportion of people will 14 choose, let's say at CSL 5, the 28-watt lamp versus the 15 25. That's a key driver, as you can imagine, to the 16 energy savings calculation. 17 MR. BROOKMAN: Okay. Thank you. 18 MS. BURK: The next slide shows the results 19 for the same baseline lamp but for another event, the 20 ballast failure event. In this event, a lamp and 21 ballast is incurred in both the baseline and standards 22 case systems. The baseline system is an electronic T12 23 system, and if the consumer still wanted to purchase a 24 baseline T12 system they would be forced to purchase an 25 electronic system because magnetic ballasts would no EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064235 1 longer be available in the year 2012. 2 In the standards case, one can see it is not 3 cost justified to replace that 34-watt T12 electronic 4 system with a more efficient 34-watt T12 lamp on a 5 lower ballast factor ballast. However, it is cost 6 justified to replace that system with a 32-watt T8 7 system. Again, the highest life-cycle cost savings 8 occur at Candidate Standard Level 5. 9 As Mike referred to earlier, DOE analyzes -- 10 puts weights to these results in the national impact 11 analysis. DOE presents all the results for all the 12 events in the life-cycle cost analysis, however DOE 13 chooses not to aggregate these results in this analysis 14 because it would not represent all the options 15 available to consumers in the real market. For 16 example, non-energy saving options are not -- we do not 17 allow that in the life-cycle cost analysis, as well as 18 options that do not maintain lumen output. 19 DOE accounts for all of these options for 20 many events in the national impact analysis, and this 21 analysis takes place over a 30-year analysis period. 22 MR. BROOKMAN: Comments on these analyses? 23 Yes, Andrew. 24 MR. DELASKI: I'm looking at the ANOPR 25 document, and in the ANOPR document you -- I may not EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064236 1 have found this yet, but you report results of Event 2 2 and Event 3 but you don't report results for Event 4 or 3 5. 4 MS. BURK: Right. 5 MR. DELASKI: Why is that? 6 MS. BURK: Mike Rivest, you can take this. 7 MR. RIVEST: It was a deliberate attempt at 8 focusing people on the methodologies and the inputs and 9 not so much on the results. Because, obviously, you 10 know, at this stage we prefer to improve our 11 methodologies and the inputs. 12 So there was that, and then there was just 13 the practical consideration that there are so many 14 results to present, and all of them are in the TSD. 15 You'll also find that in the notice we 16 aggregate results. Like, here we show them system by 17 system, whereas in the ANOPR we just showed a range for 18 each CSL. 19 MR. DELASKI: Do you expect that in the NOPR 20 you would show the results for more -- the full set of 21 -- 22 MR. RIVEST: A much more full set. I don't 23 know if they will all be there, but quite possibly. I 24 think they would have to be, frankly. 25 MR. ECKMAN: The TSD shows the distributions EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064237 1 as well, right? 2 MR. RIVEST: Yes. 3 MR. BROOKMAN: Tom Eckman -- 4 MR. RIVEST: And the sensitivities. 5 MR. BROOKMAN: The TSD shows the 6 distributions. Yes, he doesn't need to speak into the 7 mic. I'll speak for him. Thank you, Mike Rivest. 8 Okay. So then --9 MS. BURK: Moving on, so these are the life10 cycle costs and some life-cycle cost and payback period 11 results for the incandescent reflector lamp product 12 class. Specifically, this is for the 90-watt PAR 38 13 baseline lamps. Life-cycle cost savings typically 14 increase as the incandescent reflector lamp candidate 15 standard level rises. The highest life-cycle cost 16 savings occurs for the improved halogen infrared 17 reflector lamp at Candidate Standard Level 3. 18 As Mike Rivest alluded to, additional results 19 for fluorescent lamps and incandescent reflector lamp 20 life-cycle cost results can be found in the Technical 21 Support Document in Chapter 8, which can be found 22 online.23 The results of the sensitivities to the life24 cycle cost analysis can also be found online in 25 Appendix 8B of the Technical Support Document. The EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064238 1 appendix shows results for the Monte Carlo runs, which 2 includes the variability and operating hours and sales 3 tax and electricity prices and discount rates. 4 DOE also analyzed the high and low lamp 5 prices developed in the product price determination. 6 For incandescent reflector lamps, DOE used the 7 sensitivity developed in the energy use 8 characterization of the high and low operating hours in 9 the residential sector. For fluorescent lamps, there 10 is a sensitivity that assumes the ballast price is zero 11 in all cases. 12 There are other possible sensitivities that 13 users can use in the life-cycle cost analysis that are 14 not shown. For example, users may be able to select 15 high and low growth electricity price trends. They can 16 vary the start year in the analysis. They can vary the 17 analysis period as a multiple of the baseline lamp 18 service life and vary the sector for each lamp type. 19 So, DOE seeks comment on any other aspects 20 related to the life-cycle cost and payback period 21 analysis. 22 MR. BROCKMAN: So as Mike Rivest says, these 23 are illustrative. They are comments -- they want your 24 comments on the methodologies, particularly how they 25 might be enhanced, improved. So that's a good starting EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064239 1 point for additional comment. Yes, Tom Eckman. 2 MR. ECKMAN: Tom Eckman, Northwest Power and 3 Conservation. This is down in the esoterics, but you 4 have this take-back or rebound effect in the analysis 5 which cites a study from the year 2000. I'll quote. 6 It says, "For 100 percent increase in efficiency, the 7 value of take-back or rebound was between five and 12 8 percent." They're using eight and a half percent. 9 I'm not quite certain that 100 percent increase in 10 efficiency is in the range of what we're looking at 11 here. So, picking a number that was between five and 12 12 doesn't seem to track. Maybe I'm misreading this. 13 MR. BROOKMAN: Go ahead. Mimi. 14 MS. GUPTA: Well, that's more of a national 15 impacts issue. We don't take into account the rebound 16 effect in the life-cycle cost analysis. 17 MR. BROOKMAN: Mike Rivest. 18 MR. RIVEST: And to answer your question 19 specifically, that's just to arrive at the elasticity. 20 So it becomes 8.5 percent. 8.5 is not the number 21 we're using. 22 MR. ECKMAN: It's not an absolute number. 23 24 25 MS. BURK: Right. MR. RIVEST: Right. MR. ECKMAN: Okay. EXECUTIVE COURT REPORTERS, INC.

(301) 565-00642401 MR. BROOKMAN: Other comments on the life2 cycle cost and payback period analyses, particularly 3 the methodologies in play here. Steve Nadel. 4 MR. NADEL: Minor comment. If you go back 5 two slides to the one that said 90. I believe that's a 6 75-watt because the base case is 75. 7 MS. BURK: Oh. Very true. Good catch. 8 MR. BROOKMAN: They are paying attention at 9 4:20 in the afternoon. 10 (Laughter.) 11 MR. BROOKMAN: Okay. 12 PARTICIPANT: Let the record show. 13 (Laughter.) 14 MR. BROOKMAN: We're all impressed. We are. 15 So, additional comments on life-cycle cost and payback 16 period analyses, plural? 17 (No response.) 18 MR. BROOKMAN: Okay. So I did a brief 19 consultation. There is one more slide -- why don't you 20 flash that one -- in this segment. I think we've 21 covered the following four issues: operating hours, 22 general service fluorescent lamp energy consumption, 23 life-cycle cost calculation, and installment costs. I 24 think we've delved into all of those. Anybody that has 25 any additional comments on those, those would be EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064241 1 welcome now. 2 (No response.) 3 MR. BROOKMAN: So then, I consulted with Ron 4 and Linda just about half an hour ago. The agenda as 5 written says we would adjourn at four. It's now 4:20. 6 We wanted to release anybody that wanted to leave at 7 this point. We've covered one more topic, that being 8 the life-cycle cost analyses and payback. 9 Then we had intended to, today, and I guess 10 our intention is -- that is, if anybody wants to stay, 11 to just stay here and keep going through this content 12 now and work 'til, say, five o'clock. Then -- so we 13 get as much of this covered, but also to provide an 14 opportunity, for those of you that were planning on 15 leaving as the agenda reflects, to leave now. 16 Okay. So there's an option. No harm, no 17 foul. You may leave, for those that wish to leave, but 18 otherwise we're going to keep plugging on, okay? Okay. 19 So, having said that. 20 MS. BURK: Thank you. So Mimi is going to 21 talk about the national impact analysis. 22 National Impact Analysis 23 Mahima Gupta 24 (PowerPoint presentation.) 25 MS. GUPTA: All right. So I'm going to talk EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064242 1 about the national impact analysis. So this 2 presentation is composed of both the shipments analysis 3 and the national impact analysis. 4 In the shipments analysis, DOE projects -- 5 forecasts lamp shipments and the product mix of the 6 shipments and stock over the analysis period, which is 7 2012 to 2042, in both the base case and the standards 8 case. 9 In the national impact analysis, DOE uses 10 those shipment forecasts and product mixes to calculate 11 the national energy savings from general service 12 fluorescent and incandescent reflector efficacy 13 standards at different levels. It also estimates the 14 national economic impact on the nation, or net present 15 value, from general service fluorescent lamps and 16 incandescent reflector lamp efficacy standards. 17 So first, I'm going to discuss a little bit 18 about the general service fluorescent lamp shipments 19 forecast. Here we have a little flow diagram of how 20 the shipments were forecasted. The first step in 21 calculating shipments was establishing the number of 22 fluorescent lamps in inventory in 2011. Right here. 23 To do that, DOE used NEMA historical shipments from 24 2001 to 2005, extrapolated those shipments to 2011, and 25 then used an average lamp lifetime to calculate the EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064243 1 number of lamps in the inventory. 2 To establish the average lamp lifetime, DOE 3 used what we call market share matrices, which 4 basically characterize the market shares of the lamp 5 and ballast inventory in 2011. So this is very much a 6 key input to the national impact analysis, and I'm 7 going to talk more about it in detail later, but I'd 8 just like to highlight that is very important. 9 Then, using an assumption regarding the 10 number of lamps per system and the product mix, the 11 number of systems in the inventory in 2011, the total 12 lumen output of those systems was calculated, as you 13 can see right here, and here. 14 At this point, shipments were calculated to 15 meet a lumen demand due to new construction and to 16 replace lamps and ballasts that have retired. A key 17 input into those calculations is the second market 18 share matrix for the -- to characterize the market 19 shares of lamp and ballast shipments from 2012 to 2042. 20 So this is another very important input into our 21 national impacts analysis. 22 So now I'm going to go over some of these 23 inputs in more detail and assumptions that DOE used to 24 calculate their fluorescent lamp shipments. 25 MR. BROOKMAN: Mike Rivest. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064244 1 MR. RIVEST: If we go back to the meeting we 2 had for the framework document that we had discussions 3 about how we would forecast the lamps, if we would just 4 essentially go straight to a lamp forecast or if we 5 would create a ballast inventory model. 6 We found that because of the different events 7 and the completely different economics of each type of 8 event, to be able to keep track of the proportion of 9 lamp replacements versus ballast replacements versus 10 new construction, we could only do that by creating 11 this ballast inventory model. So that's why this is a 12 little more complicated, probably, than any of us would 13 have liked. 14 Also, the market share matrix here is in 15 other rules what we call distribution of efficiencies. 16 This is, again, more complex because it's not just a 17 matter of tracking the efficacy of lamps but it's the 18 efficacy of lamps correlated with the ballast on which 19 it's installed. So it's got an extra dimension to it. 20 This is probably the most important thing in 21 this whole analysis that we need to receive comment on, 22 is those market share and matrices that are shown here 23 in green. That and, obviously, the engineering 24 analysis, the actual selection of ballasts and lamp 25 pairings. EXECUTIVE COURT REPORTERS, INC. (301) 565-0064245 1 MR. BROOKMAN: Thanks for that bit of 2 emphasis. 3 MS. GUPTA: So, as I said before, the first 4 step in establishing fluorescent lamp shipments is 5 calculating the initial stock of fluorescent lamps and6 ballasts in 2011, and we did that by using the NEMA7 provided historical fluorescent lamp shipment data. 8 DOE assumed that NEMA shipments represent 9 approximately 90 percent of the total fluorescent lamp 10 shipments in the U.S. and scaled historical shipments 11 accordingly. And then DOE calculated the 2011 lamp 12 stock from average lifetimes of lamps determined by the 13 assumed market shares of the lamp inventory in 2011, 14 which I'll discuss soon. 15 But these were the lamp stocks calculated for 16 each type of lamp. So you can see the four-foot T8 17 medium bi-pin lamps are overwhelmingly the largest 18 market share. Also important to note is the eight-foot 19 T8 recessed double-contact high output lamps are 20 extremely small comparatively. 21 MR. BROOKMAN: So before we move on, what 22 about those numbers there? Tom. 23 MR. HOWLEY: This is Joe. I have -- 24 MR. BROOKMAN: Oh, Joe. Go. 25 MR. HOWLEY: -- a question. It says 2011 EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064246 1 NEMA -- but NEMA provided data from 2001 to 2005. Did 2 you extrapolate the trends? 3 MS. GUPTA: Right. So, what we did is that 4 we took the 2001 to 2005 data and generally, in most 5 cases, we took a linear fit of -- well, actually, in 6 all cases. Sorry. In all cases we took a linear fit 7 of the historical shipment data and then, based on the 8 average lamp lifetime -- for example, if the average 9 lamp lifetime was six years, then we'd sum up six 10 previous years of shipments from 2011. 11 MR. HOWLEY: So you continued to assume that 12 T8 would increase and T12 would decrease. 13 MS. GUPTA: Exactly. 14 MR. HOWLEY: Okay. Thanks. 15 MS. GUPTA: Yeah, just a linear fit to 16 historical data. 17 MR. BROOKMAN: Go ahead. Keith. 18 MR. COOK: Keith Cook, Philips. I guess one 19 concern, though, is I'm not sure you would see the 20 impact for T5s on this shipment and market because T5 21 come in just the last couple years. It had a 22 significant growth rate, though. So it's getting that 23 growth out of something. 24 MR. BROOKMAN: So I'm sure the Department 25 would welcome those as comments, written comments, if EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064247 1 you can particularly describe what that growth rate is. 2 Is that in the current -- in the new NEMA data? 3 MR. HOWLEY: Yeah, we do track T5s, but as a 4 percentage they're still a very small percent of this 5 market. They're growing fast, as Keith mentioned, but 6 it's off a low base so far. 7 MR. BROOKMAN: Okay. Any additional comments 8 on these numbers as written? 9 (No response.) 10 MS. GUPTA: All right. So after establishing 11 an initial stock of lamps, DOE made several assumptions 12 to calculate shipments. With regard to four-foot 13 medium bi-pin lamps, or lamp and ballast shipments, in 14 addition to shipping lamps to replace failed lamps DOE 15 also modeled shipments of new systems, lamp and ballast 16 systems, due to new construction and also to replace 17 failed ballasts. 18 With regard to new construction, DOE created 19 a demand for new construction by modeling an 20 exponential growth of lumens serviced by four-foot 21 medium bi-pin and eight-foot single-pin slimline lamps. 22 DOE used a 1.6 percent annual growth rate, which it 23 calculated from commercial building floor space growth 24 from the CBECS report. 25 An important point to note here is that all - EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064248 1 - in the national impact analysis all new construction 2 results in the purchase of a four-foot T8 lamp and 3 ballast system. 4 DOE also modeled shipments of new four-foot 5 medium bi-pin systems when either a four-foot T12 or a 6 four-foot T8 ballast failed. For both ballast 7 replacement and new construction, DOE assumes that new 8 system shipments are composed entirely of four-foot T8 9 systems as opposed to four-foot T12 systems. This 10 assumption was made considering the 2000 ballast 11 rulemaking banning of magnetic ballasts. 12 In addition, the four-foot medium bi-pin 13 model currently assumes commercial operating hours and 14 electricity prices. 15 MR. BROOKMAN: Steve Nadel. 16 MR. NADEL: So if I understand the 17 assumption, it's when an individual ballast fails. 18 Let's say you have a bunch of T12 ballasts. If one 19 fails, they will replace it with a T8 and so they will 20 either group relamp or mix T8 and T12. That's the 21 assumption? 22 This room, I'll say. This is T8. But let's 23 say it was all T12. If that ballast fails, your 24 assumption is that they will replace it with a T8 25 ballast -- EXECUTIVE COURT REPORTERS, INC. (301) 565-0064249 1 MS. GUPTA: Exactly. 2 MR. NADEL: Okay. 3 MS. GUPTA: I mean -- yeah. 4 MR. NADEL: What? 5 MS. GUPTA: That is the assumption. It's a 6 one-to-one replacement. 7 MR. NADEL: But you're assuming every failed 8 T12 ballast will be replaced with a T8 in the base 9 case. 10 MS. GUPTA: Yes. 11 MR. NADEL: That may be a little aggressive 12 on the T8 end. I wish it were so. I don't know what 13 your experience has been. 14 MR. BROOKMAN: Well, presumably they reach a 15 tipping point, right, where they relamp everything. 16 But in the meantime you -- go ahead. 17 MS. GUPTA: So you believe -- just to 18 clarify, you believe people will be purchasing T12 19 electronic systems to replace their T12 ballast that 20 has died? 21 MR. NADEL: I would say there will be some of 22 that when individual ballasts fail. Yes, whenever you 23 do a renovation, whenever you do a group reballasting, 24 no question. But, you know, rather than mix T12 and 25 T8, particularly if they have all halophosphor lamps, EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064250 1 you know, they may not -- there will be some T12s just 2 to keep a room looking the same. 3 MS. GUPTA: Okay. 4 MR. NADEL: It may not be a big enough factor 5 to really affect your calculations. I don't know. 6 MR. BROOKMAN: Joe, yeah. 7 MR. HOWLEY: Yes. The reality is we really 8 aren't sure what people will do once they no longer can 9 get a T12 magnetic ballast. But I would think you're 10 going to have all three events going on, actually. 11 We've heard of some of that already, where in some 12 cases people just are doing a fixture at a time in a 13 room, which is -- and so they do actually mix T12s and 14 T8s. 15 In other cases, they're doing a room at a 16 time. So if enough lamps are out, they'll let, you 17 know, 30 percent of the lamps go out until finally 18 they'll go in and just replace the whole room, and 19 they'll just do room by room. In other cases there 20 will be grouper lamps, and then, finally, there will be 21 situations where people try to get by with electronic 22 T12 ballasts. 23 But I think that actually is probably the 24 least likely because the volume of those parts are 25 going to be very low. The prices are going to be high. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064251 1 There's going to be a big incentive for them to switch 2 to T8 and electronic because that will be the commodity 3 low price ballast out there. 4 MR. LEWIS: Mimi, when does this start? The 5 date? 6 MS. GUPTA: 2012. 7 MR. LEWIS: 2012. So it's a ways out still 8 to go. So it's not what is today but a projection as 9 to what may be happening at that time. You've got the 10 trend line that you've already been plotting showing 11 the increased growth in the T8s and the takeover. So 12 the occurrences ought to be considerably fewer at that 13 point. 14 MR. HOWLEY: Yeah. It appears that you're 15 estimating maybe 20 percent of the market is T12 at 16 that point. So it's really what's -- what do the last 17 20 percent who have absolutely refused to switch to T8 18 do? These are the real laggards that you're finally 19 going to turn over. We're unsure what they're going to 20 do because they've never done anything. 21 (Laughter.) 22 MR. BROOKMAN: That exchange was Ron followed 23 by Joe. So, Mimi. 24 MS. GUPTA: Yeah. I mean, if we were to 25 incorporate that effect of T12s being replaced with T12 EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064252 1 electronics, we would need information on what portion 2 of people are going to do that in order to -- 3 MR. BROOKMAN: But, Joe, to reinforce what 4 you just said, your projection is that by -- did you 5 say 2012 -- 20 percent will -- that's what will be -- 6 that's what you project will be left. Yeah, okay. 7 MR. HOWLEY: Right. 8 MR. NADEL: This is Steve. Absent any data, 9 yeah, 80 percent T8, 20 percent T12 is roughly about 10 right. 11 MS. GUPTA: Oh. So what you were saying is 12 that 20 percent of the people will be replacing their 13 T12s with Tl2s? I thought you were saying that the 14 market share that we presented was about 20 percent. 15 MR. HOWLEY: Right. What you're saying is by 16 2011 about 20 percent of the installed stock -- 17 MS. GUPTA: Right. 18 MR. HOWLEY: -- will be T12s, and they will 19 be forced by, presumably, possibly, by a rulemaking to 20 do so. 21 MR. BROOKMAN: Okay. 22 MR. RIVEST: So, really, the information we 23 need is what percentage of people in 2012, when faced 24 with a ballast replacement and no longer have a 25 magnetic ballast to purchase, what percentage will buy EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064253 1 a T12 electronic versus a T8 electronic. Right now the 2 assumption is zero. 3 MS. GUPTA: Exactly. 4 MR. BROOKMAN: Ron Lewis. 5 MR. LEWIS: Just to add to that is at that 6 time I'm sure that because there will be fewer of them 7 available that the price differential will change, that 8 people -- to buy a 'magnetic won't be as low of a point 9 anymore because the scarcity factor and people that 10 need it at that point, and it's been outlawed and not 11 manufactured any longer. You're going to have a lot of 12 different dynamics. So I think the momentum and the 13 inertia is going to be certainly towards the T8. 14 MR. NADEL: Yeah. No, that's already 15 starting. If I recall, and you guys can tell me if I'm 16 wrong, I believe that a T8 ballast, a basic, generic T8 17 ballast, is generally cheaper than a generic T12 18 ll t b as . a 19 MR. BROOKMAN: Okay. So -- 20 MS. GUPTA: All right. So in terms of the 21 base case shipment forecast assumptions for eight-foot 22 single-pin slimline lamps, historical shipments showed 23 minimal growth in that market and actually a decline in 24 the total eight-foot single-pin slimline lamp 25 shipments. Therefore, DOE did not model any new EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064254 1 construction in that market. 2 In terms of ballast replacement, DOE assumed 3 a 14-year ballast service lifetime and that no new 4 eight-foot T12 single-pin slimline magnetic ballasts 5 are purchased after 2009 due to the 2000 ballast 6 rulemaking. 7 In addition, as eight-foot T12 single-pin 8 slimline ballasts retire, 10 percent of those systems 9 are replaced with eight-foot T8 systems and 90 percent 10 are replaced with two-lamp four-foot T8 medium bi-pin 11 lamp and ballast systems. DOE chose those 10 percent 12 and 90 percent numbers to be consistent with the slope 13 of increase of eight-foot T8 lamp shipments. 14 As eight-foot T8 single-pin slimline ballasts 15 retire, new eight-foot T8 single-pin slimline lamp and 16 ballast systems are purchased as system replacements. 17 Currently, for eight-foot single-pin slimline 18 systems, the model assumes commercial operating hours 19 and electricity prices. 20 Are there any questions about this slide? 21 MR. BROOKMAN: Steve Nadel. 22 MR. NADEL: Okay. Comment. I agree that 23 there is a trend toward more use of four feet and less 24 of eight-foot. But if I understand, generally 25 speaking, you need a new fixture to go from -- so 90 EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064255 1 percent of people -- 2 MS. GUPTA: No, it's a retrofit -- 3 MR. NADEL: Oh, they are retrofit with the 4 little double tombstone? Still, it does seem high, 5 90/10. I would expect more eight-foots than just 10 6 percent. 7 The other thing I'd say is, you're assuming 8 everybody switches from T12 to T8 even though the 9 market is dominated by T12. More so than the four-foot 10 category, I would expect some people to stick with the 11 T12s. 12 MR. BROOKMAN: Joe. 13 MR. HOWLEY: Joe Howley. I also have a14 comment. When you do go from an eight-foot to a four15 foot, it's not just a simple lamp and ballast change. 16 I mean, it either is, as Steve said, a new fixture or 17 it's what we call a retrofit kit, where they actually 18 have a kit with additional sockets and features. I 19 guess this question was, was that additional cost put 20 into the analysis, the fact that it's not just simply a 21 lamp and a ballast. 22 MS. GUPTA: No, that's currently not in the 23 analysis, but if you have information about that, 24 additional costs can be incorporated. 25 MR. BROOKMAN: The cost of the kit, the cost EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064256 1 of the labor, right? 2 MR. HOWLEY: Yeah. There would be an 3 additional cost either for a new fixture or a kit. 4 It's not just lamps and ballasts. So that should be 5 put into any kind of conversion model on this. 6 MS. GUPTA: Okay. Thank you. 7 MR. BROOKMAN: Steve. 8 MR. NADEL: We're talking now a base case, so 9 I think including the labor cost is less important 10 because it is part of the base case. Certainly, if you 11 have a case where the base case is an eight-foot and 12 you're switching to a four-foot, you have to include 13 it. 14 MR. HOWLEY: That's what I'm talking about. 15 MR. BROOKMAN: Okay. 16 MS. GUPTA: All right. And then in terms of 17 eight-foot recessed double-contact high output, the 18 shipment forecast. This may have to be reevaluated 19 considering some of the comments we got. We assume an 20 inventory of T12 lamps installed on electronic ballasts 21 right now. Because historical shipments -- DOE 22 projects that eight-foot high output shipments will be 23 relatively flat in the future, and DOE assumed that the 24 new construction in this market is serviced by other 25 technologies, such as T5 lamps. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064257 1 In addition, as I said earlier -- well, I 2 don't know. I don't think I said it earlier. Sorry. 3 (Laughter.) 4 MS. GUPTA: Because T8 lamps accounted for 5 less than 2 percent of the total eight-foot recessed 6 double-contact high output shipments in 2005, DOE did 7 not model the initial inventory of those lamps. 8 In terms of ballast replacement, DOE used a 9 10-year ballast service lifetime. As eight-foot T12 10 recessed double-contact high output ballasts retire, 11 new electronic eight-foot T12 recessed double-contact 12 high output lamp and ballast systems are purchased as 13 system replacements. 14 Currently, for the high output systems, the 15 model assumes industrial operating hours and 16 electricity prices. 17 Any questions? 18 (No response.) 19 MS. GUPTA: Okay. So now I'm going to talk a 20 little bit about the base case market share matrices. 21 I'd like to just flip back to the flow diagram real 22 quick so I can show you where they were. So, back on 23 Slide 4. You can see the green boxes are the market 24 share matrices, and Mike emphasized that these are very 25 important inputs into our analysis. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064258 1 So we have two types of market share 2 matrices, one that establishes the product mix of the 3 lamp and ballast inventory in 2011 and one that 4 establishes the product mix of new systems shipped from 5 2012 to 2042. 6 The shipment model assumes that when a lamp 7 fails it is replaced with that same lamp to maintain 8 the same system throughout that ballast lifetime. But 9 when a ballast fails, it can be shipped with a new 10 system and maybe a more efficacious system. This is in 11 the base case only. 12 So key inputs into the matrices are the 13 distribution of lamp wattages -- for example, what 14 percentage of people are at the 32-watt lamp, the 30- 15 watt, the 28-, and the 25-watt lamp -- the lamp 16 efficacy distributions across CSLs, the ballast factor 17 distributions, how many people are 0.88 ballast, 0.78 18 ballast, 0.75 ballast, any other ballast factors, and 19 the correlation of the three above properties to obtain 20 total system distributions. 21 Here's kind of a summary of the base case 22 market share matrices that we use for four-foot medium 23 bi-pin lamps. So on the right, or on the left, you can 24 see the four-foot T8 electronic systems market share 25 matrices. In 2012, you can see that we assume that 90 EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064259 1 percent of the people are at 32 watts and 10 percent 2 are at reduced wattages. However, by 2042, we assume 3 that 60 percent of the people will be at 32 watts and 4 40 percent will be at reduced wattages. 5 In terms of lamp efficacy, you can see that 6 for four-foot T8s we assume most of the people are at 7 the lower efficacies and that shifts in 2042. In terms 8 of ballast factor, we have 90 percent of the people at 9 a 0.88 ballast factor. We see a shift to lower ballast 10 factors by 2042. 11 DOE tried to establish these based on 12 manufacturer interviews and availability of product in 13 catalogues. 14 For T12 lamps, DOE assumed that 40 percent -- 15 30 percent of people would be at the 40-watt in 2012 16 and 70 percent of the people would be at a 34-watt 17 lamp. You can see the efficacy distributions here. 18 They're weighted toward the baseline lamp. 19 So you can see complete market share matrices 20 for the four-foot medium bi-pin base -- four-foot 21 medium bi-pin lamps and ballast systems in Chapter 9 of 22 the ANOPR TSD. 23 MR. BROOKMAN: Mike Rivest. 24 MR. RIVEST: I just want to point out that 25 this is uncorrelated data at this point. This is the EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064260 1 best information we have for 2012. We've extrapolated 2 an improvement in efficiency to 2042 and that's part of 3 our base case, but then we have to go the extra step of 4 correlating ballast and ballast factor. 5 So if you were to comment on nothing else, if 6 you could comment on the first slide, that would 7 already be an improvement. But the ideal one to 8 comment on would be the correlated market share matrix. 9 MS. GUPTA: Right. This slide is what Mike 10 is referring to. This is an actual market share matrix 11 that you can find in the TSD. 12 As you can see here, this is kind of showing 13 the characteristics of our system. So we have like a 14 0.88 ballast factor ballast, and we show, well, you can 15 have a 32-watt lamp with an efficacy of 86.2 lumens per 16 watt. We assume that 43 percent of the inventory is at 17 that particular system. 18 You see all the systems that we use. We 19 basically pair every lamp generated in the engineering 20 analysis with the three ballast factors. 21 MR. BROOKMAN: Joe. 22 MR. HOWLEY: Yes. Mike, did you use NEMA 23 data for the 32-, 30-, and 28-watt split as well? 24 MR. RIVEST: I don't think there was NEMA 25 data, official NEMA data. We -- EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064261 1 MS. GUPTA: Yeah. There was no official NEMA 2 data. It was a combination of information that we got 3 from interviews with manufacturers and just taking an 4 inventory of how many products were available of the 5 different types. So we could definitely do better on 6 that information. 7 MR. HOWLEY: We can look at that and see how 8 close you are. 9 MR. BROOKMAN: Paul. 10 MR. WALITSKY: The one that popped out at me 11 was zero percent for the 25-watt in 2012 when there are 12 thousands of lamps being sol 13 d now in 2008. So that number is going to be a lot 14 higher than zero. 15 MS. GUPTA: Okay. 16 MR. WALITSKY: I have no guess. I leave that 17 to Joe and NEMA to guess where that number is, but 18 certainly it's not zero. My guess is it will be a lot 19 higher in 2012. 20 The other part of the comment is, I notice 21 later on that as it would play out you have emerging 22 technology for infrared lamp but not -- for the 23 incandescent reflector but not for fluorescent. My 24 guess is sometime down the road you're going to see 25 LEDs in the ceiling replacing four-foots, sometimes EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064262 1 well before 2042. So you're going to have to take that 2 into account like you did for incandescents into this. 3 Just go down the hall and talk to Jim 4 Broderick and see what his estimates are because he has 5 them. 6 MR. RIVEST: Okay. 7 MR. BROOKMAN: It's a ways out. Steve Nadel. 8 MR. NADEL: A couple of comments on this 9 matrix, some initial comments at least. One, my 10 understanding is while the 30-watt lamp was the first 11 of the reduced wattage T8s that it's mostly being 12 replaced in terms of sales with the more efficient13 ones, the 28s or 25s. It was kind of a first14 generation energy saver. 15 So I'd would be surprised if the 30s -- I'm 16 not saying they'll go to zero, but they won't be quite 17 as robust as you're showing. That's one comment. 18 Two, in terms of ballast factors, I recall -- 19 I don't remember the exact numbers. You have a 0.78, 20 which is a very common one. My understanding is more 21 manufacturers are coming out with somewhat lower 22 ballast factors. I recall a 0.7 from one manufacturer, 23 0.68, 0.69. I don't think the 0.75 is that common. 24 There will be a bit more of a jump for that category. 25 I can look up some data, you can look up some data on EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064263 1 what that might be. 2 The third one, and this one may go beyond 3 what you want to do, is also the 1.18 ballast factors. 4 What those allow is sometimes using two-lamp fixtures 5 instead of three-lamp fixtures or one-lamp fixtures 6 instead of two-lamp fixtures. Are you going to get 7 into that at all? I know those are going up to a 8 significant extent because of those applications. 9 MS. GUPTA: Yeah. The approach we took in 10 the national impact analysis was similar to what we 11 took in the engineering and the LCC, in which we tried 12 to model the average system in terms of lamps per 13 ballast. Okay. 14 MR. BROOKMAN: Any additional comments? 15 MS. GUPTA: So this is what we want you guys 16 to fill out. 17 MR. LEWIS: This is what they have -- show 18 them in the TSD. 19 MS. GUPTA: Oh yeah. 20 MR. LEWIS: Table 933. Chapter 9. 21 MR. BROOKMAN: Oh, thank you. 22 MS. GUPTA: So those table numbers are -- 23 MR. BROOKMAN: Chapter 9. Mike Rivest. 24 MR. RIVEST: I think, again, to try to 25 simplify what comments you provide and how you provide EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064264 1 them, filling in the matrix is ideal for us. It 2 minimizes our work. But really, what that matrix is 3 then doing is it's collapsing that into a typical 4 system, an average system base case in that year with 5 an after-standards average system in that same year. 6 So if one could go right to that answer and 7 say, you know, the standard going from CSL 1 to CSL 3 8 results in a 5-watt system improvement, that would be 9 helpful as well. 10 MS. GUPTA: Yeah. If we were to get the 11 aggregated data, then we would need the price 12 associated with the average system. 13 MR. RIVEST: I didn't say anything. 14 MR. BROOKMAN: Okay.15 MS. GUPTA: So, on to the eight-foot, single16 pin, slimline base case market share matrices. We see 17 a similar thing depicted here. Here we make an 18 assumption that 100 percent of eight-foot T8 systems in 19 2012 are at 59 watts and we see a shift toward the 20 reduced wattages by 2042. Again, the lamp efficacies, 21 we see a shift toward higher lamp efficacies by 2042 22 and to lower ballast factors. 23 In terms of the T12 slimline magnetic 24 systems, we have 60 -- two-thirds of the inventory at 25 75 watts and one-third at 60 watts and the shown EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064265 1 efficacy distributions.

n mments or uestions on h 2 D ave a y co q oes anyone 3 the eight-foot slimline efficacy distributions or 4 wattage distributions or ballast factor? 5 (No response.) 6 MS. GUPTA: All right. 7 MR. LEWIS: It's just about five o'clock. 8 I'mguessing that you're going to want to get to Slide 9 38, which is the end of this section. So we ought to 10 do a check with everybody where they stand. I don't 11 want to presume that anybody is -- we've already asked 12 you to stay a little bit later today. There were 13 people that wanted to see us conclude today. 14 If there's anybody that needs to leave or if 15 there are a majority of you who think that -- 16 MR. BROOKMAN: Ron, you're covering up the 17 h

icrop one. m 18 MR. LEWIS: If the majority of you think that 19 you've had enough fun for one day. We're in the midst 20 -- you know, we're a third of the way into one section. 21 It would be hard to just pick up in that section. So 22 my instinct is to carry to the end of this section and 23 then pick up in the morning, if everybody's okay with 24 that, with the understanding that anybody that has to 25 leave or wants to leave at this point because they have EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064266 1 just endured as much as they can, feel free to do that. 2 MR. RIVEST: Also, a thing to point out is 3 that if we can get through this section what comes 4 tomorrow is a description of what will be done for the 5 NOPR. So it's less -- it requires less comment and 6 it's more familiar to a lot of people, whereas these 7 next 20 slides are very important. 8 MR. BROOKMAN: Yeah, Steve Nadel. 9 MR. NADEL: That sounds good, plowing on. 10 The one thing, if we can leave three minutes at the 11 end. Since I won't be here tomorrow, I had one 12 question about the -- laying the groundwork for that. 13 MR. BROOKMAN: Sure. Okay. So then we're 14 going to press on. Anybody that needs to leave, please 15 feel free. Okay. 16 MS. GUPTA: Okay. So if there's no comments 17 on the eight-foot slimline market share matrix inputs, 18 you can find the full market share matrices in Chapter 19 9 of the ANOPR TSD. I'll just move on.20 Here's the eight-foot, recessed, double21 contact, high-output market share matrix inputs. As 22 you can see, we have about 60 percent of our 2012 23 shipment distribution at the 110-watt lamp, 40 percent 24 at the reduced wattage, 95-watt lamp, and we see a 25 shift towards the 95-watt lamp with -- by 2042. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064267 1 In terms of lamp efficacy, we are heavily 2 weighted towards the baseline lamp in 2012 and then we 3 shift towards higher efficacy lamps. In terms of 4 ballast factors, we assume electronic ballast factors 5 of 0.90, 0.89, and 0.88 and pretty much equal 6 distribution of those. Those were the available 7 ballast factors -- commercially available ballast 8 factors that we found. So that's why we don't see much 9 variation. 10 Any questions? 11 (No response.) 12 MS. GUPTA: All right. So let's take a look 13 at some of our shipment results. This is a plot of the 14 four-foot, medium, bi-pin shipment results. As you can 15 see, the four-foot T8 shipments are growing due to new 16 construction and retrofitting of four-foot T12 and some 17 eight-foot T12 single-pin slimline systems. 18 You can also see that the four-foot T12 19 medium bi-pin lamps reach zero shipments by 2022, and 20 that's because we assume that since no new T12 systems 21 are shipped, eventually no T12 lamps will need to be 22 shipped. 23 As an output based on certain lifetimes that 24 we use in our model and new construction growth rates, 25 on average lamp replacement constitutes about 63 EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064268 1 percent of shipments, ballast replacement constitutes 2 30 percent of shipments, and new construction, 7 3 percent of shipments. 4 For eight-foot single-pin slimline -- 5 MR. BROOKMAN: Can we just pause for a 6 moment? I would really like to validate that if we 7 could. New construction, seven percent; ballast 8 replacement, 30; lamp replacement, 63 percent. What do 9 you think? Joe, yeah? 10 MR. HOWLEY: It seems reasonable. Something 11 in that range. The new construction is probably about 12 right. The ballast replacement, I guess, is the one 13 that probably has the most -- 14 MR. BROOKMAN: Variability? 15 MR. HOWLEY: -- variability associated with 16 it. 17 MR. BROOKMAN: Keith, you say yes, also? 18 MR. COOK: Yeah, I would agree with that. 19 MR. BROOKMAN: Okay. Thank you. 20 MS. GUPTA: Perfect. All right. Eight-foot 21 single-pin slimline. All right. So for eight-foot22 single-pin slimline shipments, we see that the eight23 foot T8 single-pin slimline shipments show a slight24 growth due to the retrofitting of some of the eight25 foot T12 lamp and ballast systems. We see a continuous EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064269 1 decline of the eight-foot T12 lamp shipments. Again 2 due to the banning of magnetic ballasts, we assume that 3 eventually those shipments are going to go to zero 4 because there will be no ballast on which to install 5 those lamps. 6 And for that lamp, the model outputs 7 approximately 78 percent of lamp shipments are due to 8 lamp replacement and 22 percent of lamp shipments are 9 due to ballast replacement. 10 Any comments? 11 (No response.) 12 MS. GUPTA: And finally, for the eight-foot, 13 recessed, double-contact, high output shipments, as I 14 said earlier, we model the eight-foot T12 shipments as 15 being flat from 2012 to 2042. We don't model the16 initial stock of eight-foot T8 recessed, double17 contact, high output systems. 18 The outputs of that model show that lamp 19 shipments due to ballast replacement are approximately 20 one-fifth of the total shipments and four-fifths are 21 lamp replacement shipments. Okay. 22 MR. BROOKMAN: People are going to speak up 23 if they think significantly differently. 24 MS. GUPTA: Yeah. I'm moving on to the 25 standards case, so if anyone wants to say anything EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064270 1 about the base case, now would be a good time. 2 (No response.) 3 MS. GUPTA: Okay. So in terms of the 4 standards case shipment methodology, there are two 5 major areas that we differ from the base case. One of 6 them is that instead of using a market share matrix 7 that characterizes the product mix of shipments from 8 2012 to 2042 that is in the base case, we use a 9 standards case market share matrix. 10 A second important aspect is that we 11 introduce additional standards-induced retrofits of T12 12 systems in the standards case. I'll talk a little bit 13 more about that. 14 So, as I just said, in the standards case 15 shipment methodology we developed standards case market 16 share matrices. To do that, we used several shipment 17 scenarios, or two shipment scenarios to characterize 18 how consumers will change their purchase decisions with 19 standards. 20 The standards case market share matrices 21 generally show a movement to higher efficacy lamps and 22 alternate ballast factor ballasts. We have separate 23 standards case market share matrices for consumers just 24 purchasing a lamp for a lamp replacement and a separate 25 one for consumers purchasing new lamp and ballast EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064271 1 systems. 2 A second part of the standards case 3 methodology is to incorporate standards-induced 4 retrofits. DOE assumes that the increased first cost 5 of higher efficacy four-foot T12 medium bi-pin and 6 eight-foot T12 single-pin lamps will result in 7 additional voluntary retrofits in the standards case. 8 In addition, we also incorporate mandatory retrofits of 9 T12 systems due to -- if you go to a standard level 10 that is above the level at which a T12 lamp is 11 available. So, using those two inputs, we could 12 recalculate the shipments and stock product mixes. 13 Now I'm going to just talk a little bit about 14 the standards case shipment scenarios. Our standards 15 case shipment scenarios consider lamp price, system 16 lumen output, and system energy consumption as drivers 17 for consumer purchases. We have two scenarios. One is 18 a roll-up scenario and one is a shift scenario. 19 The roll-up scenario represents a lower bound 20 of energy savings, and in that scenario only consumers 21 purchasing below the candidate standard level will 22 change their purchase decisions in the standards case. 23 These consumers will purchase the lowest first cost 24 lamp option available. 25 In the shift scenario, which represents the EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064272 1 upper bound of our energy savings, all consumers 2 reevaluate their lamp and ballast decisions. Consumers 3 currently purchasing the lowest efficacy option4 continue to purchase the lowest first cost standards5 compliant lamp, but all other consumers who are 6 purchasing above the lowest efficacy option purchase7 the lowest first cost energy-saving lamp -- or, energy8 saving option. 9 So, a second effect that we model in the 10 standards case fluorescent lamp shipments model is the 11 standards case retrofits. As I said before, we assume 12 that an increased efficacy standard will require -- 13 will result in an increased T12 lamp price and that 14 will cause some consumers to retrofit their T12 system 15 before it retires and purchase a T8 system instead. We 16 apply this to four-foot T12 systems and eight-foot T12 17 single-pin slimline systems. 18 Right now, as inputs into our model, we 19 assume at CSL 1, 10 percent of consumers will -- 10 20 percent of the remaining stock of T12 systems will 21 retrofit per year. CSL 2, it's 20 percent; CSL 3, 30 22 percent, and so on. So this is definitely an input 23 that we need your input -- your comment on and would 24 appreciate -- 25 MR. BROCKMAN: Keith. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064273 1 MR. COOK: Yeah. It was not clear to me, 2 though, how much of this voluntary retrofit was due to 3 other enticements, utility rebates, et cetera, and 4 whether or not those will continue going forward. 5 MS. GUPTA: Well, I think these are just the 6 incremental between the standards case and base case. 7 So this 10 percent, none of it is due to utility 8 rebates because it would just -- because that would be 9 incorporated in the base case. 10 MR. RIVEST: Mike Rivest. One way to think 11 about this is, so a ballast fails and they voluntarily 12 replace every ballast in the room. So it's like an 13 acceleration of the turnover of the T12 stock due to 14 the higher price of the T12 lamp. So we try to model 15 that acceleration. 16 MS. GUPTA: I'm sorry. So you were -- were 17 you just saying that the utility rebates would be 18 particularly effective in the standards case? 19 MR. COOK: Yeah, that's what I think drives a 20 lot of the voluntary retrofit, is they have other 21 enticements to make the change-out. 22 MS. GUPTA: But that's something that happens 23 in both the base case and standards case, right? 24 MR. COOK: Base case and standards -- what 25 I'm saying is, you're right, it doesn't affect the base EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064274 1 case, but you would see it in the standards case. It's 2 what allows them to go to the higher, more -- it gets 3 back to the original problem. The initial cost on the 4 higher levels is cost prohibitive, typically. 5 MR. BROOKMAN: The standards case might 6 motivate the utilities to go higher and faster? 7 MR. COOK: Correct. 8 MR. BROOKMAN: Go ahead, Gary. 9 MR. FERNSTROM: This is Gary from PG&E. I 10 think I missed that point. Could you restate that? 11 MR. COOK: Well, it's the same thing we just 12 went through with CFLs. I mean, for years and years 13 they have hardly gone anywhere, and now PG&E, for 14 instance, is subsidizing the cost of CFLs in 15 California. We've got Wal-Mart subsidizing the cost. 16 All of a sudden, you know, we're seeing a 20 percent 17 per year increase in CFLs. Everybody is saying, well, 18 great, you know, everybody is catching on to the energy 19 efficiency. I don't know that that's true. You know, 20 it's being subsidized. 21 MR. BROOKMAN: The price has come down. 22 MR. COOK: Yeah. 23 MR. FERNSTROM: Well, I mean, I'd like to 24 think that all those utilities and others around the 25 country that have education and incentive programs are EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064275 1 having a big impact, but I've got to tell you, PG&E has 2 been providing incentives for CFLs for 20 years. It's 3 just, you know, kind of recently we've seen a big 4 increase. 5 So I think the attribution has to go, you 6 know, not only to the utilities but the national 7 attention on global climate change, the increased 8 availability of these products, and a lot of other 9 things. 10 MR. BROOKMAN: Has the price continued to 11 decline for 20 years? 12 MR. FERNSTROM: Yeah. Slowly at first 13 MR. BROOKMAN: Yeah, yes. Very -- yeah, 14 right. Yeah. I just -- 15 MR. FERNSTROM: I mean, the first products 16 that we featured had a retail cost of about $28, and we 17 subsidized them and sold them for $9. 18 MR. BROOKMAN: Wow. 19 MR. FERNSTROM: But, you know, huge 20 difference between then and now. 21 MR. BROOKMAN: Yeah, right. Okay. So, 22 thanks for your point. 23 MS. ANDERSON: I have a question because a 24 lot of the T12 -- 25 MR. BROOKMAN: Please say your name again and EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064276 1 get the microphone close. Thank you. 2 MS. ANDERSON: Susan Anderson, Osram 3 Sylvania. 4 MR. BROOKMAN: Thank you. 5 MS. ANDERSON: A lot of the T12 market is 6 residential. The chief magnetic residential ballast is 7 allowed in the current ballast ruling. You're talking 8 about T12s going away by 2022. I mean, if those 9 ballasts are still out there -- 10 MR. BROOKMAN: If they're still on the 11 market, it's to be -- to serve the replacement, right? 12 Is that -- 13 MS. ANDERSON: Yeah, they're not covered. 14 They're allowed. So, I mean, there's a condition there 15 where we're still going to be selling T12 systems, 16 lamps and ballasts. 17 MR. HOWLEY: Joe Howley. You know, that 18 point also brings up kind of an important 19 consideration. Right now, perhaps a third of the 20 market as we sit here in 2007, 2008, is T12 versus T8. 21 Of that remaining third of T12 lamps we sell in the 22 four-foot fluorescent sector, a fairly significant 23 percentage now is going into the residential sector of 24 that remaining bit. 25 So that would also suggest, if you're going EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064277 1 to model who's using T12 lamps right now and who would 2 be most affected, it would be perhaps, especially if 3 you went to one of these higher levels where the T12 4 lamp simply wasn't available anymore, it would affect 5 your residential consumer who runs these about a 6 thousand hours a year. 7 Any analysis on this should definitely 8 consider the effects because by 2012, if the market is 9 20 percent T12 like we're projecting, or I think you 10 had about 18 percent based on that chart, over half of 11 those are going to be residential consumers. So this 12 regulation is going to affect the residential consumer 13 burning these a thousand hours a year. That has to be 14 modeled into your cost analysis in terms of is that 15 cost effective for them. 16 MR. FERNSTROM: This is Gary from PG&E. Let 17 me just make a comment on that. I have a 44-year-old 18 house that had a T12 fluorescent four-lamp fixture in 19 the kitchen for all of those 44 years. This last year 20 I replaced it with a T8 fixture with electronic 21 ballast. 22 MR. BROOKMAN: I bet you didn't incur any 23 labor costs, did you. 24 (Laughter.) 25 MS. GUPTA: A little round of applause. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064278 1 MR. FERNSTROM: I incurred a lot of labor 2 cost being as I did it myself. 3 (Laughter.) 4 MR. BROOKMAN: That's what I was counting on. 5 MR. FERNSTROM: But the point I want to make 6 is, there's two ways you can look at that. You can 7 say, well, you know, those poor customers are going to 8 be faced with the absence of this lamp in the market 9 and that's going to impose a tremendous hardship on 10 them. On the other hand, I've got to tell you that my 11 replacement with the new T8 electronic ballast fixture 12 was highly cost effective. 13 So if we look at it from a life-cycle cost 14 point of view, I should have done it years ago. If a 15 regulation can help me toward that decision, that's 16 probably a good thing. 17 MR. BROOKMAN: Do you think you're a normal 18 consumer in that respect? 19 MR. FERNSTROM: I am. I am a normal consumer 20 because I waited the 44 years to do it. 21 (Laughter.) 22 PARTICIPANT: And, did you get a rebate or a 23 subsidy from your local utility? 24 MR. FERNSTROM: No. 25 (Laughter.) EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064279 1 MS. GUPTA: Well, if we were to incorporate 2 these residential consumers, we would definitely need 3 some detailed information on what percentage of T12s 4 are in the residential sector. 5 MR. HOWLEY: Okay. We could provide further 6 comment on that, but I think -- this is just a factual 7 matter -- that you probably did this analysis based 8 solely on a commercial customer, and that is a mistake. 9 You really need to consider the impact on the 10 residential customer, who is going to be most of the 11 market come 2012. 12 MR. BROOKMAN: Thank you. Susan, thanks for 13 raising that point. 14 MR. FERNSTROM: Gary again. If I could add 15 something to Joe's point, it was only in the last few 16 years that California has taken a real strong step 17 toward mandating at least in new construction CFLs in 18 residential construction with dedicated pin bases. 19 There have got to be a lot of T12s with magnetic 20 ballasts in homes in California because fluorescent 21 lighting has been required for 30 years. Virtually all 22 of that is T12 and magnetic ballast. 23 MR. BROOKMAN: Thank you. Ron Lewis. 24 MR. LEWIS: I've got just enough memory left 25 to get me in trouble'here. Was there not a low wattage EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064280 1 lamp that was used in residential settings as well as 2 you've got a low power factor ballast that's out there? 3 They're not the same equipment that's used in the 4 commercial or industrial setting. Are they not unique 5 and identifiable for the most part for the residential 6 market? Like in the shop light -- 7 MR. HOWLEY: Yeah. You're referring to the -- 8 MR. BROOKMAN: Joe, yeah. Go ahead. 9 MR. LEWIS: -- the top 10 design criteria are 10 price, price, price, and price? 11 MR. HOWLEY: You're referring to the 25-watt 12 shop light lamp that was for the 1992 Energy Policy Act 13 rulemaking. That was defined in a specific way, 14 recognizing that would generally run on a consumer shop 15 light low power factor ballast. It was rated that way. 16 We sell both types today. The shop light 17 lamp is sold but also what we call the resi-lights, or 18 the kitchen and bath lights, which are basically 19 commercial lamps, are sold as well. But it is20 essentially, from a manufacturing perspective, a four21 foot T12 lamp. So it really isn't that different from 22 a manufacturing perspective. 23 MR. BROOKMAN: Go ahead, Mike Rivest. 24 MR. RIVEST: If we were to have information 25 on the shipments to the residential sector, it would be EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064281 1 helpful to know if these particular lamps are included 2 or not within the previous estimates and any new 3 estimates. 4 MR. HOWLEY: They were included in the 5 previous estimates. 6 MR. RIVEST: Oh, they were? 7 MR. HOWLEY: It was in the entire market. We 8 didn't try to separate out any of these other types. 9 That's the way NEMA collects the data, so that's -- 10 MR. RIVEST: Okay. 11 MR. BROOKMAN: Susan. 12 MS. ANDERSON: Yeah, I wanted to make one 13 other comment. That 25-watt lamp, by the way, is 14 included. We have supported including it in the 15 standards going forward. That's that 25-watt T12. 16 But the other thing I wanted to point out; in 17 the residential market you're seeing fixtures in the 18 DIYs that have electronic ballasts in them that they 19 say will operate either T8 or T12. So those are 20 perpetuating T12s in the marketplace, and that's 21 something else -- they're electronic ballasts, but they 22 market them. They'll put a pallet of fixtures in a 23 stack and they'll put a pallet of T12 lamps on one side 24 and a pallet of T8 lamps on the other. 25 MR. BROOKMAN: Okay. Steve Nadel. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064282 1 MR. NADEL: Yeah. I would note that probably 2 just in the last year or two I've started seeing a lot 3 more T8 shop lights coming out, all of a sudden, with 4 electronic ballasts. That's -- the prices have come 5 down. I mean, they're all from China or other Asian 6 countries, so that's becoming more common and will, you 7 know, start to predominate certainly by 2042 if not 8 well before. 9 The other comment is on this slide, back to 10 this. I agree that standards will accelerate retrofit. 11 That looks awfully ambitious. All of a sudden -- you 12 do Candidate Standard Level 5 in the next year and half 13 the people will voluntarily retrofit? I wish it were 14 the case, but I'm not sure I believe that. 15 MR. BROOKMAN: What would the numbers be, 16 Steve? What do you think? 17 MR. NADEL: I'd divide them at least by two, 18 but I'm making an educated guess. I don't know. 19 MR. BROOKMAN: Is there any -- is there 20 experience from previous rulemakings that's relevant 21 here? 22 MR. HOWLEY: This is Joe. I think Steve has 23 somewhat of a point that 50 percent -- because the 24 lamps don't burn out that fast. It's unlikely that 50 25 percent of the market would have to change lamps in one EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064283 1 year. Even if you assume let's say a five-year life, 2 probably your high end is going to be 20, 25 percent, 3 even on Standard Level 5, because that's simply the 4 number of lamps that would burn out in a year. 5 Your range -- 10 percent is probably not bad 6 to start with, but your top end is probably no more 7 than 25 percent, and then just range it up between 1 8 and 5 between 10 and 25 percent. 9 MR. BROOKMAN: Okay. 10 MR. HOWLEY: Fifty percent is probably very 11 aggressive. 12 MS. GUPTA: Okay. Thanks. Joe, you actually 13 bring up a good point for the next bullet on the slide, 14 which refers to mandatory T12 ballast retrofit, which 15 is done at the time of lamp failure. At certain CSLs, 16 at CSLs 4 and 5, no T12 lamps are available to 17 purchase. So when their existing T12 lamp dies, they 18 retrofit their system. So, yeah, we have 50 percent of 19 the people in the first year just doing it because 20 they're smart, but then when that lamp dies, for the 21 remaining people, they'll retrofit their system. 22 MR. BROOKMAN: Okay. We're moving on. It's 23 almost 5:30. 24 MS. GUPTA: So, do we -- we don't want to 25 stop at the comments? EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064284 1 MR. BROOKMAN: Oh, well, I thought people 2 were giving comments as we went. 3 MS. GUPTA: Are there any other, further 4 comments? 5 MR. BROOKMAN: Well, actually, that's what 6 you want. Please review this list. See if there's 7 anything else you wish to say about methodology and 8 data sources, fluorescent base case and standards case 9 market share matrices, which I thought Mike did a good 10 job of describing, fluorescent base case shipment 11 forecasts, and the other two. Additional comments on 12 those? 13 (No response.) 14 MS. GUPTA: All right. So the next topic I'm 15 going to be talking about is the incandescent reflector 16 lamp base case shipment methodology. 17 So, first, DOE used NEMA historical shipments 18 of IRL to estimate the historical shipments of covered 19 lamps, taking into account the definition of 20 incandescent reflector lamps in EISA 2007 and various 21 exemptions for those lamps -- or, various exemptions 22 for certain IRL. This also includes taking into 23 account non-NEMA members, trying to scale up those 24 shipments a bit. 25 DOE then extrapolated the shipments to 2011, EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064285 1 and then, using the product mix of the inventory, DOE 2 establishes the lamp inventory in 2011. Then, using 3 assumptions regarding new construction and the 4 penetration of emerging technologies, DOE forecasts the 5 number of lamps in inventory from 2012 to 2042. Then, 6 ll hi th d t i f th fi b t bli

y, ng e pro uc mx o na y es a s e 7 inventory over the analysis period and tracking the 8 retirement of lamps, DOE calculates total IRL 9 shipments. 10 Similar to the fluorescent lamp shipment 11 model, the first step was to establish the 2011 lamp 12 stock. NEMA provided historical shipments for non13 halogen and halogen IRL. When I say "non-halogen," I 14 mean incandescent technology. 15 So DOE made several assumptions in order to 16 get to a covered lamp shipments number. We assumed 17 that NEMA shipments represent 85 percent of total IRL 18 shipments. DOE estimated that EISA 2007 exempted 19 approximately 60 percent of incandescent reflector 20 lamps. We assumed that, of non-halogen shipments or 21 incandescent shipments, 33 percent serve the commercial 22 sector and 67 percent serve the residential sector. Of 23 halogen shipments, 60 percent serve the commercial 24 sector and 40 percent serve the residential sector. 25 All of those assumptions combined, plus a EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064286 1 lifetime assumed by our market share matrices, we 2 achieve an installed stock of covered IRL in 2011 to be 3 approximately 300 million lamps in the residential 4 sector and 77 million lamps in the commercial sector. 5 Any comments? 6 (No response.) 7 MS. GUPTA: Then, as stated earlier, the next 8 step in the IRL shipment model is to forecast the 9 number of lamps in the IRL stock from 2012 to 2042. To 10 do that, DOE takes into account two phenomena: new 11 construction and the penetration of emerging 12 technologies. 13 To account for new construction, DOE applies 14 an exponential growth to the number of IRL sockets in 15 2011 based on the CBECS and RECS building floor space 16 growth. So, in the residential sector, we have a 1.3 17 percent growth and in the commercial sector we see a 18 1.6 percent growth. 19 Historical annual growth of IRL stock 20 calculated from historical shipments is estimated to be 21 approximately eight to 10 percent. However, DOE 22 believes that this growth may be unsustainable and uses 23 the building floor space growth to estimate new 24 construction instead. 25 Another important trend that DOE takes into EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064287 1 consideration in developing the IRL stock projection is 2 penetration of emerging technologies. DOE assumes that 3 technology such as CFLs, ceramic metal halide, LEDs, 4 will penetrate the market. For the ANOPR, DOE 5 estimates that 50 percent of the 2042 IRL sockets will 6 be emerging technologies. 7 MR. FERNSTROM: This is Gary from PG&E. I 8 have a quick comment on that. Work done by the 9 California Lighting Technology Center shows that a 10 large number of California homes have cans in them now 11 in the order of 40 cans per home. I think what you're 12 doing is extrapolating, you know, what you think the 13 current market share of cans is for growth, and I think 14 the market share of cans has increased. 15 So you might want to talk to the CLTC and see 16 if you can get some information on that. I don't know 17 whether that's a California effect or a national 18 effect, but I would guess that across the country the 19 share of cans is increasing. 20 MR. BROOKMAN: Steve Nadel. 21 MR. NADEL: Yes. Along those same lines, I 22 think RLSW did a study, as did -- Home Group. I can't 23 remember which one -- where they actually trace the 24 number of cans in homes by home age, and yet the newer 25 homes have more. So just to assume, you know, that it EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064288 1 grows with the stock is probably a little too 2 conservative. 3 MR. BROOKMAN: Okay. 4 MS. GUPTA: Okay. 5 MR. NADEL: To add one more thing, it would 6 be great if these sockets get filled with something 7 other than an incandescent reflector lamp, like a 8 ceramic metal halide or solid state lighting. 9 MS. GUPTA: Well, that 50 percent assumption 10 is definitely something that we'd like comment on, if 11 anyone has more information. 12 MR. BROOKMAN: Andrew. 13 MR. DELASKI: On that assumption, you're 14 assuming that number is the same in the base case and 15 the standards case? 16 MS. GUPTA: Exactly. It's just an inventory 17 subtraction and the inventory of covered IRL is the 18 same in the base case and the standards case. 19 MR. DELASKI: You're subtracting out 60 20 percent up front because -- is outside the scope. 21 MS. GUPTA: Right. 22 MR. DELASKI: -- percent on the back end. 23 MS. GUPTA: Yeah, yeah. So here you can see 24 basically, considering our 2011 stock that we 25 calculated of covered IRL, the upper profile would -- EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064289 1 increases due to new construction growth, and then we 2 decrease the total stock by 50 percent in 2042. So the 3 blue area shows the stock of IRL off of which we're 4 calculating our national energy savings and on which we 5 base our shipments. 6 MR. RIVEST: Mike Rivest. If I understand 7 the comment about the cans, it would be that our growth 8 rate isn't sufficient because we've only got 1.6 9 percent and maybe the cans are penetrating existing 10 homes. 11 MR. FERNSTROM: Gary from PG&E. That's 12 precisely the point. One thought with emerging 13 technologies; practically all of these cans are on 14 dimmer circuits. So if our new technologies are going 15 to grow to that market share, they're going to have to 16 be dimming-compatible. 17 MR. BROOKMAN: Yes, please. Pam. 18 MS. HORNER: One comment which stems back. 19 I've made a note to check on this. By using NEMA data 20 and extrapolating, you're showing halogen shipments at 21 60 percent in the commercial sector and 40 percent in 22 the residential sector. A lot of that -- which is 23 impacting what we're saying right now. I'm concerned, 24 and we will check on it. 25 The way we collect our data, if you take a EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064290 1 Home Depot or a Lowe's, that's counted as residential. 2 MR. FERNSTROM: Yeah. If I could add to 3 that, too, we take all of the rebate activity that we 4 do through those kinds of stores and split it into 5 small commercial and residential. So we call it mass 6 market, but clearly there are a lot of products 7 supplied through those outlets that go into small 8 commercial establishments. 9 MR. BROOKMAN: How do you split it? 10 MR. FERNSTROM: How do we split it? 11 MR. BROOKMAN: Yeah. 12 MR. FERNSTROM: I believe we underestimate 13 commercial. I think we estimate it at 15 percent. I 14 believe it's more than that. 15 MR. BROOKMAN: Susan, you had a follow-on 16 comment there. 17 MS. ANDERSON: That was pretty much my 18 follow-on. 19 MR. BROOKMAN: Okay. Steve. Go ahead. 20 MR. LEWIS: To finish up that, if anybody has 21 got any more precise data, anything that may help us, 22 we would appreciate it. These base assumptions in this 23 stage, the ANOPR, a lot of them are straw man from what 24 we've got and limited data. This is exactly what we're 25 looking for. Help us to see more clearly. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064291 1 MS. GUPTA: Yeah. Just as a clarification, 2 the 60/40 assumption is not based on NEMA shipments. 3 It's based on an NYSERDA study done of the incandescent 4 reflector inventory. 5 MS. HORNER: I'm still concerned that people, 6 you know -- 7 MS. GUPTA: Yeah, of course. 8 MR. BROOKMAN: Steve Nadel. 9 MR. NADEL: Building on a comment Andrew 10 made, I agree there will be significant use of emerging 11 technologies. However, I don't think it's going to be 12 immune to the standard level. If you set a higher 13 standard and the price of the base case product goes 14 up, that's going to decrease the cost difference 15 between an incandescent product -- it might be an HIR - 16 - and an LED or a CFL or something. 17 So I think you need to have some connection. 18 I'd only be guessing at what the connection is. But 19 to assume that the standard has no impact on emerging 20 technology seems a bit of a stretch. 21 MR. BROOKMAN: Paul. 22 MR. WALITSKY: One comment. I don't think 23 that the zero point in 2011 is correct because we're 24 already selling CFLs that can dim. They're going into 25 ceilings now. Not a big number, but they're being EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064292 1 sold. So if it's not zero now, it's certainly not 2 going to be zero to start with in 2011 or '12. 3 MS. GUPTA: It's zero percent of -- I mean, 4 this -- sorry. This isn't -- it's not of the total 5 inventory of all lamps out there. It's just in 2011 we 6 calculate what the inventory is of covered IRL. Then 7 we say, taking those sockets, we project a certain 8 amount of growth from those sockets, and of that total 9 inventory we shift some of those towards emerging 10 technologies. 11 MR. BROOKMAN: I just got the word. We're 12 going to be booted from this room in about 15 minutes, 13 so make it through the rest of these slides. 14 (Laughter.) 15 MR. BROOKMAN: Keep going. No, I'm talking 16 about just the section through, what, 38, I guess. So 17 we need to keep going because they're literally going 18 to lock this place up and we want to be out of here by 19 then. 20 MS. GUPTA: Okay. Turbo. Okay. Similar to 21 fluorescent lamps, we have base case market share 22 matrices for IRL. Various assumptions are made to 23 populate these, and we'd like your input on them. 24 We look at three lumen packages in the 25 shipment model for incandescent reflector lamps, and EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064293 1 they correspond to the three baselines analyzed in the 2 engineering and LCC analysis. We got these current 3 market shares based on just product availability, so we 4 definitely welcome input on them. 5 MR. BROOKMAN: Comments on the market shares? 6 Steve Nadel, please. 7 MR. NADEL: Okay. I'm going to make one 8 comment, then ask two questions. 9 MR. BROOKMAN: Are you going to get us out of 10 here in 15 minutes? 11 MR. NADEL: I actually have to make a six 12 o'clock conference call. 13 (Laughter.) 14 MR. NADEL: The comment, and I imagine Pam 15 may say something similar, it's pretty hard, 16 particularly in the residential sector, to do all these 17 great little market shares and ignore the BR lamps. So 18 I would encourage making it explicit rather than having 19 this, you know, dream world that there's no use of BRs. 20 I recognize, and I looked on ahead, that you guys did 21 do some projections. 22 One thing I'd request is, could you provide 23 the same type of charts on the alternative scenarios? 24 That will make it easier for us to review. It's quite 25 possible -- I haven't even looked at that one -- you EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064294 1 know, we may recommend that the BR case become the 2 primary case just because there are BR lamps out there 3 and we need to account for them. 4 MS. GUPTA: So those market share matrices 5 are in the TSD appendix.6 MR. NADEL: In the TSD? If you could even e7 mail us -- 8 MS. GUPTA: Nine -- yeah, sure. We can 9 definitely e-mail them. 10 MR. NADEL: -- going to find them out of a 11 thousand pages -- 12 MS. GUPTA: Appendix 9 -- 13 MR. RIVEST: No, they are on page 30. Go to 14 page 30. 15 MR. NADEL: Thirty of what? 16 MR. RIVEST: This presentation. 17 MR. NADEL: Oh. 18 MS. GUPTA: No, that's the main scenario. 19 It's not the -- 20 MR. NADEL: That's the main scenario. 21 MS. GUPTA: It's not the -- he's asking for 22 the BR lamp scenario. 23 MR. RIVEST: Oh. This scenario does not 24 include -- 25 MS. GUPTA: The BR shift. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064295 1 MR. RIVEST: -- the BR shift. Okay. Sorry. 2 MR. NADEL: Okay. One other question before 3 I leave. I know you're asking for input on trial 4 standard levels. Is it DOE's intent to have separate 5 trial standard levels for fluorescent and incandescent 6 or are you looking somehow to align the two together, 7 so Trial Standard 1 has to line up across the two? 8 MR. BROOKMAN: Mike Rivest. 9 MR. RIVEST: My gut feel is that there isn't 10 that elasticity between the fluorescent and 11 incandescent markets that would require us to do that. 12 MR. NADEL: So there will be two separate 13 sets of trial standards. I agree. I just wanted to -- 14 MR. RIVEST: Okay. 15 MR. BROOKMAN: What Mimi's going to do now is 16 she's just going to provide the illustrative comments 17 on these remaining slides so you get the flavor for 18 them and not the full content, so that you can then go 19 back to your respective offices and then comment fully. 20 Okay? 21 MS. GUPTA: Sure. Okay. So, to develop the 22 base case market share matrices, we make various 23 assumptions regarding the residential stock and the 24 commercial stock product mixes. Generally, we 25 incorporate some HIR technology in the commercial stock EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064296 1 but not in the residential stock. 2 So, here we see the shipment forecast in the 3 commercial and residential sectors. We see decreased 4 shipments over time due to the penetration of emerging 5 technologies and the shift towards longer-lived HIR 6 lamps in the commercial sector. 7 In terms of the standards case shipment 8 methodology, the main difference between the base case 9 and the standards case IRL shipments is the 10 incorporation of standards case market share matrices, 11 similar to fluorescent lamps, that characterize what's 12 the product mix of the inventory from 2012 to 2042 with 13 the standards. 14 To develop those market share matrices, we 15 incorporate several possible scenarios. One is a main 16 scenario, which assumes that all IRL consumers continue 17 to purchase regulated IRL products. It's basically a18 roll-up. They roll up to the lowest -- or, the next19 lowest efficacy available. 20 A second scenario is the 65-watt BR 21 substitution sensitivity, which Steve was speaking 22 about earlier, in which we account for, in the 23 standards case as the IRL lamp price goes up, people 24 are going to shift to BR incandescent lamps that are 25 exempted from the standards. The only -- the one lamp EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064297 1 that we take into account is the 50-watt PAR baseline 2 lamp will be shifted towards the 65-watt BR lamp. 3 The third scenario is a 10 percent lumen 4 increased sensitivity, which addresses the idea that 5 residential consumers may not necessarily know to 6 purchase a reduced wattage lamp and may purchase 7 instead a same wattage or even greater wattage lamp to 8 replace their base case lamp. That would result in an 9 overall increase in lumens and lower energy savings. 10 I'm going fast, Doug. I'm going fast. 11 Here is an example of the standards case 12 market share matrix used for IRL, and in the 13 residential sector as well. 14 MR. BROOKMAN: So, of course, no time to 15 comment on these now, but the Department would really 16 welcome your careful scrutiny on these numbers and your 17 written comments. 18 MS. GUPTA: Now, to calculate the national 19 energy savings, we use the product stock by design, the 20 unit annual energy consumption established in the 21 energy end use, electricity site-to-site conversion 22 factors calculated from AEO, and an HVAC interaction, 23 which we got from the 2000 ballast rulemaking, and a 24 rebound rate which we estimated in both the commercial 25 industrial and residential sectors. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064298 1 We ask for comment, but later. 2 To calculate the net present value, we take 3 our shipments by product design, our per-unit installed 4 cost taken from the LCC and the product price 5 determination, electricity prices, a discount rate of 6 seven and three percent real, which are -- both of 7 which are used to calculate two different MPVs. 8 In addition, we also take into account 9 residual value of the remaining lifetime of lamps left 10 at the end of the analysis period, similar to what the 11 LCC does. 12 Here are just some sample results of the 13 general service fluorescent lamp MPV and national 14 energy savings. As you can see, generally, most 15 standard levels are cost effective and we have 16 increasing energy savings. 17 Here is the national energy savings and MPV 18 for incandescent reflector lamps in the main scenario. 19 Again, we see increasing MPV and energy savings. 20 Thank you. 21 (Applause.) 22 MR. BROOKMAN: So I never recall going this 23 late with one of these meetings before. It's testimony 24 to your interest, your expertise, and also your 25 endurance. So, thanks to all of you for hanging in EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064299 1 here. 2 Back to Ron Lewis for closing remarks. 3 Closing Remarks 4 Ron Lewis 5 MR. LEWIS: We tried our best to reach a 6 compromise here between those that wanted to end today 7 and our schedule. We were trying to allow time to 8 fully talk through everything. We hope we didn't rush 9 too much. We were trying to accommodate both. 10 So we are going to be here in the morning. 11 We're going to still discuss the rest of the agenda and 12 take questions tomorrow morning. 13 MS. HORNER: Time? 14 MR. BROCKMAN: Nine o'clock. 15 MR. LEWIS: Nine o'clock in this room. 16 MR. BROCKMAN: Right here in this same room. 17 PARTICIPANT: According to the agenda, just 18 for logistics so we can tell, it looks like you have 19 another hour scheduled beyond this. Is that about 20 right? So we'll be done around 10 tomorrow, you're 21 thinking? 22 MR. LEWIS: If we could allow maybe two 23 hours. 24 MR. BROCKMAN: There's also an overview 25 segment, and who knows -- EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064300 1 MR. LEWIS: Just to make sure. We pushed a 2 bunch of things that were supposed to be covered today, 3 and this is all to get your input and to have a 4 dialogue. So I'd rather not be compressed again 5 tomorrow if we've got some time. 6 MR. BROOKMAN: Probably, safely by noon. 7 MR. LEWIS: Yeah. But I appreciate everybody 8 hanging in here and your input. We're trying to do the 9 best we can to fully discuss this. We've got the 10 comment period. We really want to get it right. 11 So, thanks for hanging in here today. Those 12 that can still be with us tomorrow, we appreciate it 13 and look forward to see you tomorrow. 14 (Whereupon, at 6:00 p.m., on March 10, 2008, 15 the meeting was adjourned, to reconvene at 9:00 a.m., 16 on March 11, 2008.)

EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064301 1 I PORTER°S CERTIFICATE 2 3 4 5 6

7 8 9 10 11 12 13 14 15 16 17 18

19 This is to certify that the attached proceedings

before:

UNITED STATES DEPARTMENT OF ENERGY In the Matter of:

PUBLIC MEETING ON TEST PROCEDURES FOR GENERAL SERVICE FLUORESCENT LAMPS, INCANDESCENT REFLECTOR LAMPS, AND

GENERAL SERVICE INCANDESCENT LAMPS

ENERGY CONSERVATION STANDARDS FOR GENERAL SERVICE FLUORESCENT LAMPS AND INCANDESCENT REFLECTOR LAMPS Were held as herein appears and that this is the original transcript thereof for the file of the Department, Commission, Board, Administrative Law Judge or the Agency. Further, I am neither counsel for or related to any party to the above proceedings.



## r Official Reporter Dated: April 5, 2008

EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064UNITED STATES DEPARTMENT OF ENERGY 302

PUBLIC MEETING ON TEST PROCEDURES FOR GENERAL SERVICE FLUORESCENT LAMPS, INCANDESCENT REFLECTOR LAMPS, AND

GENERAL SERVICE INCANDESCENT LAMPS

AND ENERGY CONSERVATION STANDARDS FOR GENERAL SERVICE FLUORESCENT LAMPS AND INCANDESCENT REFLECTOR LAMPS

U.S. Department of Energy

Room 8E0-089 1000 Independence Avenue, Southwest

Washington, D.C. Tuesday, March 11, 2008

9:00 a.m. Participants DOUG BROOKMAN, Facilitator LINDA GRAVES Department of Energy

RON LEWIS Department of Energy

GARY FERNSTROM Pacific Gas and Electric MICHAEL SCHOLAND Navigant Consulting, Inc.

MAHIMA GUPTA Navigant Consulting, Inc. PAUL WALITSKY The Industrial Ecology Company, LLC

KEITH COOK Philips Lighting

DAIN HANSEN National Electric Manufacturers Association

FRANCES WOOD OnLocation, Inc.

EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064303 A G E N D A AGENDA ITEM: PAGE: Welcome 304 Linda Graves Opening Remarks 304 Doug Brookman National Impact Analysis (Continued) 306 Mahima Gupta NOPR Analyses 338 Mahima Gupta Frances Wood Closing Remarks 357 Ron Lewis Adjourn

EXECUTIVE COURT REPORTERS, INC. (301) 565-0064304 1 P R O C E E D I N G S 2 9:10 a.m. 3 4 5 Welcome Linda Graves MS. GRAVES: Good morning. Welcome to the 6 Department of Energy. I'm Linda Graves, and I'm here 7 with my team, and we are continuing the second day of 8 the standards and test procedure lamps meeting. 9 With that, let's get started. 10 Opening Remarks 11 Doug Brookman 12 MR. BROOKMAN: Thank you. So we covered a 13 lot of ground yesterday, and you all very easily and 14 graciously worked within the norm boundaries that we've 15 observed all these many years. I'm going to ask again, 16 though, simply that you speak one at a time. Please 17 say your name for the record. Listen as an ally. Keep 18 the focus here. Turn off your cell phones. Put them 19 on vibrate. 20 If you need to have much of a sidebar 21 conversation, the acoustics in this room are unusually 22 good compared to the Department of Energy, so we can 23 hear you and it's disruptive. So please hold those 24 down. I do hope this is an occasion when you get to 25 serve your objectives today. That is, pursue the EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064305 1 matters that are important to you, raise the issues 2 that are important to you, ask the questions that are 3 important to you. That helps the Department as well. 4 So then, let's begin. Our first speaker 5 following on from yesterday -- 6 MR. LEWIS: I asked if she could just recap a 7 little bit, just going back over the topic areas and 8 giving people an opportunity to ask any questions they 9 didn't get in yesterday. 10 MR. BROOKMAN: I think that's a real smart 11 idea. I think all of you were here yesterday. Just so 12 we're clear, we really hammered through about the last 13 10 slides. Mimi was very rushed in doing so. So let's 14 back up to which slide, Mimi? 15 MS. GUPTA: So we're going to be on the 16 National Impact Analysis part of the presentation, 17 which is the one with lots of pictures, and Slide 22. 18 MR. BROOKMAN: So, on your agenda, this would 19 be the middle of the last page in your agenda, the 20 agenda for Tuesday, March 11th. So we'll proceed with 21 the National Impact Analysis and then just keep right 22 going straight on down as described in the agenda. 23 24 25 EXECUTIVE COURT REPORTERS, INC. (301) 565-0064306 1 National Impact Analysis (Continued) 2 Mahima Gupta 3 (PowerPoint presentation.) 4 MS. GUPTA: Yesterday we got through the 5 fluorescent national impacts, or shipment model in 6 pretty good pace. So I figured I'd start asking you if 7 you needed any clarification or have any questions or 8 comments on the incandescent reflector shipment model. 9 So, is that okay with anyone? No one has any comments 10 on fluorescent, right? 11 (No response.) 12 MS. GUPTA: All right. So we kind of went 13 through this yesterday, the basic methodology behind 14 developing the base case shipment model for 15 incandescent reflector lamps. So, are there any 16 questions about this? Does anyone want me to go over 17 this again? 18 (No response.) 19 MS. GUPTA: No? And the various assumptions 20 that we included to develop the 2011 lamp stock. Those 21 included emerging technology assumptions and growth 22 assumptions. This was the resulting stock projection. 23 So, just, please stop me if you have any questions. 24 Then, this is, I think, where we really 25 started speeding up. I just wanted to emphasize that EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064307 1 this is an area that we really need your input on 2 populating these base case market share matrices for 3 IRL which characterize the inventory in 2011 and 2042 4 of incandescent reflector lamps. 5 In the commercial sockets, we account for 6 some lamps being of halogen infrared technology and 7 some of them just being of halogen. But in the 8 residential market -- residential sockets, we assume 9 all of them are halogen technology. 10 MR. FERNSTROM: So this is Gary from PG&E. I 11 have a question about this slide. Are you suggesting 12 that the residential stock of IRLs is 100 percent 13 halogen? 14 MS. GUPTA: That is correct. Of the covered 15 incandescent reflector lamps, we assume all of them are 16 halogen because we don't account for the incandescent 17 portion of the residential stock because it's not part 18 of our covered product. 19 MR. FERNSTROM: Thank you. 20 MR. BROOKMAN: Paul. 21 MR. WALITSKY: My guesstimates and visiting 22 with Light Fair and a lot of manufacturers is that by 23 2042 you're going to have probably 50 percent of the 24 lighting that's going to be LED. 25 So I think your emerging technology is going EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064308 1 to have a bigger share than you think. In 30 years, 2 that's a good -- these lamps only last 3-, 4,000 hours. 3 So the turnover rate is much greater than it is in 4 fluorescent. LED is moving very quickly. You will see 5 penetration into the household in some significant 6 numbers in five years. 7 MS. GUPTA: Okay. 8 MR. WALITSKY: So we're going out 30 years. 9 It's going to be mainly LEDs and probably still a few 10 compacts left. Incandescents, I think, are going to go 11 far -- and halogen are going to go far down. 12 The other thing that's happening in retail is 13 that with Philips' 25-watt HID integrated, that's 14 taking a share of the commercial market. So I think 15 your IR is going to be much, much lower. 16 MS. GUPTA: Okay. And so, do you think we 17 would see a difference in the penetration of these 18 emerging technologies in the commercial versus 19 residential? You're saying it's going to be much 20 higher -- 21 MR. WALITSKY: The commercial will come 22 first. 23 MS. GUPTA: Okay. 24 MR. WALITSKY: It's already starting. 25 Residential will lag behind, but it will get there. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064309 1 Thirty years is a long time span and you're going to 2 see a lot more -- I think you really need to get 3 together with Jim Broderick and his group because 4 they're working on LEDs. They've got market numbers 5 which will swamp these. So I think you've got to -- 6 you know, you've really got to talk to Jim and Jim's 7 group. 8 MR. BROOKMAN: Thank you. Yes, Keith. 9 MR. COOK: Keith Cook, Philips. Yeah, I 10 agree with what's being said. At the Atlanta DOE 11 workshop on solid state lighting, every year they've 12 underestimated the progress in solid state lighting. 13 MR. BROOKMAN: The technical progress. 14 MR. COOK: Yeah. 15 MR. BROOKMAN: Yeah. 16 MR. COOK: And so it's coming much, much 17 faster than even Jim Broderick and his group has been 18 able to estimate. Even the technical experts who 19 provided the information to Jim have been 20 underestimating that significantly. So I definitely 21 support that. 22 MR. BROOKMAN: That's helpful. You talked 23 about the increase. Could you hazard quantities? 24 MR. WALITSKY: Not being privy to the NEMA 25 numbers, I don't have a base to work from. But what we EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064310 1 see in the LED field -- I know -- they're just driving 2 forward. The white LEDs are now at the same efficiency 3 as metal halide. You can get a white LED for 100 4 lumens per watt. Now, it may be, you know, $3,000, but 5 you can do it, and those numbers are coming down. I 6 mean, my laptop was $1,000. Now it's $500. 7 MR. BROOKMAN: Yeah. 8 MR. WALITSKY: Well, that's what's happening 9 with LEDs very quickly. So this is what happens when 10 you have a disruptive technology, which is what LEDs 11 are. It will change the way we light our home. 12 MR. BROOKMAN: Ron Lewis. 13 MR. LEWIS: I think that most of what 14 Broderick and -- he's just a couple doors down from me. 15 Most of the objectives and most of the research money 16 is on the sole metric of lumens per watt increasing on 17 white LEDs. So the market penetration and the 18 commercialization, DOE's role in the R & D is really 19 more so in the development and hitting the benchmarks 20 for white LEDs, the lumens per watt. 21 The commercialization and estimates there, if 22 there's a source or outcome from the meeting in Atlanta 23 or somewhere where people are making projections, if 24 there's something we can note. Part of our difficulty 25 is as we're choosing levels that people are going to EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064311 1 have to comply with, the more that we can quote and 2 refer to bodies of expertise where there's been a 3 thorough discussion versus choosing a number that's 4 speculation. 5 People are going to have to comply with what 6 we put in the regulation. So we try to -- if we make a 7 mistake on a guesstimate of the evolution of technology 8 -- we're limited. We have to look at max tech, the 9 highest level we can identify. But then, because of 10 the two criteria, the technical feasibility and the 11 economic justification, we have to rule things out 12 starting at the highest level. 13 So in setting the minimum level of efficiency 14 that's allowable, we need to have a view on maybe the 15 national impacts and make some projections. The more 16 we can rely on bodies of expertise where they've talked 17 about market projections and commercialization, the 18 better that section will be. But our final decision is 19 -- we can't put a heavy weighting factor on speculation 20 that's something that's still to come. 21 MR. WALITSKY: Which is why I was loathe to 22 give a number. I cannot do that. 23 MR. BROOKMAN: Yeah, right. I was wondering 24 whether you all have access to -- whether you can track 25 the manufacturing capacity and see how that's ramping EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064312 1 up. 2 MR. WALITSKY: You might check with EIA. 3 They usually have numbers in the semiconductor type 4 field. Because this is a different field now. Your 5 statistics will show up in the semiconductor industry 6 rather than in the lighting industry. So maybe do 7 both. 8 But on a personal note, I made LEDs in 1972. 9 I got a master's in management engineering at New 10 Jersey Institute of Technology, and my thesis in 172 11 was to set up a company to make LEDs. So I see 30 12 years out, you know. 13 MR. BROOKMAN: We may see another career for 14 you. 15 MR. WALITSKY: Yeah, right. But the red 16 LEDs, which we made at the time, the reds and blues and 17 greens, have been around for a long, long time. 18 MR. BROOKMAN: Okay. MR. WALITSKY: White is where things are

MR. LEWIS: There was talk yesterday about 22 the compact fluorescents. Those have been around for 23 several decades as well. In speculating on when it 24 would become a major influence, a lot of people would 25 have guessed wrong on how long it took to ramp those up EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064313 1 with the potential they had. So we need to be a little 2 bit careful on how we guesstimate those things. 3 MR. BROOKMAN: That takes us back to the base 4 case market share matrices. 5 MS. GUPTA: Yeah. So, another important 6 thing to know on this slide is that in the residential 7 sector we assume of covered IRLs, not considering the 8 emerging technologies, that the covered IRL will remain 9 approximately the same efficacy, that they will remain 10 to be halogen type over the entire analysis period. In 11 the commercial sector we show a migration towards more 12 halogen infrared technology by 2042. 13 MR. BROOKMAN: Do you have any other specific 14 questions with respect to Slide 26? 15 MS. GUPTA: Do I? 16 MR. BROOKMAN: Yes. 17 MS. GUPTA: Well, I mean, I think the most 18 helpful thing for us would be just to get your input on 19 these inputs and populate these, if possible, and 20 populate what you think the emerging technologies 21 number is. 22 MR. BROOKMAN: So then, any specific edits, 23 suggestions with respect to these numbers that are in 24 the charts here would be helpful. Keith. 25 MR. COOK: Keith Cook, Philips. One thing we EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064314 1 noted yesterday was the fact you needed to include BR

MR. BROOKMAN: BR lamps. I made that note,

5 MS. GUPTA: Right now we only measure the 6 impacts on the covered IRL because with the standards 7 we don't -- we look at a separate scenario. In the 8 base case, we only want to look at the energy 9 consumption due to covered IRL. In the standards case, 10 we may show an additional shift towards BR lamps, in 11 which case we'll incorporate that into the shipment 12 forecast. I don't know if that's clear, actually. 13 MR. BROOKMAN: I didn't get that. Say it 14 again. BR lamps are not included -- 15 MS. GUPTA: Yeah. BR lamps that are 16 incandescent and exempted from standards aren't 17 included in this forecast because we're not measuring 18 the -- we don't need to take that into account in 19 measuring the energy savings in the standards case. 20 In the standards case, if there's an 21 additional shift towards BR lamps, then that will cause 22 -- so, in the standards case we do take that into 23 account, but in the base case forecast that doesn't 24 need to be shown. We're just looking at what's the 25 stock in the base case of our covered IRL. If there's EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064315 1 an additional shift towards BR lamps in the standards 2 case, then we'll show that. 3 MR. BROOKMAN: Because it's not a covered 4 item. 5 MS. GUPTA: Yeah, because it's not a covered 6 item. 7 MR. BROOKMAN: In the base case. 8 MS. GUPTA: In the base case, right. 9 MR. BROOKMAN: Ron Lewis. 10 MR. LEWIS: But in the second column, then, 11 in the stock in 2042, as we're showing some depletion 12 and partial -- looking at the first line, the 90-watt, 13 if we're looking at impacts, those impacts are 14 attributed to something. We're looking at a decline in 15 percentage of market share of that product, and that 16 decline -- from what you just said, we do not consider 17 BR as contributing to that decline; is that what you're 18 saying? 19 MS. GUPTA: Well, if we were to assume that 20 BR lamps were to have an increasing market share than 21 they do today, then that would be considered in the 22 emerging technologies. We would subtract that from the 23 stock of IRL that we consider in the base case. 24 MR. LEWIS: Even though BR is not an emerging 25 technology, it would be put in the category for -- EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064316 1 MS. GUPTA: Right. Yeah, we could create a 2 second category saying that, okay, we assume that -- we 3 want to establish what the stock of covered IRL is in 4 the base case and then look at what are the changes to 5 that stock with standards, right? 6 So if we assume that BR lamps will have an 7 increasing penetration, then we may subtract even more 8 from that blue area and decrease our covered IRL stock 9 in the base case. 10 MR. LEWIS: It's a little bit tricky here, 11 also, with EISA legislation, where we're limited to the 12 single size now, the 65-watt, as the only exception. 13 So as we look at impacts, we've got to look at the net, 14 then, between all the different sizes that were out 15 there that have blossomed in growth to now what's going 16 to happen with just a single size being available and 17 how that affects the can lights that have grown in 18 popularity. So there are a lot of dynamics here to 19 look at. 20 MR. FERNSTROM: This is Gary from PG&E. The 21 point of confusion I keep having is that it seems to me 22 the vast majority of reflector lamps you find in homes 23 aren't covered. So we're doing this analysis on a tiny 24 part of the market. 25 MS. GUPTA: That's correct. We are -- I EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064317 1 mean, we're constrained by the definition in EISA and 2 the exemptions in EISA. 3 MR. FERNSTROM: So, a lot of my comments stem 4 from that point of confusion. 5 MR. LEWIS: But I think it does become 6 clarified on the standards case as we look at 7 substitution analysis and scenario kind of situations. 8 I think that it would be absorbed there. So the net 9 on that of national impacts on energy, it will show up 10 there. But we can't consider it in the base case. 11 MR. FERNSTROM: I understand how you're doing 12 your analysis. Given the rules of the game, that seems 13 to me to be correct. 14 MR. BROOKMAN: Okay. 15 MS. GUPTA: All right. So these are the 16 resulting IRL base case shipment forecasts. DOE 17 calculated these shipments by tracking the retirement 18 based on the lamp lifetime of IRL in the stock. You 19 see a decline in the shipments, primarily due to the 20 increased penetration of emerging technologies. The 21 commercial sector shifts toward longer-lived HIR 22 technologies. 23 So, any questions on this slide? 24 (No response.) 25 MS. GUPTA: So this shows the methodology EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064318 1 behind the standards case shipment forecast. The main 2 difference here is that instead of using base case 3 market share matrices, which I just showed you two 4 slides ago, we substitute those with standards case 5 market share matrices, where the baseline technology 6 may no longer be available to purchase. So we see a 7 shift in people's consumer choices. 8 Similar to fluorescent, we looked at various 9 scenarios to characterize how consumers will respond to 10 standards. One important thing to note is that we 11 assume that the stock of covered IRL -- or, the stock 12 of IRL lamps in the standards case is the same as the 13 stock of IRL lamps in the base case. In one of the 14 scenarios, though, we do subtract some of that stock 15 and attribute them to the 65-watt BR lamp. 16 The main scenario that we analyze just 17 assumes that all base case IRL consumers who are 18 purchasing covered IRL product continue to purchase 19 that same covered IRL product but just in a more 20 efficacious form. They will basically just roll up to 21 the lowest first cost lamp, and that is generally the 22 least efficacious lamp available. 23 As I just talked briefly about before, we 24 have the 65-watt BR lamp substitution sensitivity, 25 which accounts for a standards case market migration to EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064319 1 the exempted 65-watt BR30 and BR40 lamps. So people 2 currently purchasing a 50-watt PAR lamp may choose, 3 with standards, to purchase a 65-watt BR lamp instead. 4 We have market share matrices for that scenario as 5 well. 6 So we would definitely like your input on 7 what portion of people would be moving to the 65-watt 8 BR lamp at different standard levels. 9 MR. FERNSTROM: A comment on that. This is 10 Gary from PG&E. I find it very difficult to understand 11 that substitution reasoning because in cans in homes 12 the vast majority of customers are already using BR 13 lamps. You find hardly any PAR lamps in those sockets. 14 So if we're talking about substituting BR 15 incandescent lamps for the existing PAR lamps, that 16 seems to me like a very difficult concept since they're 17 vastly all incandescent BR lamps now. 18 MR. BROOKMAN: Paul, do you want to add on? 19 MR. WALITSKY: This is Paul Walitsky. The 20 other aspect of PAR lamps is that, for a household, 21 they're outside. You can't put a BR lamp outside. So 22 if somebody's lighting up their backyards for security 23 reasons and that kind of stuff, they can't switch. 24 MR. LEWIS: They can if it's an enclosed 25 fixture -- EXECUTIVE COURT REPORTERS, INC. (301) 565-0064320 1 MR. WALITSKY: Yeah, but most are just 2 plugged into a socket and mounted on the corner of the 3 house. Unless you change the sockets and put a fixture 4 on, that's not going to happen. 5 MR. FERNSTROM: Gary from PG&E again. There 6 is an issue with the distribution of lights. So you 7 want the fairly broad distribution of PAR lamp and BR 8 lamp in the house and you want a fairly directive 9 distribution of a PAR lamp outside. 10 MR. BROOKMAN: Ron Lewis. 11 MR. LEWIS: One of the things -- I'm not sure 12 -- I'm asking the team here as much as anything -- is, 13 along with that, the issue as far as BRs versus PARs, 14 which I also have concern about. But the final 15 traction of CFLs in the target market is to be a 16 replacement for incandescents, and even the shapes and 17 the sizes that, as they become more compact. Even 18 though the optics are different for CFLs, how that 19 comes into play in this analysis of CFLs going into can 20 lights as there's a more limited base of incandescents 21 to put in there. 22 MR. FERNSTROM: Well, I think Pam Horner 23 alluded to that yesterday when she talked about the 24 directivity of light and the fact that we're mostly 25 looking at efficacy here. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064321 1 So CFLs work well in cans as a substitute for 2 BR lamps except for two things in the market. The 3 dimmable products, while they exist, aren't 4 representing very much market share now, and secondly, 5 virtually all of the CFL products have a much broader 6 distribution than the IRL lamps, so that you don't get 7 as much illumination on the work surface. 8 MR. WALITSKY: This is Paul again. I was 9 just going to say, also, inside the house the PAR lamps 10 are heavier. The household cans aren't strong enough 11 in some cases. I've had offices where the lights are 12 going out when we put the PARs in, and we put the 13 lighter BRs in and everything is fine. That's another 14 factor in the fixture acceptability. 15 MR. BROOKMAN: Michael Scholand. 16 MR. SCHOLAND: I'd like, maybe, to respond to 17 Ron's question about CFL substitutions. 18 MS. GUPTA: Yeah. I was just going to say 19 that our model does actually have the capability of 20 looking at an increased migration to CFLs in the 21 standards case. If you go to the spreadsheet, you can 22 fill in a certain market share migration to that. 23 So if you feel that's something that should 24 be incorporated into our standards case forecast, then 25 please give us the numbers. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064322 1 MR. BROOKMAN: Mike Scholand. 2 MR. SCHOLAND: Mike Scholand again. I wanted 3 to respond to this question about the BR versus the PAR 4 lamp, but I don't want to lose this thread here. Ron, 5 did you want to respond to Mimi's -- 6 MR. LEWIS: What I was going to just suggest 7 is we've got three or four different things in play 8 here all at once that all contribute to this 9 projection. So any inputs that people have got that 10 are comprehensive, that go across rather than just 11 segments of how they interplay, would be very helpful. 12 With NEMA, as far as input as you're 13 discussing the implications in the rulemaking, the 14 shifts even. We've got a -- what was it, 2042 or 15 something, time period here -- a long time period. 16 Even if it's segmented, if there's a transition from 17 one to the LEDs or projections of -- you know, any kind 18 of specificity that is the observation, the expectation 19 that you've got. If we've got some input from people 20 to take a look at how that influences it, that could be 21 helpful. 22 MR. SCHOLAND: Okay. Thanks, Ron. Mike 23 Scholand again from Navigant. On this issue of the BR 24 versus the PAR, I agree that PAR lamps are very 25 frequently used on the exterior of homes for flood EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064323 1 lighting, but I don't think they're at 50 watts. I 2 don't think that lumen package is accurate enough for 3 flood lighting. I think it's 75 or, more often, 150 4 watts. 5 So the fact that these lamps exist -- and I'd 6 like the NEMA folk, the representative from Philips 7 perhaps -- because I know Pam is the main person -- 8 reflector lamps for NEMA -- to maybe respond to this. 9 But those lamps exist. They're sold. They're made by 10 all three majors. So, at 50 watts, you don't have 11 enough light for an area light outdoors. It has to be 12 an interior. I don't think it's commercial because 13 that's also not enough for the package. 14 I hate to bring my own experience in, but I 15 do use PAR lamps in my home. I have 50-watt PARs 16 screwed in, and I would not, you know, migrate to the 17 65-watt BR lamps. But some folks might be in my 18 situation doing that and then looking at a first cost 19 of an HIR PAR lamp, make a choice to go to the BR65. 20 That's what we're trying to represent in the model. 21 MR. BROOKMAN: Ron Lewis. 22 MR. LEWIS: One possibility to account for 23 the 50-watters and interior applications, even though 24 it's a shrinking part of the market, is in track 25 lighting as opposed to down lights: can lights where EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064324 1 you've got a suspension, a weight. When you've got 2 track lights where you need a variety of beam spreads, 3 where you've got things that are specific and they want 4 that heavy-duty lamp as opposed to just a blown glass, 5 it could be a major portion of that 50-watt market. 6 MR. BROOKMAN: Mike Scholand directed a 7 question your way. Are you in a position to say 8 anything about that? 9 MR. COOK: Keith Cook, Philips. I tend to 10 agree with what Mike was saying. The one area that I 11 think we are overlooking, though, is the retail market. 12 You find more and more stores like Gap and those 13 places which are using more and more of these lamps 14 around the periphery of the stores to highlight the 15 walls, the racks, and things like that. 16 It's a very booming market and it's something 17 that I think we need to have a better understanding of 18 as to how they're going to react to these kind of -- 19 MR. BROOKMAN: Are those can lights? 20 MR. COOK: They are more track lights, 21 usually. 22 MR. BROOKMAN: Track lights, yes. 23 MR. LEWIS: And wall washer lights. 24 MR. COOK: Yeah. 25 MR. LEWIS: Asymmetrical wall washers. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064325 1 2 3 MR. SCHOLAND: Excuse me. Sorry, Ron. MR. BROOKMAN: Mike. MR. SCHOLAND: Mike Scholand again. At 50 4 watts, is that about the wattage that these lamps are? 5 MR. COOK: Yeah. It's usually between 39 and 6 75. It's in that range. It's a very, very booming 7 market. 8 MR. SCHOLAND: Okay. Maybe we'll have a 9 follow-up question with Pam. Maybe in NEMA's written 10 submission they can make a specific comment on this, 11 the apportionment, to make sure the model is right. 12 Thanks. 13 14 15 16 MR. BROOKMAN: Okay. Thank you. MS. GUPTA: Okay? MR. BROOKMAN: Yeah. MS. GUPTA: There's a lot of feedback. 17 Okay. So the third scenario that we look at 18 is the 10 percent lumen increased sensitivity, in which 19 we assume that not all residential consumers will know 20 to go to reduced wattage lamps that give them the same 21 lumen output but may rather purchase same wattage or 22 higher wattage lamps that give them more of a light 23 output. So that will result in an overall increase in 24 lumens in the residential sector. 25 So here's an example of a standards case EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064326 1 market share matrix in the main scenario. In the 2 column labeled "Stock in 2011," those are the same base 3 market shares that we saw before in the commercial 4 sector. As you can see, at CSL 1 the halogen 5 technology is no longer available. So all halogen -- 6 consumers purchasing halogen in the base case must move 7 to an improved halogen lamp in the standards case. 8 People purchasing HIR in the base case continue to 9 purchase HIR. 10 Then, at CSL 2, you have everyone in the 11 commercial sector purchasing HIR lamps. At CSL 3, you 12 have everyone in the commercial sector purchasing 13 improved HIR lamps. 14 Any questions? 15 (No response.) 16 MS. GUPTA: In the residential sector, it's 17 very similar except that we don't have that part of the 18 market -- HIR lamps in the base case. So it's pretty 19 much just a roll-up. Everyone goes from purchasing 20 halogen to improved halogen at CSL 1, to HIR at CSL 2, 21 and improved HIR at CSL 3. 22 So this is just the main scenario market 23 share matrix. If you want to look at some of the 24 sensitivities, including the BR lamp sensitivity and 25 the inputs that we have for that market share matrix, EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064327 1 you can find that in Appendix 9B of the TSD, I think. 2 Is that correct? So. I think it's 9B. 3 So, are there any other questions on the IRL 4 shipment forecast? 5 MR. FERNSTROM: This is Gary from PG&E. I'd 6 just like to make the observation that what you've seen 7 looks pretty reasonable to me for the applications that 8 we've been talking about for PAR lamps in the 9 residential and commercial sector. That would be 10 outdoor residentially and track lighting and in 11 commercial track lighting and display lighting around 12 store perimeters and so on. 13 MS. GUPTA: Okay. 14 MR. BROOKMAN: Ron Lewis. 15 MR. LEWIS: Gary and others, if you have any 16 data, if you have any -- even if it's anecdotal but if 17 you can quantify it in some way, of the can lights that 18 are dimmable right now. There was a generalization 19 made yesterday of a lot of them being dimmable, but 20 there have been problems with dimming and even with 21 halogen lamps. You have to bring them up to full cycle 22 sometimes. You lose that -- you're paying a premium 23 for the technology but you don't get the advantage of 24 it if you don't rejuvenate the halogen cycle there in 25 the lamps. EXECUTIVE COURT REPORTERS, INC. (301) 565-0064328 1 So in looking at the impacts that would have 2 on substitution analysis and CFLs and things, any input 3 that you might have on percentage of those fixtures, 4 the lumineres using these lamps, it would be good to 5 have some kind of calibration of what we approximate 6 that use to be. 7 Certainly, that would be more so in the 8 residential sector than the commercial sector, where 9 they want all the light they can get. You're probably 10 not going to be doing a lot of dimming. It's for 11 display lighting and merchandising. 12 MR. FERNSTROM: So, I believe we do have some 13 information on that for California. California might 14 be a little unique with respect to the nation on 15 account of Title 24 and the way it treats residential 16 lighting. But we'll get that for you. 17 MR. LEWIS: Thank you. 18 MS. GUPTA: Mike Scholand just held up a sign 19 to me saying that the market share matrices are 20 actually in Appendix 9A, not 9B. Sorry about that. 21 MR. SCHOLAND: A quick follow-on to Ron's 22 comment. Gary, maybe this is what you were referring 23 to. Yesterday reference was made to a residential 24 inventory sub-meter study that was done in the State of 25 California in 2005, I think, that was meant to be like EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064329 1 a similar study, I guess, to the Tacoma Public 2 Utilities from '96. Is that the study you're going to 3 be providing to the Department? 4 MR. FERNSTROM: What I was going to do was 5 get information from the California Lighting Technology 6 Center. I think they may have done some work 7 themselves in addition to referring to the RLW study 8 and a study done by HMG Consulting on the distribution 9 of residential lamp types. 10 MR. LEWIS: Is that Mike Simonovich? 11 MR. FERNSTROM: Yes. 12 MR. LEWIS: Okay. 13 MR. SCHOLAND: Thank you, Gary. 14 MR. BROOKMAN: Okay. 15 MS. GUPTA: All right. So now I'm going to 16 just talk a little bit about the calculation of 17 national energy savings and the inputs that go into 18 that. 19 National energy savings is composed of the 20 product stock by design, which is developed in the 21 shipments model; the unit annual energy consumption, 22 which we establish in the energy use characterization; 23 the electricity site-to-source conversion factors, 24 which we calculate from the 2007 Annual Energy Outlook; 25 and HVAC interaction. For the commercial and EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064330 1 industrial sector, we used HVAC interaction of 6.25 2 percent, and we got that number from the 2000 ballast 3 rulemaking. We did not model HVAC interaction in the 4 residential sector. 5 We also incorporated a rebound rate that 6 accounts for the increased lighting usage due to lower 7 operating costs. In the commercial and industrial 8 sectors we used a number of one percent for the rebound 9 rate, and in the residential sector we used a number of 10 8.5 percent. 11 Does anyone have any questions or comments on 12 the inputs to the national energy savings calculation? 13 MR. BROCKMAN: Keith. 14 MR. COOK: Keith Cook, Philips. I wasn't 15 sure I understood what the six and a quarter percent on 16 the HVAC interaction is. That's percentage of what? 17 MS. GUPTA: That's percentage of total energy 18 savings. 19 MR. COOK: From what? I guess it would be 20 dependent upon the amount of energy being saved, 21 wouldn't it? 22 MS. GUPTA: Right. So we increase our energy 23 savings estimates by 6.25 percent. 24 MR. COOK: Going from what to what? 25 MS. GUPTA: So, calculating our energy EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064331 1 savings just due to lighting. If we have -- I'm not 2 sure if I understand your question. 3 MR. BROOKMAN: The heat load is diminished? 4 MS. GUPTA: Yes. 5 MR. BROOKMAN: So the air conditioning cost 6 is diminished? 7 MR. COOK: Right. 8 MS. GUPTA: Yes. 9 MR. BROOKMAN: Yes? 10 MR. COOK: But that means that from a base 11 case to CSL 3 or -- 12 MS. GUPTA: So, at CSL 3 we calculate an 13 energy savings just due to the reduced energy 14 consumption of lighting, right. And then we -- 15 MR. COOK: That's what I don't understand. 16 Which candidate standard level are you using? 17 MS.. GUPTA: Okay. For each candidate 18 standard level we calculate a separate HVAC 19 interaction. So if at CSL 3 we save one quad due just 20 to lighting, then we'll increase that one quad by 6.25 21 percent. So we'll be saving 1.0625 quads instead at 22 CSL 3. If at CSL 2 we're saving two quads, then we 23 increase that two quads by 6.25 percent. So that would 24 be 2.125 quads that we'd be saving. Is that clear? 25 So you're just multiplying the energy savings EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064332 1 at each candidate standard level by this percentage. 2 MR. COOK: It doesn't make sense to me. You 3 don't always get the same amount of energy savings as 4 you go from class to class. So the amount of savings 5 you see from your change in HVAC load would vary 6 depending upon the total amount of energy savings. 7 MR. FERNSTROM: This is Gary from PG&E. I 8 think the question has to do with to which standards 9 improvement level does the 6.25 percent refer. 10 MS. GUPTA: Every standard. 11 MR. FERNSTROM: Well, if -- but it has to 12 vary because the air conditioning impact is a fraction 13 or percentage of the total energy. 14 15 16 17 MS. GUPTA: Right. So we assume that for -- MR. FERNSTROM: Oh, that's the percentage. MS. GUPTA: It's the percentage. MR. FERNSTROM: I understand. It's a 18 percentage. 19 MS. GUPTA: Yeah, it's a percentage. So, as 20 you save more energy due to lighting, you're going to 21 save more energy due to HVAC. It scales up. 22 MR. COOK: Oh, so it's six and a quarter 23 percent of the energy savings from the lighting you 24 attribute to the HVAC. 25 MS. GUPTA: Right. Exactly. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064333 1 MR. COOK: I get it, I get it. Okay. 2 MR. BROOKMAN: Paul. 3 MR. WALITSKY: This is Paul Walitsky. Where 4 did the -- it was in the ballast rule -- 5 MS. GUPTA: Yeah. 6 MR. WALITSKY: -- the 6.25? 7 MS. GUPTA: The ballast rulemaking did an 8 analysis for the HVAC interaction, and they established 9 6.25 percent as that HVAC factor. We looked at how 10 that number might change given time, but due to lack of 11 information we were only able to estimate that given 12 opposing -- the various opposing factors, and we 13 estimated that that number would not change 14 significantly during the analysis period that we're 15 looking at. 16 MR. FERNSTROM: Okay. So, an observation 17 about that, then. That 6.25 percent seems to me to be 18 a relatively low number because it's our sense that the 19 heat that is produced by these products goes directly 20 into the building and it takes about one unit of 21 electric energy to remove three units of heat. So 6.25 22 percent is a relatively conservative number. 23 MR. WALITSKY: Yeah, this is Paul Walitsky 24 again. The rule of thumb in the field when people are 25 changing lamps for living -- Amtech and the service EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064334 1 people -- is about a quarter of a watt for every watt 2 you save in the ceiling. That's where -- make their 3 money because they don't pass that on. That's their 4 profit margin. So they look at that pretty closely. 5 I would look at NELCO, the National -- those 6 guys and see who has some data because, I agree, I 7 think the 6.25 is on the low end. 8 MS. GUPTA: So, is that lighting-specific, 9 those estimations? 10 MR. WALITSKY: Yes. The lighting people, the 11 service lighting industry, NELCO and there's another 12 group that are the service people. They have a better 13 idea. 14 15 fixtures? 16 17 18 MR. BROOKMAN: And it's for switching out

MR. WALITSKY: Yeah. MR. BROOKMAN: Relamping? MR. WALITSKY: Exactly, exactly. That's 19 their bread and butter. 20 MR. BROOKMAN: Michael Scholand. 21 MR. SCHOLAND: I just wanted to chime in. 22 The issue of the six and a quarter percent, I think 23 it's looking nationally and it's looking over a full 24 calendar year. Obviously, in the northern regions of 25 the country there will be heating load and actually the EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064335 1 lighting is providing a service that the HVAC doesn't 2 need to provide. 3 This study was actually done by Berkeley 4 National Lab and was pretty thorough at the time. As 5 Mimi said, the same data is not available to us now. 6 It hasn't been updated. So as a surrogate, not to 7 ignore the issue, we wanted to put something there. 8 MR. BROOKMAN: Gary, go ahead. 9 MR. FERNSTROM: Gary from PG&E. That 10 explains it. I was looking at -- 11 MR. BROOKMAN: If it's national and if it's a 12 year-long basis. 13 MR. FERNSTROM: Year-round, yeah. 14 MR. WALITSKY: When we relamped our building, 15 we had to add in another $3,000 for night heating 16 because the building has no central heat. 17 (Laughter.) 18 MR. WALITSKY: But we accounted for it. I 19 still got -- Energy Star manufacturing -- 20 MR. BROOKMAN: Okay. 21 MS. GUPTA: Are there any other questions on 22 the inputs into the national energy savings 23 calculation? 24 MR. LEWIS: I love it when we have a lively 25 discussion and end up at the same place we started. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064336 1 Yeah, that's probably right. I love it when that 2 happens. 3 (Laughter.) 4 MS. GUPTA: So, to calculate net present 5 value, the inputs are the shipments, taken from the 6 shipments analysis; the per-unit installed cost, which 7 we establish in the product price determination in the 8 lifecycle cost analysis; electricity prices, the 9 averages prices taken from the LCC analysis. Future 10 energy prices are adjusted according to trends in AEO 11 2007. We use a seven percent and a three percent real 12 discount rate, and future expenses are discounted to 13 2007. 14 Also, to account for remaining lifetime of 15 lamps at the end of the analysis period, we calculate a 16 residual value in both the base case and the standards 17 case, similar to the LCC discussion yesterday. 18 Is there any comment on the inputs into the 19 net present value calculation? 20 (No response.) 21 MS. GUPTA: All right. So now I'll just show 22 some of the results here. These are the national 23 energy savings and net present value results for 24 general service fluorescent lamps in the shift 25 scenario. As you might remember, we looked at two EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064337 1 different scenarios in the GSFL NIA, the roll-up and 2 the shift. The shift is generally showing higher 3 energy savings than the roll-up. 4 So you can see here generally across all of 5 the lamp types we have increasing energy savings with 6 CSL, and generally, most standard levels are shown to 7 be cost effective. 8 MR. BROOKMAN: Gary. 9 MR. FERNSTROM: Gary from PG&E. I recall 10 yesterday we had a discussion about the utility prices 11 and thought at least for California they were shown to 12 be low in the analysis. 13 MS. GUPTA: And then for IRL, we have 14 something similar. The national energy savings, shown 15 in the bars, are increasing with increasing CSL. The 16 net present value also increases with CSL. 17 18 19 Any comments on the results? (No response.) MS. GUPTA: All right. So this concludes our 20 recap of the national impact analysis. Are there any 21 other, further comments on any of these topics: base 22 case, standards case, market share matrices? 23 MR. BROOKMAN: For those of you that want to 24 refresh your memory, you can look at Slide 38 there and 25 see a brief summary of the major topics. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064338 1 (No response.) 2 MR. BROOKMAN: Okay. 3 MS. GUPTA: Okay. So, should we just move on 4 to the next section? 5 MR. BROOKMAN: Yes. 6 NOPR Analyses 7 Mahima Gupta and Frances Wood 8 (PowerPoint presentation.) 9 MS. GUPTA: All right. So now we're going to 10 be just talking briefly about some of the NOPR analyses 11 we'll be conducting and the next steps of the 12 rulemaking. 13 So, after this public meeting and a period of 14 comment, we'll be going through several processes to 15 complete the notice of proposed rulemaking, or NOPR. 16 The first step in the NOPR is to revise the ANOPR 17 analyses that we've discussed today based on•new data 18 and input from stakeholders. So we'll consider the 19 ANOPR comments that we've received today as well as 20 written comments and revise the analyses using the 21 latest data. Those analyses will be the three main 22 analyses as well as their inputs that we talked about 23 today: the engineering, lifecycle cost, and national 24 impact analysis. 25 The next step in the NOPR is to establish EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064339 1 trial standard levels. In the ANOPR, DOE is required 2 to present CSLs, or candidate standard levels, for 3 stakeholders -- for public comment, and from the 4 candidate standard levels there are specific criteria 5 that are used to determine the trial standard levels. 6 Each trial standard level consists of a set of 7 candidate standard levels covering all product classes, 8 and they may vary between product classes. 9 Candidate standard levels cover a range of 10 efficacies and can include the most energy efficient 11 level, or max tech, the efficiency level with the 12 lowest lifecycle cost, efficiency levels with 13 noteworthy technologies and efficiency levels that fill 14 in large gaps between candidate standard levels. 15 The trial standard levels are a critical part 16 of the NOPR analysis, and we definitely would 17 appreciate your input on the trial standard levels that 18 should be chosen. As I just said before, they're 19 created from combinations of the candidate standard 20 levels that we've discussed today. 21 I think Mike Rivest addressed a comment 22 yesterday about we would probably create a separate set 23 of trial standard levels for general service 24 fluorescent lamps than we would for incandescent 25 reflector lamps. Oftentimes the trial standard levels EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064340 1 are based around a consistent theme. 2 Does anyone have any comments on trial 3 standard levels? 4 (No response.) 5 MS. GUPTA: All right. So the next step in 6 the NOPR analysis is the LCC subgroup analysis. The 7 purpose of the LCC subgroup analysis is to evaluate the 8 economic impacts of standards on consumer subgroups. 9 Some of these subgroups may include consumers operating 10 lamps in a variety of sectors, how consumers in the 11 commercial sector may be affected differently from the 12 residential sector, consumers operating lamps in a 13 variety of building types, consumers replacing 14 different baseline lamps. Consumers replacing a T12 15 baseline may have different economic impacts than those 16 replacing a T8 baseline. 17 And, consumers purchasing due to the several 18 events that we spoke about yesterday. So a consumer 19 purchasing a lamp if their ballast has died, their 20 economics may be different than a person who is just 21 purchasing a lamp because their lamp has died. 22 Another possibility is that we may consider 23 analyzing the impacts on low-income consumers. DOE 24 welcomes comment on how the LCC inputs might change for 25 each consumer subgroup. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064341 1 No comments? 2 (No response.) 3 MS. GUPTA: The next step in the process is 4 the manufacturer impact analysis. The purpose of the 5 manufacturer impact analysis is to assess financial and 6 other qualitative and quantitative impacts on 7 manufacturers due to standards. During this analysis 8 we'll identify manufacturer subgroups also that we 9 should consider in more detail. 10 In addition, we'll also consider the 11 cumulative regulatory burden on manufacturers. So if 12 some manufacturers are manufacturing other products 13 that may be subject to regulations, we'll consider that 14 as well. 15 In completing the manufacturer impact 16 analysis, we'll utilize two major tools. One is the 17 Government Regulatory Impact Model, or GRIM, and the 18 second is interviews with manufacturers. The output of 19 the manufacturer impact analysis is industry net 20 present value impacts, subgroup net present value 21 impacts, and any other impacts. 22 So the MIA, or manufacturer impact analysis, 23 consists of three phases. For phase one, we do a 24 preliminary manufacturer impact analysis to create an 25 industry profile. We use the industry profile EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064342 1 developed in phase one as an input into the preliminary 2 GRIM. In phase three, we take the information from 3 interviews and recalculate the GRIM based on that 4 information. 5 Here's just a flow diagram to see how the 6 different phases of the manufacturer impact analysis 7 fit into the other analyses that we have discussed 8 today and yesterday and some that we'll be discussing 9 further in an upcoming presentation. 10 So, phase one, which is the industry profile, 11 is an input into the engineering to help us establish 12 an engineering analysis. Then the engineering, LCC, 13 and national energy savings analyses are used to 14 develop the preliminary GRIM. Then phase three, which 15 is composed of manufacturer interviews, revised 16 industry cash flows, the manufacturer subgroup 17 analysis, and a qualitative assessment of manufacturer 18 impacts is done in conjunction with the NOPR analyses, 19 which are the LCC subgroup and utility, environmental, 20 and employment impact analyses, which we'll be 21 discussing shortly. 22 All right. So just for a little bit more 23 detail, in phase one we look at all publicly available 24 information, like industry reports and annual reports, 25 to create an industry profile. Here are some of the EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064343 1 data sources that we might use. 2 In phase two, we develop the preliminary 3 government regulatory impact model. The GRIM is an 4 industry cash flow analysis that estimates the change 5 in industry value due to the introduction of new energy 6 conservation standards. As you can see in this slide, 7 manufacturer prices and shipments, manufacturer costs, 8 and financial information are key inputs into the GRIM, 9 out of which results the cash flow impacts and changes 10 in industry MPV. 11 The second step of phase two is to develop an 12 interview guide. We generally mail this interview 13 guide to manufacturers before the interview so they can 14 look over the questions and prepare answers. The 15 interview guide will include engineering analysis 16 results, shipment results, cost structure and financial 17 parameters, conversion costs, impacts of other 18 regulations, direct employment impacts, export issues, 19 consolidation of the industry, replacement parts, 20 refurbishments, impacts of standards for the effective 21 date, and other topics that manufacturers feel that are 22 important to this rulemaking. 23 Phase three of the MIA actually includes the 24 interviews, and these will take place after the ANOPR 25 comment period closes. They will typically be on site EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064344 1 at manufacturers' facilities. 2 I'd like to also emphasize that when we 3 conduct the manufacturer impact analysis we stress 4 confidentiality. So a contractor with DOE will 5 establish a nondisclosure agreement with the 6 manufacturers so we can conduct the interviews. 7 Finally, another part of phase three is the 8 manufacturer subgroup analysis. The subgroup analysis 9 is a more focused version of the industry-wide analysis 10 where we will gather information about what subgroups 11 or characteristics are most important and how smaller 12 manufacturers may be impacted by standards. 13 The final part of phase three is taking all 14 the information that we've gathered and revising the 15 inputs into the GRIM and getting some new numbers out 16 of the model. Also, we look at qualitative impacts on 17 the industry, such as competitive impact assessment, 18 manufacturing capacity impact, employment impact, and 19 cumulative regulatory burden. 20 Now I'm going to turn the podium over to 21 Frances Wood from OnLocation to speak about the 22 utility, employment, and environmental analyses. 23 MS. WOOD: Hi. Just to give you a brief 24 overview of these three additional analyses that are 25 done as part of the NOPR processes. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064345 1 The first one is the utility impact analysis. 2 Basically, the idea here is to look at the impact on 3 the utility sector of the various efficiency levels due 4 to the potential standards. We'll be using a model I 5 think many of you are familiar with, the National 6 Energy Modeling System, a variant of that. This is the 7 model EIA uses to produce the Annual Energy Outlook. 8 It's been tailored slightly to our use for 9 the Building Technology program, so we call it NEMS-BT. 10 Basically, the modification is to allow us to take the 11 energy savings that Mimi has already shown and input 12 them into the model as energy savings in lighting for 13 the residential, commercial, and industrial sectors. 14 The model is run under the base case, which 15 is essentially the AEO, and then under different levels 16 with these additional energy savings and reductions in 17 electricity consumption resulting from the standard 18 levels. From that we can measure the difference effect 19 that the standards are causing, and we can look at the 20 change in energy sales by region -- that is essentially 21 the input from the previous analysis -- the change in 22 the mix of electricity generation, and the change in 23 the mix of new capacity construction. 24 The anticipation is with reduced electricity 25 demand we will see a slight reduction in new capacity EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064346 1 construction and we may see a slight shift in the mix 2 of generation types. 3 This is going to be a very brief overview, so 4 if there are any questions about the utility impact, 5 this might be a good time to ask. 6 (No response.) 7 MS. WOOD: Seeing no questions, I'll move on 8 to the employment impact analysis. This is to look at 9 the net jobs to the economy of the proposed standards. 10 This goes beyond the manufacturing impact to the rest 11 of the economy. 12 13 already. 14 The tool used here is -- I see a question

MR. FERNSTROM: Gary from PG&E. Could we go 15 back to the utility analysis for just a moment? You're 16 going to look at the potential change in the mix of 17 electric generation, and I presume under that category, 18 if there comes to be some sort of carbon trading or 19 carbon tax you'll look at how this energy savings 20 relates to utilities perhaps more easily being able to 21 meet their carbon emission requirements? 22 MS. WOOD: Traditionally, the impact analysis 23 and all of these analyses are done with the reference 24 case, which is current laws and regulations, rather 25 than trying to speculate on new policies. At the EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064347 1 moment there is no national carbon legislation, so we 2 wouldn't see the result of that, although that effect 3 you postulate is an interesting one. But it's sort of 4 outside the usual forecasting that we do. 5 MR. BROCKMAN: If there were some kind of 6 carbon legislation, how would you deal with it? 7 MS. WOOD: The carbon legislation can be 8 represented in the model, depending on what kind of 9 legislation it is, as a cap and trade program, in which 10 case, either for utilities only or for the entire 11 energy sector, which is being discussed on the Hill. 12 So we would represent that as a cap that must be met, 13 and the model would solve for carbon allowance prices 14 to meet that cap. 15 Certainly, appliance standards would then 16 change the energy consumption pattern and affect how 17 difficult it is to meet that cap and therefore the 18 carbon allowance prices. So the model can handle that 19 kind of question. 20 MR. FERNSTROM: Okay. So I understand how it 21 may not be appropriate to speculate. On the other 22 hand, the effects of this rulemaking go out decades. I 23 think of all of the issues, you know, facing the 24 utility industry, this carbon one is perhaps the most 25 significant. So it might be a good idea to give some EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064348 1 thought to that. 2 MR. BROOKMAN: Ron Lewis. 3 MR. LEWIS: Stay tuned. It's a little bit 4 premature, but as you're aware, a very dynamic time 5 that we're in in exploring this and looking at in the 6 stance of the U.S. Government at large, not just the 7 Appliance Standards Program. So this is only the 8 ANOPR. We note that there probably will be some impact 9 in the future, but right now, at this time, we can't 10 include it in the ANOPR. 11 As we move forward, there's a strong 12 possibility that this will be incorporated in some way 13 in the future, but right now in the ANOPR early stage 14 we can't really handle it. So, thanks for the input 15 and watch closely in the future. 16 MR. FERNSTROM: Okay. Thank you. 17 MR. BROOKMAN: You said the model does have 18 the capacity to deal with this. 19 MS. WOOD: In fact, it's been used by EIA and 20 others to look at a lot of carbon legislation being 21 proposed by Congress in the last couple years. 22 MR. BROOKMAN: Thank you. 23 MS. WOOD: So, moving on back to the 24 employment analysis, this one uses a different tool of 25 looking at jobs, a spreadsheet model. It's an EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064349 1 input/output model of the economy, taking information 2 from previous analyses, looking at the change in both 3 the cost of the products and the energy expenditure 4 savings to impact -- to look at both substitution 5 effects and income effects that may change what people 6 purchase that then has a ripple through the economy to 7 jobs in other parts. 8 The direct employment impacts specifically on 9 the lighting manufacturers will be handled in that 10 previous analysis described, the manufacturing impact 11 analysis. This one is looking at the general economy, 12 looking at net job impacts. 13 The environmental assessment looks primarily 14 at, in terms of the environment, again sort of related 15 to the utilities, the impact that reducing electricity 16 consumption for lighting will have on emissions, 17 primarily from power generators. Again, this energy 18 savings comes from the national impact analysis, and 19 NEMS-BT will be used to look at power plant emissions. 20 Air emissions are of many different kinds. 21 The primary impact that we'll look at will be C02 22 emissions, which is clearly a very relevant topic, as 23 we've just discussed. We also can look at SO2 and NOx 24 emissions. However, both of these are effectively 25 capped through current legislation, and so we don't EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064350 1 really anticipate seeing any savings from the standards 2 for those two types of emissions. 3 Mercury and the cap and trade rule. 4 Originally mercury was capped by the mercury rule, but 5 that was recently overturned by the Supreme Court. 6 It's now unclear what EPA will do. EPA will have to do 7 something on mercury regulations, but replacement 8 regulations are not yet determined. So there's a 9 little uncertainty of how we will treat mercury in this 10 rulemaking, and I think part of it will have to do 11 with, as we go through the stages, how much of future 12 policy becomes defined so that we can actually 13 represent something. 14 I think our default case will probably be the 15 continuation of the cap and trade because that shows 16 significant reductions in mercury and any replacement 17 will also likely require significant reductions in 18 mercury emissions. But if anybody has any comments on 19 the treatment of that, you're welcome to provide 20 comments. 21 Thank you. Now we'll switch back again and 22 Mimi will present the regulatory piece. 23 MS. GUPTA: All right. So I'm going to be 24 talking about the regulatory impact analysis.25 Basically, the regulatory impact analysis looks at nonEXECUTIVE COURT REPORTERS, INC.

(301) 565-0064351 regulatory alternatives to energy conservation 2 standards that may cause people to purchase higher 3 efficiency or higher efficacy lamps. It looks at 4 whether you could get the same national impact savings 5 at a given level using these non-regulatory approaches. 6 Some of them that we will be looking at are 7 consumer tax credits, customer rebates, enhanced 8 education programs, and bulk government procurement of 9 higher efficiency equipment. 10 To do this, we'll basically modify the inputs 11 into the national energy savings spreadsheet that we 12 just talked at length about. Most of that will be 13 modifying the market share matrices that we've been 14 talking about. 15 So instead of having -- with standards, what 16 you generally do is you have people who are purchasing 17 below the standard, 100 percent of the people now have 18 to move. In a non-regulatory alternative, instead of 19 having 100 percent of the people moving you would have 20 a portion of those people moving to higher efficacy 21 alternatives or higher efficacy lamps given the 22 incentives that we're creating. 23 We calculate a national energy savings and a 24 net present value for the non-regulatory alternatives. 25 That concludes the NOPR analyses section. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064352 1 Are there any questions? 2 (No response.) 3 MS. GUPTA: Okay. So, should we go on to the 4 closing slides? 5 MR. BROOKMAN: Yes. 6 MS. GUPTA: Okay. 7 MR. LEWIS: Please do. 8 (Laughter.) 9 MS. GUPTA: So we appreciate your patience 10 and your comments over the past few days. Just as a 11 recap, I just wanted to put up the seven EPCA factors 12 again that we talked about at the beginning of this 13 public meeting and some of the analyses that we've 14 talked a little bit about: the lifecycle cost 15 analysis, the manufacturer impact analysis, engineering 16 analysis, national impact analysis, and the analyses of 17 environmental, utility, and employment that we've been 18 talking about. 19 How to submit comments. Your comments are 20 very important to us. It will help us really improve 21 our analysis. All of the comments that you guys have 22 been gracious enough to give us at the public meeting 23 have been captured in the transcript, and we'll 24 consider those in developing the NOPR. We would 25 appreciate written comments as well. You can do that EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064353 1 by e-mail, mail, or courier. 2 As I said in the beginning of the day 3 yesterday, the ANOPR comment period is scheduled to 4 close 30 days after publication of the notice in the 5 Federal Register. The notice is scheduled to be 6 published on March 13th, so if all goes well, the ANOPR 7 comment period should be closing on April 12th. So we 8 would appreciate your comments by that date. 9 Thank you very much. 10 MR. BROOKMAN: Thank you. Back to Ron Lewis 11 for -- comments before we turn it back to Ron Lewis. 12 Keith and then to Gary. 13 MR. COOK: Keith Cook, Philips. One 14 question. How can we get a copy of the presentations? 15 16 online. 17 MS. GUPTA: The presentation will be posted

MR. COOK: Because it does a great job of 18 capturing all the salient points and it would be good 19 to use that as a way to provide comments. 20 MS. GUPTA: Yeah, definitely. 21 MR. BROOKMAN: Okay. Gary? 22 MR. FERNSTROM: Before we close, yesterday 23 Andrew Delaski made some opening remarks. I'd just 24 like to add on PG&E's behalf our appreciation to the 25 staff and consultants who are doing a really great job EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064354 1 with this process and giving us the opportunity to 2 comment. 3 MR. BROOKMAN: Thank you. Paul. 4 MR. WALITSKY: I'd like to echo that. I 5 think, as I said last night to some people, that our 6 comments are mainly fine-tuning and just tweaking here 7 and there, I think because you did a good base job. 8 The one comment I would make, and I've been 9 thinking a little bit about it, is that because NEMA 10 has been -- numbers, but as you pointed out, it only 11 represents 90 percent in one case and 85 percent in the 12 other for the IRLs. Is there going to be any effort to 13 get to the other 10 or 15 percent, and how do you do 14 that? It's not easy because some of them are fairly 15 small companies, like Penn Electric and there's the guy 16 at New Fargo and there's Halco. There are smaller 17 companies that are not members of NEMA. You can find 18 them, but whether they're really impacted, the analysis 19 may not be worth, you know, the while to do. 20 But it is another part of it. They will most 21 likely be affected from an impact from an employment 22 standpoint because some of their technologies are 23 older, and they're going to fade away. So that's the 24 areas where they may have a disproportionate impact 25 even though they're a much smaller share of the market. EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064355 1 So I think that's something to keep in mind. 2 MR. BROOKMAN: Mike Scholand. 3 MR. SCHOLAND: Mike Scholand. Yes, Paul, 4 thanks for that comment. Two responses. One is that 5 basically NEMA's data is, as you say, representing the 6 vast majority of the market. We use the 85 and 90 7 percent estimates to scale up the shipments that 8 they've given us to make sure that we're representing 9 shipments for the country as a whole, including the 10 small manufacturers who are not members of NEMA. 11 So from a mathematical point of view and a 12 calculation point of view, the analysis stands and is 13 representative of the country. 14 One of the things that Mimi alluded to in the 15 manufacturers impact analysis, which is going to be 16 conducted between now and the NOPR phase, is to look at 17 the impacts on manufacturers, and a subset of that -- 18 you may remember her talking about the small business 19 impacts. There is a small manufacturers subgroup 20 analysis. In that analysis in particular we'll be 21 looking at differential impacts on small manufacturers 22 of the regulation. 23 In some cases, those impacts can drive the 24 standard the Department goes to. For example, in 25 distribution transformers, impacts on small EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064356 1 manufacturers was a driving force behind the selection 2 of the standard level for medium voltage dry type. 3 So we're very interested in you providing the 4 names of those companies, contact information, and so 5 on. DOE will take that into consideration and make 6 that part of its analysis in the small business 7 impacts. 8 MR. WALITSKY: I can put together some list. 9 It won't be exhaustive, but it will have some you may 10 not know. 11 12 MR. SCHOLAND: I know we know some. MR. WALITSKY: I can, of course, check with 13 NEMA to make sure they're not members. 14 MR. SCHOLAND: Sure. We do know some. 15 Obviously, Ron's experience in the industry is very 16 helpful for the team. But anything you have to 17 contribute, that would be very helpful. Thanks, Paul. 18 MR. BROOKMAN: Okay. So then, yes, please. 19 MR. HANSEN: Dain Hansen with NEMA. I just 20 want to thank everyone for this opportunity. Anything 21 you need from us. I'm sure we'll be hearing from 22 everyone, and we'll be giving some good comments. We 23 look forward to working with you on this rulemaking. 24 MR. BROOKMAN: Thank you. Final comments 25 before I turn it back to Ron? EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064357 1 (No response.) 2 MR. BROOKMAN: So, one thing we always do is 3 we evaluate these sessions, so I'm going to hand out 4 these evaluation forms. They're very brief. It will 5 take you only 30 seconds, unless you wish to spend more 6 time on them. Ron Lewis. 7 Closing Remarks 8 Ron Lewis 9 MR. LEWIS: Yesterday I was a little bit over 10 reactive when somebody suggested we just finish up 11 yesterday. 12 (Laughter.) 13 MR. LEWIS: When I knew all that the team had 14 gone through to not just put this together but the 15 difficulty originally where we had the general service 16 incandescent lamps to consider as well and an 17 incredible heroic effort of trying to get their arms 18 around that. And then, at the eleventh hour on 19 December 19th, the new legislation removed that from 20 this rulemaking that was almost completed, the ANOPR, 21 and they had to go back to the drawing boards, redo all 22 the analysis, take out the impacts of that. 23 They have worked incredibly hard to put 24 together the presentations that they have made in the 25 last couple days. So it was kind of a sensitive area EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064358 1 yesterday knowing how hard they had worked to get this 2 together to try to rush through it and not have a full 3 dialogue. 4 I especially appreciate everybody that showed 5 up for the second day. 6 (Laughter.) 7 MR. LEWIS: And not just show up to be a 8 spectator but were clearly participants and gave us a 9 lot of good comment. We really appreciate that 10 because, at the end of the day, we all have to live 11 with this. We may not all agree and have the exact 12 same perspectives on things, but we want to have a good 13 discussion and make sure we agree on all the elements 14 that are in play and can put attention to those. 15 So thanks again for being here. Some of the 16 people that didn't make it had some bad weather and had 17 planes canceled and things. We hope that your journeys 18 back home are comfortable and safe. We look forward 19 to, as we progress from this ANOPR, advance notice, to 20 the notice, which is one notch up in being official and 21 being a proposed level, that we'll have some good 22 comments from you. We'll give serious attention to 23 those, and we'll have another good dialogue and 24 approach the final rule with everything on the table. 25 So, thanks again for your input. If you have EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064359 1 questions, we will be posting the presentations on our 2 website. So you will have those to work with. If you 3 haven't worked with the TSDs before, they are the cure 4 for insomnia. 5 (Laughter.) 6 MR. LEWIS: We measure them by the pound. 7 So if there's any question that you have that 8 wasn't presented here, it's probably in the TSD. 9 That's also on our website, popular reading. 10 So, thanks again for being here. 11 (Whereupon, at 10:30 a.m., the meeting was 12 concluded.)

EXECUTIVE COURT REPORTERS, INC. (301) 565-0064360 1 I PORTER'S CERTIFICATE 2 3 4 5 6 This is to certify that the attached proceedings before:

UNITED STATES DEPARTMENT OF ENERGY In the Matter of: PUBLIC MEETING ON TEST PROCEDURES FOR GENERAL SERVICE FLUORESCENT LAMPS, INCANDESCENT REFLECTOR LAMPS, AND

GENERAL SERVICE INCANDESCENT LAMPS AND

7 8 9 10 11 12 13 14 15 16 17 18

19 20 ENERGY CONSERVATION STANDARDS FOR GENERAL SERVICE

FLUORESCENT LAMPS AND INCANDESCENT REFLECTOR LAMPS Were held as herein appears and that this is the original transcript thereof for the file of the Department, Commission, Board, Administrative Law Judge or the Agency. Further, I am neither counsel for or related to any party to the above proceedings.

r Official Reporter Dated: April 5, 2008

EXECUTIVE COURT REPORTERS, INC.

(301) 565-0064