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UNITED STATES DEPARTMENT OF ENERGY 

PUBLIC MEETING ON ENERGY CONSERVATION STANDARDS FOR 

BATTERY CHARGERS AND EXTERNAL POWER SUPPLIES

U.S. Department of Energy 

 Room 1E-245 

1000 Independence Avenue, Southwest 

 Washington, D.C. 

Friday, September 12, 2008 

 9:00 a.m. 

Participants

 DOUG BROOKMAN, Facilitator 

 VICTOR PETROLATI 

 Department of Energy 

 LARRY ALBERT 

 Black & Decker 

 CHRIS CALWELL 

 ECOS Consulting 

 MARK VISBAL 

 Security Industry Association 

 MICHAEL HINDUS 

 Pillsbury Winthrop Shaw Pittman LLP 

 KEN SALAETS 

 Information Technology Industry Council 

 LANE WESLEY BURT 

 Natural Resources Defense Council 

 DOUGLAS JOHNSON 

 Consumer Electronics Association 

 JIM HAYNES 

 Uniden Engineering Services 

 FRANCINE PINTO 

 Department of Energy 

 MICHAEL VLADIMER 

 Navigant Consulting 

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Participants: (Continued) 

 TIM CALLAND 

 CAROLINE CURTIN 

 Microsoft Corporation 

 WAYNE MORRIS 

 Association of Home Appliance Manufacturers 

 JENNIFER AMANN 

 American Council for an Energy Efficient 

 Economy 

 MATEUSZ MALINOWSKI 

 Navigant Consulting 

 GARY FERNSTROM 

 Pacific Gas and Electric 

 RICK HABBEN 

 Wahl Clipper Corporation 

 WAYNE ANDERSON 

 Motorola 

 DR. MICHAEL MADIGAN 

 Texas Instruments Incorporated 

 ROBIN CLARK 

 ICF International 

 JOEL WATKINS 

 ECOS Consulting 

 WAYNE DIETERLE 

 CONAIR Corporation 

 DON UMBDENSTOCK 

 Tyco Fire and Safety Products 

 ARI REEVES 

 D&R International 

 

 TIMOTHY BALLO 

 Earth Justice 

 

 STEVEN COSTON 

 Sony Ericsson Mobile Communications 

 

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Participants: (Continued) 

 DONALD ERICKSON 

 Security Industry Association 

 RICHARD FRASSIER 

 Power Integrations 

 LOUIS FIORE 

 Alarm industry Communications Committee 

 STEVEN HALME 

 Sony Electronics Inc. 

 ANDREW JOHNSON 

 CUI, Inc 

 TOBIAS SWOPE 

 MATHEW JONES 

 D & R International 

 KENNETH MARKOWITZ 

 Akin, Gump, Strauss, Hauer & Feld 

 JAMES RABA 

 U. S. Department of Energy 

 MARK SHARP 

 Panasonic Matsushita Electric Corp. 

 JACOB TALBOT 

American Council for an Energy Efficient 

Economy 

MONA TANDON 

VanNess Feldman, Attoneys at Law 

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A G E N D A 

AGENDA ITEM: PAGE: 

Welcome 6 

 Victor Petrolati 

Opening Remarks, Introductions and Agenda Review 7 

 Doug Brookman 

Stakeholder Opening Statements 

 Larry Albert 12 

 Power Tool Institute 

 Association of Home Appliance Manufacturers 

 Chris Calwell 17 

 Pacific Gas and Electric 

 Mark Visbal 19 

 Security Industry Association 

 Michael Hindus 22 

 ADT Security Services 

 Sensormatic Electronics Corporation 

 Tyco Safety Products Canada 

 Tim Calland 27 

 Microsoft Corporation 

 Ken Salaets 33 

 Information Technology Industry Council 

 Wes Burt 40 

 Natural Resources Defense Council 

 Douglas Johnson 41 

 Consumer Electronics Association 

 Jim Haynes 42 

 Uniden Engineering Services 

Introduction, Background and Legal Authority 43 

 Vic Petrolati 

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A G E N D A 

AGENDA ITEM: PAGE: 

Battery Chargers Test Procedure: Definitions 67 

 Michael Vladimer 

Battery Chargers Test Procedure: Test Measurement 91 

 Michael Vladimer 

External Power Supply Test Procedure: Scope and 106 

Definitions 

 Mateusz Malinowski 

Afternoon Session

External Power Supply Test Procedure: Test 153 

Apparatus and General Instructions 

 Mateusz Malinowski 

External Power Supply Test Procedure: Test 156 

Measurement - Single-Voltage EPSs 

 Mateusz Malinowski 

External Power Supply Test Procedure: Test 165 

Measurement - Multiple-Voltage EPSs 

 Michael Vladimer 

Reporting Requirements 193 

Conclusion and Closing Remarks 222 

Adjourn 

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 9:06 a.m. 

 Welcome 

Victor Petrolati 

MR. PETROLATI: Okay. Good morning. My name 

is Vic Petrolati. I am the project leader for the 

Battery Chargers and External Power Supplies products 

under the Appliance Energy Efficiency Standards 

Program. I'd like to welcome you here to Washington, 

D.C. on a Friday. 

I want to apologize. It's very unusual that 

we have meetings on a Friday. It's just we got stuck 

this particular time with meeting dates and getting 

everything arranged. I understand most of you are 

getting ready to start your weekend as quickly as 

possible, so we're going to try to get you out of here 

as soon as possible as well. We hope we can finish 

this up by 3 o'clock. 

We're certainly here to answer as many 

questions as possible concerning our notice of proposed 

rulemaking. That is our purpose, and we certainly hope 

we're going to have a good exchange. Thank you again, 

everybody, for coming. Let me turn it over to Doug to 

get this kicked off officially. Thank you. 

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Doug Brookman 

MR. BROOKMAN: Thank you. Good morning, 

everybody. Doug Brookman, Public Solutions in 

Baltimore. This is the Notice of Proposed Rulemaking 

Workshop, Proposed Test Procedures for Battery Chargers 

and External Power Supplies. Thank you for being here 

on time. We have a full most of a day ahead of us, and 

we'll try and go through this efficiently today as we 

go. 

I want to provide an opportunity for 

everybody here at the outset to introduce him- or 

herself. I'm going to start here and move my way 

around the room, if you would, please. Name and 

organizational affiliation, please. 

 (Introductions.) 

MR. BROOKMAN: Okay. So, thanks to all of 

you for being here on time and giving us an early and 

fresh start on the day here. 

In just a moment I'm going to do an agenda 

review, but I would ask simply for your consideration 

in the conduct of the meeting today. Please speak one 

at a time. Say your name for the record. I'm going to 

be doing everything I can to recognize you by name. 

You don't need to say your name and organizational 

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affiliation every single time, but we do want you to 

say your name every single time so we've got who's 

speaking. 

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Please listen as an ally. Use short and 

succinct statements. Speak to the point. If you have 

a sidebar conversation you really need to have with 

someone, it'll distract from what's going on in the 

room. Please take it out of the room. We'll 

understand if you need to do that. 

Keep the focus on the issues here. If you 

would take the time now to turn your cell phones onto 

"silent" mode so that we're not disrupting the flow of 

the meeting today, that would be helpful. 

There are a variety of housekeeping issues. 

The main one is, if you're walking around here in the 

Forrestal Building you need to have your security 

badge, your visitor's badge, displayed. We'll go over 

some of the other details as we approach the midmorning coffee break. 

There are restrooms, men's and women's 

restrooms, at both ends of the hall, and they are 

stacked, so you can go up and down a floor or two if 

they're busy. 

Do you want to talk about the webcast? 

MR. PETROLATI: I certainly do. Okay. We 

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are actually webcasting this public meeting. This is 

the first time we've done this. It's not going to be 

interactive. The people on the webcast will not be 

allowed to ask questions. 

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We're basically providing this to accommodate 

stakeholders that are unable to attend the public 

meeting. We certainly understand that these products, 

external power supplies and battery chargers, are made 

all over the world and we wanted to accommodate as many 

people as possible. 

The web broadcast allows stakeholders to 

listen in and view the slides and the presentations. 

The stakeholders will be unable to submit comments or 

questions via the web broadcast. Only stakeholders 

physically in attendance may provide questions or 

comments during the public meeting. That's obviously 

the people in this room. 

Good enough, Doug. 

MR. BROOKMAN: Okay. And so I think all of 

you have a rather substantial packet of information. 

If you'll look, you'll note on page 3 -- 4 in fact, the 

agenda is listed on page 4 and 5. I'm going to run 

through that real briefly. 

Following these welcoming remarks and opening 

remarks there's an opportunity for individuals, 

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stakeholders, representatives of organizations to make 

brief summary remarks. So we're going to provide an 

opportunity to do that. I've got a listing of six 

individuals that have requested time to make those 

brief summary remarks. 

Following that we're going to hear a 

presentation on Introduction and Background and Legal 

Authority for this workshop. 

The general format for this workshop, for 

those of you that are new to this, is there's a lot of 

content provided in these colorful slides. Typically, 

there are a number of slides, three, four, five, six, 

as many as 10 slides, and then an opportunity for 

question and comment. That's how we generally like to 

keep the pace up and the content focused. So that's 

the general way we like to proceed with this. 

Following the Introduction, Background, and 

Legal Authority, then there is the Definitions for 

Battery Charger Test Procedure. We will take a coffee 

break mid-morning, round about 10:45 or so, and then, 

continuing on, test measurement issues surrounding 

battery chargers. Following that, External Power 

Supply Test Procedure, the Scope and Definitions. 

Following that, the Test Procedure, Test Apparatus, and 

General Instructions. 

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We will take a break for lunch round about 

12:15, 12:20, 12:30, in there somewhere. Everybody is 

on their own for lunch. We will get to the details 

when we arrive there. 

After lunch, Test Measurement once again for 

External Power Supply, and Reporting Requirements, and 

then, as Vic said, we hope to conclude today by round 

about 3 o'clock. That's the plan. Questions or 

comments here at the outset? 

 (No response.) 

MR. BROOKMAN: We do hope that this is an 

opportunity for those of you in the room that have 

things to say, that you get it said. That's the 

Department's desire here. Get your comments. This is 

your opportunity to make those comments on the record 

with everybody present. 

So then, having said that, let's do brief 

opening remarks, summary comments from those in the 

room. Vic supplied the names of six individuals, or 

actually, six organizations that requested to make 

comments here at the outset. The first one I have is 

AHAM and PTI. Please. Your name for the record. 

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Stakeholder Opening Statements 

Larry Albert 

Power Tool Institute and Association of Home Appliance 

Manufacturers 

MR. ALBERT: My name is Larry Albert. I'm 

from Black & Decker. I represent the Power Tool 

Institute and the Association of Home Appliance 

Manufacturers. I think we have some slides. 

MR. BROOKMAN: Okay. We have new 

microphones. I can't tell yet how well they work, but 

I do know this. Unless the green button is bright 

green they're not on. You're doing well, Larry. 

 (PowerPoint presentation.) 

MR. ALBERT: Broadly, AHAM and PTI support 

the DOE interpretations with respect to battery 

chargers. We understand this was difficult to come up 

with, an interpretation given in places that there were 

seemingly conflicting directions provided in the 

statute. 

We do continue to advocate for many of the 

things that we've talked about all along, which are 

namely a universal standard across many jurisdictions. 

 Specifically, we're looking at other test procedures: 

the CEC test procedure that was recently finalized I 

think as Version 2.0-something, and CSA test procedure, 

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and of course the Energy Star test procedure. 

MR. BROOKMAN: Is the clicker not working, 

Michael? Okay. 

MR. ALBERT: The other thing that we're 

concerned about is that whatever the final standard is 

with respect to energy measurement, that it's a 

standard that's comprehensive with respect to actual 

usage of battery chargers. 

We believe that if we have a standard that 

looks at the overall usage of a battery charger during 

a test cycle, even if that test cycle is something 

that's not actually measured during a test procedure 

but is computed on the basis of individual measurements 

that occur in the test procedure, and that is 

differentiated by the type of battery charger it is and 

its intended application, that that would provide the 

most meaningful results both in terms of assessing the 

energy usage of battery chargers and also being able to 

provide an indication as to what the overall savings is 

of energy to the public when regulations and standards 

are put in place. 

We believe that appliances represent a 

special case of battery chargers because in appliances 

battery systems and chargers are uniquely mated to each 

other, unlike, for example, general purpose type 

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battery chargers that charge D and C cells or 

automotive battery chargers that charge a wide variety 

of different batteries, all the same form factor in the 

cases of appliance batteries, in the case of 

detachable, or in the case of batteries specific to the 

chargers. In the cases of integral battery systems, 

they're included inside the product and therefore 

there's a unique match between the battery charger and 

the battery being charged. 

In the interest of having a broad standard to 

cover a multitude of jurisdictions we think it's 

probably the right time to start talking about 

incorporating active mode into the battery charger test 

procedure. This would provide a way of evaluating all 

different modes of application of the charger, right, 

and would provide a comprehensive measure of overall 

use in a variety of different cases. 

However, it's important to note that active 

mode can represent varying degrees of proportion in 

different types of test cycles depending upon how the 

battery charger is used and its form factor and so on. 

 Next, Mike. Thanks. 

Then going back to the appendix wire 

requirements, with respect to the standby and off mode 

definition, we believe that they're pretty well on 

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mark. A couple of suggestions would be that some care 

should be taken in the language of the standard to 

address standby mode with respect to how it would be 

implemented with integral battery products, namely 

cases where the battery is in the product. Then 

standby mode should then be the removal of the battery 

from the charging base, if there was one, or a wall 

adaptor if there was one of those. 

To that purpose, we are proposing inclusion 

of additional definitions to Appendix Y to include 

integral, detachable, and cradle type constructions. 

This is more or less consistent with the test procedure 

that is being advanced by the California Energy 

Commission. 

In addition, we're proposing to include 

active mode, and we think this could be done in a 

relatively painless manner by including what we're 

calling here E24, which is very similar to what is 

called out in the California Energy Commission test 

procedure. In E24 you basically measure the first 24 

hours of operation of the battery charger with a 

discharged battery. So this would include all the 

active modes that were being considered in the statute. 

 In addition, of course, there is some other time that 

is spent doing other things. 

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But this is how the CEC is approaching it. 

Again, we're looking to have a uniform type way of 

measuring energy usage in battery chargers, so that we 

think this is probably the best way to get at it. 

We think that the changes to Appendix Y would 

be relatively minor and would certainly be no worse 

than many of the other changes that are being proposed 

by the Department. So we think this is something that 

could be done without materially affecting your very 

aggressive schedule. Next slide, Michael. 

Currently in the test procedure this is the 

language with respect to inactive and active mode 

measurements. The active mode measurement section has 

been reserved. Next slide, Michael. 

We're proposing here to basically add 

language to this Section 4 of Appendix Y to measure E24 

during this first 24-hour period and then withhold the 

calculation of energy ratio. The reason why we're 

proposing to withhold the calculation of energy ratio 

is because we would like the Department to consider 

through its future rulemaking alternate ways of 

calculating energy ratio based upon a variety of 

different types of test procedures. That would be 

based upon different categories of battery charging 

systems. 

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So basically, the recommendation here, or the 

proposal, would be to measure active mode as E24 

consistent with the CEC method and to take out of the 

test procedure right now a determination of energy 

ratio and save that for a later rulemaking. 

I think that's it. 

MR. BROOKMAN: Thank you. 

MR. ALBERT: Thank you. 

MR. BROOKMAN: The next person I have listed 

would be from ECOS. Your name, please. 

Remarks by Chris Calwell 

Pacific Gas and Electric 

MR. CALWELL: Good morning. I'm Chris 

Calwell. I direct the policy and research activities 

at ECOS Consulting, and I'm here on behalf of Pacific 

Gas and Electric. I'll be brief. 

Pacific Gas and Electric has, for a number of 

years, funded standards and test procedure development 

activities in California in support of mandatory 

efficiency standards there. So much of our work on 

external power supplies and then on battery charging 

systems began in that context. 

The external power supply discussion here I 

think is largely in its late stages and is about minor 

refinements at the end, so I won't devote much 

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attention to that. 

What I did want to say a bit about is the 

battery charging system test procedure, as alluded to 

in the previous presentation. This test procedure work 

got underway with our team in 2004. So we're at about 

a four-year mark now in the development process. After 

a number of published drafts and stakeholder comments 

and response, California Energy Commission is prepared 

to discuss 45-day language for that test procedure next 

week. 

I know the DOE staff and consultants have 

been involved in that process, and so I just wanted to 

encourage the inclusion of active mode harmonization 

with California's approach and for consultants and 

other individuals in this room to submit comments 

during that California proceeding because I think it 

could get us to a potential juncture for consensus in a 

faster timetable than the one that's going here and 

pave the way for DOE to adopt something similarly. 

With that I'll conclude, and look forward to 

the discussions later. We'll touch on some of the 

legal and technical arguments later for the merits of 

including active mode. 

MR. BROOKMAN: Thank you. 

MR. CALWELL: Thanks. 

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MR. BROOKMAN: The next person I have listed 

is from the Security Industry Association, Mark Visbal. 

Remarks by Mark Visbal 

Security Industry Association 

MR. VISBAL: Good morning. I'm Mark Visbal. 

 I'm director of research and technology for the 

Security Industry Association, also known as SIA, S-IA. We represent about 400 manufacturers, integrators, 

dealers, distributors, specifiers, and monitoring 

companies of electronic physical access control 

systems, video safety and surveillance systems, medical 

emergency monitoring systems, as well as intrusion 

detection and fire alarm systems. 

SIA members provide solutions for physical 

security to protect the people and property of America 

in their schools and hospitals, their airports and 

seaports, their factories and offices, and especially 

their buildings of government. 

We thank you for the opportunity to provide 

comments towards the Department of Energy's 

implementation of the Energy Independence and Security 

Act of 2007. 

We believe that the Energy Independence and 

Security Act of 2007 does not apply, nor was it meant 

to apply, to the products and services our member 

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companies manufacture, specify, install, and monitor. 

In our view, the monitoring of fire, carbon monoxide, 

intruder detection sensors, and access control readers 

and exit devices requires a constant supply of energy. 

 The electronic -- the external power supplies used in 

such security and life safety systems can never be 

operated in a no-load mode or off mode because 

disconnecting them from a load destroys the intended 

functionality and integrity of the system. 

Additionally, because these are security and 

life safety systems, they are continuously monitoring 

their sensor circuits for problems, as well as 

monitoring the functionality of the control panel, the 

presence of line voltage, the state of charge of the 

backup batteries used in the event of a power failure, 

as well as the communication channels used to relay 

critical information to the responding authorities. 

Additionally, the definition of a Class A 

external power supply does not capture security and 

life safety industry devices. Under this definition, a 

Class A EPS must be connected to the end use product 

via removable or hard-wired male-female electrical 

connection, cable, cord, or other wiring. 

This implicates that these power supplies are 

standalone and constitute a complete source of power 

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that is separable from the end user's device. This is 

not the case for security and life safety systems. The 

transformer connected to the line voltage AC cannot be 

separated from the panel where the lower voltage AC is 

rectified and converted to DC voltage usable by the 

system. Essentially, a circuit within the security and 

life safety panel and the transformer together 

constitute the entire power supply. 

Please let me reiterate the fact that SIA 

members and manufacturers believe that the Energy 

Independence and Security Act of 2007 was not meant to 

cover their products. The Security Industry 

Association and its members support the goals of the 

Energy Policy and Conservation Act and the Energy 

Independence and Security Act of 2007. However, we 

also believe it would be inappropriate to require test 

procedures for off and standby modes for products that 

cannot be nor were ever intended to be used in these 

modes. These products are always on. 

Complying with test procedures proposed in 

this NOPR would add unnecessary expense to these 

products without advancing the goals of the Act. 

Importantly, these unnecessary expenses would 

ultimately be passed on to the end user. That's our 

taxpayer dollars. 

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In conclusion, SIA respectfully offers the 

following recommendations. We believe that the 

simplest way to clarify this is to amend the 

definitions of no-load mode to clarify that this mode 

does not apply to power supplies used for security, 

surveillance, and life safety products. We believe 

this would be consistent with the intent of the 

legislation, is consistent with DOE precedent, and is 

good public policy that avoids unnecessary expenses 

while not conflicting with the goals of energy 

efficiency. 

Thank you for the opportunity to provide 

these comments today. 

MR. BROOKMAN: Thank you. Thank you very 

much. The next individual that we would hear from is 

from Pillsbury Winthrop Shaw and Pittman. 

Remarks by Michael Hindus 

ADT Security Services, Sensormatic Electronics 

Corporation, and Tyco Safety Products Canada 

MR. HINDUS: Good morning. Thanks for the 

opportunity to speak. My name is Michael Hindus, and 

I'm a partner in the law firm of Pillsbury Winthrop 

Shaw Pittman. Today I'm representing ADT Security 

Services, Sensormatic Electronics Corporation, and Tyco 

Safety Products Canada, market leaders in the security, 

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surveillance, and life safety industries. We are 

largely in accord with the comments that you've just 

heard from the Security Industry Association. 

Our products are never intended to be used in 

off mode or standby mode. Our burglary detection 

system, even when not armed, or a fire detection system 

should always be on. It should never be used in off 

mode or standby mode. These products typically have no 

switches which would even permit them to be used in an 

off mode or standby mode. 

We believe it is inappropriate to establish 

test procedures for off mode and standby mode for 

products that cannot be used in those modes and were 

never intended to be used in those modes. 

For this reason, we respectfully take the 

position that the power supply efficiency standards of 

the EISA do not and should not apply to such devices 

employed in security and life safety systems in off and 

standby mode. 

Moreover, complying with the test procedures 

proposed in this NOPR would add unnecessary expense to 

those products without achieving the underlying 

efficiency benefit that the statutes intended. 

If the efficiency standards are deemed to be 

applicable, however, the regulations proposed in the 

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NOPR are not feasible to apply to security systems 

because such systems do not function in off mode or 

standby mode. 

Under an analysis similar to that required by 

this NOPR just six months ago in March in the 

fluorescent lamp NOPR, this Department concluded that 

several types of fluorescent lamps do not function in 

off and standby mode. The fluorescent lamp NOPR and 

this NOPR require analysis under the same statutory 

standard. 

This Department found that current 

technologies for certain types of fluorescent lamps 

make it infeasible to test in off mode or standby mode. 

 Specifically, those fluorescent lamps did not meet the 

criteria of off mode because those types of fluorescent 

lamps are disconnected from its power source. The 

fluorescent lamps did not meet the criteria of standby 

mode because the lamps are single function, to emit 

light, and do not offer any secondary user-oriented or 

protective functions. 

Accordingly, this Department decided not to 

expand the test procedure to incorporate measurement 

modes for off mode and standby mode energy consumption 

for certain types of fluorescent lamps. The Department 

should do the same here. 

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As with certain types of fluorescent lamps, 

security systems do not employ an off mode or standby 

mode. Accordingly, it is not feasible -- "feasible" is 

the word in the statute -- to measure energy 

consumption of power supplies used to power security 

systems in these modes. 

First, security systems are required to be 

active and continuously on and therefore are not 

capable of meeting the off mode requirement that the 

product "is not providing any standby or active mode 

function." 

Second, like the fluorescent lamps, the 

security systems are a single-function product, that 

function being to detect or monitor. Accordingly, 

security systems do not meet the criteria in the 

standby mode definition that requires the product have 

a user or protective function. 

Third, security systems typically do not have 

a switch that would permit them to be used in an off 

mode or standby mode. 

Finally, the security systems, which are in 

continuous operation, meet the definition of active 

mode as they are connected to a main power source and 

are activated to detect and monitor. Accordingly, it 

is not feasible to measure the energy consumption in 

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the standby and off modes of power supplies used to 

power security systems. 

If EISA-mandated power supply efficiency 

standards are deemed to apply to security and life 

safety systems, we believe that the simplest way to act 

consistently with the precedent established in the 

fluorescent lamp NOPR is to add the following sentence 

at the end of the definitions at Appendix Z.2.N: "This 

mode does not apply to power supplies used for 

security, surveillance, and life safety products, which 

are never used in no-load mode." 

In addition, we propose similar language 

clarifying the definitions for off mode and standby 

mode to make sure that those modes similarly do not 

apply to these devices. 

We believe that by making the changes to 

these definitions the Department of Energy would be 

acting within its statutory authority, would be 

following its own recent precedent, and would establish 

good public policy by not imposing unnecessary expense 

on products the usefulness of which is defeated if used 

in standby and off mode. 

Thank you very much for the opportunity to 

speak today. We will be filing a more complete set of 

comments next month. 

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MR. BROOKMAN: Thanks very much. The next 

person is from Microsoft. 

Remarks by Tim Calland 

Microsoft Corporation 

 (PowerPoint presentation.) 

MR. CALLAND: Good morning. Microsoft 

appreciates the opportunity to present comments 

regarding the Department's notice of proposed 

rulemaking on test procedures. We believe that energy 

efficiency is an important component of our country's 

energy strategy, and we support initiatives that 

sustain energy efficiency and advance continued 

technological and software innovation. 

Microsoft concurs with the intent of the 

proposed addition of multiple output external power 

supplies to the scope of products regulated under the 

Energy Independence and Security Act of 2007. However, 

the proposed test program does not represent actual 

usage for at least 20 million dual voltage external 

power supplies now in service. To require compliance 

with the proposed procedure as written would increase 

compliance cost without adding benefit in terms of 

greater energy efficiency or energy cost savings to 

consumers. 

We would like to suggest an alternative test 

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procedure for multiple output external power supplies 

that will enable power supply testing that reflects 

actual usage and supports energy efficiency without 

unnecessarily increasing compliance cost. 

As background to our comments on the proposed 

test method, it's worth reviewing some basic principles 

about energy efficiency of power supplies. The graph 

of efficiency of a typical power supply while varying 

the load it delivers from zero to 100 percent of the 

design limit, is a curve that we like to call a camel 

hump, like the blue line shown on the slide. 

The power supply is most efficient when 

operating somewhere in the middle between no load at 

all and the maximum load it can deliver, the top of the 

hump. 

The system consisting of the Xbox 360 game 

console and its external power supply is designed to 

operate at the top of the hump, a range from about 42 

percent -- let's see if I can hit it here. Let's see. 

 Forty-two percent to about 75 percent of full load. 

The red line on the graph represents the 

standard we're being asked to meet. As you can see, 

its range far exceeds the actual, more limited 

operating range of the product under test. 

Regarding the proposed test procedure for 

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multiple-voltage external power supplies in Appendix Z 

of the notice of public rulemaking, we note that the 

test procedure is based on the Energy Star industry 

standard for single output power supplies, which tests 

efficiency with various different loads representing 

the kinds of products it might typically be used with. 

 Next slide, please. 

Testing a general purpose power supply to a 

broad spectrum of loads makes sense. However, when we 

restrict the use of a power supply to a dedicated 

product, we can tailor its design to a set of known 

conditions rather than an infinite variation of loads 

it will never see. This allows the same level of 

performance without unnecessarily adding to compliance 

cost. 

A wide variety of external general purpose 

power supplies are available at retail electronics 

stores. You can see some on the slide above. They're 

provided with generic connectors. They don't come with 

a product to plug them into. And they power all sorts 

of electronic devices, from cell phones to cameras to 

rechargeable batteries. Because these off-the-shelf 

power supplies are intended to be used with such a 

variety of products, we agree they should be proven 

efficient for any and all electrical loads. 

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We agree that the loading described in the 

present test procedure for single output external power 

supplies represents actual use for these devices. 

However, in the case of a dedicated power 

supply, which by nature of its design can only be used 

for one particular product whose loads are controlled 

at manufacture, the proposed test procedure does not 

necessarily yield results comparable and representative 

of actual usage as mentioned in the proposal. 

A better representation of efficiency and 

actual use can be made by testing the power supply with 

its intended load under intended operating conditions. 

 Such testing will result in the same level of 

efficiency for the end user without adding needlessly 

to product cost. Next slide, please. 

There you go. Now, remember the slide that 

you just saw with the cute little AC adaptors that this 

is a perfect regulation for. Well, this is the power 

supply for the Xbox 360. The power supply of the Xbox 

360 game system is not sold separately from the 

console. You can see it has a proprietary connector -- 

there's a picture of it up there -- which can be only 

used with the console. The only kinds of loads the 

power supply will ever see are the loads that are 

delivered by the box when it goes through a relatively 

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limited number of functions. Remember the green lines 

on the graph. Next slide, please. 

Because we designed the Xbox 360 power supply 

endgame console as a system, because we specified the 

software to be used on the system, because we qualified 

the design and the software by test before the design 

is manufactured, and because we maintain control of the 

loads, we know what's going to be happening here. 

In this case, I hope you will agree that the 

proposed test does not yield results that are 

comparable or representative of actual use. 

If you'll recall, the proposed test procedure 

specifies testing at artificial loads of 25, 50, 75, 

and 100 percent of maximum rating on the nameplate of 

the power supply. As I mentioned before, because the 

power supply can only be connected to a 360 console, 

the only efficiency the user can benefit can be found 

in a range from 42 to 75 percent of the rated full 

load, once again shown by the green bars on the graph. 

 So if we test the power supply with its actual load 

instead, we can accomplish the same level of energy 

efficiency. 

Therefore, we recommend that as an 

alternative to the proposed test procedure a dedicated 

single-product power supply may be tested with its 

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intended load in all operational modes rather than with 

artificial loads. Accordingly, we have enclosed 

suggested changes to the test procedure described in 

Appendix Z of the NOPR in our comments. 

We estimate that building a power supply with 

constant efficiency from 25 percent of load to 

nameplate full load will add approximately $2 to $3 per 

Xbox 360 game console manufactured without improvement 

in overall efficiency and actual use. Over 20 million 

Xbox 360 game systems have been manufactured since the 

product launched in 2005. At $3 per unit, that 

incremental cost would have already hit $60 million. 

Total compliance cost will be even higher as the system 

continues to be sold and when including costs that will 

accrue to other manufacturers subject to this proposed 

rule. 

We're concerned that these additional costs 

are unduly burdensome and come without adding benefit 

in terms of greater energy efficiency or energy cost 

savings. 

We welcome the opportunity to provide the 

Department with additional details regarding these 

issues and recommendations we offer today. Thanks for 

allowing us to be heard. 

MR. BROOKMAN: Thank you. 

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MR. CALLAND: Thank you. 

MR. BROOKMAN: The last person that I have 

listed is from the Information Technology Industry 

Council. We want to provide an opportunity for other 

individuals that wish to speak here at the opening as 

well. The Information Technology Industry Council? 

Remarks by Ken Salaets 

Information Technology Industry Council 

MR. SALAETS: Good morning. My name is Ken 

Salaets, director of technology and trade policy at the 

Information Technology Industry Council, or ITI, which 

is a lot easier to say. We appreciate the opportunity 

to be here and offer some brief comments. We as well 

will provide more substantial comments next month, but 

we welcome the opportunity to engage in dialogue with 

the Department as well to consult on this issue. 

ITI represents some of the leading technology 

companies globally, and a few of them are in this room: 

 Microsoft, Panasonic, Sony, Texas Instruments. We 

also cover companies in Europe and elsewhere, hopefully 

soon South America. 

We have been engaged in energy efficiency 

since the '92 Policy Act, working with DOE in a number 

of areas, as well as with EPA and the Energy Star 

Program. We are encouraged by the transparency of the 

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Department's process. Again, we appreciate the 

opportunity to present and to engage in further 

dialogue. 

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Our companies have reviewed the notice of 

proposed rulemaking and we have a number of comments, 

but I will just highlight a few here. In general 

theme, there are three things I want to focus on: 

declaration of conformity, harmonization, which has 

been referenced already, and also exceptions for unique 

situations. 

We have sort of a mantra at ITI that is 

something to the effect of in a standard one test 

applies declaration of conformity, the notion being 

that if you have essentially a single standard 

requirement and you negotiate that development in a 

consensus process between all stakeholders, then it 

reduces the cost and burden not only on manufacturers 

but also on the end user and in some cases even 

governments by adopting that standard worldwide, 

allowing companies to test and declare conformance with 

that standard and to make that information readily 

available when asked. 

One concern we have with the current proposal 

is the mandatory certification and data system 

submission requirement included in the rule. While we 

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appreciate that traditionally the Department has 

included such a requirement for covered and regulated 

products, we do not believe that Congress has in effect 

mandated such activity in this case, and we will go 

through that in further detail in the written 

statement. 

Further, many manufacturers already test and 

sell declared conformance with corresponding EPA Energy 

Star efficiency requirements for the same products. As 

Chris referenced, the California Energy Commission is 

also heavily, actively, and persistently engaged in 

these issues. 

The information is then posted through the 

Energy Star process on their website as qualified 

products, a list of qualified products, and that 

information is accessible to all parties. 

We urge the Department to consider accepting 

such declarations as an alternative approach for 

satisfying the certification requirement. Again, we 

will go into more detail, but we point out that there 

is precedent for the Department doing this, referencing 

other agency reporting requirements and in some cases 

even certifications as acceptable in lieu of a single 

certification under DOE. 

Again, a high-level summary. We'll provide 

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more detail and an alternative recommendation in the 

written statement. 

On duration of test, another issue that's 

come up in the conversation with ITI members, in the 

section on the off mode test method for battery 

chargers, which starts on page 48061 in the Register, 

the Department publishes what it characterizes as a 

clarification of "current procedures" for measuring 

standby mode and battery maintenance mode energy 

consumption for battery chargers. The agency points 

out that this recommendation in the proposal is based 

largely on the test methodology that was published in 

December 2005. 

EPA, I believe, offered two options. One was 

a one-hour or a 12-hour test. In the proposed rule 

you're requiring, or recommending requiring a minimum 

of a one-hour test. 

We believe that a one-hour test as a minimum 

is unnecessary to accomplish the essential goals of the 

proposed rulemaking. As we have heard a theme here, it 

would lead to undue costs, resource requirements, and 

in some cases even waste energy. 

So what we suggest is there are commercially 

available power analyzers in the marketplace today 

which -- that give effective and reliable standby mode 

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power measurements within 10 seconds. The actual 

measurements are performed even faster due to a 

sampling rate many times per second. There's a brand 

name in here. I'll leave that out, but it's in the 

comments that I think we're submitting for the record. 

Essentially, what we found and experienced is 

that using the 10-second test versus the one-hour test, 

the results don't change. The efficiency doesn't 

improve in terms of the measurement. So what we would 

like to see is some flexibility added to the proposed 

rulemaking that when manufacturers are using technology 

that enables them to make more rapid and more efficient 

tests that produce the same result that that option be 

provided. Perhaps one way to do that is including 

language along the lines of allowing for averaging over 

a longer period. But again, the written comments will 

reinforce the same idea. 

We do note that certain tests would probably 

save more than 95 percent of the energy otherwise 

consumed in the one hour. Just an aside. 

And then in terms of detailed comments, 

single-product power supplies, Tim just referenced this 

relative to the Microsoft product. Since the real 

benchmark here is results comparable and representative 

of actual usage, we've heard from the other gentleman 

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in the security area that they also have concerns along 

this regard. While we appreciate again that there is 

some semblance of harmonization in terms of what the 

Department is proposing relative to testing at multiple 

loads that in the cases where that is really not a 

realistic usage experience of the end user that we 

would suggest that there be an exception allowed in 

that case. We would probably support the other 

comments as well. I think they're consistent with our 

position. 

So again, ultimately we will recommend that 

you consider modifications that allow exceptions. I'm 

not certain if you would want to go as specifically as 

citing situations because there may be additional 

exceptions that are considered or aren't contemplated 

before the rule is published and the accelerated 

timeline here, but again they'll be in the written 

comments. 

Some additional areas of concern that we will 

also highlight. One is to recommend amending the 

definition for battery chargers to ensure that it only 

covers equipment specifically marketed and intended to 

charge batteries. In other words, to ensure that AC 

adaptors, for example, are not labeled as battery 

chargers. We will offer some suggestions in that 

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regard. 

We also recommend that the Energy Star-listed 

external power supplies that -- that EPA or Energy 

Star-listed power supplies be deemed compliant with the 

statutory requirements and therefore not require 

additional testing. 

Finally, we would also, or will also 

recommend that the Department consider not addressing 

multi-output AC adaptors not specifically referenced in 

the statute at this time but rather conduct some 

additional, further analysis and somewhere down the 

road, after conducting that analysis, determine if 

that's an appropriate reason for creating a standard. 

Some products aren't specifically referenced in the 

legislation, so in that respect we believe that there 

is still some flexibility. 

So that concludes the comments. Again, we 

would welcome the opportunity to engage in the interim 

between the final rulemaking and look forward to public 

comments. Thank you. 

MR. BROOKMAN: Thank you. We wanted to 

provide an opportunity for anyone else that wishes to 

make brief summary remarks at this time before we 

proceed with a lot of detailed content. 

Remarks by Wes Burt 

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Natural Resources Defense Council 

MR. BURT: Yes. Good morning. My name is 

Wes Burt with the Natural Resources Defense Council. 

We're a national environmental nonprofit with 1.2 

million members and have been involved in the standards 

program of the Department since its inception. 

I wanted to speak up and second the comments 

from our colleagues at ECOS Consulting and weigh in on 

two issues. One is the need for the Department to 

create test methods that are consistent with 

international test methods, and the second being the 

need for the battery chargers test method to cover 

active mode. 

We feel that the Department should take a 

look and measure the energy use of the primary function 

of a device. Should they not do that, then they will 

be ignoring a primary energy consumption mode. 

Further, it sets a dangerous precedent for the 

Department to promulgate a preemptive federal standard 

that has such an obvious hole in scope. Thanks. 

MR. BROOKMAN: Thank you. Yes, please. Your 

name. 

Remarks by Doug Johnson 

Consumer Electronics Association 

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MR. JOHNSON: Good morning. My name is Doug 

Johnson with the Consumer Electronics Association. I 

just wanted to echo a couple of points and others that 

were brought up by ITI and Microsoft. 

One, we certainly urge the Department to 

harmonize with existing test procedures, as was also 

mentioned in the AHAM proposal this morning, or the 

AHAM presentation this morning. 

Also, with regard to one of the points or one 

of the questions brought forth for public comment, we 

would oppose the notion of collecting compliance data 

for compliant external power supplies and battery 

chargers as was suggested in the DOE's notice. This 

would be an extreme burden for both government and 

industry. It's certainly not the way that the topic 

has been handled to date. There are better ways for 

manufacturers to show compliance through selfdeclaration, self-certification. 

We, like other associations, will be filing 

comments for the public record as well. Thank you. 

MR. BROOKMAN: Thank you. Others, please. 

Yes. Your name. 

Remarks by Jim Haynes 

Uniden Engineering Services 

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MR. HAYNES: My name is Jim Haynes and I'm 

with Uniden Corporation. Basically, I think I'm also 

speaking for the telephony manufacturers. I just 

wanted to go on record that we certainly endorse the 

comments made by the security folks because telephones 

that our industry makes that use the external power 

supply are actually never in a no-load situation as 

well. 

Telephones are unique, especially cordless 

telephones that have batteries. They're a battery 

charger. They're also an operating power supply, and 

the fact that the device is never in a no-load 

situation. 

Contrary to what a lot of people think, they 

think that a telephone just sitting is doing nothing, 

but in essence a cordless telephone that is sitting is 

actually communicating back and forth between the base 

unit and the handset constantly to find out if in fact 

a call is to be placed. Of course, it has to be in the 

on position so that if a call does come in it can be 

transmitted to the handset or whatever. 

So what I'm really getting at is the fact 

that on behalf of the telephony manufacturers, most of 

which are already on record with CEA and other 

organizations to bring this out, that no-load situation 

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or the no-load condition is never prevalent with 

telephony products. Thank you. 

MR. BROOKMAN: Thank you. Others? Other 

summary comments? 

 (No response.) 

MR. BROOKMAN: Okay. Then let me add my 

voice to Vic's in welcoming anybody that might be 

listening in on the webcast. We hope this is a useful 

day for you, a useful way of engaging in this content. 

 Thanks for joining us. 

So then let's proceed with the program. 

Introduction, Background, and Legal Authority 

Vic Petrolati 

 (PowerPoint presentation.) 

MR. PETROLATI: Okay. Again, Vic Petrolati, 

the project leader for battery chargers and external 

power supplies. I'm going to be giving you a quick 

introduction on battery chargers and external power 

supplies, explaining the purpose of our meeting today 

and how you can be an active stakeholder in terms of 

providing your comments. 

All right. There are numerous examples, 

obviously, of products that use both battery chargers 

and external power supplies. We are just putting up a 

few examples for you. We have seen already a couple of 

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examples here today. We have cameras, power tools, 

cell phones, MP3 players, laptops, monitors, and many, 

many other products. 

All right. Just quickly, conceptually, 

differences between external power supplies and battery 

chargers. This is a real primer, and I'm going to also 

go into some helpful information in terms of explaining 

the rule. Major differences, of course. An external 

power supply continually converts power from mains and 

delivers it directly to the load. With a battery 

charger, mains first deliver power to the battery. 

Then the battery delivers energy to the load. 

Again, these are just quick schematics. 

These aren't legal definitions. We will get into the 

legal definitions fairly soon. 

All right. The purpose of the Test Procedure 

Public Meeting. I'd like to summarize the purpose. 

It's to present stakeholders with an overview of the 

statute and all of our departmental actions concerning 

battery chargers and external power supplies. We're 

certainly here to fulfill the Energy Independence and 

Security Act requirements, to establish definitions and 

amend existing test procedures for battery chargers and 

external power supplies, to measure standby and off 

mode, and to have that test procedure finalized by 

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December 2008. 

We are going to present the Department's 

proposed test procedures for incorporating standby mode 

and off mode into the EPS and BC test procedures. We 

are also going to present, as was initially discussed 

here, our multi-voltage test procedure for EPSs. 

We are going to discuss the Department's 

reporting requirements for Class A EPSs. We are going 

to seek, obviously, oral comments from all 

stakeholders. We hope to discuss and respond to 

specific issues or questions related to our proposal 

here today. 

All right. This is an issue box. We're 

going to put it up a number of times during the 

meeting. This is where we would like to specifically 

get stakeholder input on a number of issues that we 

think that we need further information. By no means 

does this limit you in terms of providing comments on 

any aspect of what we've got on the notice of proposed 

rulemaking. This is more or less our emphasis of where 

we think we need some further information. 

Okay. Feedback is requested. That's the 

reason we're having a public meeting. That's why we've 

got such a formal process for all of this, is to try to 

get as much feedback as possible to allow us to make 

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the best decisions possible. 

I've provided you here the information for 

providing that feedback. Let me just summarize again. 

 Comments concerning our current NOPR are due by 

October 29th, 2008. You can submit those comments 

electronically or in writing. We've given you all the 

information you need here in terms of submitting 

comments. 

Okay. Before I go into the background and 

legal authority, I think everything has been fairly 

simple right now. Any questions? 

 (No response.) 

MR. PETROLATI: Doesn't look like it. 

Okay. I'm going to be covering the 

background and legal authority for our actions. I 

believe we have, basically from all the questions that 

I've been fielding today, a lot of people that are new 

to, first of all, regulations under DOE Appliance 

Standards Program and, in some cases, any government 

regulations. 

I'm going to spend a little more time than 

usual basically giving a primer on some of these 

concepts and how we move forward. 

The first thing we're going to do is compare 

our DOE rulemakings with the Energy Star specifications 

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and explain the differences. We're going to review 

congressional direction and DOE reactions to what we've 

gotten in terms of congressional direction. Quick 

review of past and future DOE actions for battery 

chargers and external power supplies. 

I'm going to present you our timeline for all 

of our actions concerning battery chargers and external 

power supplies and just quickly present a summary of 

the content of the test procedure NOPR. 

Okay. Comparisons of Energy Star. Many 

stakeholders obviously here are familiar with the 

Energy Star voluntary specifications, but in some cases 

are new to DOE rules certainly for battery chargers and 

external power supplies. 

Okay. Obviously, both processes seek input 

from stakeholders in terms of developing their 

programs. The DOE process is much more rigorous 

because of the legal and economic consequences 

associated with mandatory standards. 

Okay. Let's take a look at the table. Both 

the Energy Star specs and the Department of Energy 

rules obviously incorporate test procedures and 

qualifying levels. 

Okay. In the Energy Star program -- by the 

way, we are certainly using the same test procedures 

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currently for battery chargers and external power 

supplies as what's used under the EPA Energy Star 

voluntary program. 

In terms of qualifying levels under each 

program, EPA generally requires levels to meet the 

Energy Star criteria in the top 25 percent of the most 

efficient products in the market. We have to do a 

thorough analysis to come up with the most technically 

and economically feasible standards. 

Again, the EPA program is a voluntary 

program. The DOE program is mandatory. That means 

whatever standards we will come up with as part of this 

program or the standards that have already been 

established under EISA, all products must meet that 

standard before they are distributed in commerce. 

Okay. DOE is the responsible party for 

implementing the Appliance Standards Program under the 

Energy Policy and Conservation Act of 1975. That's how 

far back we go for some of this legislation. 

Okay. Our statutory authority for BC-EPS 

comes from Congress's amendments to EPCA. The Energy 

Policy Act of 2005 amended the Energy Policy and 

Conservation Act, adding BCs and EPSs, battery chargers 

and external power supplies, to the Appliance Standards 

Program. The Energy Independence and Security Act of 

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2007 further amended EPCA, resulting in the current 

rulemaking today that's under discussion. 

All right. I'm sure most of you in this room 

know this, but bottom line is our statutory authority 

for BC-EPS comes from Congress's amendments to EPCA. 

Congress and the president passed the public laws. The 

public laws are codified in the U.S. State Code. EPCA, 

the Energy Policy and Conservation Act, is U.S. State 

Code. 

What we're currently here today doing is we 

have proposed rules in the Federal Register. The 

Department publishes its rules, both proposed and final 

rules, in the Federal Register and they will eventually 

be codified in the Federal Register. The current 

notice of proposed rulemaking is under 10 CFR Part 430 

of the Code of Federal Regulations. 

The thing that is critical in terms of public 

laws, bottom line, is EPACT and EISA must be viewed in 

the context of the Energy Policy and Conservation Act. 

 In other words, you need to see the revised language 

in the Energy Policy and Conservation Act to understand 

fully what the amendments under EPACT and EISA have 

done in terms of impacting both battery chargers and 

external power supplies under the Appliance Standards 

Program. 

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Just to give you an example, I get many 

questions coming in concerning whether or not external 

power supplies that are manufactured for commercial or 

industrial products are covered under our program. 

Once you have a codified version of the Energy Policy 

and Conservation Act, including amendments, you will 

find that it's included under the Consumer Products. 

So we are not covering both commercial or industrial 

products that are EPSs manufactured for commercial and 

industrial products. 

Anyway, bottom line, it's the same thing with 

our regulations. What we are doing is amending the 

previous regulations for test procedures. I'm sure 

everybody realizes that. But you need to have a copy 

of the previous regulation as well as our changes to 

fully understand what's being proposed. 

Okay. Let's get into some of the details of 

what we're doing under our current rulemakings. The 

Energy Policy Act of 2005 initiated battery charger and 

external power supply rulemaking. The EPACT 2005 was 

enacted on August 8th, 2005, to do the following: 

provide definitions for battery chargers and external 

power supplies. These are included in all of the 

handouts. It also directed DOE to develop test 

procedures for battery chargers and external power 

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supplies by December 8th, 2006; hold a scoping workshop 

for battery chargers and external power supplies by 

February 8th, 2007; and conduct a determination on 

whether energy conservation standards should be issued 

for battery chargers and external power supplies by 

July 8th, 2008. 

Okay. Just to indicate what has already been 

accomplished. We published a NOPR in July 2006. It 

was called the en masse test procedures and 

incorporated the proposed test procedures for battery 

chargers and external power supplies. There was a 

public meeting on that in September of 2006. Final 

rule for test procedures on battery chargers and 

external power supplies was published in December of 

2006. 

In that final rule under battery chargers we 

reserved a section in the Code of Federal Regulations 

for measurement of battery charger active mode energy 

consumption. 

Okay. We were conducting a determination 

analysis for both battery chargers and external power 

supplies prior to the changes in basically EISA. We 

published framework documents for that determination in 

December of 2006. We held a scoping workshop in 2007. 

 And the determination was due by August 8th, 2008. Of 

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course we had some changes. 

Okay. The Energy Independence and Security 

Act further amended the Energy Policy and Conservation 

Act, providing definitions for standby and off mode, 

what we're here for today -- again, definitions are in 

the handouts -- provided the definition for Class A 

external power supplies. 

EISA also set energy efficiency standards for 

Class A EPSs, canceling the EPACT determination for 

EPSs. 

EISA also directed DOE to amend the BC-EPS 

test procedure to account for energy consumption in 

standby and off mode and to conduct a determination 

whether energy conservation standards should be issued 

for non-Class A EPSs by December 19th, 2008. 

It also required DOE to amend Class A EPS 

energy efficiency standards that were promulgated on 

July 1st, 2008, by July 1st, 2011, and again by July 

1st, 2015, if technically and economically feasible. 

Okay. Quickly, you're probably all familiar 

with it. This is the definition for the Class A 

external power supply: a device that converts line 

voltage AC into lower voltage AC or DC, converts to 

only one output voltage at a time, powers a separate 

end use product, is contained in a separate physical 

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enclosure, is removable or permanently attached to the 

end use product, has a nameplate output less than or 

equal to 250 watts, but not a device that powers a 

medical device, a battery charger for a product that is 

fully or primarily motor operated, or a battery charger 

for a detachable battery pack where the battery is 

contained in a separate enclosure from the product, 

intended to be removed or disconnected from the product 

for recharging. 

That is the language that Congress provided 

us as to what is included in the Class A EPS standards. 

Okay. Just showing you quickly, these are 

the standards that became effective July 1st, 2008, for 

Class A EPSs. Most of you who produce EPSs are 

probably familiar with these standards since they are 

the same standards that California had promulgated by 

July 1st, 2008, as well. 

Okay. Our current action. We're proposing 

test procedures for standby and off mode. The NOPR for 

these test procedures was published on August 15th. 

That is the reason for this public meeting. It 

included amendments to the test procedures to 

incorporate standby and off mode. 

We are also proposing a new multi-voltage EPS 

test procedure. There are no standards at this time 

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established for external power supplies using multivoltage. That will be considered as part of our 

determination analysis. The determination analysis 

will look at all products that are non-Class A EPSs. 

In order to evaluate energy savings from certain 

devices such as the multi-voltage external power 

supplies, we need to have a test procedure in place. 

Okay. We are holding the public meeting 

today, obviously. Again, thank you for coming. We 

certainly have to have the final rule published by 

December 31st, 2008. That is an EISA requirement. We 

plan on making that date. 

Okay. Again, we are also in the process of 

trying to address non-Class A EPSs by conducting a 

determination analysis. For those who are not familiar 

with what a determination analysis is, we're trying to 

determine whether or not there are significant 

potential savings associated with setting standards for 

non-Class A EPS. Again, this determination is due by 

December 19th, 2009. 

We're also in the process, as we speak, of 

developing future standards for battery chargers and 

external power supplies, Class A external power 

supplies. We were hoping to have the framework 

document published at this time so we could hold one 

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meeting. The framework document is slightly delayed. 

We expect to have a framework document to kick off our 

standard-setting process for battery chargers and 

external power supplies in late 2008. An ANOPR and 

NOPR will follow. We are required, again by EISA, to 

have a final rule for future standards for battery 

chargers and external power supplies by July 1st, 2011. 

Okay. EISA has also required us to revisit 

standards for Class A external power supplies. After 

we establish potential rules in 2011, they ask us to go 

back again and, by July 1st of 2015, make those 

standards more stringent if technically and 

economically feasible. 

All right. I've thrown a lot at you in terms 

of all the actions that we're required to get 

completed. We get confused sometimes as well in terms 

of how all of these actions fit together and basically 

what our timelines are. This table will give you a 

quick timeline for all the actions we plan on getting 

completed. 

Standards for Class A EPSs, where applicable, 

on July 1st, 2008. We have to incorporate the standby 

and off mode test procedures by December 31st, 2008. 

We're required to complete the determination as to 

whether or not we should establish standards for non-

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Class A EPSs by December 19th, 2009. 

Energy conservation standards notice of 

proposed rule we believe needs to be issued 

approximately by October 31st, 2010. That is not an 

EISA date. We just have that as a planning date 

because if we are going to incorporate the active mode 

into the battery charger test procedure we need to have 

a final rule for that completed before our notice of 

proposed rulemaking for energy conservation standards 

for battery chargers. 

Again, the battery charger active mode test 

procedure is still under consideration by the 

Department, incorporating active mode. 

Okay. The Energy Conservation Standards 

Final Rule has to be issued, again, by July 1st, 2011. 

 That's an EISA-required date. 

Okay. Standards will be applicable, if we 

establish standards for energy conservation standards 

for EPSs, on July 1st, 2011. Standards will become 

effective for EPSs on July 1st, 2013. Congress did not 

give us a date for when standards should become 

effective for battery chargers. We believe it will 

probably be the same date, unless there are reasons why 

the standard for battery chargers should be delayed. 

Energy Conservation Standards Final Rule, 

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again, will have to be issued by July 1st, 2015, if we 

believe it's technically and economically feasible to 

issue more stringent standards. Standards, again, 

would be applicable by July 2017. 

Okay. Any questions before I get on just a 

quick summary of the test procedure NOPR that was in 

our Federal Register? 

MR. BROOKMAN: I see a few questions. Chris. 

MR. CALWELL: Yes. Vic, I did have one 

question about your timeline of milestones for BC -- 

there it is. That's the one. No, actually, let's see. 

 I'm looking on my slides. It's Slide 29. 

MR. BROOKMAN: Twenty-nine is right here. 

MR. CALWELL: There it is. Yeah. Thank you. 

 You're showing about nine months between the deadline 

for posting the battery charger active mode test 

procedure and the final rule being issued for the 

conservation standards. Is that sufficient time? 

MR. PETROLATI: That is the date that we 

would like to get the final rule completed for the test 

procedure for incorporating the active mode into the 

battery charger test procedure. Okay. So that date 

for us is our drop-dead date to complete the rulemaking 

for incorporating -- 

MR. CALWELL: So you could finish earlier if 

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needed and you could analyze effects of and test 

products much earlier than that. 

MR. PETROLATI: Right. Yeah. 

MR. CALWELL: Okay. Yeah. My sense is that 

that nine months there is a fairly short window 

relative to the whole time of the rulemaking. 

MR. PETROLATI: Right. Our concern is that 

for the notice of proposed rule for energy conservation 

standards for battery chargers, everybody has to 

understand what the test procedure is at that point in 

time. So we feel we have to have a finalized test 

procedure for battery chargers by approximately that 

date. That's a planning date for us right now. 

MR. BROOKMAN: Let's let this gentleman 

follow on, then I'll turn it back to you, Don. Please. 

 You, yes. Say your name for the record. 

MR. HAYNES: This is Jim Haynes again. Part 

of the definition of a Class A external power supply -- 

this is back on one of your previous slides. I wanted 

to ask the folks basically is a cordless telephone 

power supply considered a Class A external power 

supply? 

I call your attention -- I don't have one 

with me, but if you can visualize; a cordless telephone 

is a device where the AC adaptor -- rather than use the 

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words "external power supply" or "battery charger," 

that adaptor plugs into the wall. It is connected to 

the base unit of a cordless telephone and operates the 

product that way. I mean the base unit receives power 

that way. 

Now, there's also a handset which is 

removable, and that handset has batteries. While that 

handset is in the base cradle, so to speak, it's being 

charged. But of course, when you use the telephone, 

you pick that device up, the handset, and so it's 

detachable. 

So I'm trying to find out what the definition 

of the AC adaptor would be. 

MR. PETROLATI: Jim, that's an excellent 

question. Unfortunately, we're not going to be able to 

answer that for you today. 

MR. HAYNES: Okay. 

MR. PETROLATI: That is going to be handled 

as part of our framework document. I will tell you 

that we're still struggling with this language that 

Congress has given us as to how we make all of those 

interpretations under this language. We are going to 

strive to incorporate something that makes sense into 

our framework document, which will be published later 

in this year, and again seek comment on it. 

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This is probably the first time you've seen 

this language as to what a Class A EPS is, unless you 

were involved in the drafting. This is certainly the 

first time we have seen it. It's not similar to any 

other language that has been used previously. So we're 

still in the process of making our interpretations as 

well. 

MR. HAYNES: Well, on behalf of my company, 

and I believe I speak for the rest of the cordless 

telephone industry, we certainly are striving to be 

good citizens and make products that are energy 

efficient, at the same time that work. But if you can 

understand our dilemma in trying to find out which 

standards are applicable to our product. Thank you. 

MR. PETROLATI: Right. Yeah. Sorry for 

that. 

MR. BROOKMAN: Thanks, Jim. Don, please. 

MR. UMBDENSTOCK: This is Don Umbdenstock. I 

have a question on Slide 26. The focus of that 

particular activity is power supplies outside of Class 

A. 

MR. PETROLATI: Correct. 

MR. UMBDENSTOCK: And earlier in the 

presentation you made a comment that commercial and 

industrial power supplies were not included. Is this 

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focused, then, on commercial and industrial power 

supplies? 

MR. PETROLATI: It is not. I'll tell you the 

specific reason. It's because these amendments -- 

MR. BROOKMAN: Make sure to get to the 

microphone. 

MR. PETROLATI: Oh, I'm sorry. It is not 

because the amendments that EISA provided to the Energy 

Policy Conservation Act were under the section for 

consumer products. Okay. So we've got our legal 

counsel here. I know of no way that we can regulate 

commercial or industrial external power supplies and 

battery chargers based on the way that was crafted. 

MR. UMBDENSTOCK: Thank you. 

MR. PETROLATI: Yeah. 

MR. BROOKMAN: Thank you. Other comments or 

questions here at the outset surrounding these 

definitional and statutory issues? Please. Your name 

for the record. 

MR. ANDERSON: Wayne Anderson, Motorola. I 

have the same kind of product category as Jim was 

talking about. If you have a cell phone, you have the 

adaptor plugged into it, and it's charging. But once 

you take the cell phone off, you're back to a power 

supply kind of situation. So we struggle as well 

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trying to figure out what piece of this we're supposed 

to test to. 

MR. BROOKMAN: Thank you. Yes, please. 

MR. DIETERLE: Wayne Dieterle of Conair. I'm 

wondering; we manufacture products which are used for 

travel, adapting from 240-volt to 120-volt, and can be 

used with a number of different products. Would that 

be classified as a Class A EPS? 

MR. PETROLATI: At this point I see no reason 

why it would not. Did you feel that those products met 

any of the exclusions? Did it meet the definition for 

Class A? And by any chance, do you feel it was covered 

under the exclusions? 

MR. DIETERLE: Well, I guess my whole issue 

here is that it's really used for travel outside of the 

U.S. Even though we sell it in the U.S., it's not 

really used here because it's going from 240-volt down 

to 120 so you can use your domestic appliances when you 

travel. 

MR. PETROLATI: Right. And can I ask, do you 

feel that the initial criteria for that device is met 

under this definition? Converts line voltage AC into 

lower voltage AC or DC? 

MR. DIETERLE: Yeah. Yes, it does. 

MR. PETROLATI: Okay. You know, we are going 

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to be struggling with all the products that might be 

used with some of these universal adaptors. But the 

bottom line is that's what we're going to use as our 

criteria for making those decisions. Now, there is 

exclusionary criteria. I don't think that device fits 

any of the exclusionary criteria. 

MR. DIETERLE: No. 

MR. PETROLATI: Okay. 

MR. BROOKMAN: Tim. 

MR. CALLAND: Yes. Well, that brings another 

question to mind. 

MR. BROOKMAN: This would be Tim Calland. 

MR. CALLAND: Tim Calland from Microsoft. 

Will this law be enforced when products are placed on 

the market or placed into service? Which is to say if 

I buy it here but don't use it here in the United 

States, am I subject to this law? Does it fall within 

the jurisdiction of the law? And at what date will the 

law go into effect for products being manufactured 

after that date, product being placed on the market 

after that date, or product being placed into service 

after that date? 

MR. PETROLATI: Francine, would you like to 

jump in on that one? 

MR. BROOKMAN: Francine Pinto. 

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MR. PETROLATI: I'd like to -- yeah. 

MS. PINTO: Francine Pinto, General Counsel. 

 Generally, it's date of manufacture. It's definitely 

not date of service. And it's definitely also not 

where you use the product. If something is distributed 

in interstate commerce, then it's covered by our 

regulations if it meets the definitions and all that. 

We always have effective dates, though, of when a 

manufacturer has to comply with one of our regulations. 

 There's always lead time between when we publish a 

rule and when you have to manufacture to the rule. 

MR. BROOKMAN: Chris, additional question? 

MR. CALWELL: Yeah. Chris Calwell from ECOS. 

 Vic, I appreciated the clarification on commercial and 

industrial versus residential. I just wondered if 

there was any more detail you or the general counsel 

could provide because some of us are used to thinking 

about sectors the way utilities do. So commercial and 

industrial could just mean used on the premises of 

places that conduct business or manufacture things, or 

it might have to do with some more narrow legal 

definition of commercial and industrial. Can you 

provide any more thoughts there? 

MR. PETROLATI: Francine? 

MS. PINTO: Yeah. Francine Pinto. There's a 

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definition in EPCA that defines consumer products. I 

don't have it right here with me, but it's in, I 

believe, Section 321. Generally speaking, it's like 

the primary intent of the product. If you look at the 

language in the statute, it's the primary intent of the 

product to be used for consumer use. 

So a product can still be a consumer product 

even if it's used in some commercial applications. And 

then when you look in Part A1, which is commercial, A 

is consumer part, Part A1 is commercial. Again, it's 

the intent to be primarily used in commercial 

applications. But it's a little tricky because, as I 

said, you can have -- something can still be a consumer 

product even if it is used in some commercial 

applications. 

MR. BROOKMAN: Okay. 

MR. PETROLATI: Okay. Thank you, Francine. 

That is basically the same interpretation that I've 

given to the 150,000 people who have asked that 

question over the process of sending in e-mails. 

 (Laughter.) 

MR. PETROLATI: So thank you for that 

clarification as well. 

All right. Are there any more questions on 

milestones before I get into a very quick discussion of 

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what's in the test procedure notice of proposed 

rulemaking? 

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MR. PETROLATI: Doesn't look like it. We're 

all still interested in breaking for the weekend. 

Okay. 

I'm going to provide a quick summary of the 

content of the Federal Register notice just to give you 

a basic understanding of how it's organized. We 

published the NOPR for this rulemaking on August 15th. 

 On the first page of the Federal Register is the 

supplemental information, which lists the summary, 

provides an overview of the topics that are going to be 

discussed. A discussion section provides detailed 

explanation for the proposed changes that we are 

making. Then, finally in the Federal Register is the 

rule language section, which provides the precise 

proposed amendments to the current test procedure. I'm 

sure you're all familiar with the breakdown of how the 

Federal Register notice is. 

Okay. We also have provided, on page 48056 

and -7, a summary of all the proposed modifications 

that are being made as part of our notice of proposed 

rulemaking. 

Okay. The preamble ends and the rule 

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language section begins on page 48079. Just a quick, 

again, primer. The preamble explains our actions in 

everyday language, what we're trying to accomplish. 

The rule language is the specific rule requirements, 

the exact proposed changes to the existing regulation 

from December 2006. You see the use of the stars 

denotes no changes to the previous text. Today DOE 

will present and explain these proposed amendments. 

Okay. All materials, basically all the 

handouts, everything else that is part of this 

rulemaking, is on our website. So if you need any 

documents or you need to refer others to documents, 

this is the web address. 

Okay. Before we start on the battery charger 

test procedure, any other, additional questions? 

 (No response.) 

MR. PETROLATI: Very good. Thank you for 

your time. 

Battery Chargers Test Procedure: Definitions 

Michael Vladimer 

 (PowerPoint presentation.) 

MR. VLADIMER: Good morning. I'm Michael 

Vladimer from Navigant Consulting. Navigant 

Consulting, along with our colleagues at D&R 

International, support the Department of Energy in this 

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rulemaking. I'm here to present the battery charger 

test procedure proposed changes. 

We're going to start off looking at how the 

test procedure works, get into standby and off mode and 

the definitional changes, and then talk about some test 

measurement changes. 

As Vic mentioned previously, everything that 

we're proposing here is in reference to the 2006 final 

rule. So I'd encourage you to look in the packets that 

you picked up in the front and the final rule is right 

there. It looks kind of like this. So if you see 

anything here that might not make sense, this is the 

context for it. 

So when you look at the final rule for the 

battery charger test procedure, you'll see that there's 

four clearly marked sections: Scope, Definitions, Test 

Apparatus, and then finally Test Measurement. The 

Scope talks about how does the test procedure apply and 

to which products. The definitions, what are the exact 

meanings of the terms that we're using. Test 

Apparatus, how is the test lab supposed to be set up. 

Then, finally, how do we take the test measurement 

itself. 

So, as I said, we're going to talk about the 

definitions and then we're going to talk about test 

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measurement changes to address standby mode and active 

mode, which, as Vic mentioned, are required by EISA. 

Either in the middle of that or at the end of that 

we'll take a coffee break. 

I'll start with the definitions. When EISA 

directed the Department of Energy to come up with test 

procedures for standby mode and off mode, it did 

provide definitions for those terms. It also specified 

that DOE can amend those definitions, with the caveat 

that it needs to take into consideration IEC 62301 and 

IEC 62087. 

Today, the Department is proposing 

alternative definitions for those two modes, and one of 

the primary issues regarding those definitions are 

on/off switches, which aren't addressed either by EISA 

or the IEC standards. 

So the EISA definition itself reads, “the 

condition in which an energy-using product is connected 

to main power source; offers one or more of the 

following user-oriented or protective functions: to 

facilitate the activation or deactivation of other 

functions, including remote switch, internal sensor, or 

timer;” and then it talks about continuous function 

such as status displays and sensor-based functions. 

So I'm going to talk about -- that definition 

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is good in the broad sense, but when we apply it 

specifically to battery chargers we think that there is 

some need for clarification. 

So one issue is how do you apply the terms 

"user-oriented function" and status display when 

talking about a battery indicator light. Some battery 

chargers might have an indicator light, some might not. 

 Some might have one that comes on when the battery is 

removed, some might not. 

So here we present the example of if you have 

a battery charger, the battery has been removed from 

the charger, and the on/off switch, if there is an 

on/off switch, is set to on, one might have a light, 

one might not. According to the EISA definitions, one 

would be in standby mode and one would be in off mode. 

 We believe that those would be two -- even though 

there's only a light that's different, we think that 

those two modes would be comparable and we want to 

compare them. So because of that, the Department of 

Energy is proposing a consistent definition for standby 

mode. 

Similarly, the Department evaluated the IEC 

definition in IEC 62301. 62301 sets the definition 

based on the lowest power consumption mode. Again, it 

doesn't address on/off switches. By specifying the 

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lowest power consumption mode, it doesn't provide the 

option if a product is not consuming any power at all. 

MR. BROOKMAN: Michael, I think this is 

complicated enough that we'll entertain some questions 

as we're going along. 

MR. VLADIMER: Sure. 

MR. BROOKMAN: If that's okay with you. Tim 

Calland. 

MR. CALLAND: Just a quick point of 

information. Michael, I think you and I discussed this 

briefly on the phone. As we speak, a final 

implementing measure has been drafted and will be 

turned into law at the end of this year for LOT 6 and 

the European Union that deals with very specific 

definitions of standby and off mode power. In the 

interest of international harmonization, I would like 

to encourage this group to do everything they can to 

make their requirements in harmony with that which has 

already become law in the European Union. 

MR. VLADIMER: Excellent. Anyone else? 

 (No response.) 

MR. VLADIMER: Sure. Thank you, Doug. And 

thank you, Tim. 

So I was discussing how the EISA definition 

applies to battery chargers. We looked at that. Now, 

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because EISA says if the Department were to change the 

definitions it should also consider IEC, I want to talk 

about how the Department did look at the IEC definition 

for standby mode. 

In the IEC definition, there it really 

focused on the lowest power consumption mode. Again 

there is a possibility for confusion that the 

Department wants to clarify. So if you had two battery 

chargers, both with on/off switches, and the switches 

were set to "off," depending upon where the 

manufacturer chose to put that switch there's a chance 

that one could consume power while plugged in and the 

other one might not. Again, the Department believes 

that these are comparable modes that should be measured 

in the same way and meet the same criteria in the test 

procedure. The Department's proposed definitions in 

this test procedure address that. 

So, for standby mode, the Department proposes 

to just modify the existing definition, that is pretty 

tight to begin with, but add on the line that it's only 

for battery chargers with -- sorry. Standby mode is a 

condition in which the battery charger is connected to 

the main electrical supply, the battery is not 

connected to the charger, and for battery chargers with 

manual on/off switches, that all switches are turned to 

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"on." 

 Yes, please. 

MR. HINDUS: This is Michael Hindus. Just by 

way of clarification, does that mean that this 

definition would not apply to a device that does not 

have an on/off switch? 

MR. VLADIMER: It tries to address that by 

saying for battery chargers with manual on/off 

switches. So if the battery charger doesn't have a 

manual on/off switch, then the third bullet I don't 

believe would apply. 

MR. HINDUS: Therefore, the definition would 

not apply. 

MR. VLADIMER: The entire definition or that 

portion of the definition? 

MR. HINDUS: That's my question. 

MR. VLADIMER: Okay. So then the answer is, 

the first two bullets apply to all battery chargers. 

The third bullet is structured to address only battery 

chargers that have the on/off switches to close that 

loop. Do you have any suggestions as to tighter 

language to say that one and two apply to all battery 

chargers and three is only for those with on/off 

switches? 

MR. PETROLATI: Mike, we'll need to take a 

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look at that language. You're right. I think it could 

be interpreted the way you're indicating, and that 

wasn't our intent. So we will have to take a look and 

potentially revise that language. 

MR. BROOKMAN: Thank you, Vic. Okay. These 

clarifying questions are useful. Larry, please. 

MR. ALBERT: Larry Albert. Mike, the only 

comment that we had with respect to that definition is 

that when it says the battery is not connected, for 

those products that are integral battery products, and 

based upon the discussion that was in the Federal 

Register, we believe that perhaps the Department was 

contemplating that what you were really talking about 

is that the integral battery product was disconnected 

from the cradle or the power source or whatever it was, 

that you weren't contemplating actually removing the 

battery from inside the integral battery product in 

making evaluation of what standby mode was. 

Because there was some very clear discussion, 

I think, in the Federal Register about the functional 

modes of use of the products, right, where there's 

consideration given to measurements that were 

consistent with these various functional modes of use. 

 That would line up well with that. 

So I guess our comment was, and I think it 

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was in our presentation, to modify the language to make 

it clear that it would be the battery not connected to 

the charger or, in the case of an integral battery 

product, that product not connected to the charger or 

cradle or whatever it happened to be. That might 

involve some more wordy language than what you have so 

cleanly delineated up there. But I think it would get 

across what I believe your intent was. 

MR. VLADIMER: Thank you. 

MR. BROOKMAN: Thank you. 

MR. VLADIMER: Vic, anything to add? Or 

anyone else? I see Chris's hand up. 

MR. BROOKMAN: Go ahead, Chris. 

MR. CALWELL: Yeah. Chris Calwell from ECOS. 

 I'm also struggling with the language a little bit. 

Is it fair to say then that the no-load mode -- the 

terminology that appears at the top of that slide, noload mode means the battery is not there as a load but 

it doesn't mean that the battery charging circuitry is 

not there as a load. 

So I think what I had seen in your printed 

wording was you were referring to this and similar 

language that we had used in the California draft as 

the "no battery" mode. So I think this wording that 

you've written here changes that meaning slightly and 

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maybe not intentionally because the battery may not be 

there but other loads in the battery charging system or 

battery charger may be there and you can't get rid of 

those. 

Do you understand the question? 

MR. VLADIMER: So, are you suggesting that 

this read "standby mode or no-battery mode"? 

MR. CALWELL: Correct. 

MR. VLADIMER: Okay. 

MR. CALWELL: Yeah. "No-load mode" is a very 

relevant term for an external power supply where you 

can disconnect it from its load, but it's not as 

meaningful or applicable here, where what you can 

connect -- as Larry also said a minute ago, you can 

connect the -- you can remove or disconnect the battery 

but you can't remove or disconnect all loads. 

MR. BROOKMAN: I see some other individuals 

that might wish to comment on this. Wayne. 

MR. MORRIS: Sure. I would say I agree with 

Chris that I think that that's what the Department is 

intending. I think that we need to tighten up the 

definition and the wording just a little bit. 

I understand the use of the term "no-load 

mode," but I think that when it applies to battery 

chargers you've got to specify it as "no-battery mode." 

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 I really think that that's what we've done in all the 

long and other definitions in other test procedures. 

MR. BROOKMAN: Do you want to comment here? 

Your name, please, for the record. 

MR. MALINOWSKI: Matt Malinowski, Navigant 

Consulting. I just wanted to point out that within the 

scope of the battery charger test procedure the no-load 

mode actually refers to the presence or absence of just 

the battery. That's to differentiate it from the noload mode within the external power supply test 

procedure. 

MR. BROOKMAN: It looks like we need a flow 

chart or something. Larry. 

MR. ALBERT: Larry Albert. Just to follow 

up, elsewhere in the proposed recommended changes by 

the Department to Appendix Y later on where they 

describe the changes, the influence it would have upon 

the EPA Energy Star test procedure, there is specific 

language for how to evaluate this when you're dealing 

with non-detachable batteries, which would tend to 

support what Chris and Wayne and I are trying to say, 

which is that there's an understanding there for 

products that have non-detachable batteries you need to 

measure standby mode with those products disconnected, 

not the battery disconnected from within the product. 

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It's just that it doesn't -- what's in the 

directions with respect to Appendix Y is not carried 

through up in the definitions section. It would seem 

to be that they need to be consistent and be the way 

that you'd want to test it. 

MR. BROOKMAN: Any other comments with 

respect to this stream of definitional stuff? Ari. 

MR. REEVES: Ari Reeves, D&R International. 

One other point of clarification here. I think the 

reason that it stays standby mode or no-load mode is 

because that language is what is in EISA 2007. So it's 

kind of like we have to deal with it as it is and try 

to modify it the best we can. I think that the point 

of clarification earlier suggesting that we clarify 

that for battery -- I think it was good that we clarify 

that, for battery chargers, instead of standby mode or 

no-load mode what we actually mean is standby mode or 

no-battery mode. I think that's something that we'll 

consider, or the Department will consider. 

MR. BROOKMAN: An interpretation of the 

actual language. Okay. 

Okay. Other comments on this before we move 

on? 

 (No response.) 

MR. BROOKMAN: Let's go a little bit further. 

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MR. VLADIMER: Sure. Thanks, everyone, for 

that input. 

One other thing, just to follow up on what 

Larry was saying -- regarding what Larry raised with 

how this would apply to an integral battery. We do 

talk about that in the test measurement section. I see 

what you're saying, how it's unclear in the definition 

section, but we will get into that in a few more 

slides. So, just to be aware. Excellent. 

Now that we understand the Department's 

proposed standby mode definition for battery chargers, 

I'll show you the off mode definition. Again, it's 

quite similar. A condition applicable only to units 

having manual on/off switches in which the battery 

charger is (1) connected to the main electricity 

supply; (2) not connected to the battery; and (3) all 

switches are turned off. 

As opposed to the standby mode definition, 

there's no amendment here because there was no off mode 

definition previously. Again, the reason that the 

Department is proposing this as opposed to the off mode 

definition from EISA is because the EISA definition 

cites the standby mode definition. So any confusion 

that we just explained in the standby mode definition 

would then carry over to off mode. 

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MR. BROOKMAN: Chris. 

MR. CALWELL: Yeah. I think this question is 

real quick. I'm assuming that when you use the term 

"manual on/off switch" it would be a user-activated 

switch if you will, as opposed to a switch that uses 

either electrical, mechanical, or optical means to 

detect that you have a battery in the cradle. Is that 

a fair statement? 

So it's literally a switch on the side of the 

product that the user is intended to turn on or off as 

opposed to something that would automatically shut the 

device off when a battery is removed? 

MR. VLADIMER: I believe so, yeah. 

MR. CALWELL: Okay. 

MR. BROOKMAN: Do you wish -- that's your 

best thinking right now. 

MR. VLADIMER: Yes. 

MR. BROOKMAN: Okay. 

MR. VLADIMER: It's user-controlled. That's 

the purpose. That the user can control it. 

MR. CALWELL: Because I guess you would argue 

that the user, by taking the battery out of the cradle, 

can also control it and turn it on or off. I don't 

know that the distinction is huge, but since you are 

creating a new mode here you might want to be 

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absolutely crystal clear about what kind of switches 

count as a "manual on/off switch" and which ones don't. 

MR. VLADIMER: Excellent. 

MR. PETROLATI: Good point. 

MR. BROOKMAN: Thank you. Okay. 

MR. VLADIMER: Great. Okay. So, as I stated 

in the beginning, the Department was granted authority 

by EISA to amend these definitions as long as it 

considered IEC 62301 and IEC 62087, so I'm going to 

speak to that now. 

IEC 62301 is the Household Electrical 

Appliances Measurement of Standby Power. DOE looked at 

those definitions. I reviewed them previously. But 

it's choosing to propose a different definition. IEC 

62087, this largely applies to audio and video 

equipment. The Department believes that there's a wide 

variety of products that use battery chargers and IEC 

62087 is a little too narrow for this application. 

MR. BROOKMAN: Wayne. 

MR. MORRIS: Yes. Wayne Morris. Just a 

couple of minor clarifications here. What is up there 

is the current standard for 62301. However, as any 

good standard is, it's a living document. I happen to 

serve on the technical committee for IEC 62301, and 

there is a proposal going to the IEC TC59 meeting that 

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will be held later this month to make some 

modifications to that definition. 

So my only point of bringing that up is, I 

don't know that you're ever going to be able to 

completely harmonize with those standards. I think 

that you -- the Department is doing the right thing by 

defining the intent in the situation and what they 

believe, and I believe that's what EISA said to do, is 

to take into consideration the 62301 definitions. 

But there may be time when the definitions in 

62301 may be different than what we see today. I don't 

know that we have the power or the time or the energy 

within the Department of Energy to go back and make 

those changes every month or every six months or every 

year or whatever. 

So I think that we do the best that we can. 

I think the intent is what you have arrived at there. 

I support what you're doing, but it should be 

acknowledged that it isn't necessarily going to be this 

definition within the next year because by the time 

that the balloting is complete on the next version of 

62301 that definition will be different. 

MR. BROOKMAN: Thank you. 

MR. VLADIMER: Okay. So, thanks. Our first 

request for comment. The Department invites 

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stakeholder comments on proposed revisions -- revised 

definitions for both standby mode and off mode for 

battery chargers. 

MR. BROOKMAN: We've had good comments as 

we've been going a long. Perhaps there are others now. 

 Chris? 

MR. CALWELL: I spoke earlier in the week 

with Lloyd Harrington, who is working on that revision 

to 62301. So I think my only suggestion here was to 

encourage DOE staff or consultants to get in touch with 

him. I know he's in the middle of wording changes over 

the next, literally, I think, week or two. And if 

you're trying to wrap up your language, one of you may 

have some useful influence on the other toward arriving 

at common definitions. 

MR. BROOKMAN: Thank you. Other comments, 

suggestions, details, counterpoints? 

 (No response.) 

MR. BROOKMAN: I see none. Okay. I'm going 

to suggest we take a break at this point. Before we go 

to break, Francine? 

MS. PINTO: Yeah. I just had one 

clarification when we were talking about consumer 

product earlier. The actual statutory language, when I 

talked about intent, is to -- "A product which to any 

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significant extent is distributed in commerce for 

personal use or consumption by individuals." So that's 

the language. The commercial section tracks the same 

thing for commercial. 

So if a product to any significant extent is 

distributed in commerce for personal use or consumption 

by individuals and it ends up in a commercial 

application, it is still a consumer product. So I was 

talking about intent. That's the language I was 

referring to. 

MR. ALBERT: Francine? 

MS. PINTO: Yeah. 

MR. ALBERT: This is Larry Albert. Does that 

also mean that a product could be both? That the 

significant extent does not mean the majority? 

MS. PINTO: Generally speaking, it's one or 

the other. 

MR. ALBERT: Okay. 

MS. PINTO: Yeah, yeah. But I want to make 

the point that something can be a consumer product even 

if it ends up in a commercial application. That could 

be a little confusing point. 

MR. ALBERT: But if you have a product that's 

distributed both for commercial and for personal use, 

then the determination of which it were would be based 

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upon which one had the greater extent of distribution? 

MS. PINTO: Yeah. Generally speaking, I 

would say that. 

MR. ALBERT: Okay. Thank you. 

MR. CALWELL: Is there a comparable 

definition given for a commercial product? 

MS. PINTO: Yes, there is. 

MR. BROOKMAN: That was Chris, followed by 

Francine again. 

So it's now 10:45. I'm going to suggest we 

break for 15 minutes. Before everybody moves, please 

wear your security badges. This room -- there will be 

people in this room, so you can leave your materials 

here. 

There's a coffee shop one floor below us on 

the far side of the hall. You can just go down the 

stairwell or down the elevator. Don't go too far 

because we want you back here. We will start at 11. 

Thanks for a good start on the day. 

 (Brief recess.) 

MR. BROOKMAN: So then, Francine Pinto. 

MS. PINTO: Yeah. Okay. 

MR. BROOKMAN: Hey, folks. Please. 

MS. PINTO: I'm a little bit concerned that I 

may have not been clear enough or not responded 

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accurately to people's comments or misinterpreted how 

people were using words. Let me just see if I can do 

it a little better. 

We do not use a particular percentage or 

majority or any particular number that would separate 

our determination as to whether something is a consumer 

or a commercial product. We don't have a magic number, 

okay. We don't use majority. We don't use an actual 

percentage. 

What we look at, and it is not defined 

specifically, but the language in the statute says, 

"The term 'consumer product' means any article other 

than an automobile which in operation consumes or is 

designed to consume energy -- or with respect to shower 

heads, faucets, water closets, and urinals, water -- 

and which to any significant extent" -- again, there is 

no number that defines what is significant -- is 

distributed in commerce for personal use or consumption 

by individuals." 

So what I was trying to say is that if it is 

distributed, a product is distributed, to any 

significant extent, for this purpose it is a consumer 

product. And some of those products could also end up 

in commercial applications. 

So when I said it's one or the other, I was 

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trying to capture this language that we have to look 

and decide. Now, if the statute says something 

different, for example "This is a commercial product," 

then obviously the statute controls. But just in 

general, it's not a number. So we don't just look at 

percentages. 

Now, Vic, what else can you add to what I 

just said? Was there anything I missed? 

MR. PETROLATI: No. I think that's fine, 

Francine. I've been giving this interpretation to 

people who have asked this question. 

MR. BROOKMAN: Vic, get to the microphone, 

please. 

MR. PETROLATI: Sorry. Vic Petrolati. I 

just want to indicate that the interpretations that 

I've been giving to people who have written in and 

asked this question are basically along the same lines 

as Francine. I've told them that if there is any 

significant percentage of use in the residential 

sector, then it becomes a consumer product. I told 

them we don't have a definition of what that percentage 

is. I have given them examples such to the extent of 

15 percent of the product is distributed in the 

residential sector, used by consumers. Most likely the 

Department will consider that a consumer product. 

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So I think we are consistent now in terms of 

the way we have defined "consumer products" for our 

stakeholders. 

MR. BROOKMAN: Larry, please. 

MR. ALBERT: The question from before was, 

for products that are distributed both into commercial 

and residential sectors, if it is going to be covered 

under one or the other, right, then would that 

determination be made on which one had the greatest 

extent of distribution? No? 

MS. PINTO: We would probably look at a 

variety of -- we'd have to look at the market, I would 

assume, for that product. 

MR. PETROLATI: Okay. He's asking, I think, 

if I'm hearing it, if it's 51 percent commercial and 49 

percent residential, how we would define that? 

MR. ALBERT: That would be one part of the 

question, yes. 

MR. PETROLATI: Okay. And the answer is 

because there's a significant percentage of use -- 

MS. PINTO: Right. 

MR. PETROLATI: -- in the residential sector, 

we would define that as a consumer product. 

MR. ALBERT: So that takes priority, I take 

it? 

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MR. PETROLATI: Yes. 

MR. ALBERT: Okay. 

MS. PINTO: Okay. 

MR. ALBERT: All right. 

MR. PETROLATI: And if the percentages were 

20 percent in the residential sector and 80 percent in 

the commercial sector, we would define that as a 

consumer product. 

MR. ALBERT: Gotcha. All right. Very good. 

 Thank you. 

MR. BROOKMAN: Okay. Thanks, Francine. 

MS. PINTO: Okay. 

MR. BROOKMAN: Vic, thank you for those 

clarifications. 

MR. PETROLATI: Yeah. 

MS. PINTO: And this issue has been written 

up in previous rulemakings. So you can look at our 

previous Federal Register notices and see descriptions 

of this issue. 

MR. BROOKMAN: So, Chris, please. 

MR. CALWELL: Have there been any comments 

given yet on products that you've decided are not 

consumer products? Have you clarified it to that 

extent yet in responses to calls, or yet to be 

determined? 

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MR. PETROLATI: Yes, from one very minor 

standpoint. 

MR. BROOKMAN: Get close. 

MR. PETROLATI: Vic Petrolati. These were 

supposed to be omni-directional microphones. That's 

why we paid so much for them. 

 (Laughter.) 

MR. BROOKMAN: And the green button is 

supposed to be turned on. 

MR. PETROLATI: Right. 

MR. BROOKMAN: Okay. 

MR. PETROLATI: Yes, Chris, but this answer 

probably won't clarify it much. I've told anybody that 

if their product is only distributed in the commercial 

and industrial sectors they do not have to worry about 

these standards. Yeah. 

MR. BROOKMAN: Thank you. Other questions 

here at the outset before we turn it back to Mike? 

 (No response.) 

MR. BROOKMAN: Okay. Michael. 

Battery Chargers Test Procedure: Test Measurement 

Michael Vladimer 

 (PowerPoint presentation.) 

MR. VLADIMER: Good morning. Thanks again. 

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Michael Vladimer from Navigant Consulting. And so far 

we've talked -- we're continuing to talk about the 

battery charger test procedure. We've talked about the 

definitions, and I want to get into the Test 

Measurement section now. I think the conversation so 

far has been very fruitful and I would encourage more 

comments. Keep going the way we're going. 

So the test measurement consists of two -- 

the existing test measurement that you have in the 2006 

test procedure, there's only two parts, A and B, 

inactive modes and active modes. The Department is now 

proposing to add C and D, standby mode and off mode. 

So, the existing test procedure is based on 

the Energy Star test procedure for battery chargers. 

It addresses standby mode and maintenance mode energy 

consumption, and we'll explain exactly what that means 

in the next slide. The proposed amendment would create 

a separate measurement of standby mode energy 

consumption in 4C, in addition to that measurement in 

4A. 

So the existing test procedure in 4A 

considers three parts in the measurement. First, 

what's the energy consumption in maintenance mode. 

That's when the battery is completely full, plugged 

into the charger, and the charger may or may not be 

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delivering excess charge to the battery. 

The second part is standby mode. Right now 

it's also called no-load mode. That's when the battery 

is removed from the charger but the charger is still 

plugged into mains. Some chargers are going to 

continue to draw power in that mode, and we want to 

measure that. 

And then, finally, a measurement of the 

energy delivered by the battery. So when you 

completely empty the battery, how much energy comes 

out. 

Those energies are put together in an energy 

ratio. That is the metric that we're currently using 

for the energy efficiency of the battery charger. 

The proposal for standby mode and off mode is 

very similar to the standby mode measurement I just 

discussed. The main issue would be that if there's an 

on/off switch in standby mode it's set to "on" and in 

off mode it's set to "off," as you can see in the 

pictures. The test would be a one-hour test, whereas 

the standby mode for Section A is a 12-hour test. 

Again, of course, you're connected to the 

power source and there's no batteries connected to the 

battery charger. 

Any questions so far, or comments? 

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MR. VLADIMER: Great. The specific text 

would read, "Conduct a measurement of standby power 

consumption while the battery charger is connected to 

the power source. Remove the battery from the charger 

and record the power." This is going to happen over a 

one-hour test period, and all manual switches must be 

turned on for the duration of the test. 

Similarly, the off mode measurement says that 

the battery charger is going to be connected to the 

power source, the battery is removed from the charger, 

the test period is one hour. All switches are turned 

off. In this case, hopefully this language is clear, 

but, “if the battery charger does not have manual 

switches, record that the off mode measurement is not 

applicable to this product.” So off mode is only for 

those products that do have that manual on/off switch. 

This is the slide I was referring to earlier 

that addresses the issue of integral batteries versus 

other types of batteries. So the test procedure for 

standby mode specifies four different cases. The first 

case is if you have a detachable battery pack. In that 

case, you simply have the charger, as you see here, and 

you measure it without the batteries, separately. 

In the case of an integral battery pack, such 

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as a hand vacuum, you would measure the cradle or 

adaptor alone. So in this case, the cradle and adaptor 

that are connected together, that's what's measured 

alone. You don't put the hand vacuum in the cradle. 

There's another case where you might just 

have all of the battery charging circuitry inside the 

product itself and the product just comes with an AC 

cord. In that case, the power consumption is zero. 

The last case that we could think of but we 

couldn't find a product for is if all the battery 

charging circuitry is in the product itself and the AC 

cord is not detachable. Again, the standby mode and 

off mode would not be applicable to that kind of 

product because it would always be in maintenance mode 

if it were connected. 

So, to wrap up, DOE's revisions are based on 

the EPA battery charger test procedure. The time. As 

Ken, I believe, stated in the beginning, the Department 

is proposing a one-hour test. The Department welcomes 

comment on the duration of the test. I might pose a 

question in a sec about that. 

But yes, the Department has proposed one 

hour. And we cite the EPA battery charger test 

procedure that gives the option of either a one-hour 

test or a 12-hour test. And we do have the comment box 

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asking for comment. 

So, any comments at this time? 

MR. BROOKMAN: Ken. 

MR. SALAETS: Yeah, Mike. Just a question. 

Ken Salaets, ITI. In terms of the one hours, was that 

merely looking at the current practice and saying one 

hour was sufficient and then just putting that in, or 

was there a determination that a minimum of one hour 

was required to be able to obtain the desired result? 

Thanks. 

MR. VLADIMER: Thanks for the question. So 

the one hour was arrived at through a number of 

different venues. One is, of course, looking at 

precedent and looking at what's been done in the past. 

 So from that perspective, that was one consideration. 

The other issue is that -- I realize that you 

deal with mostly information technology equipment, but 

we're aware of other types of equipment that might have 

pulse modes, where over the course of an hour they 

might turn on for a minute or two in intervals. 

So the issue is if that were to happen every 

hour and you only measure the first 10 seconds, as you 

proposed in your opening statement, you might miss that 

energy consumption. 

So my question would then be, how would you 

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propose addressing this wide variety of products? IT 

products that might not have pulse mode versus others 

that would. 

MR. BROOKMAN: Ken. 

MR. SALAETS: Ken Salaets, ITI. At this 

point I'm not prepared to specify how we would suggest 

that. I appreciate the challenge in trying to create a 

broad enough rule that it captures the various 

scenarios depending on the technology and the like. We 

will take that into account and come back with 

something, another proposal or perhaps some suggested 

language that might allow the flexibility but still be 

able to take into account the different technologies 

that are at play here that might require a longer 

duration for testing. Then, of course, we would be 

happy to engage with anybody in the interim on that as 

well. 

MR. BROOKMAN: Since you've raised it, Mike, 

are there other modes other than pulse, for example, 

that make this more complicated? We might as well get 

them out now if there are. I was going to ask you -- 

MR. VLADIMER: Oh. I mean, that's how I 

know. It's either continuous or intermittent. It's 

one or the other. 

MR. BROOKMAN: Okay. Wayne. 

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MR. MORRIS: Thanks, Doug. Wayne Morris. 

Can you back up one slide, Michael? 

MR. VLADIMER: Sure. 

MR. MORRIS: Your missing mode or example 

there. I think there are some rechargeable products 

where not only is the circuitry encased in the product 

itself but the actual attachment for purposes of 

obtaining power -- in other words, it's a direct plugin type of device where it has the plug blades built 

into the side of the product and so it's meant to plug 

directly into a receptacle. So all of the charging 

circuit and the connection point are in the product and 

it's meant to do that. 

I know that there are some out there. But 

it's meant to be then taken away from the receptacle 

and used as a rechargeable product. I think that's -- 

PARTICIPANT: Flashlights. 

MR. MORRIS: I wasn't going to mention them 

particularly. 

 (Laughter.) 

MR. BROOKMAN: Chris. 

MR. CALWELL: This is Chris Calwell from 

ECOS. Yeah, I think on that particular example, 

wouldn't a UPS also apply there? It's a permanently 

attached cord. The battery is inside of the device. 

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You could detach it but it's not routinely detached in 

practice. 

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MR. VLADIMER: By UPS you mean universal -- 

MR. CALWELL: Uninterruptable power supply. 

Yeah, so I think that -- I agree with Wayne. 

 There are probably examples you could find for that 

situation. Really, the main point of raising my hand 

was to speak just briefly to the item on the last slide 

that you had up before. 

MR. VLADIMER: Okay. That one? 

MR. CALWELL: Yeah. Regarding inviting 

comment on the duration. I was in some of those 

meetings. I don't recall the exact reason for one hour 

and 12 hours. I can tell you that often in these 

situations there's a desire to achieve thermal 

stability, if nothing else, because you want the test 

to be repeatable in multiple labs. And if some plug in 

the device and measure it immediately, some plug it in 

and measure it a few minutes later, some plug it in and 

measure an hour later, the device may have warmed up to 

a different extent and that in turn has some modest 

effect on its power use. 

So I'd be in favor of one hour to achieve a 

measure of thermal stability, but not going all the way 

to 12 hours for the reasons mentioned before. Whatever 

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you gain in stability you probably lose in tying up 

expensive lab equipment for more than a day. 

MR. BROOKMAN: Thank you. Gary. 

MR. FERNSTROM: So, Doug, Gary Fernstrom from 

the Pacific Gas and Electric Company. Following up on 

Wayne's comment, Rayovac makes a little charger that 

plugs directly into the wall. There is no cord, and 

the batteries go in it. 

MR. BROOKMAN: Thank you. Thank you for 

those illustrations. Helpful. 

Other comments on this series of slides? 

Please. 

MR. ALBERT: Larry Albert. Just a general 

comment, Michael. The Appendix Y currently modifies -- 

incorporates the EPA Energy Star test procedure and 

then provides modifications to it. So proposed 

amendments to Appendix Y need to also look at the 

potential changing of the requirements in the Energy 

Star test procedure that might be necessary because of 

now additional measurements that you're making. 

Specifically, the reporting requirements in the EPA 

Energy Star test procedure would need to be amended in 

Appendix Y to account for the fact that you have now 

new measurements. Just kind of a housekeeping issue 

more than anything else. 

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MR. BROOKMAN: Thank you, thank you. Please. 

MR. VLADIMER: Doug, could I just speak to 

that briefly? 

MR. BROOKMAN: Please do. Yeah. 

MR. VLADIMER: It's actually interesting that 

you mention reporting requirements because, just to 

jump ahead, Vic will be discussing reporting 

requirements at the end of -- after we finish with 

external power supplies. So hopefully you can raise 

that again then. 

MR. BROOKMAN: Your name, please. 

MR. BALLO: Tim Ballo with Earth Justice. Is 

this on? 

MR. BROOKMAN: I don't think it's on. 

MR. BALLO: I was prepared to speak a little 

more about the need for active mode. 

MR. BROOKMAN: Please use that microphone, 

Tim. 

MR. BALLO: Is this now working? 

MR. BROOKMAN: Yeah. Thank you. 

MR. BALLO: I was ready to speak a little bit 

more about active mode use for battery chargers. I'm 

pleased to hear that the Department is considering a 

separate rulemaking for that. 

I just wanted to emphasize that currently, if 

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you're only going to cover maintenance and standby and 

off mode, the Department's test procedure would not 

meet the requirements of Section 323 of EPCA, which 

requires the test procedures to be reasonably designed 

to produce results, measuring energy efficiency during 

a representative average use cycle or a period of use 

of the product. I don't think a test procedure that 

doesn't actually measure the battery charger's energy 

consumption when it is charging a battery does not 

reflect representative energy use. 

Also, Section 325(g)(g), which is -- the 

Department also cited for this proceeding, which 

requires standby energy consumption and off mode energy 

consumption test procedures, does provide a definition 

of active mode in that section of the statute. I think 

the only reasonable way to read that section of the 

statute is that in addition to promulgating a test 

procedure that covers standby and off mode the 

Department would also have to promulgate a test 

procedure that covers active mode energy consumption. 

 That's it. 

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

please. Jennifer. 

MS. AMANN: Jennifer Amann. Just keeping on 

that issue, we're really pleased to see that there is a 

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date proposed for considering inclusion of active mode 

in the test procedures. But we'd like to encourage the 

Department to consider including that at this time so 

we can go ahead and get that process formalized and 

start collecting data and information on active mode 

power consumption. 

MR. BROOKMAN: Gary. 

MR. PETROLATI: Let me just address that. 

MR. BROOKMAN: Vic, please. 

MR. PETROLATI: I think I've mentioned it to 

a few people who have asked. First of all, am I 

speaking into the microphone? 

MR. BROOKMAN: I think so. Yeah. 

MR. PETROLATI: The bottom line is we are 

stuck with an EISA congressional date of getting 

standby and off mode incorporated by December 31st, 

2008. It would be impossible at this point, since we 

have already -- are basically in the proposed rule 

stage, to incorporate active mode into the battery 

charger test procedure for this specific regulatory 

action. 

The concept of incorporating active mode is 

still under consideration. We don't have management 

buy-in yet, but I think the comments that we've 

received today at this public meeting will be very 

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helpful in terms of making a decision in the very near 

future on that and starting a separate rulemaking for 

incorporating changes into the battery charger test 

procedure. Thank you. 

MS. AMANN: I'd like to just follow up. So 

you're saying that you don't see any reason why you 

would necessarily need until that 2010 date to make 

that next action? 

MR. PETROLATI: The 2010 date was the final 

rule for the battery charger test procedure. We would 

start the action fairly soon on that. Yes, correct. 

MR. BROOKMAN: Gary. 

MR. FERNSTROM: So, Gary Fernstrom, Pacific 

Gas and Electric. I would just like to concur with 

Jennifer. PG&E strongly believes that we're missing the 

boat here if we don't include the active mode as part 

of determining battery charger system efficiency. 

MR. BROOKMAN: Thank you. 

MR. PETROLATI: Thank you very much for that. 

MS. PINTO: Francine Pinto. The reason why 

we can't do it is because of notice and comment. We 

would have to go out with a supplemental NOPR so you 

could all give us comments. That's just a process that 

takes time to do. So to get the other date done, the 

December 31st date, procedurally we just couldn't do 

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it. 

MR. BROOKMAN: Larry. 

MR. ALBERT: Yeah. Larry Albert. The 

comments we made earlier with respect to just providing 

the E24 measurement, which would be consistent with the 

CEC test procedure, would not commit the agency, 

Department rather, to necessarily having an 

implementation. There's no separate testing that's 

required to do that. It's already built into the test 

procedure right now. It's just a matter of measuring 

the value at the end of that first 24 hours. You're 

already conducting that portion of the test. 

Just by providing that additional piece of 

information out of the existing test procedure would 

provide a number that would be consistent with the CEC 

test procedure that is shortly to become rule in 

California. So that's why we're advocating for the 

inclusion of that. We think it's a minimal impact. 

I'm not sure about how it would affect notice and 

comment because it could be -- it would seem to me to 

be incorporated just as an additional reporting 

requirement and not necessarily an additional burden 

upon testing since there is no additional time 

involved. 

MR. PETROLATI: We will take it under 

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advisement. Again, I'm not 100 percent sure at this 

point whether it meets the test of notice and comment. 

MR. BROOKMAN: Additional comments on this 

subject? 

 (No response.) 

MR. BROOKMAN: Okay. Michael. 

MR. VLADIMER: Great. Well, I guess one last 

question that I wanted to put out there before we move 

on. Because we do specify one hour and 12 hours, are 

there any people that feel that 12 hours would be a 

more appropriate standby test? Or, one hour sounds 

okay? 

 (No response.) 

MR. VLADIMER: Excellent. I'll take that to 

mean no 12-hour people. Great. 

Well, now I'd like to turn over the 

presentation to my colleague Matt Malinowski, also from 

Navigant Consulting. He's going to speak about the 

external power supply test procedure. 

External Power Supply Test Procedure: Scope and 

Definitions 

Matt Malinowski 

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 (PowerPoint presentation.) 

MR. MALINOWSKI: Thank you, Michael. My name 

is Matt Malinowski from Navigant Consulting. We advise 

the Department of Energy on helping them with this 

rulemaking. I'd like to now turn your attention to 

Appendix Z to Subpart B of 10 CFR 430, which is the 

Department's test procedure for external power 

supplies. 

Like the battery charger test procedure, this 

test procedure also includes four parts: the Scope, 

the Definitions, the Test Apparatus, and the Test 

Measurement sections. We will address proposed changes 

to each of those in turn. 

The purpose of this part of the rulemaking is 

to fulfill requirements specified in EISA 2007, which 

amends EPCA to direct DOE to test power consumption of 

EPSs in standby mode and off mode. DOE is proposing 

modifications to the existing test procedure to fulfill 

these directives as it is for battery chargers. Those 

were presented earlier. 

In addition, EISA 2007 amends EPCA to direct 

DOE to conduct a determination analysis for classes of 

external power supplies. DOE is proposing a test 

procedure for EPSs with multiple simultaneous output 

voltages, which are a type of non-Class A EPSs that 

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cannot be tested under the current test procedure. As 

part of that test procedure, DOE has made some 

departures from its current single voltage test 

procedure. So today we will also be presenting some of 

these items which DOE is considering adopting within 

the single voltage EPS test procedure. 

So let me rephrase that and clarify it a 

little bit. EISA requires the Department of Energy to 

conduct a determination analysis to see whether 

standards are warranted for EPSs outside of Class A. 

As part of that group we have multiple-voltage external 

power supplies, which were the ones that the gentleman 

from Microsoft described earlier. 

These EPSs require a new test procedure 

because they cannot be tested under the single voltage 

external power supply test procedure. We are 

presenting that test procedure shortly. Then, some of 

those changes the DOE is considering adopting within 

its single voltage external power supply test 

procedure. 

MR. BROOKMAN: Let's pause for a question. 

Tim. 

MR. CALLAND: Just a quick question. I 

believe Michael mentioned earlier that most of the test 

procedures were derived from Energy Star test 

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procedures, for example the test procedure for single 

voltage output power supplies, which you mentioned. 

Not accidentally, Energy Star has not addressed 

multiple-voltage output power supplies. Therefore, it 

looks like you had to make it up from scratch. Did you 

look into why California and Energy Star have not been 

able to develop an appropriate test procedure for this 

in the past? 

MR. MALINOWSKI: So I'll be getting into that 

a little bit later in this presentation, the origins of 

this multiple-voltage test procedure. But let me just 

say that it wasn't without precedent. We are basing it 

on two Energy Star test procedures, one for external 

power supplies and one for internal power supplies. 

MR. BROOKMAN: Chris. 

MR. CALWELL: Yes. This may or may not be 

the appropriate place to ask, and so if you'd like to 

defer it to later, that would be fine. It looks like 

you're working with the congressional language from 

EISA to try to figure out which other categories might 

be open for DOE consideration. In other words, what's 

left in the EPS world outside of Class A. 

So I see the inclusion of multi-voltage, 

which makes sense. Is there a discussion at all about 

extending it to wattages above 250 watts or to medical 

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products or to any other categories that Congress 

parked in the Class A area and therefore left for 

subsequent consideration? 

MR. MALINOWSKI: So this will be more fully 

addressed in the framework document that will be 

published later this year. However, of those other 

possible categories outside of Class A, we have not 

found ones that cannot be measured using the existing 

test procedure. So as far as this rulemaking, we're 

only dealing with the test procedure for multiplevoltage external power -- 

MR. BROOKMAN: Vic Petrolati. 

MR. PETROLATI: Yeah. Just let me also 

clarify. At this point we're proceeding with a 

determination analysis that includes all products not 

covered under Class A. So that is what our 

determination scope is currently. Which would also 

include the exclusions under Class A. 

MR. CALWELL: Okay. I think I understand. 

So we're really just dealing with the test procedure 

scope as opposed to standard scope here. As long as 

your test procedure could extend to those other 

products, it doesn't need further consideration. 

MR. PETROLATI: Right, right. 

MR. CALWELL: Makes sense. 

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MR. BROOKMAN: Okay. So, Matt, keep going. 

MR. MALINOWSKI: Here's a quick diagram of 

Appendix Z. As you can see, all of the sections of 

Appendix Z -- or, the proposed amendments apply to all 

the subsections of Appendix Z. 

We'll begin with the scope. Because EISA is 

requiring DOE to examine -- or, to test for standby 

mode and off mode energy consumption, DOE is proposing 

to expand the scope such that it covers test 

requirements for all modes of energy consumption. 

 Any questions? 

 (No response.) 

MR. MALINOWSKI: Next, DOE is also proposing 

changes to the definitions. First, of course, 

definitions for standby mode and off mode. However, 

DOE is also proposing -- we are proposing some other 

definitions. 

So, first, EISA provided definitions for 

standby mode and off mode and allowed DOE to amend 

these definitions, taking into consideration IEC 62301 

and 62087. DOE is proposing new definitions which, as 

in the case of battery chargers, resolves some 

ambiguities that are present when applying these EISA 

or IEC definitions to external power supplies with, for 

instance, indicator lights. 

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These definitions, furthermore, explicitly 

address EPSs with on/off switches, as was the case for 

battery chargers. 

So, just a bit of background. EISA 2007 

defines standby mode as the condition in which an 

energy-using product is connected to a main power 

source and offers one or more of the following useroriented or protective functions. This is the same as 

was discussed for battery chargers. 

Off mode, in contrast, is defined as the 

condition in which an energy-using product is connected 

to a main power source but is not providing either an 

active mode or a standby mode function. 

These, again, are unclear in this case. For 

instance, light may be considered a user-oriented 

function. So, two EPSs may be in different modes 

depending on whether or not they have light, an LED 

indicator light, even when they're disconnected from a 

load and connected to mains. 

So DOE is proposing a new definition for 

standby mode that will resolve this issue. The text 

reads, "The condition in which the external power 

supply is in no-load mode, and for external power 

supplies with on/off switches, all switches are turned 

on." 

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No-load is amended -- DOE is proposing to 

amend the no-load definition as well to apply to 

multiple-voltage power supplies. The proposal reads, 

"The mode of operation when an external power supply is 

connected to a main electricity supply and the output 

is (or ‘all outputs are’, for a multiple-voltage 

external power supply) not connected to a load (or 

‘loads’.)" 

Any questions on these definitions? 

MR. BROOKMAN: Larry. 

MR. ALBERT: Yeah. Larry Albert again. Just 

to clarify, for an EPS in general, that is the 

inclusive category that covers both Class A and nonClass A, does that -- just that which is enclosed in 

the single, separate enclosure? And the reason I'm 

asking the question here is, given that definition, 

would standby mode in the case of a cradle connected to 

a wall adaptor, would the disconnection point be 

between the cradle and the wall adaptor or would it be 

at the cradle itself? 

MR. MALINOWSKI: I imagine it would be 

between the wall adaptor and the cradle. However, I'm 

not sure. I don't think DOE has stated conclusively 

where that would be. Vic, do you -- 

MR. PETROLATI: Let's take that one under 

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advisement, Matt. We do not have an answer at this 

point. 

MR. ALBERT: Thank you. 

MR. BROOKMAN: You heard the response? 

MR. ALBERT: Yes. 

MR. BROOKMAN: Okay. Chris. 

MR. CALWELL: I guess I read the two 

definitions but I don't fully understand the 

distinction between them. The first definition 

mentions the presence of an on/off switch and says it 

needs to be turned on. The second definition doesn't 

mention the presence of an on/off switch. So, are you 

distinguishing a separate -- oh, okay. Separate 

condition when switch is turned off shows up on the 

next slide. 

Then the only other question would be, is 

there any chance for confusion here with existing rules 

and requirements? I'm thinking of the state standards, 

the Energy Star specs, the international standards, and 

so forth, who have a no-load power requirement, and 

whether these redefinitions create any potential for 

inconsistency with that. 

I'm not saying they do. I'm asking if 

there's any chance that they would because I don't 

fully understand the distinction yet between the two. 

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MR. MALINOWSKI: Sure. So that is, I think, 

the reason why DOE is moving to keep two separate 

definitions such that all the existing other standards 

and test procedures that refer specifically to no-load 

mode would not be affected and standby mode would draw 

on -- is based on no-load mode. 

MR. CALWELL: So, does that mean, then, that 

if an external power supply has a switch it's not held 

to a no-load requirement? 

MR. MALINOWSKI: No, I think it would be. 

MR. CALWELL: Okay. 

MR. MALINOWSKI: Yeah. The -- 

MR. PETROLATI: That's with the switch on, 

isn't it, Matt? 

MR. MALINOWSKI: Yeah. It would be tested 

with the switch on. 

MR. CALWELL: But it says -- it calls that 

the standby mode, whereas it distinctly calls the next 

one down the no-load mode and there's no reference to a 

switch there. So, see, Vic, part of the curiosity here 

is the first definition, which is called standby, 

references no-load mode. The second definition is 

called no-load mode. 

MR. PETROLATI: Right. 

MR. CALWELL: So you can understand how 

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someone might wonder where to put their product when 

the same wording appears in both definitions. 

MR. BROOKMAN: So, would you recommend any 

specifics on this? 

MR. CALWELL: I would acknowledge bafflement, 

but I don't know if I have a suggestion for you. 

 (Laughter.) 

MR. CALWELL: Honestly, I'm not trying to 

make a legal point or obfuscate here. It's really 

just, if we're not totally sure around this table what 

no-load means, we want to make sure that manufacturers 

would be absolutely sure when they're testing their 

products. That's all. 

MR. PETROLATI: And please provide your 

recommendations in terms of what you think we should 

define each of these. 

MR. BROOKMAN: Okay. Other comments on these 

definitions? Yes, please. Jim. 

MR. HAYNES: Jim Haynes with Uniden. I just 

wanted to bring out another point just for concern. I 

know that we still have the definition of a Class A 

power supply for cordless or for telephones kind of up 

in the air. But also, I just wanted to point out that 

the term "standby mode" as it relates to the products 

such as a cordless telephone, if it's obviously -- if 

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it's not in a no-load you're saying it's in the standby 

mode. There are multiple standby modes. I mean, there 

are multiple different categories, possibly four or 

five different categories, of standby modes. 

I just wanted to bring that to the attention 

of this group because, you know, it's not a black-andwhite situation or an on/off situation. It's various 

degrees of what the loads are that may still be in 

standby. 

MR. BROOKMAN: Thank you. Yes, Wayne. 

MR. MORRIS: Wayne Morris. This is why IEC 

62301 in the latest draft is considering not using that 

terminology as strongly and using a multiplicity of 

low-power modes rather than this situation. Because we 

got into the same thing that Jim is alluding to with 

what does "standby" mean. If you use the old, old 

definition of "standby" being the lowest powerconsuming mode, that didn't fit. I mean, we recognized 

that right away, that that didn't help us through the 

situation of all the different product configurations 

that are out there that could be left in a mode that 

isn't necessarily the lowest power-consuming mode for a 

very extended period of time. 

So we now use this lower power mode, the lowpower modes, as being a better way of looking at this. 

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 The Department may wish to consider that suggestion. 

MR. PETROLATI: Wayne, could I ask; 

generally, I think what you're referring to is standby 

modes for the end use consumer product. 

MR. MORRIS: Yes. 

MR. PETROLATI: We're referring strictly to 

standby mode for the external power supply. Yes, we 

fully understand there can be a lot of different 

standby modes associated with the end use consumer 

product. I don't think we believe that's the case with 

the external power supply. 

We are stuck with the definition of standby 

mode from Congress, which we have taken and revised to 

fit well under what we consider to be the appropriate 

testing for external power supplies. 

MR. BROOKMAN: Larry. 

MR. ALBERT: Larry Albert. I think that 

works as long as the understanding is that the EPS then 

is that single unit and that you couldn't possibly 

interpret EPS to include additional circuitry connected 

to the initial power conversion block. Then it becomes 

just that one unit that does the power conversion. So 

then you can -- it's a lot simpler than looking at what 

could happen when you're talking about additional 

circuitry that might have multiple low-power modes. 

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MR. PETROLATI: Right. And the test 

procedure of course does not test the end use consumer 

product. Okay. But we have heard from Microsoft that 

they would like to see the end use consumer product be 

incorporated into the test procedure in certain 

applications. That might raise some issues as to how 

we define standby and off mode, maybe, in those 

particular applications. 

MR. ALBERT: For multiple output. 

MR. PETROLATI: Right. 

MR. BROOKMAN: Thank you. That was Vic just 

then. Now to Tim Calland. 

MR. CALLAND: Yes. To clarify, we are being 

held to other standards regarding standby power for the 

combination of power supply and the console. So I 

think to put in any additional requirements at the EPS 

level would be redundant and possibly in conflict with 

the other requirements we have to meet. 

MR. BROOKMAN: Thanks. Additional comments 

on these? Chris. 

MR. CALWELL: Yes. I do recall one 

conversation I had with Lloyd earlier in the week, 

Lloyd Harrington, where a possible way to clarify some 

of this maybe for stakeholders internationally would 

be, there's been a debate for a while now about IEC 

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pursuing its own standardized test procedure just for 

external power supplies. 62301 was a preexisting test 

procedure for standby that was meant to apply 

horizontally to all products and got underway long 

before we all started creating test procedures for 

EPSs. 

So I don't know if it's within your purview 

relative to what Congress has asked you to do, but if 

the U.S. and other parties were just to get together 

and do a standard IEC test procedure for EPSs, any 

meaningful definition of "standby" could appear there 

instead of having two different IEC test procedures 

both affect the same products. 

I don't know if that makes sense. Just to 

clarify again, so 62301 is generally intended for 

finished consumer products in their full configuration. 

 So, power supplies plus the devices they're powering. 

 It's a little less applicable to treat just a power 

supply as a component of that product under 62301. It 

would be better to just have an IEC standard test 

procedure for that, to which DOE could provide input. 

MR. BROOKMAN: Okay. Thank you. Okay. Back 

to Matt. 

MR. MALINOWSKI: Moving on. That was the 

definition for standby mode. Now on to off mode. DOE 

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proposes to define off mode as the condition applicable 

only to units with manual on/off switches in which the 

EPS is connected to the main electricity supply, the 

output is not connected to any load, and all switches 

are turned off. And this definition parallels the one 

we presented earlier for battery chargers. 

MR. ALBERT: Larry Albert again. When you 

say the "unit," do you mean the EPS? 

MR. MALINOWSKI: That is correct. 

MR. ALBERT: Okay. 

MR. MALINOWSKI: And DOE does request 

stakeholder comment on this issue. 

MR. BROOKMAN: Should there be any additional 

ones. 

 (No response.) 

MR. MALINOWSKI: So, moving on. DOE also 

proposes to change additional definitions and add some 

new definitions. Modifications to existing definitions 

would promote consistency with the definitions that 

stakeholders currently use. DOE also proposes new 

definitions to clarify undefined and possibly confusing 

terms. I'll go through both of these categories next. 

DOE proposes modifications for consistency 

with IEEE 1515-2000 to the definitions of active mode 

efficiency, THD, and true power factor, and proposes 

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modifications for consistency with EISA, to the 

definition of active mode, and proposes modification to 

the definition of no-load mode to accommodate multiplevoltage external power supplies. 

Furthermore, DOE proposes new definitions to 

clarify the existing definition of true power factor. 

Those would be for active power and apparent power, as 

well as new definitions that would be consistent with 

IEEE Standard 1515 for ambient temperature and unit 

under test. 

Finally, DOE proposes new definitions for 

instantaneous power, nameplate input frequency, input 

voltage, output current, output power, and output 

voltage. These would be consistent with the existing 

Energy Star test procedures. 

So, all of these were terms that were used in 

the test procedure but were not explicitly defined. 

DOE is trying to make sure that there is no confusion 

in the use of these definitions. 

Are there any comments? 

 (No response.) 

MR. MALINOWSKI: Okay. Great. Moving on. 

Finally, as I mentioned earlier, DOE will be proposing 

a test procedure for multiple-voltage EPSs. As part of 

that test procedure, DOE has found it necessary to 

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propose additional definitions. Those would be 

definitions for minimum output current, for multiplevoltage external power supply, as well as for output 

bus. 

DOE is also proposing a definition for a 

special case of a single-voltage external power supply. 

 This would be the switch-selectable single-voltage 

external power supply. DOE has tried to find 

definitions that would make that definition consistent 

with ones used by other programs. 

That concludes the run-down of the 

definitions there. All definitions are listed in the 

notice for your comment. 

MR. BROOKMAN: Chris. 

MR. CALWELL: Could I just ask; what's the 

need for a definition of minimum output current? I 

mean, in the past we've thought of minimum output 

current as being none, zero. So, why define it? What 

do you want to do with it that requires a definition? 

MR. MALINOWSKI: So this will be addressed a 

little later in the presentation. But basically, in 

the case of multiple-voltage EPSs, there are cases 

where the specification of the EPS requires a minimum 

output current on one of the buses for the other buses 

to operate. 

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MR. CALWELL: Okay. So it's like a standby 

rail or a plus-five SB rail, something like that? 

MR. MALINOWSKI: Not necessarily. 

MR. CALWELL: Okay. 

MR. MALINOWSKI: But I guess you can say it 

that way. 

MR. CALWELL: All right. Thanks. 

MR. MALINOWSKI: And I'll proceed next with 

Section 3 of Appendix Z, which is the Test Apparatus 

and General Instructions, where DOE is proposing to 

insert Subsection B to deal specifically with multiplevoltage external power supplies. 

This is a typical setup for testing in 

accordance with the DOE test procedure. As you can 

see, it involves an input power meter, a unit under 

test, and output current and voltage meter, as well as 

the load. 

For testing multiple-voltage external power 

supplies, this setup will be modified to include 

multiple loads, one for each output bus, and multiple 

sets of output meters. 

Yes, that's just a brief overview just to get 

everyone familiar with the setup of the test procedure. 

When deciding on how to frame this test 

procedure, DOE consulted two existing test procedures, 

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one for internal power supplies and one for external 

power supplies. The first one that DOE consulted was 

the IPS test procedure, internal power supply test 

procedure, which has been -- 

MR. CALLAND: Sorry. 

MR. BROOKMAN: Tim Calland. 

MR. CALLAND: Tim Calland, Microsoft. 

Internal power supplies for what kind of product? 

MR. MALINOWSKI: These are typically used for 

personal computers. 

MR. CALLAND: Okay. 

MR. MALINOWSKI: And, yeah, this test 

procedure has been adopted by the 80-plus industry 

standard as well as Energy Star in their, I think, 

latest specification for personal computers. 

This test procedure was used because it 

prescribes methods for safely dividing the output 

current between the different outputs. There are cases 

which we'll present later where it's not possible to 

simply load all the outputs of a multiple-voltage 

external power supply to 100 percent of nameplate. 

MR. CALLAND: Tim Calland again. Are you 

referring to the Tier 1 or Tier 2 requirements of 

Energy Star 4.0? I believe that Tier 2 requires actual 

software exercise and evaluation of test under load. 

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MR. MALINOWSKI: I'm not familiar with Tier 

2. 

MR. CALLAND: Okay. 

MR. CALWELL: This is Chris. I can answer 

that. It's Tier 1. So the 80-plus requirements for 

efficiency and the test procedure to determine them 

were adopted by Energy Star in their version 4.0, Tier 

1 for computers. 

MR. BROOKMAN: Thank you. 

MR. MALINOWSKI: And the second test 

procedure that was used in the drafting of this 

multiple-voltage EPS test procedure was the singlevoltage test procedure which has been adopted by DOE 

and Energy Star. This test procedure contains 

measurement conditions for standby mode as well as 

warm-up times that DOE believes would be more 

applicable in the testing of multiple voltage external 

power supplies. It also forms the basis for various 

international regulations as well as, as I mentioned, 

the EPA Energy Star program for EPSs. 

So the proposed Section 3 for multiplevoltage EPSs largely parallels the existing structure 

of the single-voltage test procedure. However, it 

differs in four significant ways. One is the adoption 

of modified requirements regarding the calibration, 

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uncertainty, and the resolution of measurement 

equipment. 

Second is dropping what DOE felt was kind of 

too restrictive a requirement on the AC source, that it 

be capable of supplying 10 times the nameplate power. 

Third, the requirement that AC source THD be 

less than 3 percent versus the current 2 percent. 

And finally, the requirement that all test 

losses be fully accounted for when performing the test 

procedure. 

As I mentioned earlier, DOE is considering, 

not currently proposing, just considering, adopting 

these same requirements for the single-voltage EPS test 

procedure. 

MR. BROOKMAN: Chris. 

MR. CALWELL: My only suggestion here would 

be to confer with the EPRI staff that developed the 

original test procedure. I was more of a secondary 

participant in that, but EPRI led the effort. I know 

they had gotten comments from manufacturers as they 

went through this. This second provision about 10 

times the nameplate output power, I agree; when you 

look at it, it seems onerous. But there was a desire 

for the robustness or the stiffness of the source so it 

wouldn't be influenced by the test. 

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Just a variety of things that EPRI engineers 

could comment on or perhaps even unearth the comments 

they got from industry that suggested why those were 

there. It might save you the time of getting the 

comments again from industry who offered it originally. 

MR. BROOKMAN: Thank you. 

MR. MALINOWSKI: Thank you. And I'll go 

through each one of these proposed departures from the 

single-voltage test procedure in turn. The following 

set of slides is organized with the current singlevoltage language on the left and the proposed multiplevoltage language on the right. 

The first set deals with calibration 

requirements. Standard practice is to periodically 

calibrate equipment to traceable standards. The 

modification includes an explicit reference to existing 

calibration standards. So on the left you can see the 

current single voltage EPS test procedure just requires 

that equipment be suitably calibrated, versus the 

proposed multiple-voltage test procedure actually 

specifies which standards that equipment should be 

calibrated in accordance with, as well as that the 

equipment be within its calibration period. 

MR. BROOKMAN: Larry. 

MR. ALBERT: Larry. Interestingly, you 

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invoke ISO 17025 with respect to equipment calibration. 

 But that standard covers a fairly broad range of 

laboratory practices to ensure that you get 

satisfactory results. Are you suggesting that perhaps 

17025 should be invoked in the entire standard as a 

requirement for the processes that are used during all 

the measurements? 

MR. MALINOWSKI: The proposal is fairly 

limited. It just specifically refers to the 

calibration of equipment. 

MR. ALBERT: Okay. Thank you. 

MR. MALINOWSKI: I'm sorry, Larry. Were you 

suggesting that the proposal be expanded to refer to 

17025? 

MR. ALBERT: Just a question as to -- 17025, 

for example, you need to ensure that laboratory 

personnel are trained in the operation of the test 

equipment, right, which is -- so it's not just the 

calibration procedure but it extends to other 

laboratory practices. I was wondering whether the 

Department was considering the broader referencing of 

17025. 

MR. MALINOWSKI: Not currently. 

MR. CALLAND: Tim Calland, Microsoft. There 

are a lot of other requirements in 17025 that would be 

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far more than is needed to prove this. So I hope you 

don't go down that path. 

MR. MALINOWSKI: Next would be a slight 

amendment to the uncertainty requirement. Uncertainty 

is, of course, the errors that accumulate from all the 

different steps of the measurement process. The 

proposed language includes a confidence level for the 

uncertainty requirement, something that was absent from 

the single-voltage EPS test procedure but is present in 

the multiple-voltage IPS test procedure. This would 

make the test procedure consistent with IEC 62301 and 

the IPS test procedure in this regard. 

 Any comments? 

 (No response.) 

MR. MALINOWSKI: Next would be a resolution 

requirement. Resolution is the ability of measurement 

equipment to reflect the smallest change in the 

quantity being measured. It can both be limited by the 

measurement resolution as well as the display 

resolution of the equipment. 

The current single-voltage EPS test procedure 

requires measurement instruments to have a resolution 

of 0.01 watts or better for active power. The proposed 

language is based around a tiered approach, whereby the 

resolution requirements becomes successively less 

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stringent at higher output powers just because of the 

difficulty of maintaining a 0.01 watt resolution at 

output powers greater than 100 watts. 

Again, this proposed resolution requirement 

is consistent with the internal power supply test 

procedure as well as IEC 62301. 

The next proposal refers to the AC source 

requirements. This is the one that Chris referred to 

earlier. And the existing requirement requires that 

the source be capable of delivering at least 10 times 

the nameplate input power of the unit -- output power 

of the unit under test. The proposed language 

maintains that as a suggestion, similar to IEEE 

Standard 1515, which also just recommends that. 

However, the proposal does maintain a plus or minus 1 

percent requirement on the AC source voltage. 

So keep the performance-based requirement of 

plus or minus 1 percent and just maintain the 10 times 

output power as a guideline. 

MR. BROOKMAN: Gary. 

MR. FERNSTROM: Gary Fernstrom, PG&E. There 

might technically be a slight difference here depending 

upon how you measure the input voltage and maintain it, 

plus or minus 1 percent. Since many of these loads are 

nonlinear, you'd have to maintain the voltage on an 

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instantaneous basis plus or minus 1 percent, not 

average? 

MR. ALBERT: Larry. My assumption is what 

they're talking about is the RMS value of the voltage. 

 The question in my mind is, is it the measurement of 

the RMS value of the voltage prior to the beginning of 

the test. Because if it's at any point in time, then 

you're really saying over line and load conditions and 

not just over line conditions, right. 

I think the original requirement of plus or 

minus 1 percent was for the UUT power supply 

independent of the connection to the product being -- 

the UUT being measured, right, which is just a line 

variation type requirement. 

MR. FERNSTROM: What I want to make sure is 

that we don't get harmonic distortion in the voltage. 

That is that supply is stiff enough so that you're not 

seeing little instantaneous voltage dips. 

MR. ALBERT: That would probably be addressed 

-- I'm sorry. Larry Albert. That would probably be 

addressed by the THD requirement that's also there, 

providing that THD requirement is understood to be 

present under load conditions. What was the -- that's 

the next set of slides, I guess. 

MR. MALINOWSKI: That's right. 

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MR. ALBERT: Matt, was that your intention, 

that they would be as connected to the UUT -- the THD 

requirement or -- 

MR. MALINOWSKI: Yes. 

MR. ALBERT: -- the THD requirement of the 

source prior to connection to the load? 

MR. MALINOWSKI: That would be under load, 

which I think is also as specified in the existing 

single-voltage test procedure. 

MR. ALBERT: All right. So, Gary, that would 

address that, I think. 

MR. FERNSTROM: Thank you. 

MR. BROOKMAN: Thank you, Gary. Thank you, 

Larry. Some fairly -- quite a bit of detailed bits of 

discussion. I want to make sure we're not going too 

fast. We don't want to lose anybody in this. So speak 

up. It's getting on towards lunch, also. We may be 

fading slightly. 

 Yes, please. 

MR. HABBEN: Rick Habben. I just have a 

general question. The language that's proposed for the 

multiple-voltage EPSs, is that language also going to 

go back and be applied to the single-voltage EPSs or 

are they going to be two different requirements? 

MR. MALINOWSKI: So, currently DOE is 

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proposing this language but also considering it for 

inclusion in the single-voltage test procedure, 

depending on stakeholder comments. So either is a 

possibility at this point: maintaining separate test 

apparatus requirements for multiple-voltage and singlevoltage or making them consistent, depending on how 

stakeholders weigh in. 

MR. BROOKMAN: Tim. 

MR. CALLAND: Don’t differentiate between 

single-voltage output and dual-voltage output in this 

context. This is just good test practice. So if it's 

applied to one, it should be applied to the other. 

MR. BROOKMAN: Do you wish to weigh in again? 

MR. PETROLATI: No. 

MR. BROOKMAN: Okay. 

MR. PETROLATI: Anybody else have comments on 

that issue? 

MR. BROOKMAN: Thank you. Vic. 

MR. PETROLATI: One of our concerns, 

obviously, that we incorporated into the NOPR was the 

fact that if we changed the single-voltage EPS test 

procedure it would not be harmonized with some of the 

other countries that are using that EPS voltage test 

procedure. 

MR. BROOKMAN: Chris. 

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MR. CALWELL: Vic, thanks for prompting a 

comment. This is similar to an issue that I had raised 

in some earlier remarks I sent to DOE. I don't know if 

these changes affect the measured values. I do know 

that there's a very carefully arrived at roman numeral 

labeling system to allow power supplies tested in one 

country to be treated as having achieved a certain 

efficiency in others. 

So I just wanted to suggest that either DOE 

publish some testing showing that these changes don't 

affect the measured efficiency values and therefore it 

is consistent with existing labeling methodologies, or 

consider trying to make these sorts of changes through 

the IEC process I mentioned earlier so that when they 

take effect they would be simultaneously adopted by all 

the IEC subscribing countries rather than arriving at a 

situation where you might be measuring something in a 

meaningfully different way than your fellow trading 

partners are. 

MR. CALLAND: This is Tim Calland. The term 

"IEC-adopting countries" is not exactly correct. IEC 

standards -- in some cases the same standards may be 

adopted by some countries. However, there are many 

subscribers to IEC standards, many different countries 

who pick and choose which standards and which editions 

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of standards they choose to use. 

So I think that ultimately we can't refer to 

an IEC document unless we tie it down by revision 

number and edition number. We will need to -- any time 

that document changes, we'll need to go through this 

process again. 

MR. BROOKMAN: Larry. 

MR. ALBERT: Just to clarify, this is only -- 

this would only be an issue if through the Department's 

determination analysis they come to the conclusion that 

multiple-output EPSs are worthy of regulation because 

higher-power EPSs could be handled by -- above 250 

watts could be handled by the single-voltage output EPS 

test method that's already available. That's correct? 

 Or has it already been determined that multiple-output 

-- 

MR. BROOKMAN: Vic Petrolati. 

MR. PETROLATI: Larry, my confusion probably, 

but we're still on the issue of making changes to the 

single-voltage EPS and whether or not making those 

changes would cause problems with harmonization. 

One of the things we also are considering if 

we do make changes to the single-voltage EPS to 

incorporate some of these same changes here that are 

being discussed for the multi-voltage, is to phase in 

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that test procedure, possibly with an effective date of 

the test procedure that coincides with the effective 

date either of the standards or the issuance of the 

standards, such that we don't have a harmonization 

issue up until 2011 or 2013, which would also allow 

countries to consider adopting our test procedure as 

well. 

But we are very interested in getting 

stakeholder comment on making any changes to the 

single-voltage EPS test procedure and how we should do 

that. 

MR. BROOKMAN: Chris. 

MR. CALWELL: I guess I would just say I 

think the phase-in idea sounds like a promising one. 

It might allow people -- what you're really up against, 

I think, is you've got a set of people who now know 

they have to meet a federally prescribed test procedure 

and standard that the government put into EISA. Trying 

to make a change midstream on them could throw them 

off, whereas if you know you're going to have a new 

standards adoption date a few years from now phasing in 

this change to the test procedure to take effect then, 

it could also give you time to make your case before 

IEC to make the same changes you're making. 

MR. BROOKMAN: Thank you. 

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MR. MALINOWSKI: Let me continue. The next 

proposed change in the requirements deals with THD. 

That stands for total harmonic distortion, which is a 

measure of the deviation of the AC source voltage wave 

form from an ideal sine wave. 

Currently, the single-voltage test procedure 

requires that the THD of the supply voltage not exceed 

2 percent, up to and including the 13th harmonic. DOE 

is proposing that that requirement be loosened such 

that it does not exceed 3 percent, up to and including 

the 13th harmonic, mainly to alleviate some of the 

burdens on the testing laboratories of maintaining a 2 

percent THD. 

The final requirement deals with test lead 

loss measurements. The test leads are cables that are 

connected to the units under test during measurement. 

They do have some losses and may slightly change the 

test results. So DOE is proposing to require that 

these losses, the voltage drops across the test leads, 

be added or subtracted from the input and output 

voltage measurements just for a full accounting of any 

losses present in the test apparatus. 

Again, DOE doesn't believe that that will 

significantly add to the testing burden because 

laboratories do routinely perform these measurements. 

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The goal here is to be explicit. 

MR. BROOKMAN: Gary. 

MR. FERNSTROM: Gary Fernstrom. So you're 

talking about here the test leads, not the leads 

associated with the equipment under test itself; is 

that correct? 

MR. MALINOWSKI: That is correct. 

MR. FERNSTROM: Thank you. 

MR. BROOKMAN: Thank you. 

MR. CALLAND: So, to clarify. Tim Calland, 

Microsoft. The measurements would be done at the 

termination of the test leads of the equipment under 

test? I'm sorry. The termination of the integral cord 

associated with the equipment under test? 

MR. MALINOWSKI: That is correct. 

MR. CALLAND: Okay. 

MR. MALINOWSKI: Similar to the singlevoltage EPS test procedure. The NOPR, again, is -- 

describes this in detail. 

MR. BROOKMAN: Please say your name. 

DR. MADIGAN: Michael Madigan, Texas 

Instruments. Could you please clarify exactly where in 

the test setup -- if you could bring the slide up that 

had the picture of it? -- where that would be measured. 

 Is it -- specifically, which side of the watt meter, 

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the power meter? 

Because the power meter requires a resistive 

shunt. When you have a system that doesn't have power 

factor correction there's a big difference between the 

harmonics that are measured on one side of that shunt 

and the other. The shunt tolerance is specified but 

the shunt impedance is not. In some cases I've used a 

shunt of 10 ohms, which is terribly large, and I've 

gotten completely different power measurements for noload power than using a shunt that was one-tenth of an 

ohm. 

So, are there any specifications somewhere in 

that signal -- the power train, in that part of the 

power train that spell out the shunt? 

MR. MALINOWSKI: I would imagine the -- I'll 

have to look through it again. But if you wouldn't 

mind actually raising -- elaborating on that concern in 

a written comment, that would be very helpful. 

DR. MADIGAN: Okay. 

MR. BROOKMAN: Can you point to it? Can you 

point to the location? 

MR. MALINOWSKI: I think we're talking about 

the power meter itself. 

DR. MADIGAN: Yes. 

MR. MALINOWSKI: And the drop across the 

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power meter. 

MR. BROOKMAN: So, those comments in writing 

would be helpful. Please. Larry. 

MR. ALBERT: Larry Albert. Expanding on the 

gentleman from TI's comments, this would also apply, I 

guess, to the measurements of THD and also tolerance, 

right, because the THD measurement can be different 

before or after the watt meter, depending upon the 

internal shunt impedance. 

MR. FERNSTROM: So this is Gary Fernstrom. 

Common practice is to measure the voltage on the load 

side of the shunt and the current through the shunt, 

right? 

MR. BROOKMAN: Larry? 

MR. ALBERT: Yes. The question here is with 

respect to the source, right, and what the requirements 

are for the source and whether the THD is measured when 

the UUT is connected or not and under load conditions, 

right. 

To your earlier point about how do you 

normalize the measurements with changing source 

impedances on the AC source, right, by controlling THD 

at the UUT under the load conditions you could do that. 

 However, if you're measuring on the wrong side of the 

watt meter, then you might get erroneous results. That 

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would also apply, of course, with source tolerance as 

well. 

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MR. FERNSTROM: Thanks. I understand the 

question. 

MR. BROOKMAN: Thank you. Thanks to both of 

you. Other comments on this before we move to close to 

the final slide? Yes, please. Michael. 

MR. VLADIMER: Hi. This is Michael Vladimer 

from Navigant. 

MR. BROOKMAN: Is it on? 

MR. VLADIMER: I think so. To the gentleman 

from Texas Instruments, could you just briefly 

elaborate a little bit further? If you look at the 

picture you could see that there's an external power 

supply. Its cable is black, and then there's a 

connector going to a black and a red output cable, and 

pretty much the same thing on the input side as well, 

which you can't see. 

So, how would you propose addressing -- like, 

because I would expect to measure it at exactly that 

output and exactly that input. 

DR. MADIGAN: The AC source -- well, it can 

be either viewed at the transformer that's -- the 

output voltage adjustor, actually. The input voltage 

adjustor. Or on the other side of the watt meter. 

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The watt meter actually measures voltage but 

it also measures current. So, really, the voltage 

that's being applied to the adaptor itself is looking 

at the impedance of the watt meter in series with the 

other elements in the test setup. So there's sort of a 

total impedance, if you will, that will affect the 

performance, the modes, and efficiency of the adaptor. 

 Are there any limitations on it? We're specifically 

addressing things like the cables, but this seems to be 

one element that may have slipped our attention. 

MR. BROOKMAN: Okay. Thank you. So those 

written comments. 

MR. PETROLATI: Yeah. 

 (Laughter.) 

MR. BROOKMAN: Okay. Then let's move on. 

MR. MALINOWSKI: Here's a brief summary of 

the different proposed requirements that I just went 

through, as well as DOE's estimated impacts of adopting 

these requirements versus what is currently in the 

single-voltage EPS test procedure. 

Again, DOE is requesting comment on all of 

these proposed changes to the requirements. 

MR. BROOKMAN: Do you want to go back to the 

previous slide? Just leave it there for a moment. 

So this is a summary slide. Additional 

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comments, questions, clarifications on this whole bunch 

of definitional proposals, changes, and the like? Yes, 

Chris. 

MR. CALWELL: Chris Calwell from ECOS. Just 

one question that reflects the fact that we have a lab 

technician that makes these measurements and it's not 

me. So I may just not understand something here. In 

your visual that in effect leads to this summary slide 

-- there you go. So you're showing an isolation 

transformer and then an input voltage adjustor. It 

looks like that's what I as a layperson would call a 

manual voltage adjustor, meaning that you're dialing it 

to the level that you want but that, as Gary mentioned 

before, as you conduct your test you could be 

influencing that voltage by loading the system. 

We have a reference voltage source in our 

lab, and I know EPRI uses something similar, sometimes 

a very large UPS, that will automatically hold you at 

that voltage regardless of how you load the device. 

So it seems as if those two setups might have 

different levels of precision or assured voltage 

stability. I guess thus my concern -- when we had 

drafted the EPS single-voltage test procedure and when 

EPRI had drafted the multi-voltage, they were working 

largely under IEEE's guidance and manufacturer comments 

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that they wanted that degree of certainty, 

repeatability, and automatic voltage stability. I just 

wonder if this is too much of a shortcut when you 

consider the caliber of the labs that are likely to be 

involved and the fact that automatic -- I'm sorry, that 

reference voltage sources, I think, are routine in 

those labs. 

So that would be my comment. Even though I 

clearly acknowledge that you're going to save money in 

the lab, I don't know if it actually cuts the cost of 

the testing much since reference voltage sources are 

the integral front end of every test we do in our lab 

for every purpose for every test procedure. The bottom 

line: we use them all the time. 

MR. BROOKMAN: Thank you. Tim. 

MR. CALLAND: Real quick. What this really 

talks to is tolerance and how close you are. The 

concerns that we're discussing right here will depend 

on whether I want to take advantage of the 1 percent 

error built into the system or not. If I have 

something that clearly complies I don't have an issue. 

 Otherwise, I might have to send it out to an outside 

lab to get a second opinion. 

MR. BROOKMAN: Wayne. 

MR. MORRIS: Wayne Morris. I understand and 

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appreciate the interest in trying to get at the most 

accurate measurements, but I also don't want to start 

taking this into the realm of where we have to hire 

laboratories that charge increasingly huge amounts of 

money to have this done and where it takes it out of 

the hands of a manufacturer with a suitable laboratory 

facility and abilities to be able to produce these 

results within the tolerance range, within the 

stiffness range, and within the repeatability range 

that we're looking for. 

So while I perfectly understand the interest 

in this, I'd suggest to us that we watch very carefully 

that we aren't pursuing perfection to the extent that 

we are eliminating the ability of many manufacturers to 

do this on a cost-efficient basis. 

MR. BROOKMAN: Yes. Gary. 

MR. FERNSTROM: Gary, PG&E. When I do these 

measurements I use a precision voltage supply that 

maintains 115 volts to one-tenth of a percent pretty 

much instantaneously. I think what Chris Calwell was 

reacting to was the presence of what I would call a 

variac in this picture, which is the variable voltage 

transformer. 

As the utility mains voltage varies, it's 

usually impossible to maintain even 1 percent precision 

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throughout a measurement period. So the whole notion 

of having a laboratory grade constant voltage supply is 

important here, so we should collectively look into 

this to make sure we're not giving up too much. 

MR. BROOKMAN: Okay. So that also would be 

welcome in your comments. Tim. 

MR. CALLAND: Just one last, I hope last, 

real small comment, which is that I think the precision 

we're pursuing right now is fine for type testing, but 

the kind of variation we're going to see in normal 

manufacturing practices is going to exceed this. So I 

may have a sample somewhere that passes with this kind 

of precision, but if I cut it this close a certain 

percentage of what I manufacture is going to be out of 

tolerance. 

MR. BROOKMAN: How would you suggest the 

Department should address that? 

MR. CALLAND: My only suggestion is perhaps 

worrying too much about this resolution, getting it 

this tight when actual manufacturing variation is 

probably on the order of 10 times greater than what 

we're measuring. 

MR. BROOKMAN: Okay. So I would call your 

attention once again -- Gary, go ahead. 

MR. FERNSTROM: Well, this issue comes up in 

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all standards with air conditioners, refrigerators, and 

so on. The performance is measured in the laboratory 

and then manufacturers certify that production off the 

line meets those requirements. 

So it does us no good to test a sample and 

find that it complies and then find that due to normal 

manufacturing tolerances a third or a half of the 

product off the line doesn't comply. This is a 

standard. All the product off the line should comply. 

 If I go buy a sample and test it in my lab using 

precision equipment, I would expect it would comply. 

MR. BROOKMAN: Okay. So once again, I'd like 

to refer you to Slide 90, the summary slide, and ask 

you to survey this one more time and make final 

comments on these if you wish. Yes, Larry. 

MR. ALBERT: Just to follow onto what Gary 

was asking about, with respect to what's on Slide 81, 

which refers to the uncertainty limits, doesn't this 

imply that you're establishing a sampling level for 

measurements and then that would mean that any 

consequent referee measurements or field surveillance 

or something would be done with a similar sample size 

to achieve the same competence limits? What was your 

intention there, Matt? 

MR. MALINOWSKI: So the intention there is to 

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specify the accuracy of the test equipment. I won't 

bother going back to the slide here, but this would be 

-- most test equipment comes with accuracy 

specifications. That accuracy, assuming a normal 

distribution of errors in the equipment, it's 

unbounded. So we're trying to bound that such that 95 

percent of the time that equipment will be accurate to 

2 percent. 

MR. ALBERT: I'm sorry. I must have 

misinterpreted that. You're talking about the 

measurement itself rather than the -- 

MR. MALINOWSKI: Right. But I guess the -- 

as I understand, there are two ways to describe the 

error in the measurement. One is to perform lots of 

measurements and the other is to take the equipment and 

add together the errors from each piece of equipment to 

come up with an estimate of the total error. So that's 

how that was -- that's what that was intended to do. 

I don't think DOE expects manufacturers to 

perform multiple tests on a single UUT to discern what 

the error would be. 

MR. ALBERT: -- 5 percent of the population 

of manufacturers' products may be noncompliant? 

MR. MALINOWSKI: No, I don't think so. I 

think what it implies is that it's possible that even 

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though the equipment -- 95 percent of the time the 

equipment is accurate to within 2 percent, 5 percent of 

the time it may not be accurate to within 2 percent. 

It might be accurate to within 2.1 percent, and so on. 

MR. ALBERT: It's an equipment competence 

limit, not a measurement competency. 

MR. MALINOWSKI: That's right. 

MR. BROOKMAN: Thank you. Thanks for that 

interpretation. 

Final comments at this point? 

 (No response.) 

MR. BROOKMAN: Okay. So then I'm going to 

suggest we go to lunch. I call your attention to one 

thing on the agenda. I don't think I covered this at 

the outset this morning. At the end of the day today, 

round about 2:45, 3 o'clock or so, there's yet another 

opportunity for any of you to raise additional issues 

that you wish to raise, or reaffirm points, or clarify 

things that went forward. 

So if you found that this period of 

concentrated stuff was -- if you find that you wish to 

comment further on it, that would be an opportunity for 

you to do that. 

It's now 12:25. I'm going to suggest we take 

an hour for lunch. Please wear your badges inside the 

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building. For those of you that have not been here 

before, there's a full-service cafeteria down one floor 

and all the way underneath the street. There will be a 

whole herd of people heading in that direction. 

 (Laughter.) 

MR. BROOKMAN: I suggest you stay with the 

flow. 

We will be locking this room, so you can 

leave your materials in here. We will reopen it at 

1:20. At 1:20 we'll reopen it. We'll resume at 1:25. 

 Please don't go off the premises. Don't go outside or 

you'll have to reenter through security, I think. 

That's all I can recall. There are 

bathrooms, once again, on both sides of each corridor. 

 Vic? 

MR. PETROLATI: Yeah. One other thing. We 

have, I think, two foreign nationals here. Do we have 

any foreign nationals here in the audience? I need to 

talk to you about -- we had problems with the cafeteria 

before, so if I could see you before we head off to 

lunch down in back of the room. 

MR. BROOKMAN: Enjoy your lunch. We'll 

resume at 1:25. 

(Whereupon, at 12:26 p.m., the meeting was 

adjourned for lunch, to reconvene at 1:30 p.m.) 

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A F T E R N O O N S E S S I O N 

1:30 p.m. 

MR. BROOKMAN: I'm glad you all could find 

your way back. That's the first step. 

Second, Brenda reminds me that the Department 

will supply a photocopy compilation of everybody's 

business cards. They will have that for you by the end 

of the day. 

Any other items that we should -- yes, yes. 

I'll take care of that. 

MR. PETROLATI: Transcripts. 

MR. BROOKMAN: Oh, transcripts. Is the best 

way to do transcripts simply to speak to Green 

directly? 

MR. PETROLATI: No. Transcripts will be 

posted on our website at some future point in time. 

PARTICIPANT: Hopefully before October 29th. 

MR. PETROLATI: That I can't guarantee. 

PARTICIPANT: Are these presentations also 

available on the website? 

MR. PETROLATI: They are now, yeah. 

MR. BROOKMAN: Any other questions here at 

the outset that relate to these housekeeping and other 

logistical kinds of issues? 

 (No response.) 

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MR. BROOKMAN: Okay. Then, do you want to 

say anything at the outset before we turn it back to 

Matt? 

MR. PETROLATI: Let's get going. 

MR. BROOKMAN: Okay. Matt. 

External Power Supply Test Procedure: Test Apparatus 

and General Instructions 

Mateusz Malinowski 

 (PowerPoint presentation.) 

MR. MALINOWSKI: Welcome back. I hope you 

had a nice lunch. Let me continue with the Test 

Apparatus and General Instructions section, which is 

Section 3 of Appendix Z to Subpart B of 10 CFR 430. 

Before the break I talked about the proposed 

changes to Section 3 which address multiple-voltage 

external power supplies. During the discussion we went 

over some changes to the requirements on the AC source, 

the equipment resolution and uncertainty, as well as 

test lead measurements, or I should say test lead loss 

measurements. These the Department is proposing for 

adoption for the multiple-voltage EPS test procedure. 

DOE is also considering adopting these for 

the single-voltage EPS test procedure but does not 

necessarily intend to implement them without 

stakeholder comment. We touched upon that briefly 

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before the break, and I'll go into a little bit more 

depth on that right now. 

Again, the two terms are "propose," which is 

what is in the notice, what is currently in the rule 

language of the notice, versus "consider," which is 

left a little bit more open and is DOE's -- they're 

waiting for stakeholder comments on that. 

So DOE is considering changes to the singlevoltage test procedure in the Test Apparatus and 

General Instructions Section. These changes would be 

similar to the proposed changes for the multiplevoltage EPS test procedure. 

Again, just to refresh, there was the three 

tiered measurement resolution requirement. Then there 

was the AC source requirement, the THD requirement, and 

the test lead losses. 

The issue that was highlighted earlier is 

that this would make the single voltage -- adopting the 

changes would make the single-voltage EPS test 

procedure no longer harmonize with the test procedure 

used by Energy Star as well as international 

jurisdictions. However, DOE does believe that 

incorporating these changes would improve a lot of the 

accuracy and repeatability of measurement as well as 

easing the manufacturer burden. 

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The Department does request your comment on 

this issue. 

MR. BROOKMAN: Please. Is it Robin? 

MS. CLARK: Yes, it's Robin. Robin Clark 

with ICF International. We provide consulting support 

to EPA on Energy Star. I just wanted to offer one 

suggestion with regards to the international 

harmonization comment. It is important to EPA. This 

test procedure, though, has been in existence for a 

while and they certainly understand that over time it 

may need some modifications and adjustments. 

I wanted to suggest that there are some 

international stakeholders who will be in Washington, 

D.C., in late October, I think the week of October 

20th, for APP and IEA meetings. That includes 

representatives from the Australian government, who 

also use this test procedure for external power 

supplies. 

I just wanted to suggest that through EPA we 

could potentially help to organize a meeting or a brief 

call with Vic, DOE, to just sort of talk through these 

issues, make sure they're aware of them, and figure out 

how we're going to continue to be, hopefully, 

internationally harmonized and still work through these 

adjustments and improvements. 

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MR. PETROLATI: Robin, thank you. We'll take 

you up on that offer. Thank you. 

MS. CLARK: Thank you. 

External Power Supply Test Procedure: Test Measurement 

Single-Voltage EPSs 

Mateusz Malinowski 

 (PowerPoint presentation.) 

MR. MALINOWSKI: Continuing on, we're moving 

to Section 4 of Appendix Z, which deals with Test 

Measurement. This is the heart of the test procedure, 

the instructions for how to conduct the test procedure. 

 We'll proceed with the single-voltage EPS test 

procedure. 

The single-voltage test procedure is the one 

that you're all familiar with that was adopted by 

Energy Star. The modifications that DOE is proposing 

would deal with incorporating measurements of standby 

mode and off mode in addition to the existing test 

procedure. Again, just to refresh, the definition for 

standby mode requires that tests be conducted with any 

manual on/off switches set to "on" versus "off." The 

measurement of off mode will be conducted with those 

switches turned to "off." 

Again, the Department welcomes comments on 

this proposal. 

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 (No response.) 

MR. MALINOWSKI: Continuing, in terms of the 

measurement requirements, just to refresh, the current 

single-voltage test procedure measures efficiency at 

25, 50, 75, and 100 percent of nameplate output current 

and does not address multiple-voltage EPSs. 

One of the things that DOE is considering in 

addition to the test apparatus changes that are up for 

consideration, DOE is also considering an improved 

stability requirement for the single voltage test 

procedure. Currently, the stability requirement reads 

that over a period of five minutes if the power level 

does not drift by more than 5 percent from the maximum 

value observed, the UUT -- unit under test -- can be 

considered stable. 

DOE is considering an alternate stability 

requirement. The power level does not drift by more 

than 1 percent. DOE does recognize that that may not 

always be achievable, in which case an alternate 

measurement method involving average power as specified 

in IEC 62301 is under consideration. 

Here's just a quick illustration of what that 

would look like. 

DOE does hope that this would result in more 

repeatable and accurate test results, as well as, 

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again, providing an out in case that stability cannot 

be reached. 

MR. BROOKMAN: Go, please, right ahead. And 

then Gary. Gary, let's let this gentleman go first. 

DR. MADIGAN: I want to ask a question -- 

MR. BROOKMAN: Say your name again. 

DR. MADIGAN: -- maybe you could clarify. 

Michael Madigan. 

MR. BROOKMAN: Thank you. 

DR. MADIGAN: Do you mean to actually average 

-- the alternative is to average over the full five 

minutes? 

MR. MALINOWSKI: Yes, that would be correct. 

DR. MADIGAN: Okay. 

MR. MALINOWSKI: So it would either be an 

instantaneous measurement, if the device is stable, or 

an average measurement over five minutes if it is not 

stable. 

DR. MADIGAN: Okay. 

MR. BROOKMAN: Gary. 

MR. FERNSTROM: Okay. So, Gary Fernstrom. 

We're talking about the power supply output voltage 

here? 

MR. MALINOWSKI: This would be for all the 

power measurements. This would be both input and 

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output power. 

MR. FERNSTROM: Okay. 

MR. BROOKMAN: Please. 

MR. HABBEN: Rick Habben. I just have -- 

MR. BROOKMAN: That's not on. 

MR. HABBEN: I just have a question. Can you 

give the background and rationale why you're going from 

-- wanting to go from five to one? 

MR. MALINOWSKI: I believe we used -- I think 

-- let me just double-check. If I'm correct, I think 

that was based on the internal power supply test 

procedure, which uses a similar stability requirement. 

 I'm not sure -- the notice goes into more detail on 

that. I can't recall specifically what the precedent 

was. We felt that given that the uncertainty of 

measurement is specified at 2 percent, a 5 percent 

swing in the power measurement seems a little excessive 

in this case. 

DR. MADIGAN: Michael Madigan. Is that the 

section of the IEC standard that calls for five minutes 

or 200 sampling cycles, the longer -- does that include 

the sampling cycles? 

MR. MALINOWSKI: Not as currently -- 

DR. MADIGAN: Not currently. Okay. 

MR. MALINOWSKI: Not as currently proposed. 

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DR. MADIGAN: Okay. 

MR. MALINOWSKI: Or, not as currently written 

in the notice. 

So, continuing. A further change to the 

single-voltage EPS test procedure, this time that DOE 

is proposing, would be to allow for the testing of 

switch-selectable external power supplies. These are 

single-voltage units -- rather, they can provide only 

one output voltage at a time. However, what that 

output voltage is, is controllable by the user. So 

these would be replacement adaptors that one could buy 

after-market that would work with a host of other 

products. 

Here, for example, there's an illustration of 

one with the voltage selector switch clearly marked. 

To test these, DOE is proposing that their 

efficiency be measured both at the maximum and minimum 

voltage settings, which will bound all the possible 

efficiencies of the power supply. This proposal is 

consistent with the way these types of units are tested 

in Australia and New Zealand as well as under the 

Energy Star program here. 

In addition, DOE is proposing that these be 

tested in standby mode and off mode and, again, the 

test setup would be consistent with the single-voltage 

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EPS test procedure, i.e., standby mode would be tested 

with the on/off switch set to "on," off mode with the 

on/off switch set to "off." However, these units would 

again be tested twice, once at the highest voltage 

setting, once at the lowest. 

DOE invites stakeholder comment on these 

proposed changes to the single-voltage external power 

supply test procedure, specifically as it applies to 

switch-selectable single-voltage EPSs. 

 (No response.) 

MR. MALINOWSKI: Thank you. And another 

issue that came up in the drafting of the multiplevoltage EPS test procedure is that some units may not 

have all the nameplate -- all the information necessary 

for the conduction of the test procedure specified on 

the unit itself. 

This is particularly an issue with high-power 

external power supplies such as those used for, for 

example, ham radio applications, where the units are 

slightly different from what we've been seeing so far. 

 They can be in metal enclosures, and the nameplates 

for those units may not list all the data available or 

all the data about the device. 

MR. BROOKMAN: Tim. 

MR. CALLAND: I just wanted to say that you 

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will often find -- or another situation where you won't 

actually find nameplate ratings are for dedicated use 

power supplies. For example, Underwriters Laboratories 

will forego ratings if there is a hard -- a nondetachable cable between the two or if there are 

markings on the power supply and on the end-use product 

specifying: for use with this and for use with that. 

You don't need to put a nameplate. This is just yet 

another little plug that dedicated power supplies are 

often treated differently than general purpose power 

supplies. 

MR. MALINOWSKI: Is there another source for 

those ratings? Is there another way to obtain them in 

order to conduct -- 

MR. CALLAND: Well, the combination of the 

two, the system would have a rating on it instead. 

MR. BROOKMAN: Larry. 

MR. ALBERT: Just a point of clarification. 

Larry Albert. The UL 1310 covers only Class 2 power 

supplies and only for a certain subset of applications. 

 Considering that there is no voltage limit in the 

description of low voltage output for EPSs and since 

that could include voltages that exceed the Class 2 

limits, as was the case that was brought up by the 

gentleman from Conair earlier, you probably don't want 

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to provide any specific standard reference to UL 1310. 

Since you're also including power supplies 

that could be powering laboratory equipment or other 

applications like that, or IT equipment, which might be 

covered under 60950, or many other standards out there 

where one could -- you could get a safety approval on 

an external power supply other than 1310, that might 

have different marking requirements. 

MR. BROOKMAN: Okay. Chris. 

MR. CALWELL: Yeah. Chris Calwell from ECOS. 

 It seems like if you're asking for comment on what 

might be done to rectify the problem, one option would 

be for DOE to require that these four pieces of 

information be on the nameplate of external power 

supplies. Then it's not a UL safety issue, it's 

product labeling for purposes of efficiency standards 

compliance labeling question. 

MR. BROOKMAN: Yes, Wayne. 

MR. MORRIS: There's a fairly large track 

record within DOE that you have responsibilities for 

delivering data to DOE under 10 CFR 430 on an annual 

basis, at least for new product development, and you 

must update the Department when you have a new product 

coming on board. At the time that you do that, this 

information could certainly be made available and could 

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be kept as one of the records that the DOE keeps. It 

doesn't seem like it's necessary to require additional 

marking to be put on product if in fact the Department 

would already have that information available. 

MR. BROOKMAN: Tim. 

MR. CALLAND: The UL nameplate marking is 

intended to indicate maximum normal load and in fact is 

used to determine what kind of testing is done for the 

power supply, whereas, again, as discussed before with 

the efficiency characteristics associated with the 

power supply, it's very inefficient at a true maximum 

normal load. 

So for a lot of different reasons, for that 

reason as well, we don't necessarily want to work with 

the nameplate power -- output power rating is what we 

should be testing to. 

MR. BROOKMAN: Other comments on this 

subject? 

 (No response.) 

MR. MALINOWSKI: None? The next section of 

the presentation will deal with the multiple-voltage 

EPS test procedure that's proposed, and my colleague 

Michael Vladimer will continue. 

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External Power Supply Test Procedure: Test Measurement 

Multiple-Voltage EPSs 

Michael Vladimer 

 (PowerPoint presentation.) 

MR. VLADIMER: Hi. Good afternoon again. 

I'm Michael Vladimer from Navigant Consulting. I hope 

you all had a good lunch, and thank you, Matt, for the 

presentation so far on test measurement and test 

apparatus. I'm going to speak about the test 

measurement for multiple-voltage external power 

supplies, and then I'll hand off to Vic Petrolati, 

who's going to wrap up with the Reporting Requirements 

section. 

So once we talk about this, I'm going to 

briefly talk about standby and off mode and how that 

would apply to multiple-voltage external power supplies 

and then get into the measurement requirement section, 

which focuses on active mode. It's pretty detailed, 

and that's where most of the focus is going to be. 

So the Department is proposing a test 

measurement for multiple-voltage EPSs in standby and 

off mode. This is similar to the single-voltage 

proposal that we talked about so far. The main 

difference would be that for a multiple-voltage 

external power supply that we specify that all outputs 

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are disconnected as opposed to for a single-voltage 

where it's just one. 

What that means in practice is you can see 

the output cable right here for multiple-voltage power 

supply. There are a number of different pins. All of 

those pins should be disconnected. None should be 

connected to the product during the standby or off mode 

test measurement. 

The Department welcomes comment on that 

proposal. Any thoughts, suggestions? 

 (No response.) 

MR. VLADIMER: Okay. Thank you. Now I'd 

like to turn to active mode for multiple-voltage power 

supplies. First, a quick summary. We're looking at 

the stability requirements for when we take the test 

measurements as well as addressing how to take that 

measurement for the general case. Then, because 

multiple-voltage power supplies are a little bit more 

complicated than their single-voltage counterparts, 

there are two special cases that we'll get into. 

First, with stability requirements, it's 

similar to what Matt was talking about with singlevoltage external power supplies. There is no precedent 

other than the single-voltage language that talks about 

a 5 percent drift over five minutes. We would propose 

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a 1 percent drift. Any comments on that, or thoughts? 

 (No response.) 

MR. VLADIMER: Okay. So, yeah. Same thing I 

just said. 

MR. BROOKMAN: Why don't you repeat it again. 

MR. VLADIMER: Sure. 

MR. BROOKMAN: Yeah. I think they didn't 

stay with you on that one. 

MR. VLADIMER: Okay. So once again, the 

graph shows that it would be a five-minute duration for 

the test to take the measurement and then a 1 percent 

drift would be the acceptable tolerance of variation 

over those five minutes. 

MR. BROOKMAN: Rick. 

MR. HABBEN: This is Rick Habben. 

MR. VLADIMER: Sure. 

MR. HABBEN: I don't know how the 1 percent 

for sure is going to affect us, but I think that 

potentially something may need to be considered in 

relationship to the amount of voltage that's being 

recorded. So for instance, 1 percent on 1 volt is a 

lot different than 1 percent on 30 volts as far as your 

error there. So there may have to be a range where you 

may have to open it up a little bit when you get down 

to the smaller voltages and outputs. 

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MR. VLADIMER: Thanks. I would follow that 

up with a suggestion that if you do want to look into 

that further and comment later. If you wanted to 

suggest a certain cutoff point, or if anyone else could 

think of a cutoff point. I mean, I totally understand 

what you're saying, but is it at 1 volt or at 5 volts 

or at 30 volts. 

MR. BROOKMAN: Larry. 

MR. ALBERT: Larry Albert. Michael, you're 

considering the stability requirement, yet the out for 

it is essentially taking the average over the fiveminute period. So there's no requirement for 

stability. It's just suggesting that your voltage 

reading would be considered accurate if you can 

evidence that you can stay within the peak of that, 

within 1 percent over a five-minute period, right? 

MR. VLADIMER: In order for the -- although 

you might be averaging, or you're going to be averaging 

your power, that power measurement is valid as long as 

you stay within 1 percent of your peak. If you -- it's 

not like you can vary outside that 1 percent range and 

then, just because you're averaging, use that 

measurement. 

MR. ALBERT: But, isn't that what your last 

bullet is saying? Isn't it saying that 62301 provides 

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an out that if stability can't be achieved then you 

make the measurement through averaging? 

I guess the question is, that's the test 

method anyway. Why would you need to fulfill a 

stability requirement prior to taking the measurement 

if your out is to take the average anyway? 

MR. VLADIMER: I see what you're saying. 

MR. ALBERT: And I guess the follow-on to 

that is, even when you're talking about a peak and 

you're measuring power, you're still talking about 

averaging within a certain sample window, right? So 

you still have to stipulate, I think, that a sample 

taken for, whatever, 200 milliseconds, right, that that 

peak value average during that sample window compared 

to alternate sample windows taken at all other times, 

right, would not vary by more than 1 percent. 

I guess I'm not seeing the utility of having 

a stability requirement separate from an averaging 

requirement. 

MR. VLADIMER: Okay. I think when Matt was 

speaking before he was talking about taking an 

instantaneous measurement versus the average. 

MR. ALBERT: I think he had almost the 

identical slide that you have here. 

MR. VLADIMER: Identical graph for sure. 

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MR. ALBERT: Yeah. 

MR. VLADIMER: But I think that that's the 

issue. If you want to take an average or you want to 

do -- energy and divide by time, you can do that. The 

key idea here is such that you don't have -- I mean, 

before we were talking about battery chargers, but 

again, maybe with an external power supply you might 

have a pulsed operation or an intermittent operation. 

So that, if you're going to look at that intermittent 

operation you don't record it when the product is off, 

or essentially off. 

So if you want to average it out, like the 

bullet says -- I should be more specific. As the 

bullet says, if that's the case, you can average. But 

if you want to take an instantaneous measurement you 

need to meet these requirements. 

MR. ALBERT: Instantaneous over five minutes? 

 Or, instantaneous measurement providing you meet a 

stability requirement as ascertained through a fiveminute sample. 

MR. VLADIMER: Like that. 

MR. ALBERT: Right. 

MR. VLADIMER: So if you're within 1 percent 

for five minutes, then you can go instantaneous. 

Otherwise you need the average. 

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MR. ALBERT: Okay. Thank you. 

MR. BROOKMAN: Chris. No? Okay. Other 

comments on this? That was really slicing it pretty 

thin, I thought, right there. 

 (Laughter.) 

MR. BROOKMAN: As a non-electrical engineer. 

MR. FERNSTROM: Larry is a master at that. 

 (Laughter.) 

MR. VLADIMER: Okay. We'll continue. So now 

we're going to talk about the active mode test 

procedure and how that would apply. 

One of the questions that's posed when you 

have a multiple-voltage product is how do you load the 

outputs. You could vary one at a time, you could vary 

both at a time, or both together I should say. So the 

proposed test procedure simultaneously loads each 

output to the same percentage of their output current -

- of their nameplate output current. So they would all 

be at 25 percent at the same time, all at 50 percent at 

the same time, all at 75 percent, and so on. 

Those four points would then be averaged 

together to get your -- and that average would be the 

efficiency of the actual power supply. 

There has already been discussion previously, 

and I'm sure we'll continue on it, as to why those 

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points and how we should deal with products that might 

operate at different points. One or two things just to 

mention before I open it up is that these loading 

points -- it is an average. It isn't that if the 

Department were to set a standard -- for which there is 

not even a determination done yet -- but if it were to 

have a positive determination, the standard would be 

based on the average of those four points and would not 

hold any one of those four points to that standard 

alone. 

That's one thing. And then the other thing 

to raise when considering these loading points is how 

to come up with a test procedure across a number of 

different products because that's another challenge 

that the Department faces in developing any test 

procedure. 

 Doug? 

MR. BROOKMAN: Tim. 

MR. CALLAND: Okay. Just to clarify, I 

understand and appreciate the concept that this is an 

average. However, we still object to the principle of 

averaging in points that the power supply would never 

see in actual use under actual load for dedicatedproduct power supplies. 

MR. BROOKMAN: Okay. 

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MR. CALLAND: Thank you. 

MR. BROOKMAN: Other comments on this slide, 

and these two points especially, on 113? Yes, Chris. 

MR. CALWELL: Chris Calwell from ECOS. I did 

want to speak a little bit to why 25, 50, 75, and 100 

percent because the historical basis for this goes back 

a few years. It was a long and lively discussion with 

a lot of manufacturers. One of the most common points 

raised, which we hear again today, is "My product is 

unique. My application is unusual. Something about my 

product doesn't behave the way the test procedure 

does." 

I think we would all stipulate that the 

universe is large enough that it contains unique 

products. But that test procedure's purpose is to lend 

some standardization and some uniformity to the way you 

measure and compare them to each other. 

So for example, lots of individual 

manufacturers showed that they had products that either 

didn't reach 100 percent or never fell as low as 25 

percent. But the purpose of the test procedure and the 

resulting standards was not to improve the efficiency 

of the end use product, it was to improve the 

efficiency of the universe of power supplies that could 

be connected to such end use products and therefore 

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make them all more affordable because the industry is 

changing over their efficiency en masse. 

So maybe the relevant point here is, on this 

Xbox unit that we're seeing, I would totally agree that 

a model I might buy today could have a power use of no 

greater than X and no less than Y. But if subsequent 

design changes allow it to drop down to a lower period 

of maximum power during periods of inactivity, I would 

want its power supply to run efficiently there. 

Similarly, if I could add some element into 

it later that could cause it to draw more power than it 

maximally does today, I would want it to run 

efficiently there. 

So I think you will have an endless series of 

exceptions in your test procedure if you try to 

accommodate every manufacturer and every product that 

makes an assertion that they don't run somewhere 

between 25, 50, 75, and 100 percent. 

MR. BROOKMAN: Tim. 

MR. CALLAND: In direct response to that, if 

this rule becomes law, it's the obligation of the 

people who put the power supply into commerce that they 

meet all possible cases of loading, or at least meet 

whatever we decide on for the test procedure. 

We're honored by the example of Xbox in the 

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up and coming pictures, so we can go ahead with that. 

If that's the product -- if we have sufficiently 

satisfied the United States government that we designed 

a power supply for the Xbox and we designed the Xbox 

for the power supply, then if we make any modifications 

in the Xbox, we would have to make modifications to 

accommodate the additional load in the power supply. 

If you pull one off the shelf and it doesn't 

comply, we would be in violation of your law and we 

understand that. We feel that's sufficient without 

trying to hit an artificial loading point that we know 

for a fact we're not meeting right now. 

MR. BROOKMAN: Additional comments or a 

counterpoint? 

 (No response.) 

MR. VLADIMER: Thanks. So let's take a look 

at the Xbox. With everything that I'm presenting I'm 

going to give an example as well as an explanation, as 

I just finished with the general case. So here let's 

examine how to apply that general test procedure. 

You can see that we have an Xbox power supply 

with a nameplate rating. It specifies 203 watts as the 

maximum output power. Then there are two output buses, 

one at 12 volts, one at 5 volts. 

What is really crucial for the test 

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procedure, or the proposed test procedure I should say, 

are the rated output currents for the 5-volt and 12-

volt output buses. Once we have identified those off 

the nameplate, we can then calculate the proper loading 

conditions. 

In this case, you take 25 percent of 16.5 

amps and 25 percent of one amp. You come up -- and if 

you want to test at the 25 percent load condition, 

which gives you 4.125 amps and then a quarter of an amp 

on the other bus. Then you sum up the output powers 

across both of those output buses, divide that by your 

input power, and that's going to be the efficiency at 

that single point. Take that, along with the 

efficiency of the other points, and you get your 

average efficiency for the power supply. 

MR. BROOKMAN: Tim. 

MR. CALLAND: This is Tim from Microsoft. 

This illustrates our point exactly. Our 5-volt line 

goes to 100 percent of full load at one watt. It stays 

that way throughout the operation. It would never ever 

see 25 percent loading. The power supply isn't 

designed to be that way. So, to do this is just 

artificial. 

Additionally, our console never ever hits 25 

percent of full load. 

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MR. BROOKMAN: Thank you. 

MR. VLADIMER: Okay. The Department invites 

any other stakeholder comments? Okay. 

MR. BROOKMAN: Gary. 

MR. FERNSTROM: Gary Fernstrom. But wouldn't 

it be nice if your console could at some point hit 25 

percent of full load? 

MR. BROOKMAN: Tim. 

MR. CALLAND: That's the subject of a 

different day and a different meeting. Certainly, we 

understand the importance of energy efficiency at all 

modes and loads. We understand that there are 

circumstances in which we can hit other energy 

improvement goals. We are indeed pursuing those 

separately and mostly through a voluntary process 

rather than a mandatory one. 

MR. BROOKMAN: Other comments in this vein? 

 (No response.) 

MR. BROOKMAN: Seeing no additional comments. 

MR. VLADIMER: Okay. As I said in the 

beginning, we're going to look at one general case and 

two special cases. Now I want to explain why this case 

is not a special case. 

The two possible special cases are minimum 

output current or overloading at 100 percent current. 

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When we look at minimum output current, sometimes the 

output buses, especially on the multiple-voltage power 

supplies, will specify certain minimum levels in order 

for it to operate properly. If that's the case, then 

we have to make sure that when we load it, for instance 

at 25 percent load, that we're not going to dip below 

that because we want to make sure that we stay within 

the rated operating conditions of the product. 

At the same time, we also want to make sure 

that we don't overload the product. Some of these 

products will be able to put a lot of power through one 

output bus at a time but won't be able to provide that 

same output power through both buses simultaneously. 

In that case, we've come up with a derating scheme to 

handle that. 

But in this case, you can see on our graph 

here that the total bus output power, 198 watts plus 5 

watts, is the same as the nameplate output power of 203 

watts. 

Now let's examine the minimum output current 

limits. In this case, like I said, there will be a 

specification that says if you dip below a certain 

current it's not within the operating range of the 

product. As Matt mentioned before, we did look to 

other standards out there and there was an existing IPS 

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test procedure standard that we referenced that also 

addresses this issue. By IPS I mean internal power 

supply. 

MR. CALLAND: Also, I believe he mentioned 

that that was an internal power supply that's used in a 

computer, which is a unique kind of product that hits a 

wider range of power and has a generic description, not 

a unique, dedicated product. 

MR. VLADIMER: Okay. Anything else? Anyone 

else? 

 (No response.) 

MR. VLADIMER: So, now let's look at an 

example. Here we have a multiple-voltage power supply 

with three output buses. Although it's not written on 

the nameplate itself, there is a specification sheet 

that comes along with it. It delineates for each of 

those output buses a minimum output current. 

What's interesting is that for output bus 

number two, that minimum output current is higher than 

for the other ones, on a percentage basis. In fact, if 

we were to load that output bus to 25 percent of 

nameplate output current, we would be going below that 

limit. 

In order to address this during the 25 

percent loading measurement, we would load Output Buses 

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1 and 2, still at 25 percent, but for Output Bus Number 

2 we would go up to that minimum level. Does that make 

sense? 

MR. REEVES: Ari Reeves here. 

MR. VLADIMER: Yes. 

MR. REEVES: Just to clarify, I think you 

loaded -- you would load Buses 1 and 3 at 25 percent. 

MR. VLADIMER: Oh, did I say -- 

MR. REEVES: I think you said 1 and 2. 

MR. VLADIMER: My bad. Thank you. 

MR. REEVES: Okay. I just wanted to make 

sure. 

MR. VLADIMER: One and three would be at 25 

percent and output bus number 2 would be at the minimum 

level. In this case, 31 percent. Thank you, Ari. 

Okay. Any stakeholder comments for the 

special case? 

 (No response.) 

MR. VLADIMER: Excellent. Let's examine the 

next special case, which is a little bit more 

complicated. So for the case of an over -- sorry. How 

do I say this? Sometimes the total output bus power 

may be more than the nameplate output power. 

Here on the graph you can see that we have -- 

if you look at the ratings for these three output 

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buses, they are more than the nameplate output power. 

Sometimes the output power is going to be provided 

directly. Sometimes we'll have to calculate it based 

on the provided voltage and current. Either way it's 

definitely possible to ascertain. The Department in 

this case would propose a proportional allocation 

method to derate each bus. 

Again, there is a precedent for this idea 

with the IPS test procedure. 

In order to figure out the derating method, 

what you would do is you take the nameplate output 

power and then you look at the total bus output power 

and put those together to calculate D, or derating 

factor. Once you have your derating factor, that will 

allow you to scale each output bus. 

If the value of D is greater than one or 

equal to one, then your total bus output power is going 

to be less than your rated output power, or equal to, 

and you don't need to go through this. 

So, D is applied at all four loading points. 

 All four loading points shift down. At the highest 

loading point, at D times 100 percent, the total output 

power for the EPS is going to be the same as the total 

bus output power. 

In an example, we have this external power 

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supply that is rated for 27 watts, as you can see here. 

 But if you calculate the output power for the two 

buses individually, it comes to 43 watts. So if we 

were to try to load those together, we would be well 

over 27 and it would not be in the normal operating 

range of this product. 

So what we do is we calculate D, the derating 

factor, as 27 watts divided by 43 watts, 0.63. 

Multiply 0.63 times our loading conditions. In this 

case we're looking at 25 percent load. When we apply 

that, we look at the output buses at more or less 16 

percent of their nameplate output current instead of 25 

percent. 

Again, the Department welcomes comment on 

proportional allocation. 

MR. BROOKMAN: Tim. 

MR. CALLAND: This is a unique and clever way 

of addressing a very artificially structured situation. 

 I think that -- I do see that you did manage to find 

one other multiple output voltage power supply. I 

don't know if it was for a dedicated product or not. I 

suggest it was. I guess it is. 

Every step, you start with artificial loads 

and then you derate them in an artificial way. You're 

geometrically complicating the artificialness of the 

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whole proposal to begin with. I strongly recommend 

that wherever possible, when you have tied down to the 

satisfaction of the law of the United States of America 

and the Code of Federal Regulations that one will be 

used with the other, that that is what you use for the 

load. 

MR. BROOKMAN: Thank you. Other comments 

about this method, really? 

MS. PINTO: Excuse me. 

MR. BROOKMAN: Francine. 

MS. PINTO: Could you please restate what you 

just said? 

MR. BROOKMAN: Tim. 

MR. CALLAND: If it is my obligation as a 

manufacturer that sells a system product, you open up a 

box and you take what's in the box and you plug it into 

the wall, that that system be tested as intended to be 

used, rather than take the system apart, test one 

portion of the system in an artificial manner in case 

it were misused in some way, and load it in this rather 

arbitrary means so it would comply with some artificial 

standard. 

Whereas, when they're both tied together in 

such a way that they will always be used together and 

never be used separately, a more appropriate way to 

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test it is to test them together. 

MR. BROOKMAN: Gary. 

MR. FERNSTROM: So your argument is very 

reasonable. But how do you then understand the 

efficiency of the external dedicated power supply under 

different operating conditions of the device which it 

was designed to supply? 

Take your Xbox for example. The Xbox, I 

presume, depending upon what it's doing, can present 

different loads on the power supply, maybe not with 

respect to the 5-volt bus but with other outputs. 

So, in a simple universal way for the purpose 

of having a standardized test, how would you define the 

different operating points of the device under which 

the power supply would be tested? 

MR. CALLAND: Let me give you another example 

which is also part of the Code of Federal Regulations. 

 In this case it's covered by the Federal 

Communications Commission, having to do with 

electromagnetic compatibility and unintentional 

radiators. 

The Code of Federal Regulations requires that 

unintentional radiators do not radiate beyond a defined 

limit in all modes doing all functions. It's the 

obligation of the manufacturer to design a product that 

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meets that rather than hit artificial points. It's my 

obligation. It's my product. I designed the product 

and I know how it's going to operate. 

You mentioned 25 percent earlier. I know you 

can't get to 25 percent with my product. If my product 

is redesigned such that it is, it's my obligation to 

redesign my power supply so it operates at whatever the 

efficiency level set by this public rulemaking is at 

that level. I'm simply proposing an alternate to the 

arbitrary, artificial loading method that I can 

actually load with my product. 

MR. FERNSTROM: Okay. So if I understand 

your response correctly, you would simply suggest that 

the power supply meet the efficiency requirement under 

any operating condition that the product might present. 

MR. CALLAND: That's correct. If you find -- 

you look at our comments, you'll find on the last page 

a proposal that states just that. All modes, all 

functions. 

MR. BROOKMAN: Okay. Other viewpoints on 

this subject? Rick. 

MR. HABBEN: One other thing that you may 

want to consider is, the proposal that you have with 

the derating potentially would allow manufacturers that 

are maybe having difficulty passing a particular 

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efficiency rating to play with the output rating to 

meet the particular efficiency rating that they need 

to. So you can play with the output to adjust your 

ratings accordingly rather than testing according to 

what Tim here is saying as far as using the actual 

output load. 

MR. CALLAND: I agree with that. That's a 

good point. The curve that you show here shows you 

starting with not very good efficiency, at zero, and 

then it kind of asymptomatically approaches some level 

as it goes to 100 percent. I propose that's an 

artificial curve and it's done by derating the maximum 

output power. If you're really loading to the maximum 

output power, the curve is going to drop off kind of 

like a camel hump as you start approaching 100 percent 

of load because you have a certain amount of components 

within the power supply that operate less efficiently 

as they start to warm up. 

Again, that 100 percent rating on the 

nameplate label, the reason why it's even there is 

because that's what it was tested at in terms of 

temperature and fire hazard. It has nothing to do with 

efficiency. 

MR. VLADIMER: I just want to respond to that 

because I think you're raising a couple interesting 

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points there. First, as far as actual test, this 

curve, although it is generic, we've measured this in 

the lab with at least 50 products and they all more or 

less come to the same curve, including -- I don't 

remember offhand the results, but I know that we -- as 

you can see, we purchased the Xbox and tested that, 

too. 

MR. CALLAND: Yes, so I'd love to compare 

data with you. Thank you. 

MR. VLADIMER: Excellent. So I looked at the 

data and the variation between 25 percent and 100 

percent is minimal. I mean, by minimal, I think 

roughly speaking it's probably somewhere around 85 

percent at all points, plus or minus two. 

MR. CALLAND: And if your limit is one, you 

just messed me up. I would contend that it's -- 

MR. VLADIMER: I'm saying that if you average 

it, you might be a little bit above or a little bit 

below. But I don't want to quote numbers because I'm 

roughly remembering them. But I do want to stress that 

we looked at the Xbox, but we looked at a lot of other 

multiple-voltage power supplies as well. There are a 

lot of printers and multi-function devices, which are 

kind of all-in-one combination printers, that we looked 

at. We went onto the different external power supply 

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distributors' websites and looked at their multiplevoltage power supplies. 

This was really not done in a vacuum. This 

was looking at a number of different products. Any 

regulation that comes forward, the determination as it 

goes forward, is going to be based on a wide amount of 

data. 

I understand that you have one product in 

particular, but we're trying to consider your product 

as well as many other products. 

MR. CALLAND: No, that's understood. Again, 

I'm not saying that you eliminate your proposal for 

those people who choose to pursue it. I'm simply 

saying that you give the rest of us the option of using 

the actual load. 

MR. BROOKMAN: Is it Joel? 

MS. WATKINS: It is. 

MR. BROOKMAN: Please. 

MS. WATKINS: Joel Watkins. Concerning the 

argument of making one system and not wanting to take 

it apart, I think that -- isn't it a reality that it's 

likely that aftermarket products would be made to 

replace those external power supplies in the same way 

that you can go to stores and buy pieces for your cell 

phone? 

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The point is to regulate things that the 

consumers are purchasing more than it is to maybe 

protect the manufacturer's monopoly, perhaps, on that. 

MR. CALLAND: We're not suggesting a monopoly 

at all. We're just suggesting that because we do tie 

these two together we can meet it with our load. If 

there's an aftermarket power supply that somehow or 

other has used our patent and our connector, then it 

would still be their responsibility to meet the loading 

requirements in your standard. Because it doesn't come 

with the product, it would have to meet it according to 

this curve instead of using our product as the load. 

MS. WATKINS: That's what I thought was a 

bonus. 

MR. BROOKMAN: Okay. Yes, Vic. 

MR. PETROLATI: Doug, one comment. Mike, I 

may have misheard you, but it sounded to me like you 

indicated that we had tested 50 multi-voltage external 

power supplies. I believe we've only tested a very 

limited number of multi-voltage external power 

supplies. 

MR. VLADIMER: That's true. Thank you. I'll 

clarify. So we've tested about 50 power supplies in 

general. 

MR. PETROLATI: Right. 

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MR. VLADIMER: Of which a handful of those, 

like Vic said, just a few. Not the majority. But we 

are pursuing multiple-voltage power supplies, but not -

- the majority were single-voltage. 

MR. PETROLATI: Right. If possible, if we 

could get some data from manufacturers or others using 

this test procedure to show us that there may be 

problems, we would certainly ask you to submit that. 

It wouldn't have to be by the end of the comment 

period, but if you're willing to use this test 

procedure and you can provide some information, I think 

that would be very helpful. 

MR. CALLAND: Absolutely. 

MR. PETROLATI: Okay. 

MR. BROOKMAN: Great. Thank you. Other 

comments on this series of slides? 

 (No response.) 

MR. BROOKMAN: Okay. 

MR. VLADIMER: Okay. So I'm just going to 

conclude by discussing how all these special cases and 

general cases relate to each other and how the test 

procedure applies. 

If it gets a little complicated, it's all 

clearly laid out in the Federal Register. But the way 

it works is, step one is figure out if there's an 

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overloading condition. Step two is look at any minimum 

loading condition. Step three is do your testing. 

So, step one, figuring out the overloading 

condition, you calculate that derating factor, D. If D 

is greater than or equal to one, then you don't need to 

derate. You can go ahead at those 25, 50, 75, and 100 

percent loading points. If D is less than one, then 

you apply the derating factor to those four points. 

Next, you look at the lowest point, either 25 

percent or D times 25 percent, and decide if for any of 

those buses that that would be below its minimum rated 

output current. Then, now that you've identified all 

the loading conditions, apply the loading conditions, 

test at the four loads, average those values together 

to get your efficiency for the external power supply. 

So, any other questions with that order of 

operations? 

 (No response.) 

MR. VLADIMER: Great. Well, with that, I 

thank you for your time. I'll just briefly run through 

everything that Matt and I covered. 

We talked about widening the scope. We have 

definitions that address standby mode, off mode, as 

well as a number of new definitions to work with this 

multiple-voltage external power supply test procedure. 

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 We talked about the test apparatus and four proposed 

changes for multiple-voltage external power supplies 

and considered changes for single-voltage power 

supplies. Then we talked about the test measurement 

and how that would be for standby and off mode singlevoltage EPSs, and then concluded with multiple-voltage 

EPSs, their standby and off mode measurements, as well 

as the active mode measurements. 

At this point I'd like to hand off to Vic 

Petrolati, who will wrap up with the Reporting 

Requirements section. 

MS. CLARK: Doug? 

MR. BROOKMAN: Yes. 

MS. CLARK: Could I make one general comment? 

MR. BROOKMAN: Please do. Please, Robin. 

MS. CLARK: Robin Clark. 

MR. BROOKMAN: Is your mic on? 

MS. CLARK: I believe so. It looks bright 

green. 

I just wanted to make a general comment. EPA 

does not have any specific comment at this time on the 

multi-voltage EPS test procedure but overall is 

supportive of DOE's work in this area. We recently 

were working on the Version 2 external power supply 

specification for Energy Star, and a number of 

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stakeholders through that process suggested that EPA 

take a look at multiple-voltage EPSs. EPA was not able 

to do that at the time given resources and the time 

constraints that they were working within. 

So they are definitely interested in the 

feedback from stakeholders and the ongoing work on this 

test procedure. 

MR. BROOKMAN: So you'll consult what DOE 

receives by way of comment. 

MS. CLARK: Yes. 

MR. BROOKMAN: Yes. Thank you. 

Reporting Requirements 

Vic Petrolati 

 (PowerPoint presentation.) 

MR. PETROLATI: Okay. I'm going to cover the 

last area, the reporting requirements for Class A 

external power supplies. First of all, I want to thank 

everybody for sticking with us through this part of the 

presentations. We'll try to get this through as 

quickly as possible. 

Okay. EISA established standards for Class A 

external power supplies, as we covered previously. 

Those standards went into effect on July 1st, 2008. 

All manufacturers of covered and regulated products 

must report to DOE that their products are in 

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compliance with the applicable energy conservation 

standards. All products currently that have standards 

are required to submit compliance reports and 

certification reports. We'll get into the details of 

those a little later. 

We are now at the point where we must 

implement the certification enforcement procedures for 

Class A external power supplies, and we're going to 

discuss one portion of those. 

Let me talk about all of the certification 

enforcement procedures actually as they exist 

currently. We are proposing that manufacturers certify 

what's called each basic model of an external power 

supply, but we're also considering an alternative 

approach called the design family approach that is used 

by the Energy Star program. 

Manufacturers will select units to test under 

certification and enforcement using a sampling plan. 

The sampling plan currently isn't in existence at this 

point. It was proposed in the July 2006 rule. The 

Department of Energy is currently trying to finalize 

the certification and enforcement procedures for EPACT 

2005 products, in which battery chargers and external 

power supplies are both included. When that is 

finalized, there will be sampling requirements. 

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Manufacturers will measure energy efficiency 

with the DOE test procedure currently in existence, and 

the product must meet the energy efficiency standard 

currently in existence for Class A EPS standards. 

Manufacturers certify according to DOE 

reporting requirements, and DOE is currently proposing 

reporting requirements specific to external power 

supplies. 

This is probably a little confusing. Is 

there any questions before I go on concerning this? 

MR. BROOKMAN: Yes. Ken. 

MR. PETROLATI: Yes. 

MR. SALAETS: Ken Salaets, ITI. Vic, I'm 

trying to read your body language and kind of decipher 

your emphasis. You seem to emphasize the word 

"proposing" in the fifth bullet there. I just wanted 

to make sure I heard that correctly? 

MR. PETROLATI: In the fifth bullet. 

MR. SALAETS: It's something to the effect 

that DOE is currently proposing reporting requirements. 

MR. PETROLATI: Yes, that is correct. 

MR. SALAETS: Okay. But the emphasis 

suggests that there's -- the mind is not made up, 

there's some flexibility, you're inviting comment, and 

-- 

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MR. PETROLATI: That's the case with every 

proposed rule. 

MR. SALAETS: I understand. 

MR. PETROLATI: Right. And that is the case 

-- 

MR. SALAETS: I just wanted to make sure -- 

MR. PETROLATI: -- here as well. Now, in 

this particular case, and we'll get into it in a few 

seconds, we've got the standard reporting approach and 

we've got an alternative approach. But yes, we are 

open to comments on all aspects of the reporting 

requirements. Yeah. 

MR. BROOKMAN: Michael, do you want to add 

on? 

MR. VLADIMER: Yeah. Hi. This is Michael 

Vladimer, Navigant Consulting. I think just to address 

what Ken's question is getting at, some of the 

reporting requirements are already established. We're 

going to show -- in the Federal Register there's 

actually a copy of a sample document for reporting 

requirements. The proposed reporting requirements are 

additional ones that Vic is going to talk about. 

So that's why he was stressing "proposed," 

because what's in the copy that's in the Federal 

Register is -- it doesn't address specifically external 

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power supplies. 

MR. BROOKMAN: Let's let him keep going and 

then we'll double back as needed. 

MR. ALBERT: Just a quick question. 

MR. BROOKMAN: Yeah. Larry. 

MR. ALBERT: Just to clarify, right now there 

is a test method. 

MR. PETROLATI: Right. 

MR. ALBERT: And it's for July 1, '08. 

MR. PETROLATI: Right. 

MR. ALBERT: There's a test method, there's a 

standard, right? 

MR. PETROLATI: Correct. 

MR. ALBERT: Therefore, manufacturers must 

comply to that standard. 

MR. PETROLATI: Correct. 

MR. ALBERT: However, there are no reporting 

requirements in place right now. 

MR. PETROLATI: Correct. And no sampling 

requirements in place right now in terms of the number 

of units that have to be tested with the test procedure 

before reporting. 

MR. ALBERT: Okay. 

MR. PETROLATI: All right? 

MR. ALBERT: So, in the interim, 

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manufacturers should be doing what? They just have to 

comply and then just keep it to themselves, right? 

MR. PETROLATI: I will give you a 

recommendation which makes perfect sense to me. It may 

not make perfect sense to everybody. The July 2006 

rule had sampling requirements. There were no comments 

on the sampling requirements for external power 

supplies in that July 6th, 2006, rule. Most likely, 

the final rule is going to have those same sampling 

requirements. They also are the same sampling 

requirements that exist for all products, for all 

practical purposes. 

MR. ALBERT: Do the sampling requirements 

also indicate the required information that will most 

likely be used in the reporting requirements? 

MR. PETROLATI: No. That's what's in our 

proposed rule. What information has to be submitted. 

MR. ALBERT: So, as a practical matter, if a 

manufacturer right now is attempting to comply, so they 

conduct the testing themselves -- 

MR. PETROLATI: Right. 

MR. ALBERT: -- to the test procedure -- 

MR. PETROLATI: Right. 

MR. ALBERT: -- they record the data -- 

MR. PETROLATI: Right. 

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MR. ALBERT: -- or what they think the right 

data and information are. 

MR. PETROLATI: Right. 

MR. ALBERT: However, let's say they miss -- 

it would be unlikely they would be no more extensive 

than those? 

MR. PETROLATI: That's correct if you're 

talking about the sampling requirements which were 

proposed in July 2006 and the reporting requirements 

that we're going to be discussing in the next few 

minutes. 

MR. ALBERT: Okay. Thank you. 

MR. PETROLATI: Yes. And I'm sorry it's so 

confusing. I'm also sorry we're breaking it up into so 

many different pieces. Yes. 

MR. BROOKMAN: Jim, go ahead. 

MR. HAYNES: Mine will be real quick. I just 

wanted to go on record that -- I'm speaking of 

telephony products but primarily cordless telephones -- 

that school is still out whether or not they are 

considered Class A. 

MR. PETROLATI: Yes. 

MR. HAYNES: Thank you. 

MR. PETROLATI: I guess that's a fair 

statement. 

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MR. HAYNES: Thank you. 

MR. PETROLATI: Yeah. It's a fair statement 

because we haven't provided any specific guidance yet. 

 You do have the legislation and what is defined under 

Class A. So you'd better be aware that your product is 

either excluded or isn't part of the criteria under 

Class A. 

MR. HAYNES: Okay. 

MR. PETROLATI: Yeah. Okay. 

MR. BROOKMAN: Okay. 

MR. PETROLATI: I'll try to go on. 

 (Laughter.) 

MR. PETROLATI: Basic model. This should be 

simple because it's the same definition that's been 

used by DOE for all of its products, all of its basic 

models. All units of a given type of a covered product 

manufactured by a manufacturer, et cetera, with respect 

to external power supplies which have electrical 

characteristics that are essentially identical and 

which do not have any different physical or functional 

characteristics that affect energy consumption. 

Now, our interpretation of that language is 

that external power supplies are different basic models 

if they differ by characteristics such as output power, 

output voltage, output cord length. That's our 

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interpretation based on the fact that we feel that all 

of those will affect energy efficiency of the model. 

MR. BROOKMAN: Chris. 

MR. CALWELL: Vic, in response to the last of 

your three items there, wouldn't it be output cord 

resistance, since you could actually have a change in 

the length or the gauge of the wire and it would affect 

the power lost in the cord? 

MR. PETROLATI: I think that's correct. NCI, 

agree with that? 

PARTICIPANT: Can you say that one more time? 

MR. CALWELL: He had prefaced these three 

items that are listed at the bottom there by saying 

those are the three that could affect the measured 

value. But I think it's not actually output cord 

length, its output cord resistance should be affected 

either by length or gauge of wire, but not only by 

length. 

MR. BROOKMAN: Okay. 

MR. PETROLATI: Okay. Good point. Thank 

you. 

All right. For each basic model DOE proposes 

a requirement for a compliance statement and a 

certification report. The compliance statement attests 

that the basic model meets applicable standards, the 

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application of the test procedure conformed with the 

requirements, and all information is true and accurate. 

The certification report goes into the 

details of the product itself, such as the 

manufacturer's name, manufacturer's model numbers, 

product class, private labeler's name, product type, et 

cetera. 

Okay. DOE is proposing that certification 

reports specific to external power supplies include 

information on the active mode efficiency and the noload power consumption. Both standards have been 

established under the Class A external power supplies 

for both of those descriptors. 

MR. BROOKMAN: Comments on those? Wayne. 

MR. MORRIS: This is Wayne. Just to -- no, I 

got it. Thanks. Never mind. 

MR. BROOKMAN: Okay. Other comments on 

those? 

 (No response.) 

MR. BROOKMAN: Okay. 

MR. PETROLATI: Okay. Quickly -- 

MR. BROOKMAN: Tim. 

MR. CALLAND: Just one thing that was kind of 

bugging me. We're talking about certification. I 

think the general term of art in this case is 

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"declaration" and a certification is something that's 

offered by a third party. To be consistent, I think 

"declaration" works pretty good. It means I'm saying 

so, I'm not getting you to say so. 

MR. PETROLATI: Okay. First of all, let me 

try to address the third party concept. The Department 

of Energy for this product, and I believe all the other 

products, does not require third party certification at 

all, any testing by any independent laboratories. 

These basic -- what we're talking about basically is 

manufacturer certification. A manufacturer can test it 

himself and certify by the compliance statement and the 

certification report that the product is in compliance. 

MR. CALLAND: No, I agree. Just, it's been 

my understanding and practice in the past 25 years that 

if I do it myself it's considered a declaration. 

MR. PETROLATI: Yeah. 

MR. CALLAND: If someone else does it, it's a 

certification. 

MR. PETROLATI: Okay. 

MR. CALLAND: What you're asking me to do is 

to declare that I comply with the law. So that might 

be a better term to consider going forward. 

MR. PETROLATI: Thank you. All right. We're 

providing within the Federal Register notice here a 

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copy of the standard compliance statement and 

certification report. This is in the Code of Federal 

Regulations. It doesn't differ at all for this product 

from any of the other products. 

Okay. Now, first of all, before I go on to 

the alternative approach, any last questions on the 

standard reporting requirements? I'm going to hold you 

to this. 

MR. BROOKMAN: Chris. 

MR. CALWELL: This one is short. The secondto-last bullet says "active mode efficiency." Are you 

wanting them to report the average or report the four 

values that were used to compute the average? 

MR. PETROLATI: That is a real good question. 

 (Laughter.) 

MR. PETROLATI: Our Code of Federal 

Regulations does not specify for any of the other 

products that I could find. I will have to get back to 

you as to whether or not there's something that I've 

missed through the language in the Code of Federal 

Regulations that requires the actual test data or an 

average of the test data or what. 

Francine, by any chance, do you have an 

answer for that? 

MS. PINTO: I don't, no. 

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MR. PETROLATI: Okay. I don't know, either, 

other than reading the Code of Federal Regulations. It 

doesn't sound very specific to me. I would like to 

make it more specific. Thank you. 

MR. BROOKMAN: Wayne. 

MR. MORRIS: As I'm sure Vic is aware, and 

others -- Wayne Morris. Sorry -- there's a long 

history within NAECA that, where an energy factor or 

other kind of number is arrived at, manufacturers are 

not required to deliver the portions of that number 

that are used to arrive at the final number. 

So for instance, when an energy factor of 

another appliance which may be the sum or may be a 

product of multiple different values, they are not 

required, as I understand it, to report all of those 

individual values that go back to make up that final 

value. They're required to report the final value. In 

the case of an energy factor, that factor. 

MR. BROOKMAN: And you cited NAECA? 

MR. MORRIS: That's my understanding. 

MR. BROOKMAN: NAECA there? 

MR. MORRIS: NAECA. 

MR. BROOKMAN: Okay. 

MR. MORRIS: Yes. 

MR. PETROLATI: Okay. 

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MS. PINTO: But you also -- this is Francine 

Pinto. 

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MR. BROOKMAN: Francine. 

MS. PINTO: You are required to keep the 

data. 

MR. MORRIS: Right. Absolutely. 

MR. BROOKMAN: Okay. 

MR. PETROLATI: Which may be made available 

upon request, right? 

MS. PINTO: Correct. 

MR. PETROLATI: Thank you. That's a good 

clarifying point as well. Thank you. 

All right. Let me quickly discuss the 

alternative approach that we have for reporting. 

Again, it's based on, as I'll get to, an approach 

that's used under the Energy Star program. It's called 

the Design Families Approach. 

Design families consist of external power 

supplies that have the same output power rating, the 

same input voltage range, the same fundamental electric 

circuit design, but different output voltages. 

Under the design family approach, 

manufacturers would submit a compliance statement and a 

certification report for all the basic models in the 

design family, supported by test results for the lowest 

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output voltage model and the highest output voltage 

model. 

Let me mention that the statement about test 

results may be inaccurate, based on my latest reading 

of the Code of Federal Regulations, but we definitely 

want the results of the active mode efficiency and noload mode efficiency for those devices. All right. 

I'll have to check on the concept of whether test 

results can be submitted, or have to be submitted, 

excuse me, in the design family. 

Again, this approach is based on an approach 

that has been used by the Energy Star program for quite 

a while. 

Okay. The alternative approach, just going 

through it again. The manufacturers would certify and 

be responsible for compliance for all the EPSs within 

the design family. The design family approach does not 

address differences in output cord length. Chris had a 

good comment on output cord length. It's more than 

just the length, it's resistance. Output cords could 

affect and could vary between external power supplies. 

 Manufacturers are required to attest that all external 

power supplies within the design family meet standards 

regardless of differences in output cord or any other 

differences associated with those products within the 

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design family. That should be primarily the only 

difference. 

DOE is considering this alternative approach 

if it reduces manufacturer burden while ensuring 

compliance with standards. This may reduce reporting 

burden for custom built external power supplies, which 

are a significant segment of the external power supply 

market. 

MR. BROOKMAN: If it's part of a family you 

can do it as a family. 

MR. PETROLATI: Okay. Basically, just a 

chart showing that if in fact we incorporated the 

design family approach into reporting, on the left you 

would see that all four of those external power 

supplies would have to be reported individually. Under 

the design family approach, you would be submitting one 

compliance statement and one certification report for 

all of those four external power supplies. 

So we certainly feel that we're reducing 

reporting burden. I do want to emphasize that the 

manufacturer is still responsible for ensuring 

compliance with all of the external power supplies 

within the design family. 

Okay. As mentioned before, we're seeking 

comment on our reporting requirements, on the 

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approaches that are presented or any other alternative 

approaches that you feel might be acceptable. 

MR. BROOKMAN: Ken. 

MR. SALAETS: Ken Salaets, ITI. Being the 

least knowledgeable person in the room, I'm going to 

ask what might be considered a silly question. But, 

what does the agency do with the information that's 

submitted? 

MR. PETROLATI: That's not a silly question 

at all, Ken. I believe the agency right now has a 

database. We do respond to requests for information 

that has been submitted. We're currently responding to 

a request from an outside organization to provide them 

information that has been submitted on certain 

products. 

The information that is submitted certainly 

serves as the basis for ensuring compliance of the 

products, both the fact that the manufacturers have 

knowingly demonstrated that compliance and in fact have 

assured themselves through the testing that those 

products are in compliance. 

MR. SALAETS: So if I may follow up, then, 

based on all of those obligations that fall on the 

Department based on statute -- 

MR. PETROLATI: Right. 

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MR. SALAETS: -- et cetera, you could 

accomplish all of those tasks if the manufacturer 

retained that information at their facility in whatever 

format you require rather than submitting that as a 

report. I mean, that information would still be 

available. You would still have the privilege or the 

right to request that information to be provided 

directly. I think Wayne was suggesting or intimating 

that that information could be made available for 

other, for example, government bodies or the like that 

might be requesting or have similar requirements 

relative to adopting this regulation, for example, for 

their marketplace. 

MR. BROOKMAN: Do you have reservations about 

the actual submission? 

MR. SALAETS: There are some reservations 

that may be just in terms of burden and the utility of 

doing that relative to having the manufacturer retain 

it. Again, supplier's declaration of conformity is 

usually, as Tim was suggesting, a declaration of 

conformance. I think in the standards world it's 

essentially the same as compliance, for the most part. 

 Lawyers might disagree. 

But the notion is that the information is 

retained and made readily available. In fact, at one 

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time ITI was contemplating creating a mechanism whereby 

global parties or interested parties can request that 

information and have it in a single location instead of 

having to distribute it everywhere where somebody might 

desire to retain it for whatever purpose. 

But just in terms of the cost factor and 

utility, I think it might even be more cost efficient 

if the manufacturers were required to retain that 

information and make it readily available at the 

request of the Department. 

MR. PETROLATI: Let me ask, Ken; unless I'm 

mistaken, the design family approach and the 

information that's reported in the design family 

approach to EPA would make that very consistent with 

the same information that EPA is already gathering. Is 

that correct? 

MR. SALAETS: Ken, ITI. The EPA process -- 

and I'm a surface person, I'm not an in-depth person on 

everything that's required there; Chris could probably 

address this better than I can, or perhaps Robin --

but I believe the manufacturer submits the 

data. Basically, EPA posts the qualified products and 

some of that data on the website as a qualified list. 

For example, that list is utilized by the European 

Union, which is also a partner in Energy Star. 

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I'm not certain if it requires the submission 

of all of the data. In fact, I do not believe it does 

require that. I think it's just a declaration, and in 

fact a voluntary declaration in a "voluntary" program, 

and that information is examined in some cases on kind 

of an ad hoc basis by EPA, maybe triggered by a 

complaint by a competitor, perhaps a request from 

another agency, in this case maybe the European Union 

again. 

But I mean, I could respond or have one of my 

members respond to that more completely. 

MR. PETROLATI: Please do. We were under the 

impression that much of the information that we would 

be requesting here is very similar to what EPA is 

getting. We're also under the impression that a 

significant percentage of external power supply 

manufacturers are already reporting in this same manner 

for much of this information to EPA and the Energy Star 

program. 

MR. SALAETS: Let me defer to Chris and see 

if he can enlighten us. 

MR. BROOKMAN: Chris, do you want to follow 

on there? 

MR. CALWELL: Yeah. I was just going to make 

two points here, I guess. The first is that I agree 

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with Vic that the detail or the amount of information 

being requested here is not substantially different 

from what would be requested by, say, the Energy 

Commission in California for a state standard or what 

Energy Star would request for its voluntary ones. 

The other point is that we now know that you 

have two other statutory deadlines where you're looking 

at possible revisions to the standard. So one could 

imagine that beyond the utility of simply knowing what 

complies you probably want to know how efficient it is 

so you can evaluate that data set in the future as you 

contemplate standards revisions. 

So I would say there is a material difference 

between knowing that someone has asserted their product 

complies and knowing exactly how efficient it is 

quantitatively. 

MR. BROOKMAN: Okay. Robin. 

MS. CLARK: I would just add, I agree with 

what Chris said. There's a lot of consistency. There 

is a significant amount of data that is reported by the 

manufacturers to EPA Energy Star for external power 

supplies. Not all of that is reflected up on the 

website. That is summarized and streamlined to some 

extent, just given the medium in which it's being 

presented. 

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MR. BROOKMAN: Let me go to Wayne and then 

back to Ken. 

MR. MORRIS: Wayne Morris. I don't disagree, 

Ken, and I don't want you to think that I do, with your 

comments or suggestions. 

I would say that based on our experience with 

the Department on other product categories there is a 

certain level of -- certain amount of leveling of the 

playing field, shall we call it, where every 

manufacturer has an obligation to submit data. They 

know that they have to submit that data. They know 

they have to certify or declare that data as being 

accurate. It brings them the realization that they 

have a compliance obligation here in the United States 

to be placing product on the market, to be shipping 

product on the market. 

If it is a matter that they would just simply 

send a letter saying, "Hey, we're okay. Thanks very 

much. Call us if you need some data," I guess I'm 

wondering whether or not that really requires that 

company to fulfill all of their obligations. 

We've been through some other regulatory 

phases here in the last few years with other countries 

of the world where they are back and forth in terms of 

declarations and supplier declaration and other kinds 

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of things, and it's a tricky issue. 

I think if there was a way -- by the way, 

there are other ways that it's done with, in some 

cases, certification programs. It's done through trade 

associations, where trade associations will gather data 

and submit it en masse to the Department or to CDC or 

to EPA or to other places so that they can make it less 

burdensome on manufacturers. 

We fulfill that function in some of our 

certification programs, as I imagine you do, too, where 

if the manufacturers submit to you one time, you can 

then submit it multiple times to multiple places so 

that it takes the burden off the manufacturer. The 

Department has always been willing to consider those 

kinds of situations. 

I think that there is a level of obligation 

that we would like to encourage so that all 

manufacturers that are delivering product in here, 

especially those that are maybe less familiar with the 

laws and requirements of the United States, would want 

to make sure that they are paying particular attention 

to that. 

Again, there are multiple ways of doing it. 

I'm not suggesting that this is what you're suggesting. 

 But I guess I'm hoping that we can -- we appreciate 

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the Department's willingness to consider alternatives 

that are much less burdensome. 

I think that we do need to be careful that we 

are getting to the point where all the manufacturers 

working here in the United States are fulfilling 

completely their obligation so that it protects the 

companies that are being very diligent as well. 

MR. BROOKMAN: Ken, you're next in the queue. 

MR. PETROLATI: I'd like to make one other 

comment. Wayne, thank you for that. I think that was 

very helpful. It even gave me some other ideas. 

I mean, we are dealing with, in this 

particular case, external power supplies where we 

believe the majority of the products are manufactured 

overseas. I do not believe we even know at this point 

all of the manufacturers of external power supplies. I 

think we've got a fairly good handle on the majority of 

manufacturers. We certainly believe that the minority 

of manufacturers that are manufacturing their products 

are in the United States. 

This is an extremely complex product to deal 

with, with a significant number of manufacturers out 

there, and I'm not 100 percent sure we even know every 

one of the manufacturers out there at this point, which 

even makes it even more difficult for us to ask 

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somebody for their data at some future point in time. 

But either way, we do appreciate the 

comments. 

MR. BROOKMAN: Ken. 

MR. SALAETS: There may be situations or 

circumstances where you're dealing with an unknown 

entity or maybe it's a new supplier in the marketplace. 

 Maybe it's a new supplier geographically somewhere in 

the world where you need -- maybe it's a very large 

country that's on the other side of the Pacific. 

Whatever the case may be, I think you err on the side 

of caution, and you have even additional reporting 

obligations. 

I think in terms of the manufacturers I deal 

with in the hardware space, their process for 

evaluating, validating, et cetera, is as rigorous, if 

not more so, probably than the Federal government's. 

The reason being ultimately they are held in some cases 

liable if there is some misrepresentation or the like 

in the product they offer. 

That's not the only motivation. The other is 

brand, good will, all the other things that drive the 

market and enable you to be successful in that 

marketplace. 

The process is rigorous and complete. Case 

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in point, going through just the recent requirements to 

change the power supply efficiency, it was a major, 

major undertaking that still hasn't reached complete 

fruition and maturity in the marketplace, which is 

reflected in some of the low numbers and percentages we 

have under some of the specifications under Energy 

Star. 

But the point is that if every jurisdiction -

- we'll call it a jurisdiction -- requests data 

submission retention and goes through that process, and 

they typically will, then that burden -- I mean, I 

appreciate what you're talking about, Vic, here with 

the family approach and everything else. I get a sense 

of genuine focus and commitment to the notion of 

reducing the burden and the cost to accomplish the 

goals that Congress has stipulated here, not just the 

goals but the statutory obligations. But I just think 

that there may be some other ways. 

Wayne suggested there's flexibility. I 

appreciate that. I know in Energy Star there is 

flexibility. ITI reports on market penetration on 

displays, computers, et cetera, again to reduce the 

burden and in some cases to reduce the exposure of some 

of the internal information so that it's retained 

through an association as opposed to putting it out in 

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public. 

What we will do in written comments, let's 

engage and continue to talk. We're sensitive to the 

requirements, sensitive to the fact that this is a 

different process as opposed to what we have dealt with 

in the past. There are some benefits to this process 

as opposed to what we deal with in the other 

environment that we appreciate as well. And I 

appreciate the time to raise the issue and the fact 

that there's a willingness to continue to engage on it. 

 I'll leave it at that. Thanks. 

MR. BROOKMAN: Let's take additional comments 

on these two approaches. Wayne. 

MR. MORRIS: On a different subject but still 

one under your reporting obligations -- Francine, maybe 

you could cite me the specific section of EPCA -- but 

there is a section in EPCA that refers to the fact that 

once there is a test procedure and once there is a 

standard in effect for that particular product all 

manufacturers that are reporting or having any 

advertising of the elements required in any form -- 

sales literature, packaging, Internet displays, 

whatever -- must be using the test procedure that is 

under the requirements of, in this case, the federal 

government or U.S. DOE. 

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That's an obligation that manufacturers also 

have. It may be one that's pretty difficult to go out 

and enforce a lot of times. It is still an obligation, 

and I think it's one that in some cases manufacturers 

may not realize or may not necessarily pick up on every 

particular day of the week. Thanks. 

MR. BROOKMAN: Okay. Thank you. So, 

additional comments and moving, perhaps, towards final 

comments on these approaches. Larry. 

MR. ALBERT: Just to clarify, Vic -- Larry 

Albert, by the way -- this section here regarding 

reporting requirements applies at this point only to 

EPSs? 

MR. PETROLATI: Correct. 

MR. ALBERT: And presumably when there's a 

battery charger standard put out, there would also be 

similar requirements for battery chargers? 

MR. PETROLATI: Correct. 

MR. ALBERT: I think this is -- an earlier 

comment I made with respect to Appendix Y is that it 

incorporates by reference the Energy Star test 

procedure, and in the Energy Star test procedure there 

is a heading for reporting requirements that is not 

modified by Appendix Y. So I'm wondering whether those 

-- within the context of the regulation, are those 

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truly reporting requirements or are they really just 

recording requirements, right, for the test procedure? 

 What do you do when you have a test procedure but you 

don't have a standard? What do you call that data that 

you record? You're not reporting it at that point, 

right? 

MR. PETROLATI: Okay. Anybody from NCI have 

an answer as to that section that Larry's referring to 

as to what the intent was? If not, we'll take the -- 

go ahead, Matt. Do you have -- 

MR. MALINOWSKI: This is Matt Malinowski. I 

believe that reporting requirements is Section 6 of the 

EPS test procedure. 

MR. PETROLATI: Yes. 

MR. MALINOWSKI: It is not included within -- 

it is not referenced within Appendix Z, which only goes 

as far as to reference Sections 4 and 5. 

MR. BROOKMAN: So, interpret that for us. 

MR. ALBERT: That's for EPS, but for BCs and 

-- we have -- 

MR. BROOKMAN: Let Matt finish. 

MR. ALBERT: I'm sorry. Go ahead. 

MR. BROOKMAN: Yeah, Matt. 

MR. MALINOWSKI: I'm actually not sure about 

BCs. 

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MR. PETROLATI: Okay. We'll check on that 

anyway. Okay. 

MR. VLADIMER: I can speak to one other 

thing with regard to that. 

MR. PETROLATI: Go ahead. 

MR. BROOKMAN: Michael. 

MR. VLADIMER: This is Michael Vladimer. I 

think, usually with the test measurements, they're 

supposed to produce specific metrics as outputs. So 

when you're talking about the intermediate values that 

are used to calculate those metrics, I know that 

there's interest in having those reported as well, but 

the key thing is the outputs themselves. 

So in the case of a battery charger with the 

existing test procedure, it’s energy ratio. With 

external power, it's average active mode efficiency and 

no-load power. 

MR. PETROLATI: Okay. Thank you. 

MR. BROOKMAN: Okay. Other comments about 

these approaches? Larry, you still look like you've 

got -- no? Okay. Other comments on these approaches? 

 (No response.) 

MR. BROOKMAN: So then, I think we've reached 

the spot now where we want to provide an opportunity 

for anybody -- 

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MR. PETROLATI: We do, but let me just 

mention one last slide I missed. How to submit written 

comments. I want to emphasize how important it is to 

get your comments in writing. We've had a tremendous 

amount of comments that we need to consider from this 

meeting. I would really appreciate for you to put it 

in writing and provide those comments by the close of 

the comment period, October 29th. 

Okay. Thank you. Doug's right. We are at 

the last portions of our agenda here. 

MR. BROOKMAN: Yeah. We want to provide an 

opportunity again for anybody to make closing remarks, 

brief summary remarks, and I'm going to hand out the 

evaluation form. That can be circulated while this is 

taking place. 

So, yes, Chris. 

Conclusion and Closing Remarks 

MR. CALWELL: I was looking over my notes 

from the conversation today, and the only major issue 

that I heard questions raised about but no resolution 

was the notion of whether certain major product 

families may or may not be considered Class A external 

power supplies. 

So I'm looking on Slide 23. There's a 

restatement of the congressional definition of what a 

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Class A external power supply is. Vic, is there some 

process or timetable by which DOE would declare which 

products it believes to be Class A, or what's the 

process for resolving this uncertainty between 

manufacturers and others on whether their products are 

covered by Class A? 

MR. PETROLATI: That's a good question, 

Chris. Obviously, we don't have answers for every 

particular product as to whether it's covered in Class 

A at this point. We're hoping to provide the framework 

for that -- I probably should have used a different 

term -- in our framework document that we plan on 

publishing within the next few months. That will give 

our initial thinking of what the interpretation is for 

which products are Class A and which ones we consider 

to be non-Class A. 

MR. CALWELL: Yeah. And so, does that then 

mean that any manufacturer that asserts that they 

believe their products are not Class A is in effect 

protected from violating the law until you issue that 

opinion? 

MR. PETROLATI: I don't know, to be perfectly 

honest. I would say that the definition has some 

ambiguities. If I am a manufacturer concerned with 

being in compliance with a standard I would want to 

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make sure that I had a legal opinion that that product 

isn't covered under the current definition, or I was 

proceeding in a manner that was obviously appropriate 

from a legal standpoint. 

MR. CALWELL: Yeah. Okay. I think that 

makes sense. Since the state standards that preceded 

this still remain in effect for the products that 

aren't Class A, it seems like the products are 

regulated regardless. They're just either regulated by 

a handful or states or they're regulated federally. 

But I guess it wasn't one of the topics I expected to 

come up today because it seemed like power supply 

manufacturers already had multiple obligations in 

various jurisdictions to make efficient power supplies. 

MR. PETROLATI: Thank you. 

MR. BROOKMAN: Additional summary remarks, 

closing comments? Gary. 

MR. FERNSTROM: So, Gary from PG&E. PG&E 

would encourage DOE to consider active mode and is 

delighted that you're doing that. We would also 

appreciate as much as possible a process and outcome 

that is consistent with the advocacy that we've 

provided in California for California's standards for 

this test procedure. 

MR. BROOKMAN: Thank you. Michael? Michael, 

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get close to the microphone. 

MR. HINDUS: Thank you again. First of all, 

I'm very appreciative to DOE staff today for clarifying 

again that consumer products are covered by this 

rulemaking and not commercial and industrial products, 

and for the further guidance as to how to decide what 

products fall into that category. That addresses many, 

but not all, of the concerns of my clients who are in 

the security, surveillance, and life-safety industries. 

At the same time, having listened to all the 

comments today, it struck me how inappropriate it is to 

apply these test procedures to products that do not 

have on/off switches which were never intended to be 

used in the no-load, off mode, or standby, and for 

which no energy efficiency benefits would be gained by 

this testing, only additional expenses. 

So again, we would urge you to look at our 

proposed definition, which would make clear that those 

modes that are under study today should not apply to 

devices that are not intended ever to be used in those 

modes, specifically for the security, life safety, and 

surveillance products. 

MR. BROOKMAN: Thank you. Vic, please. 

MR. PETROLATI: Can I ask, do you have an 

objection to your products meeting the active mode 

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standard? 

MR. HINDUS: No, not at all. Of course, we 

did comply with the July 1st, 2008, standards. 

MR. PETROLATI: Okay. 

MR. BROOKMAN: Thanks for that clarification. 

 Thank you. Michael. 

MR. VLADIMER: Hi. This is Michael Vladimer 

from Navigant Consulting. As I mentioned in the 

beginning, we support the Department of Energy. As 

part of that support, we speak with manufacturers to 

understand the technologies that they have been using 

and the energy efficiencies they've been achieving and 

any costs associated with that. 

I highly welcome any of the manufacturers who 

have been kind enough to come today, or any of the 

other associations that have any data related to 

efficiency, cost, market data, to speak with me or my 

colleague Matt, or our colleagues at D&R International. 

 We appreciate any information that anyone can provide. 

 Thanks. 

MR. BROOKMAN: Okay. Thank you. Yes, 

please. Wayne. 

MR. MORRIS: Doug, thank you. Thank you to 

the Department for all the work that they put in, and 

D&R and others, into these public meetings. We know 

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that there are a significant amount of time and effort 

put into these, and we appreciate it. 

At the risk of drawing a cloud with lightning 

coming down, I will agree with Gary Fernstrom and with 

others that -- 

 (Laughter.) 

MR. MORRIS: And I think it's important that 

there is a consensus among many stakeholders that there 

really doesn't seem to be a reason why, in the battery 

chargers test procedure -- especially with consensus of 

the stakeholders present -- that we couldn't include an 

E24 active measurement in this particular edition of 

the test procedure coming up, with due respect about 

notice and comment. 

I know that the Department in some cases has 

shortened that process -- I'll use the term "shortened" 

rather than "eliminated" -- shortened that process in 

some cases when there has been consensus of 

stakeholders. 

I think also, to Larry's original point, 

we're not asking necessarily that the test procedure, 

if it were modified would have any impact because 

there's no standard yet. So what we're really doing is 

just gathering a data point. We're asking for 

manufacturers at the time that they are connecting 

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their battery charger up to a piece of test equipment 

to take a measurement, a measurement that will already 

exist, and write it down or have it recorded in a data 

logger. 

It really is not burdensome. At least to us 

it certainly isn’t -- and we're the manufacturers. We 

don't think it's burdensome to do that kind of thing. 

I think it's time now to do that in regard to the 

harmonization of other activities that we've looked at. 

I also think, now that we have, at least 

barring the 45-day language, we have a final test 

procedure essentially in California that will really 

set the stage here in the United States. I think it is 

in keeping with what's going on internationally. 

With this all said, with a very few words 

added to the test procedure I think that we could 

accomplish this. We could set this up. We could 

eliminate the Department having to go through a 

separate rulemaking for this at some time later. It 

actually saves energy, amazingly. 

 (Laughter.) 

MR. MORRIS: Human energy, albeit. 

It also means that we're one step closer to 

finalizing this situation so that we set ourselves 

forward for a rulemaking and we keep on track with the 

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schedule. 

I know that what I'm asking between the 29th 

of October and the end of December is a lot, but I 

think that with consensus and with the minimum of 

changes that really are affected by this, I really do 

believe it's possible. 

So I guess I would plead and ask for General 

Counsel's Office to review this and see whether that 

causes a problem with notice and comment significantly, 

whether this could be taken back to the policy office, 

and whether they would agree that this is a 

possibility. We would certainly pledge ourselves to 

work with staff, and we will be delivering exact 

language of where we think that that could be modified 

to cut this down to a minimum of effort on the part of 

staff. Thank you. 

MR. PETROLATI: Could I ask Gary, maybe, from 

California, is there anybody in the California process 

that you're aware of that objected to the incorporation 

of active mode? 

MR. FERNSTROM: Not that I'm aware of. I'd 

like to double-check with Chris, however. 

MR. CALWELL: Yeah, Vic, I think the main 

point is just that at a high conceptual level we're 

talking about measuring products over a 24-hour period, 

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as they mentioned, to capture active and maintenance. 

The devil is in an enormous number of individual 

details, though, and so I think the CEC is trying to do 

the due diligence to make sure that someone else 

doesn't show up at the hearing who maybe hasn't sat in 

on these discussions so far but brings forward some new 

concern that hadn't been voiced yet. 

So there's a lot to look at here. I think 

there's an encouraging general sense of support for 

including active mode, but all of us, I think, would 

want some time to go back and say do we agree 90 

percent, do we agree 100 percent, how much variation is 

there in this position that's been espoused today. 

MR. PETROLATI: Okay. Very good. 

MR. BROOKMAN: Okay. Yes. 

MS. AMANN: Jennifer Amann. I would just add 

to that, I think we would want to look and talk to some 

more of the technical experts and some of the other 

advocates that we work with, but we would certainly 

welcome an opportunity to work with AHAM and any of the 

manufacturers to see what we could come up with in 

terms of some consensus language that might allow us to 

get active mode included in the test procedure this 

year. 

MR. PETROLATI: Thank you. That would be 

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great. 

MR. BROOKMAN: Gary. 

MR. FERNSTROM: I'd be remiss if I didn't 

similarly thank DOE, the staff, the consultants, and 

participants for a very productive workshop. 

MR. BROOKMAN: Thank you. Thanks very much. 

 Other closing remarks? 

 (No response.) 

MR. BROOKMAN: I want to take the opportunity 

to thank those people that participated in the webcast. 

 I think we had 35 or 37 individuals listening on the 

webcast today. So I would encourage those individuals 

that participated to send their comments to DOE about 

how it worked for you on the webcast and how that might 

be improved. DOE is about constant improvement in 

their approach to things. 

So having said that, I would thank you for 

doing the evaluation form, and turn it back to Vic for 

closing remarks. 

MR. PETROLATI: Thank you for coming. 

Adjourned. 

 (Laughter.) 

(Whereupon, at 3:10 p.m., the meeting was 

concluded.) 

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1 REPORTER'S CERTIFICATE

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 This is to certify that the attached proceedings 

before: 

UNITED STATES DEPARTMENT OF ENERGY 

In the Matter of: 

PUBLIC MEETING ON ENERGY CONSERVATION STANDARDS FOR 

BATTERY CHARGERS AND EXTERNAL POWER SUPPLIES

 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. 

 

16 Wendy Greene 17 

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 Official Reporter 

Dated: September 30, 2008 

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