EXECUTIVE COURT REPORTERS, INC. 

(301) 565-0064

U.S. DEPARTMENT OF ENERGY 

PUBLIC MEETING ON ENERGY CONSERVATION STANDARDS FOR 

METAL HALIDE LAMP FIXTURES 

Room 1E-245 

U.S. Department of Energy 

1000 Independence Avenue, S.W. 

Washington, D.C. 20585 

9:00 a.m. 

Tuesday, January 26, 2010 

 

 DOUG BROOKMAN, Facilitator 

U.S. Department of Energy Attendees

 LINDA GRAVES 

 RON LEWIS 

 ERIC STAS, ESQ. 

Attendees

 JESSICA W. FRIEND 

 Government Affairs Advisor 

 Steptoe and Johnson, LLP 

 1330 Connecticut Avenue, NW 

 Washington, D.C. 20036-1795 

 MAHIMA GUPTA 

 Navigant Consulting 

 TOM HARDING 

 Vice President, Engineering 

 Venture Lighting International 

 32000 Aurora Road 

 Solon, Ohio 44139 

 THOMAS D. HIRT 

 Product Safety Manager 

 Hubbell Lighting, Inc. 

 701 Millennium Boulevard 

 Greenville, South Carolina 29607 

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Attendees

 JOHN D. GREEN, P.E., LC 

 Principle Engineer 

 Cooper Lighting 

 1121 Highway 74 South 

 Peachtree City, Georgia 30269 

 DR. S. PEKKA HAKKARAINEN, M.A., Ph.D. 

 Vice President 

 Lutron Electronics Co., Inc. 

 Coopersburg, Pennsylvania 18036 

 OINDRILA HAZRA 

 Lighting Engineer 

 Pacific Northwest National Laboratory 

 Energy and Efficiency Division 

 15 New England Executive Park 

 Burlington, Massachusetts 01803 

 PAMELA K. HORNER 

 Director, Industry Relations & Standards 

 Osram Sylvania General Lighting 

 100 Endicott Street 

 Danvers, Massachusetts 01923 

 BARBARA ATKINSON 

 Lawrence Berkeley National Laboratory 

 MS9R4000, 1 Cyclotron Road 

 Berkeley, California 94710 

 ROBERT ERHARDT 

 Phillips Lighting Electronics 

 10275 West Higgins Road 

 Rosemont, Illinois 60018 

 JOANNA MAUER 

 ASAP 

 529 14th Street, NW, Suite 600 

 Washington, D.C. 

 COLLIN WEBER 

 Navigant Consulting 

 815 North Oakland Street, Apartment 303 

 Arlington, Virginia 22203 

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Attendees

 ROBERT LINGARD, LC 

 Lighting Scientist 

 Pacific Northwest National Laboratory 

 Technology Planning and Deployment 

 620 SW 5th Avenue, Suite 810 

 Portland, Oregon 97204 

 Michael Myer 

 Lighting Scientist 

 Pacific Northwest National Laboratory 

 15 New England Executive Park 

 Burlington, Massachusetts 01803 

 REBECCA RAINER 

 National Technical Sales Manager, Greenworks 

 Cooper Lighting 

 P.O. Box 820824 

 Vicksburg, Mississippi 39182-0824 

 DOUGLAS J. ROSSIN 

 Navigant Consulting 

 AMANDA SLOCUM STEVENS 

 Project Manager 

 Energy Solutions 

 1610 Harrison Street 

 Oakland, California 94612 

 DAVID LIS 

 ALVIN M. RAZON 

 Sr. Engineering & Operations Representative 

 National Rural Electric Cooperative Assoc. 

 4301 Wilson Boulevard 

 Arlington, Virginia 22203 

 DALE R. SIMPSON, LC 

 Technical Marketing Manager 

 Business Unit Professional Luminaires 

 Philips 

 1611 Clovis Barker Road 

 San Marcos, Texas 78666 

 MATTHEW WALKER 

 Navigant Consulting 

 

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 JENNIFER THORNE AMANN 

 Director, Buildings Program 

 ACEEE 

 529 14th Street, NW, Suite 600 

 Washington, D.C. 20045 

Attendees

 TIMOTHY BALLO, Esquire 

 EarthJustice 

 1625 Massachusetts Avenue, Suite 702 

 Washington, D.C. 20036 

 BRIAN COFFEY 

 Navigant Consulting 

 CHERYL ENGLISH, FIES, LC 

 Vice President, Market & Industry Development 

 Acuity Brands Lighting 

 One Lithonia Way 

 Conyers, Georgia 30012 

 ERIC S. ANDERSEN 

 Mechanical Engineer, Project Manager 

 Energy & Environmental Directorate 

 Pacific Northwest National Laboratory 

 902 Battelle Boulevard 

 P.O. Box 999, MSIN KS-22 

 Richland, Washington 99352 

 W.T. BUSCH 

 Senior Project Manager 

 HID Indoor and Commercial 

 Philips 

 938 South Green Street 

 Post Office Box 1687 

 Tupelo, Mississippi 38802-1687 

 ANDREW deLASKI 

 Executive Director 

 Appliance Standards Awareness Project 

 20 Belgrade Avenue, Suite 1 

 Boston, Massachusetts 02131 

 PETER FRANCK 

 Optical Engineer 

 Lightolier 

 631 Airport Road 

 Fall River, Massachusetts 02720 

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A G E N D A 

ITEM: PAGE: 

Morning Session

Welcome 6 

Introductions and Agenda Review 6 

 Doug Brookman 

Opening Remarks 13 

Regulatory History and Test Procedure 14 

 Mahima Gupta 

Energy Conservation Standard Rulemaking 17 

Overview and Scope of Coverage 

 Mahima Gupta and Doug Rossin 

Market and Technology Assessment and 49 

Screening Analysis 

 Brian Coffey 

Engineering Analysis 70 

 Mahima Gupta 

Markups for Equipment Price Determination 92 

 Robert Lingard 

Energy Use and End-Use Load Characteristics, 96 

Life-Cycle Cost and Payback Period Analysis 

 Robert Lingard 

Afternoon Session

Shipments Analysis, National Impact Analysis, 121 

And Life-Cycle Cost Subgroup Analysis 

 Michael Myer 

Manufacturer Impact Analysis 140 

 Doug Rossin 

Utility Impact Analysis, Employment Impact 157 

Analysis, Environmental Assessment, and 

Regulatory Impact Analysis 

 Michael Myer 

Other Issues and Comments; Closing Remarks 153 

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

2 (9:07 a.m.)

3 Welcome

4 MS. GRAVES: Good morning. I'm Linda Graves. 

5 I'm pleased to welcome you on behalf of the U.S. 

6 Department of Energy. 

7 This is a public meeting to introduce the 

8 first stage of the Rulemaking on Metal Halide Lamp 

9 Fixtures Standards and, as usual, we have our wonderful 

10 facilitator here with us, Doug Brookman, who will 

11 manage the agenda for us and keep us on target and with 

12 that, I'll turn the meeting over to Doug. 

13 Introductions and Agenda Overview

14 MR. BROOKMAN: Thank you. Good morning, 

15 everybody. Glad you could join us. Thanks for being 

16 here on time. We typically start these meetings by 

17 doing introductions, so we're going to do that. Please 

18 say your name and organizational affiliation. Not all 

19 of this will be completely recorded but we do have a 

20 registration list, so we'll know who's in the room with 

21 us. I'll start with Pekka. 

22 DR. HAKKARAINEN: I'm Pekka Hakkarainen, 

23 representing Lutron Electronics, and I'm also the Vice 

24 Chair of the NEMA Lighting Systems Division. 

25 MS. ENGLISH: And I'm Cheryl English. I'm 

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1 with Acuity Brands Lighting. We're a manufacturer of 

2 luminaires. 

3 MR. BUSCH: Bill Busch with Philips 

4 Daybright, manufacturer of luminaires. 

5 MR. ERHARDT: Bob Erhardt, Philips Lighting 

6 Electronics and also Chair of the NEMA Ballast Section. 

7 MR. HANSEN: Dain Hansen with NEMA, the 

8 National Electrical Manufacturers Association. 

9 MS. HORNER: Pam Horner with Osram Sylvania 

10 and also representing NEMA as the Lamp Section Chair. 

11 MR. HARDING: Tom Harding, Venture Lighting, 

12 manufacturer of metal halide lamp ballasts. 

13 MS. RAINER: Rebecca Rainer, Cooper Lighting, 

14 also the Vice Chair of the Luminaires Section for NEMA. 

15 MR. HIRT: Tom Hirt with Hubbell Lighting, a 

16 manufacturer of luminaires. 

17 MR. BROOKMAN: Let's double back this way. 

18 MS. FRIEND: Jessica Friend with Steptoe and 

19 Johnson. 

20 MR. SIMPSON: Dale Simpson with the Lighting 

21 Division of Philips, manufacturer of exterior 

22 luminaires. 

23 MR. SYPES: David Sypes with Philips. 

24 MR. BROOKMAN: We can go over here, please. 

25 MS. MAUER: Joanna Maurer, Appliance 

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1 Standards Awareness Project. 

2 MR. RAZON: Alvin Razon, National Rural 

3 Electric Cooperative Association. 

4 MR. BROOKMAN: I guess we just -- I thought 

5 we already tested them. We don't need this on the 

6 record. We know who's here. 

7 Please say your name and organizational 

8 affiliation. 

9 MR. LIS: Dave Lis, Northeast Energy 

10 Efficiency Partnerships. 

11 MR. FRANCK: Peter Franck with Philips 

12 Lightolier. 

13 MR. GREEN: John Green with Cooper Lighting, 

14 a manufacturer of luminaires and controls, also Vice 

15 Chair of the NEMA Ballast Section. 

16 MS. SULLIVAN: Meg Sullivan, Department of 

17 Energy. 

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

19 MR. ANDERSON: Eric Anderson, Pacific 

20 Northwest National Laboratory. 

21 Ms. Hazra: Oindrila Hazra, Pacific Northwest 

22 National Laboratory. 

23 MS. STEVENS: Amanda Stevens, Pacific Gas and 

24 Electric Company. 

25 MR. deLASKI: Andrew deLaski, Appliance 

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1 Standards Awareness Project. 

2 MR. STAS: Eric Stas, DOE. 

3 MR. LEWIS: Ron Lewis, DOE.

4 MS. GRAVES: Linda Graves, DOE. 

5 MS. GUPTA: Mahima Gupta, Navigant 

6 Consulting.

7 MR. COFFEY: Brian Coffey, Navigant 

8 Consulting.

9 MR. ROSSIN: Doug Rossin, Navigant 

10 Consulting. 

11 MR. LINGARD: Bob Lingard, Pacific Northwest 

12 National Laboratory. 

13 MR. MYER: Mike Myer, Pacific Northwest 

14 National Laboratory. 

15 MR. BROOKMAN: We have one announcement here 

16 at the outset. If anybody in the room's a foreign 

17 national and did not yet pre-register -- you're all 

18 set. You've got a badge. The department's careful 

19 about these matters. So if you are a foreign national, 

20 you need to see Brenda if you have not pre-registered. 

21 So let me welcome you, again glad you're 

22 here. 

23 Linda gave you the overview, the purpose of 

24 this meeting, this framework meeting. I'm going to do 

25 a very brief agenda review and then we're going to 

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1 launch right square into it. 

2 Immediately following this agenda review, 

3 there's an opportunity for anybody that wishes to do so 

4 to make opening remarks, brief summary statements about 

5 issues that are important to you. Following that, 

6 we'll go immediately into a description of the 

7 Regulatory History and Test Procedure, and then 

8 straight into Energy Conservation Standard Rulemaking 

9 Overview and Scope of Coverage. 

10 We'll take a break mid-morning, around about 

11 10:30 or so. Following that, a description, plus 

12 discussion, Market and Technology Assessment and 

13 Screening Analysis, then Engineering Analysis. We'll 

14 break mid-day for lunch, around about noonish, maybe a 

15 little later, and then from there, Mark-ups for 

16 Equipment Price Determination, Energy-Use and End-Use 

17 Load Characterization, Life-Cycle Cost and Payback 

18 Period Analysis, Shipments Analysis, National Impact 

19 Analysis, Life-Cycle Cost Subgroup Analysis, all of 

20 those analyses described. 

21 We'll take a mid-afternoon break and then go 

22 into Manufacturer Impact Analysis, and you can see the 

23 complement of them, Utility, Employment, Environmental 

24 Assessment and Regulatory Impact Analyses, all of 

25 those. 

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1 There's another opportunity for comment for 

2 anybody that wishes to do so at the end of the day, 

3 you'll see it listed in your agenda, and we intend to 

4 adjourn by 4:30 today. We'll try and be as efficient 

5 as possible. If we get there quicker, that's what 

6 we'll do. 

7 That's the plan for today. Questions and 

8 comments about the agenda as written? 

9 (No response.) 

10 MR. BROOKMAN: Let me note that there's also 

11 some additional room up here at the table. If any of 

12 you expect you're going to have a lot of comment and 

13 would want to, you're welcome to join us up here at the 

14 front table. 

15 I might ask for your consideration, in the 

16 span of these years doing these appliance standards 

17 meetings, we would ask for your consideration. Please 

18 speak one at a time. Please say your name for the 

19 record. There will be a full transcript of this 

20 meeting and if, each time you speak, you would say your 

21 name, that will make it clear who's speaking and who is 

22 not. You don't need to say your organizational 

23 affiliation. Please say your name for the record. 

24 I'll be queuing people by name as best I can 

25 to speak. I also wish to encourage follow-on comments. 

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1 Sometimes that follow-on comment is very useful for the 

2 Department as it tries to discern the information that 

3 appears here. 

4 If you could keep the focus here, please turn 

5 your cell phones on silent mode. Please limit the 

6 side-bar conversations. These microphones now work 

7 well, so we can hear you, and also there's a little 

8 green LED button. If it's not glowing green, it's not 

9 turned on. So if you can turn it on and off, please 

10 remember to turn it on and I'll try and remind you, 

11 and, finally, if you'd try and be concise, share the 

12 air time. There's a lot of ground to cover here, a lot 

13 of analysis, and we want to make sure we give it its 

14 full due. 

15 I think all of you received a packet as you 

16 came in the door. The general format for this meeting 

17 is that there are a whole lot of detail slides. We're 

18 going to be going through them one by one. There are 

19 also comment boxes for which the Department elicits 

20 comment. So that's the general plan and the way we 

21 intend to do this. 

22 Questions, comments here at the outset before 

23 we begin? 

24 (No response.) 

25 MR. BROOKMAN: Okay. I see nothing 

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1 additional. 

2 Linda Graves. 

3 Opening Remarks

4 MS. GRAVES: Okay. So the purpose of today's 

5 meeting is to present the procedural and analytical 

6 approaches to evaluate energy conservation standards 

7 for metal halide lamp fixtures. 

8 This meeting will provide a forum for public 

9 discussion of the rulemaking issues. 

10 We also encourage interested parties to 

11 submit data information and written comments. We also 

12 wish to inform interested parties and facilitate the 

13 rulemaking process. 

14 The public comment period for this meeting 

15 ends January 29th. So besides whatever comments occur 

16 during this meeting and they're on the transcript, the 

17 Department will also take into account any written 

18 submissions of comment. 

19 I hope that all of you have downloaded or 

20 have with you picked up the framework document that 

21 this meeting is based upon. There are issues of 

22 particular interest to the Department identified in the 

23 Framework document. The Issue Boxes in your 

24 presentation package correspond to those same numbered 

25 issues. 

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1 However, you are more than welcome to comment 

2 on any issue that you would like to raise, whether or 

3 not the Department has specifically addressed it as an 

4 issue of interest. 

5 And with that, I'll turn it over to Mahima 

6 Gupta to present the Regulatory Background. 

7 Regulatory History and Test Procedure

8 MS. GUPTA: Good morning. I'm Mahima Gupta, 

9 and I'm going to start off today's presentation with 

10 just a brief Regulatory History Overview and a summary 

11 of the Department's latest actions on the Test 

12 Procedure for Metal Halide Lamp Ballasts. 

13 So EPCA, the Energy Policy and Conservation 

14 Act, established the Energy Conservation Program for 

15 Appliances. EISA, the Energy Independence and Security 

16 Act of 2007, amended EPCA to provide several provisions 

17 related to metal halide lamp fixtures and metal halide 

18 lamp ballasts. 

19 Firstly, it directed DOE to develop a test 

20 procedure for metal halide lamp ballasts based on the 

21 ANSI Standard C82.6. It also directed DOE to 

22 incorporate standby mode and off mode standards in any 

23 subsequent energy conservation standards rulemakings. 

24 Specific to our framework meeting today, EISA 

25 prescribed energy conservation standards for metal 

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1 halide lamp fixtures by setting minimum ballast 

2 efficiency requirements and directed DOE to amend those 

3 standards by January 1st, 2012. 

4 In addition, EISA directed DOE to conduct a 

5 second rulemaking to amend the energy conservation 

6 standards with which it should complete by January 1st, 

7 2019. 

8 In July 2009, DOE published a Notice of 

9 Proposed Rulemaking, Test Procedure for Metal Halide 

10 Lamp Ballasts, and the final rule will be published 

11 shortly, but in that NOPR, DOE developed an active mode 

12 test procedure in accordance with ANSI C82.6. It also 

13 developed a standby mode test procedure which it 

14 preliminarily determined that was relevant only to 

15 dimming and DALI-enabled ballasts, and, finally, it 

16 made the preliminary determination that off mode is not 

17 a relevant mode of operation for metal halide lamp 

18 ballasts. 

19 And so in the context of increasing the 

20 energy conservation standards for metal halide lamp 

21 fixtures, DOE's requesting comment on whether any 

22 additional changes need to be made to the Test 

23 Procedure. 

24 MR. BROOKMAN: So let's pause there. You see 

25 the Issue Box that Mimi's referencing and also we want 

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1 to provide an opportunity, the Department does, 

2 opportunity for brief summary comments here at the 

3 outset now. Let's do that. 

4 Yes, please, Bob, you're up. 

5 MR. ERHARDT: Yes, Bob Erhardt. ANSI is in 

6 the process of issuing an updated method of 

7 measurement, C82.6. It should be released in 2010. 

8 It's our recommendation that DOE look to use the latest 

9 revision of ANSI 82.6. 

10 MR. BROOKMAN: Do you know when in 2010? 

11 MR. ERHARDT: I believe it is out for final 

12 comments, so it should be out by the next months. 

13 MR. BROOKMAN: Okay. Pretty quickly then. 

14 MR. ERHARDT: Yes. 

15 MR. BROOKMAN: Okay. Thank you very much. 

16 Other comments here at the outset? This is an 

17 opportunity for anybody to raise the issues that are 

18 important to them. 

19 Yes, Cheryl. 

20 MS. ENGLISH: Cheryl English. Thank you. 

21 Cheryl English, Acuity Brands Lighting. On the standby 

22 mode, the HID Systems typically are not used with 

23 dimming. However, there are systems that use wireless 

24 or signal type of control where there might be some 

25 minimal standby power. 

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1 So if you choose to consider a standby power 

2 consideration, I think my words of advice is just 

3 making sure that we re-evaluate the ballast efficiency 

4 of a ballast that's operating at a lower wattage. 

5 There's tremendous energy savings versus the small 

6 amount of standby power. 

7 MR. BROOKMAN: Okay. Thank you. Other 

8 comments here at the outset? 

9 (No response.) 

10 MR. BROOKMAN: So let me ask you, also, then 

11 to direct your attention to Item 5, Comment Box, and 

12 comments on whether it's necessary to update the Metal 

13 Halide Lamp Test Procedure, anything additional on 

14 that? 

15 (No response.) 

16 MR. BROOKMAN: Okay. Thank you. 

17 Energy Conservation Standard Rulemaking Overview and 

18 Scope of Coverage

19 MS. GUPTA: So now I'd like to just give you 

20 a brief Rulemaking Overview. 

21 So EPCA directs DOE to consider seven factors 

22 when citing energy conservation standards. These 

23 factors are listed on this slide and beside these 

24 factors are the analyses that DOE conducts to address 

25 these factors and we'll be discussing each of these 

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1 analyses in more detail throughout the day. 

2 Here's a brief timeline of the Metal Halide 

3 Lamp Fixtures Rulemaking. As you can see, we start off 

4 with the framework document and the public meeting that 

5 we're having today. Several months later, DOE will 

6 publish a preliminary analysis which will be 

7 accompanied by a public meeting in which DOE will 

8 welcome public input. 

9 Following that will be the Notice of Proposed 

10 Rulemaking and the public meeting for that NOPR and, 

11 finally, DOE plans to publish the final rule in 2012. 

12 Any amended standards in that final rule will become 

13 effective in 2015. 

14 For the first phase of the rulemaking, the 

15 framework document, DOE published the framework 

16 document on December 30th, 2009, and as Linda stated, 

17 the comment period for the framework document ends on 

18 January 29, and the framework document and any 

19 materials from this public meeting will be available at 

20 the web address listed on this slide. 

21 For the next phase, -- 

22 MR. BROOKMAN: Yes. We have a comment. 

23 Amanda. 

24 MS. STEVENS: Amanda Stevens, PG&E. Is there 

25 any way that DOE would consider extending that comment 

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1 period which is only a few days away to give folks more 

2 time to submit their written comments? 

3 MR. BROOKMAN: Ron Lewis. 

4 MR. LEWIS: We'll consider the request, but I 

5 can't answer it immediately on the spot. 

6 MR. BROOKMAN: Thank you. Okay, okay. 

7 MS. GUPTA: Okay. So for the second phase of 

8 the rulemaking, the preliminary analysis phase, DOE 

9 conducts several analyses, such as the Market and 

10 Technology Assessment, the Engineering Analysis, the 

11 Life-Cycle Cost and Payback Period Analysis, and the 

12 National Impact Analysis, which will all be discussed 

13 later today. 

14 In the Notice of Proposed Rulemaking stage or 

15 the NOPR, DOE revises the preliminary analyses in 

16 response to stakeholder comments and any updated 

17 resources that are available and DOE conducts several 

18 new analyses, such as the Manufacturer Impact Analysis, 

19 the Utility Impact Analysis, the Environmental 

20 Assessment, and, finally, in the final rule stage, DOE 

21 will revise the NOPR analyses in response to interested 

22 parties' input. 

23 So now I'll turn over the presentation to my 

24 colleague Doug Rossin to talk a little bit about scope 

25 of the rulemaking. 

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1 MR. ROSSIN: Thank you, Mimi. Good morning, 

2 everybody. My name is Doug Rossin. I'll be presenting 

3 the discussion on Scope of today's Metal Halide Lamp 

4 Fixtures Rulemaking, and I'll begin by discussing some 

5 provisions from EISA 2007. I'll discuss what's the 

6 current standards for metal halide lamp fixtures and 

7 then I'll get into what or how DOE plans to amend these 

8 standards. 

9 So Section 324 of EISA 2007 defines several 

10 key terms relevant to metal halide lamp fixtures and 

11 these include ballast, ballast efficiency, electronic 

12 ballast, metal halide ballast, and probe start and 

13 pulse start metal halide ballasts. 

14 EISA 2007 also defines the scope of metal 

15 halide lamp fixtures broadly as light fixtures for 

16 general lighting applications designed to be operated 

17 with a metal halide lamp and a ballast for metal halide 

18 lamp. So there's no mentioning of wattage, voltage, or 

19 starting method, for example. 

20 And, finally, EISA 2007 establishes standards 

21 for only a subset of all metal halide lamp fixtures and 

22 I'll get into this a little bit more in the next slide. 

23 So what are the current metal halide lamp 

24 fixture standards? Well, EISA 2007 begins by covering 

25 metal halide lamp fixtures that are designed to be 

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1 operated with lamps rated greater than or equal to a 

2 150 watts but less than or equal to 500 watts. 

3 Within this wattage range, metal halide lamp 

4 fixtures must contain ballasts that meet minimum 

5 ballast efficiency requirements set by EISA 2007. So, 

6 for example, a metal halide lamp fixture that contains 

7 a magnetic probe start, that probe start ballast must 

8 have a minimum ballast efficiency of 94 percent. So 

9 here again, we see that, depending on the type of 

10 ballast included in that fixture, you will have a 

11 different set of minimum ballast efficiency 

12 requirements. 

13 Also included in the standards are the 

14 exclusions set by EISA 2007 and these include fixtures 

15 with regulated lag ballasts, fixtures that use 

16 electronic ballasts that operate at 480 volts, and 

17 fixtures that meet these other three sets of 

18 requirements to be excluded. 

19 So now that we have an understanding of 

20 what's currently covered and what's the current 

21 standards, let's discuss how DOE plans to amend these 

22 standards. 

23 So although metal halide lamp fixtures may be 

24 composed of the fixture or housing itself, a ballast, 

25 and a lamp, EPCA sets minimum efficiency requirements 

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1 for only the ballast component of the fixtures. So for 

2 today's rulemaking that we're discussing metal halide 

3 lamp fixtures, DOE has preliminarily decided to only 

4 evaluate amending minimum ballast efficiency 

5 requirements as to be consistent with the EPCA approach 

6 and here we have our first item for comment, which is a 

7 request for comments on this approach to only amending 

8 the minimum ballast efficiency requirements. 

9 MR. BROOKMAN: Yes, Pam. 

10 MS. HORNER: Pam Horner. Well, the 

11 manufacturers have a few different ideas on this and 

12 they will be expressed more thoroughly in our formal 

13 comments on the 29th. 

14 While we realize that, as lamps in this 

15 category develop, the ultimate efficiency and efficacy 

16 of the luminaire, shall we say, is dependent on the 

17 lamp, the large point that the lamp manufacturers would 

18 like to make is that with the onset of the HID 

19 determination, lamp determination, I guess you could 

20 say that we, in general, would prefer to keep these 

21 items separate. 

22 To intertwine a lamp efficacy standard with a 

23 luminaire or, in this case, ballast discussion and then 

24 revisit it virtually simultaneously within the HID 

25 rulemaking, we think that the HID -- well, we think 

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1 it'll become an HID rulemaking -- that the HID 

2 rulemaking is the more appropriate place to address 

3 this. 

4 And one of the key points is that this 

5 particular rulemaking affects new luminaires. Lamp 

6 standards affect not just new luminaires but also 

7 existing. 

8 Thank you. 

9 MR. BROOKMAN: Just to clarify, Pam, you're 

10 speaking on behalf of NEMA? 

11 MS. HORNER: Well, I would say we do have an 

12 additional comment from one of our members that 

13 indicates that the efficacy of lamps could be 

14 considered as we start to talk about dimming 

15 capabilities. 

16 So, in other words, there's an issue here, 

17 but, in general, the lamp companies see the HID lamp 

18 rulemaking as the appropriate place to determine lamp 

19 efficacy. 

20 MR. BROOKMAN: So I guess we'll leave that to 

21 some interpretation. Bob. 

22 MR. ERHARDT: Yeah. I would like to offer 

23 some clarification in the -- we made a comment that the 

24 DOE may wish to consider not defining efficacy of lamps 

25 but defining -- but in evaluating the efficiency 

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1 requirements of ballasts take into consideration the 

2 type of lamps they are to operate. 

3 This was done in California. The California 

4 Energy Commission has put some allowances into their 

5 latest rulemakings, such that lamps that are recognized 

6 as being more efficacious, ballasts that are designed 

7 to operate lamp categories that are more efficacious 

8 have some allowance on their efficiency to discourage 

9 the use of lamp categories that are less efficacious. 

10 California also has put in some allowances 

11 for slightly lower ballast efficiencies if the ballast 

12 is capable of dimming. 

13 MR. BROOKMAN: Okay. Yes, please. 

14 MS. AMANN: Jennifer Amann, ACEEE. At this 

15 point in the rulemaking, we would encourage the 

16 Department to consider a broader range of opportunities

17 in metal halide fixtures, such as the State of 

18 California in their standards, and also the Outdoor 

19 Lighting Agreement that has been negotiated by industry

20 and the advocacy groups and is now before Congress 

21 includes other elements, including the actual fixture 

22 efficiency system, the full system, in different ways, 

23 whether it's lamp ballast, fixture efficiency itself, 

24 and potentially controls.

25 So at this early stage we would encourage DOE 

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1 to consider all of those components and not limit their 

2 analysis strictly to ballast efficiency. 

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

4 MR. deLASKI: I guess I have a follow-on 

5 question for Pam or a comment or question maybe to help 

6 clear up because I didn't sit through the California 

7 proceedings which many of you did, and I guess my 

8 question to you is typically we like to look at the 

9 system because it gives the manufacturers more 

10 opportunities to optimize the system according to their 

11 various strengths and to do it at the lowest cost and 

12 deliver the efficiency, as Pam has educated me on many 

13 instances, getting the light where people want it, and 

14 so I guess I'd ask the question, you know, in this 

15 instance, you know, why not do something that is more 

16 at getting the light where people want it as opposed to 

17 taking it piece by piece for the components of the 

18 system? 

19 MR. BROOKMAN: Pam. 

20 MS. HORNER: Pam Horner. Now, again, I 

21 haven't asked all 16 members of the NEMA Lamp Section, 

22 so allow me a little latitude here. 

23 I would say the general feeling is we are 

24 onboard with the system approach. What I was getting 

25 at here is that to isolate the lamp within this 

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1 rulemaking and give, you know, thou shalt have this 

2 efficacy for this lamp and that efficacy for that lamp 

3 seems out of place here. 

4 I hope -- generally, we are certainly onboard 

5 with the systems approach. We talk about it all the 

6 time at NEMA amongst all sections, but for lamp people 

7 the system is the luminaires. So I'm gong to have to 

8 turn this over to the luminaire folks to see how they 

9 would think about it. 

10 MR. BROOKMAN: Additional comments how you 

11 might suggest this differs from a system approach? 

12 Yes, Cheryl. 

13 MS. ENGLISH: Cheryl English, Acuity Brands. 

14 You know, I think we can certainly look at the system 

15 approach. We believe that's the smartest way to energy 

16 efficiency, but I think after last year we all realize 

17 that it's not simple and what ends up happening when we 

18 start getting into describing the distribution of a 

19 luminaire, we start having to talk about applications 

20 rather than products which makes it much more difficult 

21 to craft something that can be enforced and so, you 

22 know, if we choose to look at those things, we're 

23 talking about a much more complex analysis, a lot of 

24 analysis of lamp and ballast combinations. 

25 Luminaire manufacturers do not always sell a 

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1 fixture with a lamp included. If we look at requiring 

2 through Federal regulation to include a lamp, we're now 

3 putting our products in a class where we have to deal 

4 with hazardous substance because the lamps do contain 

5 mercury and then we have additional burden in terms of 

6 labeling, notification, reporting, and transportation 

7 issues related to hazardous substances. 

8 So it's more complicated. We all, you know, 

9 have lived through that last year and I think it's 

10 really what is DOE's appetite relative to the 

11 complexity and the analysis and your ability to enforce 

12 the regulations. 

13 MR. BROOKMAN: thank you. 

14 MR. deLASKI: So just to follow on, I think, 

15 Cheryl, in your reference to last year, are you 

16 referring to the outdoor lighting negotiations and to 

17 their recommendation which is now before Congress, and 

18 the approach taken in our -- that we all came up with, 

19 advocates in the industry together, was this notion of 

20 a table of standard lamps as a way to address the 

21 problem that you -- as Acuity, you don't make lamps. 

22 You don't package lamps in your products. So we needed 

23 this outcome of table of standard lamps. 

24 Is an approach along those lines plausible 

25 for this kind of product or, I mean, given your 

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1 experience or is it something -- or is this market 

2 different from the outdoor lighting that that approach 

3 wouldn't work? 

4 MS. ENGLISH: Cheryl English. The approach 

5 could certainly work. We would have to establish some 

6 kind of mid-level thresholds for the lamps to determine 

7 the overall fixture performance. So we wouldn't want 

8 to take the lowest common denominator because we're all 

9 trying to promote energy efficiency, but we have to be 

10 very careful that whatever that assumption is does not 

11 exclude some new technologies that might have favorable 

12 energy impacts. 

13 What we worked on last year for Congress was 

14 specifically a class of outdoor lighting. It didn't 

15 include all outdoor lighting. What this regulation 

16 deals with is any luminaire that my company makes that 

17 can use a metal halide lamp. So we're now talking 

18 about, you know, indoor and outdoor, in some cases some 

19 very specialized types of applications. 

20 If we go that route, then we may want to 

21 choose to define a narrow segment of product 

22 applications, much like we did in the outdoor 

23 regulation for Congress covered, area lighting, 

24 streets, pole-mounted luminaires. It didn't include 

25 wall-mounted which is included in this current EISA 

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1 bill. So there's some reconciliation. 

2 I'm a little concerned about if Congress does 

3 pass the outdoor bill, we've got to be very careful 

4 that we don't create a dual standard that makes 

5 additional challenges for luminaire companies. 

6 MR. BROOKMAN: Okay. Yes, Pekka. 

7 DR. HAKKARAINEN: Pekka Hakkarainen. I would 

8 also comment that since it is complicated to define the 

9 system, perhaps we should give the legislation that's 

10 before Congress right now a chance and see how well it 

11 works before we expand from the area of outdoor 

12 lighting regulation to other areas where we may run 

13 into difficulties. 

14 MR. deLASKI: I'm sure it's going to work 

15 great, Pekka. 

16 MR. BROOKMAN: Having been negotiated in its 

17 normal fashion, it's a breeze, right? Okay. 

18 Additional comments on this subject? Yes, 

19 Bob Erhardt. 

20 MR. ERHARDT: Yeah. Bob Erhardt. I think 

21 there's an opportunity to comment further on this later 

22 on, but one thing to take into consideration when 

23 looking at ballast and ballast efficiency, in effect 

24 perhaps driving towards electronic ballast, is the 

25 impact on the overall redesign of the luminaire and the 

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1 impacts of the overall costs of redesigning the whole 

2 luminaire to accommodate electronic ballasts. 

3 MR. BROOKMAN: Pam, did you have additional 

4 comment? 

5 MS. HORNER: Yes, Pam Horner. I just wanted 

6 to echo from the lamp perspective a phrase that Cheryl 

7 just stated and not to let it get lost among DOE and 

8 the consultants and that is that the last thing the 

9 lamp industry needs is two sets of standards. 

10 So as we move forward with the HID lamp 

11 determination/rulemaking that does include metal halide 

12 and I just want to caution that that would be untenable 

13 for us should that happen. 

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

15 Amanda. 

16 MS. STEVENS: Amanda Stevens for PG&E. So 

17 following on Andrew and Jen's comments on maybe looking 

18 a little bit broader than just ballast efficiency, 

19 specifically I was wondering and maybe the 

20 manufacturers could comment specifically on metrics, 

21 such as TER or FTE that's being used in the ENERGY 

22 STAR® Program. 

23 I saw that for when setting the ENERGY STAR 

24 criteria for some outdoor LED luminaires, DOE had 

25 evaluated several hundred HID luminaire photometric 

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1 files in order to establish the baseline in order to 

2 then set the ENERGY STAR criteria level. So that may 

3 be one source of data that DOE might already draw upon 

4 when looking at some of these other metrics, but, you 

5 know, I recognize that there is potentially a lot of 

6 complexity associated with going that route. 

7 So if the manufacturers or DOE had any 

8 specific comments on FTE or TER, that might be helpful. 

9 MR. BROOKMAN: I guess we'll look to the 

10 manufacturers first. Cheryl English. 

11 MS. ENGLISH: Cheryl English. I believe that 

12 actually ENERGY STAR has a different metric than FTE 

13 because there were a number of comments about the 

14 applicability of the FTE metric and I think it's also 

15 important that we're here talking about a regulatory 

16 approach, not a market transformation. 

17 If you use something like that in regulatory, 

18 you will obsolete some niche products that are very 

19 critical to certain applications. So my opinion on 

20 behalf of Acuity Brands is that that would be a very 

21 problematic approach for a regulatory process. 

22 MR. BROOKMAN: Yes. Please say your name and 

23 organizational affiliation. 

24 MR. SIMPSON: Dale Simpson with 

25 Philips/Gardco. Just a comment on the comment about 

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1 FTE and the ENERGY STAR regulation. 

2 There's currently a task force within NEMA 

3 working with DOE to potentially look at an alternate 

4 metric and there is some concern, some serious concern, 

5 I believe, on the part of NEMA members about the fitted 

6 target efficiency metric. 

7 So just in general, the other question I have 

8 is whether within the scope of EISA is to really go 

9 into the level of detail all the way to pure luminaire 

10 efficiency or whether the scope really is proper to 

11 look at perhaps lamp and ballast efficiency together or 

12 just ballast efficiency. That's just a question that I 

13 would have. 

14 And the complexity, I would echo that the 

15 complexity of trying to get into a targeted measure for 

16 each of what could be 20 or more applications that 

17 would have to be defined. We learned just in trying to 

18 define one subset of applications in outdoor lighting 

19 that it's pretty difficult. 

20 MR. BROOKMAN: Thank you. Appreciate that. 

21 Yes, Rebecca. 

22 MS. RAINER: Yes. Just to echo those 

23 comments, you had talked about the outdoor legislation 

24 and the photometric data that we reviewed. 

25 My company just for the outdoor, just for 

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1 that small section that we looked at, reviewed almost 

2 7,000 photometric files, and just to echo the 

3 complexity of the situation, we would be looking at 

4 somewhere over 20,000 photometric files to pull in all 

5 the data. 

6 MR. BROOKMAN: Thanks for that. That's 

7 useful. Okay. 

8 So additional comments on this stream? Mimi 

9 Gupta. 

10 MS. GUPTA: I just wanted to ask a follow-up 

11 question to Bob. Either today or in your written 

12 comments, could you provide more detail on what kind of 

13 luminaire redesign would be necessary as you increase 

14 ballast efficiency? 

15 MR. BROOKMAN: Bob. 

16 MR. ERHARDT: Yes, I think NEMA's going to be 

17 giving more detail further on. In principle, we had 

18 some comment and that's why I made the comment at this 

19 point, but later on when we start talking about 

20 technologies, we have some further detail. 

21 In principle, the form factor and thermal 

22 requirements of an electronic ballast are significantly 

23 different than that of an electromagnetic ballast and 

24 therefore it is generally the case that when a 

25 luminaire manufacturer wishes to use an electronic 

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1 ballast, that there is a luminaire redesign or a new 

2 design associated with it. It is not a drop-in 

3 replacement and that's what I was referring to. 

4 MR. BROOKMAN: Yes, please. 

5 MR. SIMPSON: Dale Simpson. I'd like to 

6 amplify Bob's comment just a little bit and 

7 specifically to exterior luminaires, a change, say, 

8 from electromagnetic to electronic ballast creates a 

9 different form and thermal characteristics which may 

10 necessitate larger housings, sometimes even larger 

11 poles to hold those larger housings up in an exterior 

12 environment. 

13 So it is, in our opinion, improper to just 

14 look at the difference of acquisition costs between 

15 ballast A and ballast B. You also have to look at the 

16 whole effect it has on the system switching from 

17 ballast A to ballast B and that cost sometimes in our 

18 analysis can be as much as 10 times the additional cost 

19 of the ballast alone. So going from A to B may inflate 

20 the system cost by up to a 10-time multiplier. 

21 MR. BROOKMAN: Okay. Thank you. Are we all 

22 set? We're going to move on here. Okay. Let's go. 

23 MR. ROSSIN: Okay. So also part of amending 

24 energy conservation standards, DOE is looking to expand 

25 the scope of the energy conservation standards for this 

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1 rulemaking. 

2 So DOE is considering expanding to include 

3 metal halide lamp fixtures that are designed to operate 

4 with lamps rated below a 150 watts and above 500 watts. 

5 DOE is also considering including fixtures that were 

6 specifically excluded by EISA 2007 and here we see a 

7 graph which is snapshot of the metal halide lamp 

8 ballast market prior to 2009 and this data that you see 

9 there was taken from the manufacturers' catalogs and 

10 the efficiencies were calculated based on that 

11 information. 

12 The shaded blue box, I guess, that you see 

13 there is the wattage range that EISA prescribes 

14 standards for. Now DOE, by considering expanding the 

15 scope to include all these other units, sees the 

16 potential to have significant energy savings. 

17 So here we have the other two items for 

18 comment. Specifically, if DOE should include the metal 

19 halide lamp fixtures rated below 150 watts and above 

20 500 watts and also to include the fixtures that were 

21 excluded by EISA. 

22 MR. BROOKMAN: Bob Erhardt. 

23 MR. ERHARDT: NEMA recognizes that currently 

24 the rulemaking only looks at one slice of the range, 

25 but while the total number of SKUs, if you will, or 

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1 ballast models indicates a high number of products 

2 outside the current covered range, in actuality, more 

3 than half or I think our numbers indicate 60 percent of 

4 the total energy usage of metal halide luminaires falls 

5 within the range specified. 

6 Furthermore, while, at the lower end, there 

7 does on a percentage basis, if you look at the range of 

8 ballast efficiencies, it does represent the highest 

9 range of ballast efficiencies, the total energy use of 

10 the sector is very low, is rather low, and there is 

11 already a pretty strong market transition already to 

12 the higher-efficient product and so we recommend that 

13 the DOE take this into consideration when determining 

14 the energy impact of further rulemaking. 

15 At the higher power levels, there is 

16 significant power being used but these generally are 

17 rather highly-efficient ballasts to begin with and it 

18 may be questionable if further gains in ballast 

19 efficiency can be realized. 

20 MR. BROOKMAN: Do you have a specific 

21 recommendation with respect to these lower-powered 

22 units? 

23 MR. ERHARDT: I'm sorry? 

24 MR. BROOKMAN: I didn't understand your 

25 comment. It's useful to tell the Department what you 

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1 think it should do. 

2 MR. ERHARDT: Well, as NEMA, companies, 

3 various companies have their opinions and so -- 

4 MR. BROOKMAN: This is not a unified 

5 position. What is your position? 

6 MR. ERHARDT: Philips Lighting Electronics 

7 does not think the impact of energy savings at the 

8 lower power levels warrants additional rulemaking. 

9 MR. BROOKMAN: Okay, okay. Thanks for that 

10 clarity. So additional thoughts, comments on these two 

11 issue boxes here? Yes, Pam. 

12 MS. HORNER: Pam Horner. From a lamp 

13 perspective, we simply have a question. We sort of ran 

14 into this issue when we dealt with mercury vapor lamps. 

15 So ahead of the game, we want to make certain 

16 we understand that this is for general lighting 

17 applications. What can happen and the reason I'm 

18 questioning this is what can happen inadvertently with 

19 these types of rulemakings is one can snag the dolphins 

20 with the fish and so you end up with, for example, 

21 specialty projector lights and display lights getting 

22 swept in to this without concern. 

23 So I wanted to clarify today for the lamp 

24 section if those lamps and systems are included or 

25 excluded from this rulemaking. 

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1 MR. BROOKMAN: Mimi Gupta. 

2 MS. GUPTA: I don't think that the statute 

3 specifically excludes any applications. If there are 

4 specialty applications in the wattage ranges or 

5 exclusions of EISA that the manufacturers or any 

6 interested parties believe DOE should exclude, then I 

7 would encourage you to submit those comments. 

8 MS. HORNER: Okay. Thank you. 

9 MR. BROOKMAN: Thank you. Additional 

10 comments on these two issue boxes, particularly related 

11 to expansion of the scope? Andrew. 

12 MR. deLASKI: So we support the approach the 

13 Department's taking on this. I kind of quibble a 

14 little bit with the phrasing of Item 2. They're in the 

15 scope, the statute, but this isn't a question of the 

16 discretion of the agency to consider the scope. 

17 I think Bob put it right. It's the question 

18 of where does the analysis take you in terms of, you 

19 know, do the sales and the savings merit a standard I 

20 think is a separate question, but they're clearly in 

21 the scope under the statute. So I think there's an 

22 obligation for the Department to evaluate the products 

23 as you've scoped them. 

24 And then I think to Pam's point, if certain 

25 products need to be excluded, then that calls for, I 

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1 think, coming up with specific narrow exclusions that 

2 address those niche applications that need the 

3 exclusion, but I think the statute, I think, speaks for 

4 itself in terms of the scope being broad. 

5 MR. BROOKMAN: Okay. Thank you. Mimi Gupta. 

6 MS. GUPTA: Actually, I was completely 

7 incorrect. So the statute does say that it's for 

8 general lighting applications, but I would note that 

9 the definition of general lighting application is not 

10 extremely crisp and clear. So if NEMA has 

11 recommendations on how to specify that definition. 

12 MR. BROOKMAN: Thank you, Mimi. Thank you. 

13 Yes, Jennifer. 

14 MS. AMANN: Jennifer Amann, ACEEE. Actually, 

15 I think the general lighting application definition 

16 would address the issue that you raise, Pam, as it has 

17 in previous rulemakings. It is the term "general 

18 lighting application" means lighting that provides an 

19 interior or exterior area with overall illumination. 

20 So it could be tightened but at least for projectors or 

21 other, you know, devices, I think it might be. 

22 MR. BROOKMAN: Andrew. 

23 MR. deLASKI: This is maybe a question for 

24 the Department. If stakeholders and the Department 

25 decided that further clarification was needed in 

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1 regulatory language, you could enhance that definition 

2 to give folks more comfort that what was excluded and 

3 what's not based on -- I see nodding. 

4 MR. BROOKMAN: I see some heads nodding. Do 

5 you wish to respond affirmatively for the record? Eric 

6 Stas. 

7 MR. STAS: Eric Stas, DOE. DOE can always, 

8 you know, put different definitions in the CFR, as long 

9 as it's not violating the statutory definition. We can 

10 certainly clarify it. 

11 MR. BROOKMAN: Thank you. Thank you. That's 

12 useful. Okay. Are we ready? Ron Lewis. 

13 MR. LEWIS: One other recent practice in the 

14 last year to two years has been where things have come 

15 out after the fact where we are directed by the 

16 statutes which are not always crisp and clear, I think 

17 as Mimi indicated. 

18 Where there are times of confusion and 

19 there's some comment given to us, there's some dialogue 

20 that takes place in these meetings, there's some 

21 comment from the stakeholders that helps to clarify, we 

22 have been posting Frequently Asked Questions on our 

23 website for a lot of the rulemakings where there has 

24 been confusion. 

25 So I think doing it upfront and doing what we 

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1 can within the CFR language is certainly our 

2 preference, but even afterwards, if there are points of 

3 confusion and somebody has something that they believe 

4 substantially contributes to the clarity, please get 

5 those to us and even later on we can put those up as 

6 Frequently Asked Questions. 

7 MR. BROOKMAN: To clarify, yes. Okay, okay. 

8 So we're going to move on now. 

9 MR. ROSSIN: Okay. And finally, we can 

10 discuss standby mode and off mode standards. 

11 As previously stated, EPCA directed DOE to 

12 incorporate standby mode and off mode standards into 

13 all of its rulemakings that are to be completed by July 

14 2010. 

15 In the 2009 NOPR, Metal Halide Lamp Ballast 

16 Test Procedure, DOE preliminarily found that while it 

17 was possible for metal halide lamp ballasts to operate 

18 in the active mode and standby mode, the off mode 

19 conditions were not applicable. Therefore, in this 

20 rulemaking, DOE is only considering the active mode and 

21 standby mode energy use provisions from EISA 2007 and 

22 here we have another item for comment, specifically if 

23 DOE should take into consideration these standby mode 

24 and active mode only and also on which metal halide 

25 lamp fixtures operate in the standby mode, and 

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1 additional comments that you see there in the list. 

2 MR. BROOKMAN: Bob. 

3 MR. ERHARDT: In general, very few. I'm not 

4 aware of any currently luminaires that are using power 

5 in the standby mode. It can be moving forward some 

6 electronic ballasts, if they're using the digital 

7 protocol, the DALI system, they will have some power 

8 consumption in the standby mode. So it is possible 

9 that some luminaires using dimming or controls may use 

10 some power in standby mode, but, generally speaking, 

11 metal halide luminaires currently, for the most part, 

12 aren't using power in the standby mode. 

13 MR. BROOKMAN: Okay. Additional comments on 

14 these two issues? Yes, Pekka. 

15 DR. HAKKARAINEN: So following up to what Bob 

16 was saying, I think it's premature to define standby 

17 mode limits for a class of products that doesn't yet 

18 really exist in the marketplace. I think we need to 

19 let that product class develop a little bit to see what 

20 happens. 

21 MR. BROOKMAN: Okay. Thank you. You wish to 

22 follow on? No. Okay. Andrew. 

23 MR. deLASKI: Yeah. This is a follow-on. 

24 I'm not sure if it's for Pekka or Cheryl who commented 

25 earlier. I think the gist of the earlier comment was 

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1 that the -- I think it was Cheryl, that the savings, 

2 you know, that you're going to get from controls are 

3 going to dwarf what you might consume in standby mode, 

4 and I'm wondering if you could comment on, you know, 

5 when you -- looking ahead to sort of products that 

6 might be coming down the pike using controls 

7 approaches, what kind of savings, you know, are you 

8 talking to your -- are you hoping that those kind of 

9 products will deliver? 

10 MS. ENGLISH: Okay. Cheryl English, Acuity 

11 Brands. To reiterate Bob's comment, it's very few 

12 today that actually use a type of control system that 

13 would utilize standby power, typically wirelessly14 controlled luminaires, and speaking only for my company 

15 but that is a class of kind of emerging roadway 

16 products. 

17 The wireless controls not only allow a 

18 utility to tune the lighting relative to the 

19 demographics or traffic patterns but they provide a 

20 very significant utility to electrical utilities 

21 relative to safety. They can monitor outages, address 

22 those outages much more quickly than they can without 

23 the centralized management systems. 

24 So I don't really have enough data on it at 

25 this time because it's not a widely-used technology. I 

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1 just would caution that if we include a standby power, 

2 we'll want to look specifically at that class of 

3 products that have the potential between now and 2015 

4 to provide significantly more energy savings through a 

5 centralized energy management system by tuning the 

6 lights down by 40 or 50 percent or even off in some 

7 cases. 

8 There's a potential for large areas, like 

9 stadium parking lots, where a centralized control can 

10 be at various levels of power or off to really provide 

11 significant energy savings. 

12 Any small amount of standby power is going to 

13 be dwarfed in comparison. So that just needs to be 

14 included in that analysis if we choose to address this. 

15 MR. BROOKMAN: Thank you. Bob Erhardt. 

16 MR. ERHARDT: Yeah. To elaborate a little 

17 bit on Cheryl's, metal halide lamps can be dimmed, 

18 generally speaking, up to 50 percent. The typical 

19 systems will dim them by 45 percent to have some 

20 margin. 

21 Depending on the application, as Cheryl says, 

22 parking lots in the evening that may have little or no 

23 usage, warehouses where various rows of product may see 

24 a forklift once or twice a day can be dimmed for 

25 significant periods of time. 

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1 There's some usage in roadway where, during 

2 the periods from, let's say, midnight until 4 a.m. or 

3 something or 11 to 4 a.m., you may dim the lamps a bit 

4 when there's not the high usage and while they're 

5 dimmed you can see power savings of 30 or 40 percent, 

6 30 to 50 percent, actually, which, on, for instance, a 

7 400-watt metal halide results in dramatic energy 

8 savings. 

9 MR. BROOKMAN: Okay. Thank you. Yes, Dale. 

10 MR. SIMPSON: Dale Simpson. We'd just like 

11 to request some clarification. I presume or I'm 

12 presuming that standby mode would mean the amount of 

13 power consumed when the luminaire is producing 

14 absolutely no light or the amount of power consumed 

15 when it's producing light at the lower of two levels. 

16 Which is defined as standby mode? 

17 MR. STAS: Well, there is a statutory 

18 definition of off mode. 

19 MR. BROOKMAN: Eric Stas. Michael, do you 

20 know? 

21 MR. MYER: Michael Myer, PNNL. It's more 

22 towards the first answer of it's not producing light 

23 but the statutory definition doesn't say those specific 

24 words and the Test Procedure specifically removed the 

25 no-producing light because of a fault load issue if the 

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1 lamps failed and the ballast is active. 

2 So, in essence, it's when it's not producing 

3 any light, what is the power draw there, but the actual 

4 definition has some other words in it that deal with 

5 the fault load issue but that's the idea, yes. It's 

6 performing one or more functions that is not the main 

7 function is the technical word. You know, the main 

8 function, of course, is powering the lamp. In this 

9 case, it would be possibly powering a clock or a 

10 wireless signal or something else. That's a secondary 

11 function but that's the gist of it. 

12 MR. STAS: Eric Stas, DOE. And if you want 

13 to just check when you go back, it's 42 USC 

14 6295(gg)(1)(3) is the statutory definition and when the 

15 Test Procedure final rule comes out, you'll get more 

16 clarification. 

17 MR. BROOKMAN: Okay. Dale, yes. 

18 MR. SIMPSON: Just so I'm understanding, so 

19 standby mode is that when it's not supposed to be 

20 producing light? 

21 MR. MYER: Yes. 

22 MR. SIMPSON: But may be consuming power? 

23 MR. MYER: Yes. Michael Myer, PNNL, again. 

24 In the roadway instances everyone's been talking about, 

25 at 4 o'clock in the afternoon in the summer when you're 

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1 not expecting any light, it's probably drawing a little 

2 power to talk to central control system. That's the 

3 power we're talking about, yes. 

4 MR. BROOKMAN: Thank you, Michael. Thank 

5 you. Okay, okay. Yes, Amanda. 

6 MS. STEVENS: Amanda Stevens for PG&E. So 

7 when we're talking about the standby load of the 

8 luminaire, I'm assuming we're talking about the standby 

9 load of the ballast as well as any other component or 

10 sensor that's in the luminaire, is that correct, or are 

11 we just -- or is DOE Test Procedure measuring the 

12 standby load that's associated with just the ballast? 

13 Just kind of a point of clarification, I think. 

14 MR. BROOKMAN: Mimi Gupta. 

15 MS. GUPTA: In the NOPR, since the NOPR Test 

16 Procedure only addresses the ballast, it only provides 

17 test procedures for the standby mode of the ballast, 

18 but DOE's required to look at standby mode for metal 

19 halide lamp fixtures, so if an interested party 

20 believes that we should look at standby mode in the 

21 fixture context the please comment. 

22 MS. STEVENS: Yeah. I don't have any data 

23 and so maybe the manufacturers have a better sense, but 

24 I would be curious to just know what the standby load 

25 is from the other components outside the ballast, as 

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1 well, just to know if that's significant, receivers or 

2 different occupancy sensors, things like that. I don't 

3 have a sense, but it would be worth -- I would 

4 recommend that DOE at least look for some data on that 

5 to assess if it's significant. 

6 MR. MYER: This is Michael Myer, PNNL. In 

7 related work and I'd like the manufacturers to comment, 

8 we're seeing it around two watts or possibly less. It 

9 depends on a couple of devices, but two watts or around 

10 there is what we've found. 

11 MR. BROOKMAN: For those parts she listed? 

12 MR. MYER: Yes, extraneous devices, like 

13 photo-sensor or occupancy sensor, other devices that 

14 are being controlled, that are being somewhat powered 

15 by the ballast. 

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

17 Thank you. Okay. I'm eager for us to move on. Yes, 

18 let's go. 

19 MR. ROSSIN: And that concludes the Scope. 

20 So I think we had a break or -- 

21 MR. BROOKMAN: Let's keep going another 20 

22 minutes. 

23 MR. ROSSIN: So I'll pass along to my 

24 colleague, Brian Coffey, who will present the next 

25 stage that talks about Market and Technology 

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1 Assessment. 

2 Market and Technology Assessment and Screening Analysis

3 MR. COFFEY: Market and Technology Assessment 

4 is the first of nine parts of the Preliminary Analysis 

5 and its purpose is to get information about markets, 

6 manufacturers, and ways that one could think about 

7 improving equipment efficiency. 

8 So that would include, for example, learning 

9 about manufacturers, shipments, market shares and 

10 trends, both regulatory and non-regulatory initiatives 

11 intended to improve efficiency and opportunities for 

12 technological improvements in design and manufacturing. 

13 The Market and Technology Assessment is 

14 important because it serves as a basis for later 

15 analyses yielding, as you can see, technology options 

16 for the Screening Analysis that themselves become 

17 design options in the Engineering Analysis and also 

18 equipment classes directly to the Engineering Analysis. 

19 Of course, we'll talk about both of these analyses 

20 later. 

21 So in Item 6 and 7 here, DOE asks for comment 

22 on the key inputs to the Market and Technology 

23 Assessment, market shares, equipment features, 

24 efficiency trends, manufacturers and distribution 

25 channels for covered equipment. 

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1 MR. BROOKMAN: Comments on that listing of 

2 variables? 

3 MS. HORNER: Just a second. 

4 MR. BROOKMAN: Okay. 

5 MS. HORNER: Let me get the notes. 

6 MR. BROOKMAN: Bob Erhardt. 

7 MR. ERHARDT: Are you asking market shares of 

8 luminaire classifications? 

9 MR. COFFEY: It's an open-ended question. 

10 Any information relating to that. 

11 MR. ERHARDT: Okay. NEMA will be supplying a 

12 detailed formal response, but if one weights the sales 

13 and power usage by classification, the 150-to-500-watt 

14 range represents about 54 percent of the energy usage, 

15 the over-500-watt range represents about 40-41 percent 

16 of the energy usage, and the less-than-150-watt range 

17 represents about six percent of total energy usage. 

18 MR. BROOKMAN: Thank you. Pam, please. 

19 MS. HORNER: Pam Horner. I was just reading 

20 some notes from my ballast lady. She indicated, and, 

21 Bob, please correct me if I'm wrong, but in a recent 

22 call among NEMA to express cooperation with DOE to 

23 provide this information, that they desired to provide 

24 it as two lists, one from the ballast manufacturers and 

25 one from the luminaire manufacturers, is that correct? 

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1 MR. BROOKMAN: So I see Cheryl nodding yes 

2 and Rebecca nodding yes, also. So that's your desire 

3 from NEMA. Okay. Thank you for that clarification. 

4 Additional comments? You see the comment 

5 boxes there. 

6 MR. LEWIS: Doug? 

7 MR. BROOKMAN: Yes, Ron. 

8 MR. LEWIS: This is the early stage of this 

9 rulemaking, but we end up many times further down the 

10 road where we've been waiting for data and there have 

11 been difficulties in getting data. We have a couple of 

12 them right now where we've been greatly disappointed on 

13 how long it took us to get data and, in fact, sometimes 

14 there were things presented to us very late in the 

15 ballgame where people said they couldn't present it 

16 when the expectancy was there to get it. 

17 So it's really important that we get data 

18 quickly, but, secondly, the disaggregation of things to 

19 the degree that it can be disaggregated, if there's 

20 information that is like pulse start versus probe 

21 start, if there are things that would help us since 

22 there are going to be impacts on the efficiency, things 

23 that would be noteworthy that we should be considering, 

24 things that you would want to make sure that we're not 

25 with a broad brush setting requirements on products 

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1 that don't have those capabilities because they're 

2 confined to a certain technology. 

3 To the degree that you can give us 

4 disaggregated information that would be very helpful. 

5 MR. BROOKMAN: Okay. Thank you. Yes, okay. 

6 Cheryl English. 

7 MS. ENGLISH: As you know, Ron, you know, 

8 through NEMA we can consolidate data and prepare 

9 information for you and really try to customize it 

10 relative to this rulemaking. 

11 Where we start to get into challenges of 

12 disaggregating is when we start talking about 

13 applications. So if we can talk about lighting 

14 technologies, we do not track sales based on ballast 

15 efficiency. We don't track sales based on photometric 

16 performance, but we can try to distil that down and I 

17 fully appreciate where you're trying to get to is that 

18 data will help us define where is an energy savings 

19 potential and where are we really focusing a lot of 

20 effort but we're not going to get the energy savings. 

21 So I think through NEMA, you know, we can 

22 start to craft what a framework of that data would be, 

23 make sure upfront that it's going to make sense for the 

24 analysis, and then go back and try to aggregate or 

25 disaggregate that data for you. 

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

2 MR. COFFEY: So with Slide 34 here, we launch 

3 into a discussion of equipment classes for each of 

4 which DOE may establish separate conservation 

5 standards. 

6 The equipment is divided into classes based 

7 on the type of energy used and, maybe more 

8 interestingly, capacity and other performance-related 

9 features that affect consumer utility. 

10 In the case of metal halide lamp fixtures, 

11 DOE considered using a number of features to set 

12 equipment classes which we'll briefly touch on, but a 

13 review of manufacturer catalog data led DOE to 

14 initially use only rated lamp wattage and input voltage 

15 in setting equipment classes. So that can mean, as you 

16 see here, using one of two different approaches. 

17 In the case of rated lamp wattage, for 

18 example, one could split the equipment range into bins 

19 and set a separate standard for each. Alternatively, 

20 on the right is the option just to set efficiency 

21 requirements based on a continuous function of wattage. 

22 So here's one possible way to set equipment 

23 classes using both wattage and voltage. The wattage 

24 numbers come straight from EISA 2007 with the obvious 

25 expansion of coverage above 500 watts and below 150 

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1 watts. The voltage divisions reflect the fact that 

2 different utility could exist at different levels of 

3 electrical service. 

4 DOE has also identified a number of 

5 characteristics that at least initially don't appear to 

6 provide both unique consumer utility and inherently 

7 lower efficiency and because of that, DOE is not 

8 initially considering using them to set equipment 

9 classes. 

10 For example, most ballasts that DOE came 

11 across in its preliminary catalog review were designed 

12 to operate a single lamp. A handful of those could 

13 operate more than one lamp, but they didn't appear to 

14 have notably different efficiency. 

15 The next three, starting method, electronic 

16 configuration and circuit type, absolutely did seem to 

17 correlate to efficiency, although it wasn't obvious 

18 that the different choices there provided unique 

19 consumer utility and they seemed in many cases to be 

20 used as direct substitutes for one another. 

21 Finally, there are a number of ballasts that 

22 are able to operate at two or more input voltages or a 

23 range of input voltages and initially DOE does not 

24 understand that to provide unique consumer utility. 

25 So at the end of the market portion of the 

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1 Market and Technology Assessment, DOE requests comment 

2 on equipment classes and how to define them, how 

3 ballast efficiency correlates to both lamp wattage and 

4 input voltage, information useful in setting the number 

5 and range of wattage bins, and as we just mentioned, 

6 how best to address the case of universal voltage 

7 ballasts. 

8 MR. BROOKMAN: That was a good summary. 

9 Comments? Bob Erhardt. 

10 MR. ERHARDT: Yes. We do challenge the 

11 assumption that the product classes are directly 

12 interchangeable. As we stated earlier, electronic 

13 ballasts are not direct replacements for electro14 magnetic products and do require a dedicated luminaire 

15 for them to operate properly. 

16 Also, as far as utility of multiple voltages, 

17 it is the norm and not the exception for ballasts to be 

18 operating either for an electromagnetic as multi-tap or 

19 if it's an electronic it's universal input. 

20 In the case of electromagnetic ballasts, for 

21 instance, there is additional utility. A ballast 

22 running at 277 volts or 480 volts will generally have a 

23 120-volt tap that will operate on auxiliary equipment. 

24 It's not expected that this product is going to be 

25 operating at a 120 volts, and also while it's not a 

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1 true utility function, it does have an impact on the 

2 cost because by decreasing total number of SKUs and 

3 improvement of distribution, having multiple voltages 

4 off of a given product do aid in allowing a wider 

5 variety of products to be distributed in the 

6 marketplace and at a lower cost than would be the case 

7 if there were dedicated voltages. 

8 MR. BROOKMAN: Okay. Thank you. Jennifer.

9 MS. AMANN: Jennifer Amann. Yes, in reading 

10 through and looking at the proposal to eliminate 

11 starting method in electronic configuration, one of the

12 concerns that came up for us in our review is that, 

13 given the existing standards set out in EISA, depending

14 on the levels established in this rulemaking, it could 

15 run afoul of the rollback provisions.

16 If you look, the standard for magnetic probe 

17 start is a 94 percent ballast efficiency and so 

18 establishing any lower standard that covered those 

19 products would violate the rollback provision, in our 

20 understanding. We'd certainly appreciate any insight 

21 on that. 

22 MR. BROOKMAN: Thank you. Okay. Yes, Pam 

23 Horner. 

24 MS. HORNER: Pam Horner. I have a question 

25 for Bob Erhardt. 

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1 MR. BROOKMAN: Do you want to take this out 

2 of the room? 

3 MS. HORNER: No. 

4 MR. BROOKMAN: Go ahead. 

5 MS. HORNER: To take your statement further 

6 which we agree with that you use multi-tap for lots of 

7 reasons, universal voltages for lots of reasons in the 

8 market, they're the most common, would you also further 

9 state that any standards that might be set should be 

10 based upon those types and not on the single voltage 

11 type? 

12 MR. ERHARDT: Yeah. I think that -- yes. 

13 MS. HORNER: Okay. Because I was going to 

14 say while that is all true, would you then further 

15 recommend -- 

16 MR. ERHARDT: My assertion didn't imply we 

17 would -- 

18 MS. HORNER: Thank you. 

19 MR. ERHARDT: We do not agree with separating 

20 into voltage bins as has been proposed. 

21 MR. BROOKMAN: Bob, thank you. So the answer 

22 is yes. 

23 MR. ERHARDT: Yes. 

24 MR. BROOKMAN: Okay. Thank you. Great. Let 

25 me see. 

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1 MR. HARDING: Tom Harding. 

2 MR. BROOKMAN: Tom, please. 

3 MR. HARDING: Just a comment about the bins 

4 that were proposed where you have separation of lower 

5 than 150 watts and then you have 150, 250, 250, 500, 

6 and you separate them by line voltages. 

7 Based on our experience with California Title 

8 20, don't make more bins than you have to. 

9 MR. BROOKMAN: Thank you. 

10 MR. HARDING: And if there's no energy 

11 savings by different taps on a ballast, let's not make 

12 up one watt and call it significant, and there was a 

13 comment about 250 watt being an easy break. I don't 

14 see an easy break there. I don't know where that came 

15 from, but just when you do your study make sure you 

16 don't add more. 

17 MR. BROOKMAN: And I'm assuming the 

18 Department would appreciate you, based upon your 

19 California experience, to give detailed comments on how 

20 to bend these things, where the breakpoints would be. 

21 Dale. 

22 MR. deLASKI: Just a follow-on to that. If 

23 you could flip back to Slide 35, so as a general 

24 matter, we like curbs. You know, I think when you have 

25 a step function kind of function like that with bins, 

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1 you're going to see a clustering of products at the 

2 foot of the stair, at the foot of the step, and, you 

3 know, we saw this with the general service lamp 

4 standard that California established and I think you'll 

5 see it, you know. 

6 So if we can find a relationship that defines 

7 the continuous relationship, that's one that's going to 

8 prevent products being marketed -- products moving to 

9 take advantage of these breaks in the standard. 

10 MR. BROOKMAN: Gotcha. Thank you, Andrew. 

11 Dale. 

12 MR. SIMPSON: Dale Simpson. Just wanted to 

13 amplify a little bit about the universal voltage 

14 question and challenge a bit the notion that it offers 

15 no utility. 

16 I would venture to say that the presence of 

17 universal voltage, particularly in electronic ballasts, 

18 has been an element in their adoption and has allowed 

19 their movement into the marketplace much quicker than 

20 if single voltage were required and a movement in 

21 general or any standard that penalized universal 

22 voltage would, in essence, penalize current electronic 

23 ballast technology. 

24 MR. BROOKMAN: Okay. Thank you. Additional 

25 comments on this series of factors and the Department's 

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1 preliminary thinking on it? Okay. Andrew. 

2 MR. deLASKI: If I could just follow up with 

3 Dale? Dale, is there typically an efficiency penalty 

4 that the product would have universal voltage or 

5 relative to applying to single voltage? 

6 MR. SIMPSON: At some times, yes. Is it 

7 significant? You'd have to look at individual cases to 

8 say whether or not it's significant. 

9 MR. BROOKMAN: I see Bob may have a comment. 

10 MR. ERHARDT: Yeah. I can amplify on Dale's 

11 comment. There can be at some voltages in a multi-tap, 

12 you may have some voltages that don't have -- aren't 

13 optimized for efficiency in order to get the same 

14 layer, the same turns per layer, etcetera. Electronic 

15 ballast, there could be some small penalty, as well, in 

16 having the higher VA ratings, ranges, but I would say 

17 it's probably on the order of half a percent to a 

18 percent. 

19 MR. BROOKMAN: Okay. 

20 MR. COFFEY: Okay. Great. This brings us to 

21 the technology portion of the Market and Technology 

22 Assessment which serves as sort of a brainstorming 

23 where DOE attempts to identify all the ways one could 

24 improve ballast efficiency which those are called 

25 technology options and start with moving from a 

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1 magnetic to an electronic ballast. 

2 There may even be further gains associated 

3 with high-frequency operation, but even in the case of 

4 low-frequency electronic, there appear to be efficiency 

5 benefits from switching from discrete components to 

6 integrated circuits. Of course, in both cases you can 

7 always use higher-grade components, whether that's 

8 improved semiconductor materials or, say, higher-grade 

9 electrical steels, and then at the systems level, also 

10 in both cases, there can be gains associated with 

11 improved circuit design. 

12 DOE welcomes comments on these preliminary 

13 technology options and whether there are others. In 

14 doing so, please discuss impacts on safety, performance 

15 and consumer utility. 

16 MR. ERHARDT: Bob Erhardt. 

17 MR. ERHARDT: Please. 

18 MR. ERHARDT: Concerning electronic ballasts, 

19 while there is some trends that high-frequency 

20 electronic ballasts can be -- are often slightly more 

21 efficient than low-frequency electronic ballasts, it's 

22 not the frequency itself, it's rather the ballast 

23 configuration. The low-frequency electronic ballast is 

24 typically a three-stage design versus a two-stage 

25 design for high-frequency ballasts. 

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1 So it's not the frequency of operation of the 

2 lamp necessarily that gives the improvement in system 

3 efficiency. So we would discourage any rulemakings 

4 that tried to specify technology on the basis of 

5 frequency. 

6 Similarly, with integrated circuits, while 

7 integrated circuits can allow optimization of a 

8 product, the integrated circuit itself does not have 

9 any direct impact on ballast efficiency. 

10 I guess higher-grade components, we do agree 

11 you can use higher-grade components at a cost and the 

12 cost impact would have to be evaluated. 

13 MR. BROOKMAN: So the Department is 

14 specifically seeking comment on safety, performance, 

15 and consumer utilities. So if you could weave that in. 

16 Dale. 

17 MR. SIMPSON: Dale Simpson. I would just 

18 reiterate my earlier comment briefly, that when you 

19 think of -- if a standard were to mandate electronic 

20 ballasts, for instance, you need to consider the cost 

21 beyond just the difference between ballast A and 

22 ballast B. There's form, there's thermal, and there 

23 may in fact be some consumer utility issues in that a 

24 wattage might be available in magnetic but not in 

25 electronic purely because of form and thermal. 

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1 MR. BROOKMAN: Okay. Jennifer.

2 MS. AMANN: Jennifer Amann. Just as we were 

3 encouraging DOE to expand the scope to look beyond just

4 ballast efficiency, that would entail looking at 

5 additional technologies for improving system efficiency

6 or fixture efficiency and so forth, and we'll provide 

7 further comment on that in our written comments.

8 MR. BROOKMAN: Okay. So final comments on 

9 this comment. You see the list of technology options 

10 there and the Department's request for specific 

11 comments on safety, performance, and consumer utility 

12 as they relate. 

13 Additional comments? Yes, Cheryl English. 

14 MS. ENGLISH: Cheryl English. Just one final 

15 comment is relative to electronic ballasts and we've 

16 talked about the thermal issues. 

17 We personally consider it still very much of 

18 an emerging technology because of the thermal 

19 management issues. We find, especially for fixtures 

20 that are used in hot environments, that they fail very 

21 frequently. That, of course, can present a safety/ 

22 security concern and electronics don't perform well 

23 when there's not good power quality. 

24 So for outdoor lighting, where the power is 

25 not quite as regulated or controlled, the failures have 

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1 a much higher percentage and the safety issue is much 

2 more significant in the outdoor environment. 

3 MR. BROOKMAN: Okay. Thank you. Bob, yes, 

4 Bob. 

5 MR. ERHARDT: Yeah. Concerning consumer 

6 utility, if you are redesigning a luminaire for an 

7 electronic ballast, as Dale commented, the luminaire 

8 may -- will change its form factor and that can affect 

9 its utility. 

10 To elaborate a little bit on Cheryl's 

11 comment, especially in outdoor power quality, if you're 

12 using an electronic ballast, you likely will have to 

13 add some additional line transient protection within 

14 the luminaire beyond what the ballast itself is capable 

15 of. 

16 Electromagnetic ballasts typically can 

17 withstand well in excess of 10,000 volt transients and 

18 electronic ballasts are typically rated for 6,000 volt 

19 transients. 

20 MR. BROOKMAN: Okay. Thank you. Final 

21 comments on this subject matter? 

22 (No response.) 

23 MR. BROOKMAN: So I'm going to suggest we 

24 take a break now. It's now 10:30 almost, 10:29 or so. 

25 We'll resume at 10:45. While you're in the Forrestal 

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1 Building, you've got to wear your visitor's badge. 

2 (Recess.) 

3 MR. BROOKMAN: Can you return to Slide 27? 

4 At the break, someone approached me and said that they 

5 didn't get a chance to fully cover Item Number 3 which 

6 is on Slide 27. So we want to return to that and 

7 provide that opportunity. Tom. 

8 You can see DOE welcomes comments on the 

9 expansion of the scope of this rulemaking to include 

10 all metal halide lamp fixtures currently excluded under 

11 42 USC 6295(h)(h)(1)(B). Tom. 

12 MR. HARDING: Tom Harding. So I just noticed 

13 that we missed that item and we had a couple of things 

14 to say about it. In fact, Bob Erhardt was going to say 

15 some things about it. 

16 MR. BROOKMAN: Okay. Thank you. Bob, are 

17 you ready? 

18 MR. ERHARDT: Yes. 

19 MR. BROOKMAN: Yeah. Also at the break, if 

20 you could make sure that the microphone is somewhat 

21 close to your face and you're directing your comments 

22 into it. Please, Bob. 

23 MR. ERHARDT: Okay. I've never been accused 

24 of not being heard. 

25 MR. BROOKMAN: We'll try and make sure it 

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1 never happens here. Keep going. 

2 MR. ERHARDT: Okay. Concerning the 150-watt 

3 exclusion, we'd like to point out the 150-watt 

4 exclusion does promote the use of a more efficacious 

5 lamp compared with the 175-watt that it replaces and it 

6 was put in place in principle so that this large market 

7 had a place to go while saving energy and -- excuse me. 

8 I don't have my notes in front of me, so I'm ad libbing 

9 a little bit. 

10 And concerning the regulated lag, that's a 

11 very small percentage of the market and we encourage 

12 you to keep these exemptions in place. 

13 MR. BROOKMAN: Do you want to find your 

14 notes? Do you want to refer specifically to them? 

15 Yeah. Let's use prepared comments for yourself. Let's 

16 make sure you get a chance to say them. 

17 MR. ERHARDT: Okay. Yes. The 150-watt and 

18 again the outdoor exclusion, we talked about outdoor 

19 already, about how the requirements for line 

20 transients, etcetera, are more stringent and so the -- 

21 and a 150-watt ballast -- 150-watt lamps compared with 

22 a 175-watt lamps are an energy-saving replacement and 

23 that was the rationale for putting this exclusion in to 

24 begin with. 

25 The 480-volt electronic ballast, to my 

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1 knowledge, I don't think there are any on the market 

2 today, 480-volt electronic ballasts. There's a small 

3 market for indoor applications, but the semiconductors 

4 needed for 480-volt ballasts are already kind of put to 

5 their limits for indoor application. If you had to add 

6 additional transient protection, it would be very 

7 difficult for outdoor, and the regulated lag, this 

8 again is a rather small market but it's outdoor with I 

9 transients and we don't feel that the small number of 

10 products out there represents a significant energy 

11 savings. 

12 MR. BROOKMAN: Okay. 

13 MR. LEWIS: Bob, are you going to be 

14 submitting those in your comments, written comments? 

15 MR. ERHARDT: Yeah. NEMA -- this is -- 

16 MR. LEWIS: Okay. 

17 MR. ERHARDT: -- part of the NEMA comments 

18 that we'll submit formally. 

19 MR. LEWIS: Okay. Thank you. 

20 MR. BROOKMAN: Thanks very much. Okay. Now 

21 we're going to go back to where we had left off just 

22 prior to the break, which is Slide Number? 

23 MR. COFFEY: 41. 

24 MR. BROOKMAN: Thank you. 

25 MR. COFFEY: So now we find ourselves at the 

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1 Screening Analysis which takes as inputs to the 

2 technology option we mentioned and screens them on the 

3 basis of four criteria which you see right here: 

4 Technological Feasibility, Practicability to 

5 Manufacturer Install and Service, Impacts on Equipment 

6 Utility or Availability to Consumers, and Impacts on 

7 Health and Safety. 

8 Technology options that meet all four of 

9 these criteria are known as design options and carried 

10 through to the Engineering Analysis. 

11 DOE welcomes comment on how any of these 

12 criteria might pertain to these or other technology 

13 options. 

14 MR. BROOKMAN: Go back to Slide 42, just 

15 leave it there. Technological Feasibility, 

16 Practicability to Manufacturer Install and Service, 

17 Impacts on Equipment Utility or Availability to 

18 Consumers, Impacts on Health or Safety. Andrew. 

19 MR. deLASKI: This is more just a cautionary 

20 note than, I think, -- the lighting market in this 

21 largely international market with international 

22 companies that compete mostly globally. So I think 

23 it's important that DOE look internationally at 

24 technologies and I think that one of the things that 

25 we've observed in some other dockets is the tendency to 

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1 say, well, if it's not available in the U.S. market 

2 today, then that's not practical to manufacture in the 

3 U.S. market which I think is a leap that is not 

4 justified. 

5 So I think DOE needs to be cautious or needs 

6 to look expansively at the lighting, what's happening 

7 globally in lighting to assess the second criteria 

8 there and not limit itself to an assessment of what's 

9 happening domestically. 

10 MR. BROOKMAN: Okay. Bob Erhardt. 

11 MR. ERHARDT: Yeah. Just a small response to 

12 that. Generally, we're multinational companies and I'm 

13 not exactly aware of what technology -- as a matter of 

14 fact, I just came back from Europe. I spent a week in 

15 London and a week in Frankfort at IEC meetings which is 

16 the International Standards Group and I'm not 

17 particularly aware of any metal halide technology 

18 that's available outside the United States that isn't 

19 available inside the United States. 

20 MR. BROOKMAN: Okay. Thank you for that. 

21 Thank you. Yes, Cheryl. 

22 MS. ENGLISH: Cheryl English. I guess one 

23 comment on the international and global perspective is 

24 it probably embeds in what you've defined here on 

25 practicability to manufacture, but there may be some 

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1 need to consider trade agreement issues and stimulus 

2 funds have certain requirements related to Buy American 

3 that could be very problematic if we shift this 

4 regulation to forcing us to look at foreign-sourced 

5 components. 

6 MR. BROOKMAN: Okay. 

7 MR. COFFEY: So that brings us to the end of 

8 the Screening Analysis and I'll turn it over to a 

9 colleague, Mimi Gupta, for the Engineering Analysis. 

10 Engineering Analysis

11 MS. GUPTA: Okay. So after developing the 

12 equipment classes and the Market and Technology 

13 Assessment and the design options from the Screening 

14 Analysis, DOE uses those inputs in the Engineering 

15 Analysis and the Engineering Analysis determines the 

16 relationship between costs and efficiency. Cost, 

17 specifically the manufacturer's selling price, and 

18 efficiency relationship. 

19 That cost-efficiency relationship is then fed 

20 into the downstream analyses that DOE conducts, such as 

21 the Life-Cycle Cost Analysis and the Manufacturer 

22 Impact Analysis and Employment Impact Analysis. 

23 To conduct the Engineering Analysis, DOE goes 

24 through several steps. The first is choosing 

25 representative equipment classes to be analyzed in the 

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1 Engineering Analysis. Then it defines baseline models 

2 for each representative equipment class from which DOE 

3 assesses the impacts of standards. 

4 DOE then identifies higher-efficient 

5 substitutes to those baseline models and develops 

6 manufacturer selling prices for both the baselines and 

7 the higher-efficient substitutes. DOE then develops 

8 candidate standard levels that span the full range of 

9 ballast efficiencies from the baseline to the maximum 

10 technologically-feasible level and, finally, DOE scales 

11 the results of the representative equipment classes to 

12 those equipment classes not directly analyzed in the 

13 Engineering Analysis. 

14 So DOE will choose a subset of equipment 

15 classes called representative equipment classes to 

16 analyze the Engineering Analysis and the Life-Cycle 

17 Cost Analysis. These equipment classes are chosen 

18 generally based on what DOE believes to be the highest 

19 volume and here on this slide you can see that the 

20 framework document presents several proposals for 

21 representative equipment classes, one in each wattage 

22 bin, and in the voltage bin that DOE believes to be 

23 most common. 

24 And DOE welcomes comments on these 

25 representative equipment classes. 

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1 MR. LEWIS: Doug? 

2 MR. BROOKMAN: Yes, Ron Lewis. 

3 MR. LEWIS: If we can go back to Slide 45 

4 just for a second, Mimi? 

5 MS. GUPTA: Mm-hmm. 

6 MR. LEWIS: Okay. 

7 MS. GUPTA: Sorry. 

8 MR. LEWIS: That first bullet, it states, "A 

9 key factor in setting standards considers the increased 

10 cost of more efficient products." I think Phil and Bob 

11 both brought up the potential complications with form 

12 factor and with pole size, things of that nature that 

13 aren't normally a consideration. 

14 So to the degree -- we went over that pretty 

15 fast, but to make sure that you give us input, you 

16 know, and any specifics you can give us that help us to 

17 best understand that in this stage, but I heard you, 

18 but this is the stage where that really fits and if you 

19 can make sure and give us as much education on that as 

20 possible, that would be really appreciated. 

21 MR. BROOKMAN: Rebecca. 

22 MS. RAINER: I'd also like to add that, along 

23 with the thermal factors and the redesign of product, 

24 you also need to consider in the cost the longevity of 

25 electronic ballasts, along with the reliability of 

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1 electronic ballasts versus the electromagnetic. 

2 MR. BROOKMAN: Thank you. Ron Lewis. 

3 MR. LEWIS: One of the things for us to 

4 consider is having supporting information and data. So 

5 if you have data that shows that, that would be very 

6 helpful. 

7 MS. RAINER: Understood. We'll have that. 

8 MR. BROOKMAN: And to be specific, the 

9 Department, I'm certain, would love to hear from NEMA 

10 as a whole. However, if individual companies could 

11 supply the specifics, that would also be very, very 

12 helpful to the Department. Okay. Thank you. 

13 Okay. We're going to press on. 

14 MS. GUPTA: Than for each representative 

15 equipment class, DOE defines a baseline model that will 

16 serve as reference points to assess changes due to 

17 energy conservation standards. 

18 Typically for equipment classes that have 

19 existing standards, the baseline model just meets the 

20 current energy conservation standards. However, as 

21 discussed earlier, DOE's considering expanding its 

22 scope of coverage beyond current EISA regulation and 

23 therefore for equipment classes where DOE's considering 

24 expanding coverage, DOE generally selects a baseline 

25 model that represents the most common lowest-efficiency 

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1 product on the market. 

2 And on this slide we see the plot that Doug 

3 presented earlier that shows what we see as the -- what 

4 DOE took from catalog literature as the market for 

5 metal halide lamp ballasts. 

6 The black lines on the plot indicate the EISA 

7 levels and as presented in the framework document, DOE 

8 proposes some initial baseline models as ballasts that 

9 operate a 70-watt lamp, 250-watt lamp, 400-watt lamp, 

10 and a 1,000-watt lamp. 

11 And now I'd like to pause to invite comment 

12 on the baseline models. 

13 MR. BROOKMAN: Dale. 

14 MR. SIMPSON: Dale Simpson. I just wanted to 

15 comment in general that with metal halide, we know that 

16 it's true that typically the higher you go in wattage 

17 within a certain range, the higher the efficiency, and 

18 specifically there is a wide range of efficiency 

19 between 100- and 150-watt metal halide and 20-watt 

20 metal halide and over that range, and we would express 

21 a concern that lower-wattage metal halide may get 

22 precluded from the standard and that lower-wattage 

23 metal halide is often used to replace much less 

24 efficient incandescent and fluorescent. 

25 So I would urge caution as you look at that 

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1 range to recognize that potential. 

2 MR. BROOKMAN: Okay. Thank you. Bob. 

3 MR. ERHARDT: Yeah. This is Bob Erhardt. 

4 Just in general concerning the -- and I apologize. I 

5 guess I missed it. We were commenting on Item 13 and 

6 we do wish to reiterate the non-reoccurring costs of 

7 developing new luminaires for some of the technologies, 

8 specifically electronic ballasts, and to the 

9 requirements for increased transient protection, 

10 etcetera, that are required often with an electronic 

11 ballast in comparison with the electromagnetic ballast. 

12 In general, also, we talked a little bit 

13 about how the rule rather than the exception is the 

14 multi-tap or universal voltage and we do find the 

15 equipment classes to be rather complicated and, as Tom 

16 Harding commented earlier, we prefer that we not have 

17 an overly-complex set of rulemaking to make it easier 

18 to understand compliance and enforcement. 

19 So then we have commented on -- well, again, 

20 that reflects again with the baseline models and this 

21 whole process of choosing one power level at one 

22 voltage. We're not necessarily objecting to this idea 

23 of having a continuous function or to have, you know, 

24 representative wattage levels, but we do find the 

25 existing -- the proposed classification of products to 

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1 be rather complex, overly-complex. 

2 MR. BROOKMAN: So we covered this a few 

3 slides back, but the Department asked for comments on 

4 the equipment classes, and as you see on Slide 47, do 

5 you wish to comment further on that? 

6 MR. BUSCH: Bill Busch. I have a comment on 

7 that. I think you could greatly simplify those by 

8 making one class less than 300 volts and the second 

9 class greater than 300 volts because, as Bob has 

10 mentioned, the multi-tap is 120 basically through 277 

11 and that's where most of your volume is. Above that 

12 you have 480 volts. So it would be much simpler to do 

13 that. 

14 While the 150-watt may predominantly be 120 

15 volts because of the small size and usage, it would 

16 just be much simpler to have two classes in each of 

17 those categories. 

18 MR. BROOKMAN: Okay. Yes, Dale. 

19 MR. SIMPSON: Just to amplify on that, that 

20 would also serve the utility of continuing the 

21 universal voltage which we believe does in fact 

22 encourage adoption of more efficient electronic 

23 technology. 

24 MR. BROOKMAN: Okay. So additional comments 

25 -- well, I guess we've returned to equipment classes 

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1 here for a moment. Additional comments on that before 

2 we move on? I want to make sure that -- I'm trying to 

3 make sure that we are efficient, but we sure don't want 

4 to diminish your opportunity for comment here. 

5 So if you need time to find your notes or 

6 whatever it is, let's make sure we do that. Pam. 

7 MS. HORNER: Pam Horner. I just put on my 

8 Osram Sylvania hat, if you want to note that. 

9 I'm not looking at the voltage column now, 

10 I'm looking at the wattage column. So we have a 

11 recommendation that amplifies Dale's point and that is 

12 that when you have a huge range of efficiencies in this 

13 150 all the way down to 20 watts which is common now 

14 for a lot of applications, our lamp folks are 

15 recommending a stop at the 50-watt. So it's a 

16 recommendation to look at instead of having a big 

17 barrel of less than a 150, have it 150 down to 50 

18 because anything below that (a) is low wattage and (b) 

19 is part of that huge range issue in this category. 

20 MR. BROOKMAN: Huge range in application? 

21 MS. HORNER: Efficacies. 

22 MR. BROOKMAN: Okay. Cheryl. 

23 MS. ENGLISH: Cheryl English. I guess to tag 

24 on to what Pam's saying is that, as you get into your 

25 Engineering Analysis, within that class of 50 to 150 

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1 and you do see that variability, the 150 as the 

2 baseline is probably not the appropriate baseline for 

3 those lower wattages, so probably looking more at the 

4 50 to 70 watts being the baseline for that class, if 

5 you choose to even address that. 

6 We had commented earlier that we believe that 

7 there's a very small percentage of sales in that low8 wattage range anyway and then the energy impact is 

9 small because of the small wattage, but if you do 

10 consider addressing that, then the 150 as the baseline 

11 is probably not representative. 

12 The other comment I wanted to make is on 

13 Slide 50 where you show your scatter plots of lamp 

14 wattage versus ballast efficiency. I know at NEMA, you 

15 guys are very good at doing these types of analyses, 

16 but those represent a product that is made but perhaps 

17 not even sold and so we'll want to work with you to try 

18 to do some kind of sales rating to make sure that we 

19 don't have a single spot up there that looks like a 

20 great promising technology but its application is very, 

21 very limited. 

22 MR. BROOKMAN: So it's mostly on the high23 efficiency end where that issue might show itself? 

24 MS. ENGLISH: Correct. 

25 MR. BROOKMAN: Okay, okay. So I'm sure the 

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1 Department would really appreciate that data. Yes, 

2 Bob. 

3 MR. ERHARDT: Yeah. Now that I'm looking at 

4 your scatter plot, I would also ask that the Department 

5 of Energy take a very good look at the, shall I say, 

6 certification of those test results that put those 

7 points on the chart? I'm pretty confident you're not 

8 going to find a 98-percent efficient ballast. I don't 

9 think you can build a 98-percent efficient ballast, and 

10 when we've gone through this before, we've found that 

11 when you really dig into specifications, some 

12 manufacturers, for instance -- if you're looking at 

13 Internet results, for instance, some manufacturers will 

14 define lamp-rated wattage and input power and they may 

15 be running at lower than a 100-percent ballast factor. 

16 So you may find that a manufacturer may be 

17 running two-to-five-percent lower lamp power and then 

18 specifying the rated lamp wattage. I have seen that in 

19 at least one case in analyzing Internet results. So I 

20 strongly recommend that you look at only using results 

21 that are submitted by some type of certified lab and I 

22 believe California has a requirement, for instance, in 

23 their submissions that you have a certified lab doing 

24 measurements. 

25 MR. BROOKMAN: Okay. Jennifer. 

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1 MS. AMANN: I'm Jennifer Amann. I just had a 

2 quick question, Cheryl, to follow on with your comment 

3 about the 150-watt not being an appropriate baseline. 

4 As I'm looking at it, DOE's proposing looking 

5 at 70 watts as the baseline for the below 150 watt and 

6 I wonder if you could comment if that's appropriate, if 

7 you think 70 would be the appropriate model. 

8 MS. ENGLISH: I probably am not prepared to 

9 answer that here today. I think collectively we need 

10 to go back and look at the data and see what would be 

11 most representative. 

12 If that class is covered, we may have to have 

13 multiple baselines within that range of product to 

14 address it. 

15 MS. AMANN: Okay. It would be very helpful 

16 for us to know your input on the baseline models 

17 proposed for all the different wattage bins. Thanks. 

18 MR. BROOKMAN: Is that in the TSD? It's not 

19 in the slides, right? 

20 MS. AMANN: Yeah. It's on Page 28. 

21 MR. BROOKMAN: Okay. I missed it. Okay. I 

22 want to make sure that you get the chance to comment on 

23 defining the baseline models. That's the current issue 

24 box that the Department's pushing up for your 

25 consideration. 

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1 (No response.) 

2 MR. BROOKMAN: Okay. No additional comments 

3 on this. Okay. 

4 MS. GUPTA: After defining the baseline 

5 models, DOE will then identify more efficient 

6 substitutes and DOE intends to begin doing this by 

7 utilizing a database of commercially-available ballasts 

8 and as was discussed at length earlier, DOE recognizes 

9 that the ballast does not work in a vacuum and that it 

10 works with a lamp and therefore DOE intends on looking 

11 at the entire system in evaluating total energy 

12 consumption and light output and ballast system 

13 substitutions will be made such that the light output 

14 of the higher-efficiency systems maintain the light 

15 output within 10 percent of the baseline system. 

16 After developing the baseline models and the 

17 higher-efficiency substitutes, DOE will then develop a 

18 manufacturing selling price for each of the models. To 

19 do this, DOE will calculate a manufacturer production 

20 cost by disassembling multiple manufacturers' ballasts 

21 that span a range of efficiency levels. 

22 From these tear-downs, DOE will develop a 

23 bill of materials that describe the equipment in 

24 detail, including manufacturing steps and material 

25 costs. Then DOE will apply manufacturer mark-ups to 

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1 the manufacturer production costs to calculate the 

2 manufacturer's selling price and ultimately construct 

3 the industry cost-efficiency curves. 

4 For equipment for which bill of materials are 

5 not generated, DOE will consider using retail prices to 

6 help develop manufacture selling prices for those lamps 

7 or for those ballasts. 

8 DOE will develop candidate standard levels 

9 that span the range of ballast efficiencies from the 

10 baseline to the maximum technological feasible level. 

11 As discussed earlier, the construct of the candidate 

12 standard levels will obviously depend on DOE's 

13 decisions on equipment classes, whether it decides to 

14 bin lamp wattages or provide a continuous equation. 

15 Also, DOE is required to analyze the maximum 

16 technological feasible level and is aware that that 

17 level might not correspond to the highest-efficiency on 

18 the market. Therefore, as part of the Engineering 

19 Analysis, DOE will conduct engineering interviews which 

20 in part is to help us determine what the max-tech 

21 efficiency for metal halide lamp fixtures is and we 

22 seek input from all interested parties on this issue. 

23 Here we have the actual items for comment 

24 which ask for comment on the approach that I've 

25 discussed in developing the cost-efficient relationship 

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1 for metal halide lamp fixtures and DOE's proposed 

2 approach to use commercially-available lamp ballasts in 

3 its analysis. 

4 MR. BROOKMAN: For each of the baseline 

5 models. Dale. 

6 MR. SIMPSON: Dale Simpson. Question. It 

7 isn't clear to me in reading through these slides or 

8 the documents whether the cost is going to be developed 

9 on the ballast, the more efficient ballast alone or on 

10 the complete luminaire containing the more efficient 

11 ballast. Which is actually going to happen on this 

12 process? Thank you. 

13 MS. GUPTA: Well, I think, given your 

14 comments earlier on how higher-efficiency ballasts 

15 might affect luminaire costs, I think it would be 

16 prudent to look at both -- like the entire luminaire, 

17 including the ballast. 

18 MR. BROOKMAN: Go ahead, Dale. 

19 MR. SIMPSON: Follow-on then. So you're 

20 actually going to not just calculate manufacture 

21 production costs by disassembling multiple 

22 manufacturers' ballasts, you're going to have to go and 

23 look at multiple manufacturers' luminaires. 

24 MR. BROOKMAN: Ron Lewis. 

25 MR. LEWIS: First of all, I apologize. I was 

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1 looking at Phil before and I was addressing you, Dale. 

2 Sorry. I think I called you Phil earlier. 

3 We're open for input at this time on things 

4 that you're recommending and observations and we're 

5 proposing things here that as a starting base and 

6 taking input of recommendations or things that you 

7 think are not going to capture what we need to capture. 

8 So your input is important to us at this stage. So 

9 we're not committing to what we're doing at this point. 

10 We're not going to give you a final resolution, but we 

11 are very anxious to make sure that we get your input so 

12 we consider all the factors. 

13 MR. BROOKMAN: Yes, Bob. 

14 MR. ERHARDT: Again, to reiterate what we 

15 said earlier, we think that the non-reoccurring costs 

16 are going to be -- should be considered, as well, 

17 because if you're talking about redesigning luminaires 

18 for electronic ballasts, these costs are significant 

19 and you should also in your impact analysis take into 

20 account the effect that a more expensive luminaire will 

21 have on the future sales of that power level. 

22 There is -- we've already seen, and I think 

23 we're commenting at another point, we've already seen, 

24 for instance, in California a shift in technology. If 

25 you start raising the cost of metal halide luminaires, 

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1 you're going to see higher adoption of high-pressure 

2 sodium and I'm not sure if that's your intent. There 

3 is -- you know, a metal halide lamp is a higher4 performance luminaire, but it is a very cost-sensitive 

5 market. 

6 Also, in talking about -- I'll reiterate when 

7 you start talking about max-tech ballast technology, 

8 please don't rely on just manufacturer claims. We 

9 strongly recommend that you verify claims of 

10 performance because it's very difficult to -- 

11 especially when you're talking about electronic 

12 ballasts, especially high-frequency electronic 

13 ballasts, the equipment needed to accurately measure 

14 ballast efficiency is rather expensive and it's likely 

15 that companies -- it has been -- I have seen where even 

16 prestigious organizations, such as Lawrence Berkeley 

17 Laboratory, have issued a report measuring efficiency 

18 and their equipment didn't have the specification to 

19 accurately measure efficiency. 

20 When you're talking about a ballast running 

21 at 100 kHz and higher, you need a 300 kHz bandwidth or 

22 more for your power measurement. The accuracy of these 

23 measurements can be off by three to five percent and 

24 when you're talking about ballast efficiencies and 

25 you're trying to delineate efficiency levels between 92 

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1 and 95 percent and a five percent error on your output 

2 power is dramatic. 

3 So we strongly recommend that you take a good 

4 look at the certification of the results that you're 

5 taking into account when you're looking at these 

6 various power levels, efficiency levels. 

7 MR. LEWIS: Bob, in response to your issue 

8 about non-recurring expenses, there was a phase in this 

9 called the Manufacturer Impact Analysis that is done 

10 where they actually will be visiting and discussing 

11 things with you to look at those kinds of impacts, and 

12 on the tolerances and the actual testing and 

13 certification of the accuracy of the testing, is that 

14 in the ANSI Standard right now? Is there a -- when 

15 you're talking about the testing, do you have something 

16 you can point to that shows specific requirements that 

17 you're quoting there? 

18 MR. ERHARDT: The 2005 that you are citing 

19 does not have a method of measurement for electronic 

20 ballasts. It's something that is being developed for 

21 the 2010 version and, you know, that should have the 

22 requirements. 

23 MR. BROOKMAN: Tom. 

24 MR. HARDING: Tom Harding. Bob's right. The 

25 2010 version of these refer to it, but it is going to 

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1 have electronic but at this stage only low-frequency 

2 ballasts, less than 400 hz. The high-frequency one 

3 that Bob referred to, 100 kHz, will not be in that 

4 particular document, though it is an ongoing issue, but 

5 it won't be in that one. 

6 MR. BROOKMAN: Let's see. Michael, go ahead. 

7 MR. MYER: This is Michael Myer, PNNL. Just 

8 a clarification regarding the ANSI Standards we keep 

9 talking about. 

10 When you say it's been addressed, low11 frequency electronic ballasts, are you talking C82.6 or 

12 C82.14 because doesn't C82.14 already address some of 

13 that? 

14 MR. BROOKMAN: Tom. 

15 MR. HARDING: Yes. C82.14 is the low16 frequency ballast standard. What Bob's referring to is 

17 C82.6. It's the method of measurement standard and it 

18 is only going to deal within this year the low19 frequency. The high-frequency will wait till some 

20 other future time. 

21 MR. BROOKMAN: Bob Erhardt. 

22 MR. ERHARDT: Yeah. We'll also comment that 

23 currently there are only lamp ballasts compatibility 

24 standards for low-frequency electronic ballasts. When 

25 you start looking at high-frequency electronic ballasts 

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1 where some of the higher ballast efficiencies are 

2 realized, there are no ANSI Standards for it. 

3 Each lamp ballast compatibility has to be an 

4 agreement between manufacturers of the ballasts and 

5 each specific lamp manufacturer which complicates the 

6 adoption of these types of ballasts immensely. 

7 MR. BROOKMAN: Okay. Thank you. Just want 

8 to make sure we've got all the comments that we want to 

9 get on Item 17 and 18 before we move on. 

10 (No response.) 

11 MR. BROOKMAN: Okay, okay. 

12 MS. GUPTA: As a final step in the 

13 Engineering Analysis, DOE then scales the analyses 

14 conducted on the representative equipment classes to 

15 the other equipment classes and on this slide, you can 

16 see some initial approaches to how DOE intends to scale 

17 mostly across the different voltage bins that were 

18 initially proposed as product classes. Obviously if 

19 the equipment class structure changes, DOE's scaling 

20 approach will also change. 

21 Initially, DOE proposes scaling by using 

22 ratios and catalog data or extrapolation to other 

23 equipment classes, and I'd like to pause here to invite 

24 comment on the approach to scaling and DOE also 

25 welcomes comments on how ballast efficiency varies with 

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1 lamp wattage, voltage, or any other ballast parameter. 

2 MR. BROOKMAN: So I think the slide gives a 

3 good illustration of the Department's approach. 

4 Comments on that? Bob. 

5 MR. ERHARDT: When the NEMA companies met, we 

6 didn't generate -- we don't have strong opinion on the 

7 scaling factors because we'd like to see the scaling 

8 factors before we comment on them. 

9 There are some general trends that, yes, it's 

10 generally true that higher-power products have better 

11 efficiency than lower-power. This has somewhat to do 

12 with the lamp voltages. Lamp voltages get higher, the 

13 ballast efficiencies can get better. 

14 Again, we are reserving the right to comment 

15 further when we see the actual scaling factors. 

16 MR. BROOKMAN: For now, noting that you want 

17 more specific scaling as an approach that's okay with 

18 you. 

19 MR. ERHARDT: As we discussed earlier, having 

20 some kind of curve-defining ballast efficiency 

21 requirements as a function of wattage, we think that 

22 can be reasonable. 

23 MR. BROOKMAN: Okay. So additional comments 

24 on this? 

25 (No response.) 

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1 MR. BROOKMAN: Okay. 

2 MS. GUPTA: So just on some supplemental 

3 points related to the Engineering Analysis, DOE will 

4 evaluate all design options that are commercially 

5 available or present in working prototypes, including 

6 proprietary designs and technologies. However, 

7 proprietary designs will only be considered if they do 

8 not present a unique path to a given efficiency level, 

9 and any information provided on proprietary designs 

10 will be held in strict confidentiality. 

11 Item 20 highlights DOE's request for comment 

12 on any proprietary design issues that might be used in 

13 commercially-available ballast or metal halide lamp 

14 fixtures. 

15 MR. BROOKMAN: And also in that comment box, 

16 the Department asks about cost data, how that might be 

17 acquired. Pam. 

18 MS. HORNER: Pam Horner. This is just an 

19 obvious answer, but ask us during the manufacturer 

20 interviews and we'll be happy to talk to you about it. 

21 MR. BROOKMAN: There are proprietary designs 

22 that need to be described and costed, I'll reiterate on 

23 behalf of the Department. Thank you. Okay. 

24 Rebecca, do you want to follow on here? 

25 MS. RAINER: No. 

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1 MR. BROOKMAN: Okay. You're all set. Okay. 

2 Dale, yes, you're with it? Okay. Same thing. Okay, 

3 okay. 

4 Please take another look at that comment box, 

5 see if there's anything else to be said. 

6 MS. GUPTA: And on the final issue related to 

7 the Engineering Analysis, DOE takes into consideration 

8 the effects on manufacturers of other regulatory 

9 changes outside the standards rulemaking process that 

10 might affect the Engineering Analysis and DOE welcomes 

11 comments on any of these regulatory burdens and any 

12 general comments related to the Engineering Analysis. 

13 MR. BROOKMAN: Dale. 

14 MR. SIMPSON: Dale Simpson. On the 

15 regulatory burdens just in general, I think DOE should 

16 take into consideration the proposed outdoor lighting 

17 bill because it does have specific things requiring 

18 labeling and other things for an outdoor luminaire 

19 manufacturer. 

20 As far as the comment about other things that 

21 might affect the Engineering Analysis, it hasn't come 

22 up yet, but later in the document there's a statement 

23 by DOE that essentially says that they presume or 

24 assume that metal halide luminaires are disposed of at 

25 end of ballast life and I believe I speak for all NEMA 

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1 members when I say emphatically that is not the case. 

2 The average metal halide luminaire has its 

3 ballast replaced at least once and in the case of 

4 exterior luminaires the life ranges from 20 to 25 years 

5 or longer with multiple ballast changes occurring 

6 during the life of the luminaire. So that would 

7 affect, of course, your Engineering Analysis. 

8 MR. BROOKMAN: Thank you. That's helpful. 

9 And does that vary by model type or application or the 

10 specifics I think would be very helpful to the 

11 Department. 

12 MR. SIMPSON: We would be happy at another 

13 time to, I think all of us from NEMA, to go into the 

14 details of what information we would have available on 

15 that subject, but it does very by application and also 

16 by class of luminaire and a variety of other things, 

17 but the general assumption that metal halide luminaires 

18 are disposed of once the ballast has failed is just all 

19 wrong. 

20 MR. BROOKMAN: Thank you, thank you. 

21 Additional comments on these issues? 

22 (No response.) 

23 MR. BROOKMAN: Okay. 

24 Mark-ups for Equipment Price Determination

25 MR. LINGARD: Good morning. I'm Bob Lingard 

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1 with Pacific Northwest National Laboratory. 

2 Doug, I had a quick question for you. I 

3 think in our agenda, we show us going to the Mark-ups 

4 Analysis, whereas the slides go to Energy Use. So I 

5 was going to see if people would mind skipping forward 

6 a few slides, if they wouldn't mind going forward, then 

7 coming back to stay with the agenda. I think in terms 

8 of presentation order, it makes good sense. 

9 MR. BROOKMAN: Sure. That makes sense to me, 

10 too. Let's make certain we return to it. 

11 MR. LINGARD: So, folks, if you wouldn't mind 

12 skipping forward to Slide 64? Here's where we're going 

13 to talk about the Mark-ups for Equipment Price 

14 Determination. We're going to begin to talk about the 

15 inputs for the economic analyses. 

16 The purpose of this analysis is to use 

17 manufacturer customer mark-ups to convert the 

18 manufacturer selling prices that come out of the 

19 Engineering Analysis to customer prices which are then 

20 used in the Life-Cycle Cost and the Payback Period 

21 Analyses as well as the Manufacturer Impact Analyses. 

22 The method that's used here is by applying 

23 manufacturer to customer mark-ups. These consist of 

24 distribution channel mark-ups and sales tax to the 

25 manufacturer's selling price estimates that come out of 

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1 the Engineering Analysis. So to do this, we must 

2 identify the distribution channels. We have an example 

3 for you here. A distribution channel consisting of the 

4 ballast manufacturer to the OEM fixture manufacturer, 

5 then to the electrical wholesaler or distributor on to 

6 the contractor and finally to the end user of the 

7 lighting system. 

8 Now once we have confirmed these distribution 

9 channel or channels, DOE will rely on economic data 

10 from public sources and industry input to determine how 

11 the equipment is marked up from this path from the 

12 ballast fixture manufacturer to the customer. That 

13 leads us to our items here that we request comment. 

14 First, regarding the distribution path, we 

15 request comments on the planned distribution path for 

16 metal halide lamp fixtures covered under this 

17 rulemaking and whether we should consider any 

18 additional paths. 

19 We also request information on the relative 

20 fraction of shipments that go through this path or 

21 other paths that you identify. 

22 We also request in Item 25 feedback on the 

23 overall mark-ups that would be reflected in these mark24 ups paths for metal halide lamp fixtures. 

25 And finally, we seek comments on other 

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1 sources of relevant data that we could use to 

2 characterize mark-ups for metal halide lamp fixtures in 

3 this rulemaking. 

4 So with that, I'll pause for comment. 

5 MR. BROOKMAN: Pam. 

6 MS. HORNER: Pam Horner. On Item 24, the 

7 distribution path is typical. So you've identified it 

8 well. Item 25, I think that's a case for individual 

9 manufacturer interviews, and I believe that our 

10 colleagues in the luminaire group have stated that 

11 other sources which they may identify to you in the 

12 individual manufacturer interviews, but there are 

13 municipalities that do purchase certain of these 

14 luminaires, say on contract basis or whatever, but 

15 again I think your consultants are well aware of those 

16 paths and would certainly know to ask about them, if 

17 that's clear. 

18 MR. BROOKMAN: Thank you. So, Bob, please. 

19 MR. ERHARDT: I think the general comment was 

20 there are publicly-available price lists for most of 

21 our products. 

22 MR. BROOKMAN: This distribution channel 

23 that's listed here, it's typical. Are there atypical 

24 distribution channels, as well, or is this the great 

25 majority of it? Yeah. The great majority? Yes, 

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1 Rebecca. 

2 MS. RAINER: This is typical, but there are 

3 other instances. Utilities may buy direct. Some 

4 municipalities or cities may buy direct. 

5 I'd also like to make a comment on the 

6 overall mark-ups for the metal halide fixtures. My 

7 instance is a little bit different maybe than most 

8 because I am a ballast manufacturer and I'm also a 

9 fixture manufacturer. So there are other issues that I 

10 will have to consider during the whole process, such as 

11 loss of jobs, if we consider the electronic. I do not 

12 manufacture electronic ballasts. 

13 So I have a lot of issues that may not be 

14 with every luminaire manufacturer. 

15 MR. BROOKMAN: Okay. Thank you. Do you see 

16 the comment boxes? We're going to keep moving ahead 

17 here. Yes, okay. Here we go. 

18 Energy Use and End-Use Load Characterization, Life19 Cycle Cost and Payback Period Analysis

20 MR. LINGARD: Well, actually, to move ahead, 

21 we're going to step back a few slides. How often in 

22 life does that occur? 

23 If we would go back to Slide Number 60, 

24 please? 

25 Here's where we're going to speak about the 

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1 Energy Use and End-Use Load Characterization. This is 

2 an input to the Life-Cycle Cost and Payback Period 

3 Analysis. 

4 The purpose of this analysis is to identify 

5 how consumers use the equipment and thereby we can 

6 identify the energy savings potential of energy 

7 efficiency improvements. DOE analysis will focus on 

8 how end users install and operator these fixtures. 

9 Now the method we use here, Number 1, is 

10 operating hours. How many operating hours are users 

11 using these fixtures? We will obtain data to develop a 

12 distribution of operating hours from a number of data 

13 sources, including the 2002 U.S. Lighting Market 

14 Characterization, this is the Volume 1 Report, as well 

15 as the Commercial Building Energy Consumption Survey, 

16 CBECS, 2003, as well as the 2007 version when it's 

17 completed, and, finally, the 2002, Energy Information 

18 Administration's 2002 Manufacturing Energy Consumption 

19 Survey. 

20 We'll correlate the electricity price 

21 distribution and sales price distribution with the 

22 operating hour distribution by census division. 

23 Finally, multiply system power by the number of 

24 operating hours per year, this will give us our system 

25 energy use, and conduct a sensitivity analysis for the 

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1 estimates of the high and low operating hours. 

2 These two inputs or these two variables, the 

3 system input power, we will look to manufacturer 

4 information verified by catalogs, and we give you an 

5 example of an operating hour distribution here. Here's 

6 an example of a commercial sector distribution for 

7 metal halide lamp fixtures given below. This is an 

8 example of the kind of data that we will draw upon to 

9 develop these representative operating hours. 

10 We have an opportunity for input here. Item 

11 23. We welcome comments on DOE's use of planned 

12 operating hour profiles for metal halide fixtures. DOE 

13 also welcomes comments on whether the end-use operating 

14 profiles are different for the various types of metal 

15 halide lamp fixtures covered under this rulemaking and, 

16 if so, how. 

17 I'll pause for comments here. 

18 MR. BROOKMAN: Pekka. 

19 DR. HAKKARAINEN: Pekka Hakkarainen. So 

20 small comment here. The CBECS 2003 data became 

21 publicly available in 2008. So I'm just curious as to 

22 how you're going to be able to use the 2007 data in 

23 time for this rulemaking. If you do, then it's at a 

24 time when it's not publicly available. 

25 MR. BROOKMAN: Well, that's a big lag, isn't 

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1 it? Do you know when the CBECS data -- 

2 MR. LINGARD: I don't have a date for you, 

3 but it would be fair to say we will use the most recent 

4 data available. 

5 MR. LEWIS: Good answer. 

6 MR. BROOKMAN: Okay. Pam. 

7 MS. HORNER: Pam Horner. I have a question 

8 that I asked last year. We all have our dog-eared 

9 copies of the 2002 Lighting Market Characterization 

10 Study and it's fabulous and at the time we got a hint 

11 that it might be updated. Could you -- Ron's going 

12 eek. 

13 MR. BROOKMAN: Ron Lewis. Ron Lewis is going 

14 to repeat that comment into the record. 

15 MR. LEWIS: I don't have any information as 

16 far as activity that's underway to update that, but we 

17 will look into it and pass along your encouragement to 

18 do so. 

19 MS. HORNER: Yeah. We like that study. 

20 MR. BROOKMAN: How would that information be 

21 transmitted, if it was, as it was being completed? 

22 Would you send out a blast e-mail? 

23 MR. LEWIS: I don't think it's underway. So 

24 as far as telling somebody it's completed. Okay. 

25 After a slight sidebar, as you're aware, the Regulatory 

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1 Program is part of the Building Technologies Program 

2 and the R&D Program for Buildings Equipment is also 

3 under that. So there's some functions that sometimes 

4 are going on where we're not always fully aware of what 

5 the other parts of the office are doing. 

6 There may be activity that's getting started. 

7 So where we have an inquiry here, we will ask the 

8 people that are in charge of that to get back to the 

9 parties and let them know the status. 

10 MR. BROOKMAN: That's helpful. Thank you. 

11 Okay. Dale, do you have a comment? 

12 MR. SIMPSON: Yes. Dale Simpson. As far as 

13 the request for comment on the operating hour profiles, 

14 yes, there are by various applications a wide range of 

15 operating hour profiles. 

16 I can only speak here to exterior lighting 

17 which my division is involved in. The extremes are 

18 typically your 12-hour night or approximately 4400 

19 annual hours for your typical exterior luminaire, and 

20 then the other end of it is your parking garage which 

21 is typically continuous burn. 

22 So I do think it's important that you profile 

23 various applications, both interior and exterior, 

24 whatever, to determine sort of the mean operating hours 

25 for that application rather than just rely on a table 

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1 like you have here because I don't think it will give 

2 you as good a picture as you otherwise could get. 

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

4 please. 

5 MR. BUSCH: Bill Busch. If you use that 2002 

6 Lighting Market Characterization, I haven't seen it, 

7 but in my estimation it's got a lot of metal halide in 

8 it, and the current market trend is towards fluorescent 

9 high-bays, away from metal halide. So if you use that 

10 for volumes, you're going to be way off. 

11 MR. BROOKMAN: So where's that data? 

12 MR. BUSCH: That would be in the new study. 

13 MR. BROOKMAN: Okay. 

14 MR. BUSCH: The fluorescent high-bay market 

15 basically took off in 2002 and it just has gone through 

16 the roof. 

17 MR. BROOKMAN: NEMA would also be trying to 

18 aggregate that data somehow, would it not? Yes, 

19 Cheryl. 

20 MS. ENGLISH: Yeah. NEMA has some reports 

21 where we do compile metal halide -- well, I don't think 

22 we pick up metal halide but HID and we can probably go 

23 back through our historical data to look at what the 

24 shift has been in that type of product. Because of 

25 daylighting control and motion sensors, there has been 

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1 a dramatic shift on interior HID lighting to 

2 fluorescent systems. 

3 MR. BROOKMAN: Okay. Thanks for that 

4 clarification. Bob. 

5 MR. ERHARDT: There also are some trends that 

6 are just now initializing to solid-state lighting, for 

7 instance, and as we've mentioned, as the requirements 

8 for metal halide have gone into place, there's been 

9 seen a shift towards high-pressure sodium. So when 

10 you're doing your future projections, you need to 

11 consider the impact of cost-effectiveness of other 

12 technologies and these type of things. 

13 MR. BROOKMAN: Okay. Thank you. 

14 MR. LINGARD: This is Bob Lingard with PNNL. 

15 So regarding the penetration of other technologies, for 

16 example fluorescent, into the metal halide market, just 

17 to tease out a few more comments from you folks, I 

18 guess given the ability to control fluorescent, would 

19 you expect the usage patterns or the operating hour 

20 profiles to be different between fluorescent and HID? 

21 MR. BROOKMAN: So if you could comment on 

22 that, that'd be helpful. 

23 MR. LINGARD: In these different 

24 applications. 

25 MR. BROOKMAN: Cheryl. 

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1 MS. ENGLISH: You know, I can't answer it 

2 specifically, but I think you've got the right 

3 variables. It's obviously energy uses, power and time, 

4 and I think the variable that you'll find is going to 

5 be application. This is where application standards 

6 become problematic, but, you know, Dale alluded to this 

7 to some degree and warehouses illuminated with metal 

8 halide high-bays, you will typically find a high/low 

9 operation. So it's never off, it's always in a low 

10 operation, except when people are there and it goes up 

11 to a high operation. So that reduces not the time but 

12 the power and many outdoor applications, you know, some 

13 roadway billboards, things like that, they actually 

14 will be controlled on a time clock or some kind of a 

15 part-like type of sensor and in those cases, they often 

16 will turn off for a certain number of hours, reducing 

17 the total annual hour usage. 

18 In some cases, they're even smarter and will 

19 dim down at a certain time at night, then turn off at 

20 midnight or 2 a.m. and then come back on for morning 

21 commute. So it may be some combination of watt 

22 reduction, power reduction. I can't give you a 

23 specific recommendation, other than I think we probably 

24 need to identify different applications and look at 

25 some estimates on what is the average power reduction, 

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1 average hour reduction. 

2 MR. BROOKMAN: Please say your name. 

3 MR. FRANCK: This is Peter Franck with 

4 Philips Lightolier, and I just wanted to give an 

5 anecdotal example where our manufacturing plant 

6 switched from metal halide to fluorescent high-bays and 

7 before when they were metal halide, they had to 

8 essentially be on all the time when people were working 

9 there, even working in certain sections, whereas now 

10 there are certain sections that are on occupancy 

11 sensors where it can be completely turned off unless 

12 someone walks into that specific area and then they 

13 turn on. 

14 So the profile of on versus off has changed 

15 dramatically by changing the technology. 

16 MR. BROOKMAN: Bob. 

17 MR. ERHARDT: I was just going to make one 

18 other comment, that I think when you talk to individual 

19 manufacturers, they may be able to help you with some 

20 sales trends for the various product types. 

21 MR. BROOKMAN: Okay. So any specifics would 

22 be very helpful to the Department. This is very 

23 complicated to calculate, very, very complicated. 

24 Okay. So final comments on this segment 

25 before we move on. In this case, we move forward, 

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1 right? 

2 MR. LINGARD: Yeah. We do. We jump forward, 

3 move forward. If you would step forward to Slide 67? 

4 Here's where we will address the Life-Cycle 

5 Cost and Payback Period Analyses, the LCC PBP Analyses. 

6 Of course, our purpose here is to assess the 

7 net Life-Cycle Cost and Payback Period impacts on the 

8 consumer of the metal halide lamp fixture efficiency 

9 standards. 

10 Our method, the LCC equals the consumer price 

11 plus the sum of annual operating costs discounted to a 

12 particular base year. Obviously, this analysis is 

13 directed towards the consumer perspective. The 

14 analyses are implemented in an Excel spreadsheet. The 

15 results are expressed as the LCC difference, the 

16 baseline minus the standard level. 

17 We also consider simple payback. This is in 

18 years. This is the time needed to recover what would 

19 generally be the higher first costs through operating 

20 cost savings. It's also calculated here and you see a 

21 little flow diagram here at the bottom where the first 

22 costs of the equipment and the operating costs feed 

23 into the consumer's life-cycle and then again we make 

24 that comparison to determine the LCC impacts. 

25 A little more detail here on the LCC and 

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1 Payback Period Analysis approach. DOE analyzes the net 

2 effect on consumers by calculating the LCC and Payback 

3 Period using the engineering and performance data, the 

4 Energy Use and End-Use Load Characterization that we 

5 were just talking about, as well as the Mark-ups for 

6 Equipment Price Determination. 

7 DOE also conducts a rebuttal presumption 

8 payback period analysis as required under EPCA and for 

9 the preliminary analysis, we will conduct the LCC and 

10 Payback Period Analyses using typical values to reflect 

11 the conditions in the field for equipment retail price, 

12 life, energy costs, energy usage, and discount rates. 

13 As we proceed forward into the NOPR stage of 

14 rulemaking, we will carefully review all the comments 

15 garnered on the preliminary analyses and evaluate any 

16 additional parameters not included in those preliminary 

17 analyses and make any necessary revisions. 

18 On the next slide, this is sort of a 10,000 

19 foot view, if you will, of the LCC and Payback Period 

20 Analyses where you can see the variables that feed into 

21 total installed cost, operating cost, and lifetime 

22 operating cost. Those would be the shades in lighter 

23 green and how these in turn will feed into the Payback 

24 Period and Life-Cycle Cost results. 

25 So this could be a touchstone of sorts or a 

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1 quick reference to give us an overview of what we're 

2 doing in these analyses. 

3 In terms of determining energy prices for 

4 these analyses, we will survey residential -- well, in 

5 this case commercial and industrial tariffs as a means 

6 of establishing marginal electricity prices for 

7 consumers. We will also use data from CBECS, the 

8 Commercial Buildings Energy Consumption Survey, to 

9 estimate the building energy use characteristics that 

10 could in turn affect electricity prices, and we will 

11 also use projections of the national average energy 

12 prices, this from the Energy Information 

13 Administration's Annual Energy Outlook. We will be 

14 using the most recent versions of these available as 

15 inputs for future energy prices in the energy prices 

16 that are used in the LCC Analysis. 

17 And at this point, we would certainly welcome 

18 your input on the information sources and projection 

19 methods for electricity prices used in these analyses. 

20 MR. BROOKMAN: No additional comments on 

21 electricity prices? Where's Steve Rosenstock when we 

22 need him? 

23 (No response.) 

24 MR. BROOKMAN: Okay. I just want to give you 

25 another opportunity. Data sources. Any other thing 

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1 that you could think of? 

2 (No response.) 

3 MR. BROOKMAN: Okay. 

4 MR. LINGARD: Okay. We'll move on to 

5 installation, maintenance and repair costs. Back with 

6 you on Slide 72. 

7 The LCC Discount Rates. Of course, DOE uses 

8 these discount rates to determine the present value of 

9 the lifetime operating expenses and these are derived 

10 for both a distribution of discount rates for both 

11 commercial and industrial sectors. 

12 I should make a note here. You'll probably 

13 see a slight difference -- no, you won't see a slight 

14 difference between the hard copy and the screen 

15 version. Please disregard the discount rates of three 

16 and seven percent. We'll be talking about those as 

17 they refer to the National Impact Analysis. 

18 Instead, we're going to be drawing upon the 

19 weighted average cost of capital approach for 

20 determining these discount rate distributions for both 

21 commercial and industrial consumers of the fixtures. 

22 Now the WACC, this includes the financial 

23 cost of debt used to incur products as well as the 

24 opportunity costs of any equity used to purchase 

25 products and these are the two common pathways that 

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1 companies would use to fund investments. Again, if 

2 you'll disregard that next bullet point on the three 

3 and seven percent, that's not applicable in this case 

4 which brings us to our request for comment here. 

5 We welcome your input on these planned 

6 approaches for estimating discount rates, both the 

7 approach and information sources for consumers of these 

8 metal halide lamp fixtures. 

9 MR. BROOKMAN: No commenters, both approach 

10 and sources? 

11 (No response.) 

12 MR. BROOKMAN: No? Okay. I'm looking over 

13 here towards Jennifer Amann. I'm wondering if 

14 California or somebody has compiled that in all the 

15 work they've done. Weighted average cost of capital. 

16 Okay. Give you a chance to chew on that one. Okay, 

17 okay. 

18 Okay. So we're going to move on then. 

19 MR. LINGARD: I think here's one we can wrap 

20 our heads around. Metal halide lamp ballast lifetimes, 

21 ballast and fixture lifetimes. 

22 We have several information sources to draw 

23 upon. Manufacture product catalogs, other various 

24 literature sources that we can find, technical reports, 

25 conference proceedings, as well as, importantly, input 

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1 from manufacturers and other interested parties to 

2 establish the ballast lifetimes for use in the LCC and 

3 the subsequent analyses. 

4 Here's where we'll pause for comment. We 

5 welcome any comments on appropriate lifetimes for the 

6 lamp fixtures and ballasts contained in this rulemaking 

7 and this certainly harkens back to earlier comments I 

8 recall from Cheryl and Rebecca regarding reliability of 

9 electronic ballasts and certainly welcome any other 

10 input at this time. 

11 MR. BROOKMAN: If usage patterns are 

12 shifting, that'd be nice to get. Go ahead, Bob. 

13 MR. ERHARDT: I think, as NEMA, when we were 

14 in California, we kind of agreed to the typical 

15 lifetimes for electromagnetic HID ballasts to be about 

16 60,000 hours and electronic HID ballasts are designed 

17 for a lifetime of 30 to 50,000 hours. 

18 As far as reliability rates, anecdotally, we 

19 can comment and maybe you can discuss with individual 

20 manufacturers their proprietary experiences with 

21 reliability. 

22 MR. BROOKMAN: Based on test data or 

23 something? 

24 MR. ERHARDT: Or warranty returns. 

25 MR. BROOKMAN: Warranty returns. Okay. Yes. 

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1 Dale. 

2 MR. SIMPSON: Dale Simpson. Just to 

3 reiterate my earlier comment that the typical metal 

4 halide luminaire goes through multiple ballasts and is 

5 in fact repaired rather than replaced when the ballast 

6 fails. 

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

8 MR. ERHARDT: I didn't comment. I was 

9 thinking somebody from the luminaire section might, but 

10 some luminaires, from our NEMA discussions, can last 25 

11 years or more. 

12 MR. BROOKMAN: Okay. Rebecca, you want to 

13 add on here. 

14 MS. RAINER: Just a comment to what Bob said. 

15 Luminaires many times can last more than 25 years. I 

16 typically estimate 30 to 40 years on electromagnetic, 

17 much less on the electronic, but I think that's 

18 something I would like to cover, along with warranty 

19 data, in a manufacturer meeting. 

20 MR. BROOKMAN: Thank you. Okay. Yes. 

21 Amanda. 

22 MS. STEVENS: I was just going to add one 

23 other source of data, that PG&E sponsored a case study 

24 which is Codes and Standards and Enhancement Study, 

25 when we worked on the 2008 Standard and ACEEE was 

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1 actually the lead technical author, and so that cites 

2 some data, as well, on lifetime for ballasts and 

3 fixtures. 

4 Additionally, I mentioned maybe taking a look 

5 at the California DEER database, Database for Energy 

6 Efficiency Resources. I know that has expected 

7 lifetimes of some components. 

8 MR. BROOKMAN: Thank you. That's helpful. 

9 Okay, okay. I think in a little bit we're going to 

10 pause for lunch, but where are we now? 

11 MR. LINGARD: I think we can make it through 

12 this section. 

13 MR. BROOKMAN: Yeah. Through this section. 

14 Okay. 

15 MR. LINGARD: Yes. Stepping on to 

16 installation, maintenance and repair costs, 

17 installation costs may not change with more energy18 efficient designs as the new regulations may not change 

19 either the ballast lifetime or the labor costs for 

20 installing a standards-compliant ballast. 

21 Maintenance costs. DOE, we do not expect 

22 that the maintenance or labor costs for metal halide 

23 lamp fixtures will change with the more efficient 

24 designs. However, certainly at this preliminary point 

25 we recognize that more energy-efficient ballasts could 

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1 affect the useful life of the lamps in the fixture. 

2 Longer-life lamps would certainly defer and otherwise 

3 affect maintenance schedules and DOE does not -- at 

4 least at this stage we do not expect energy-efficient 

5 ballast designs to shorten lamp life. 

6 Repair costs. This may or may not be a part 

7 of the LCC Analysis because metal halide lamp ballasts 

8 are not repaired and ballasts are typically replaced at 

9 the end of their useful life and again this brings us 

10 to another opportunity for comment. 

11 We welcome any comments on how to develop 

12 these installation, maintenance and, if, indeed, 

13 applicable repair costs for metal halide lamp fixtures. 

14 If the lamp's operated by a more efficient ballast 

15 design would be affected, we would like comments on how 

16 that might impact relamping practices. As an example, 

17 either spot or group relamping, and how it could change 

18 as a result of energy conservation standards and 

19 ballast design. 

20 MR. BROOKMAN: Bill, do you want to comment? 

21 MR. BUSCH: Bill Busch. I think with Bob's 

22 previous comments, you can expect more maintenance 

23 costs due to a more frequent replacement of electronic 

24 ballasts than magnetic ballasts. So you need to 

25 consider that, as well as lamp replacement. 

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1 MR. BROOKMAN: Thank you. Yes. Bob. 

2 MR. ERHARDT: The subject of lamp lumen 

3 maintenance has come up repeatedly in various 

4 discussions of ballast regulation. Some electronic 

5 ballasts do improve lamp maintenance and lamp life, 

6 others do not, and as a matter of fact, some electronic 

7 ballasts can decrease lamp life and therefore also, as 

8 we've mentioned, the lamp ballast compatibility 

9 standards are very well defined for electromagnetic and 

10 are just now evolving with electronic. 

11 So especially if you're considering some of 

12 the higher-efficiency/high-frequency ballasts, there 

13 are no standards for lamp ballast compatibility and be 

14 very suspect of claims of -- you should not assume -- 

15 let's say -- let's put it this way. You should not 

16 assume that you will automatically get an increase in 

17 lamp lumen maintenance because I know from our Lamp 

18 Division they test right now to determine 

19 compatibility. All lamps have to be tested with all 

20 ballasts and some electronic ballasts increase lamp 

21 life, some electronic ballasts decrease lamp life. 

22 So we do not think that lamp life should be a 

23 determining factor in looking at maintenance costs as a 

24 function of ballast efficiency. 

25 MR. BROOKMAN: Okay. Thank you. Pam. 

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1 MS. HORNER: Pam Horner, wearing the Osram 

2 Sylvania hat. Our lamp people take -- it's not issue. 

3 We agree with the way DOE has stated this, but I'm 

4 going to read this sentence. 

5 It says, "DOE expects that the increased 

6 energy efficiency of ballasts could," I'm going to 

7 underline "could," that's to Bob's point, 

8 "significantly affect the useful," underline "useful 

9 lifetime," and as you proceed with your analyses, it's 

10 critical that you understand what we think you mean by 

11 "useful." 

12 To us, what that means is lumen maintenance 

13 could be increased and total years of life, if you turn 

14 them off, if you include controls, which I don't know 

15 if you're going to. 

16 Our company, at least, is not expecting to 

17 change rated life. Am I being clear? Okay. So if you 

18 mean what we mean, then we're okay with that phrasing, 

19 but this is sort of a course correction workshop. So 

20 we want to make sure that we're all understanding what 

21 yellow bricks we're laying down on the road. 

22 I also got input, the other companies may 

23 disagree on this, but at least our company so far would 

24 not make a recommended change in spot or group 

25 relamping based on ballast efficiency. 

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1 MR. BROOKMAN: Rebecca, you look like you 

2 might wish to comment. 

3 MS. RAINER: No. 

4 MR. BROOKMAN: I can't lure you in, huh? 

5 MS. RAINER: No. I'm in agreement with Pam. 

6 MR. BROOKMAN: Thank you for that. Yes. 

7 Dale. 

8 MR. SIMPSON: Dale Simpson. I notice on the 

9 slide just to point out that the Slide 74 says that the 

10 ballasts are not generally repaired when in fact the 

11 document says luminaires are not generally repaired, 

12 fixtures are not generally repaired, and that brings us 

13 to the earlier comment, that ballasts are in fact 

14 replaced within luminaires. 

15 As far as maintenance costs, we'd urge you to 

16 consider that, particularly in exterior environments, 

17 maintenance costs can be quite significant. It's 

18 difficult to get a bucket truck to a site to work on 

19 pole-mounted luminaires for less than a thousand 

20 dollars just to get it there and the average that our 

21 experience shows needs to be attributed somewhere 

22 between $150 and $300 per luminaire per servicing. So 

23 that is higher than you would traditionally think it 

24 would be for interior and just wanted to make that 

25 comment. 

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

2 Yes. Cheryl. 

3 MS. ENGLISH: Bob, I actually just have a 

4 question. If you can go back to Slide 70 on this chart 

5 that describes costs, at the very top we've got ballast 

6 installation costs feeding into a total installed cost, 

7 and I believe that what you've described is much 

8 broader than that, but I just wanted to clarify that, 

9 you know, when we talk about total installed cost, 

10 we're talking about something much broader than just 

11 the ballast. 

12 MR. LINGARD: Yeah. It probably would be 

13 more appropriate to say the fixture installation costs 

14 which would incorporate the ballast. 

15 MS. ENGLISH: Yeah. There may be a small 

16 impact, I believe it would be small, but because of the 

17 increased use of controls, there may be some 

18 commissioning costs that do impact that initial 

19 installed cost, as well. 

20 MR. BROOKMAN: Would you say that 

21 commissioning costs are for larger applications? 

22 MS. ENGLISH: Yeah. Anywhere that the 

23 controls would be used, so you're talking about 

24 warehouse bays, maybe some large outdoor parking lots, 

25 roadway-type of things, but yes, they generally tend to 

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1 be -- 

2 MR. BROOKMAN: Distributed among many units. 

3 Yes, okay. Okay. Yes. Bob. 

4 MR. ERHARDT: Yeah. Just to elaborate a 

5 little bit. As a general trend, we're trying to point 

6 out that you should not be looking at the incremental 

7 cost of the ballast. There are many other costs with 

8 the luminaire and this is a luminaire rulemaking and 

9 you should be looking at luminaire costs, total 

10 luminaire costs and not just the ballast cost, 

11 incremental cost. 

12 MR. BROOKMAN: Okay. Thank you. Good 

13 clarification. Jennifer. 

14 MS. AMANN: Hi. Jennifer Amann. I'm sorry. 

15 I was taking some notes, Dale, and I missed the point 

16 you were making. I just wanted to ask you a question 

17 to clarify. 

18 Were you saying that there were reasons why 

19 the maintenance costs are higher for more efficient 

20 luminaires than they are for typical metal halide 

21 luminaires? 

22 MR. BROOKMAN: Dale. 

23 MR. SIMPSON: Dale Simpson. No. What I was 

24 just saying is that when you're dealing with 

25 applications, such as an exterior application, 

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1 maintenance costs are driven by the location of the 

2 luminaire which requires unusual equipment. 

3 MS. AMANN: Okay. So for the purposes of 

4 this rulemaking, there's not a difference. So moving 

5 to a more efficient one wouldn't necessarily increase 

6 maintenance costs relative to a standard luminaire? 

7 MR. SIMPSON: If moving to a more efficient 

8 one decreased the lifetime of componentry, yes, it 

9 would and that needs to be taken into consideration. 

10 MR. BROOKMAN: Rebecca and then Bob. 

11 MS. RAINER: Yes. As I had stated earlier, 

12 we need to make sure that we take the total life-cycle 

13 cost analysis because it could potentially because of 

14 the reliability and the stated lifetime of the 

15 components, it could, indeed, increase your maintenance 

16 costs. 

17 MR. BROOKMAN: Bob. 

18 MR. ERHARDT: Yeah. I think that's what we 

19 pointed out just a little earlier. The design lifetime 

20 of electronic ballasts typically is lower than the 

21 design lifetime of an electromagnetic product. So that 

22 will increase the lifetime costs of a luminaire because 

23 you'll have to replace the ballast more often. 

24 MR. BROOKMAN: Okay, okay. So Ron Lewis. 

25 MR. LEWIS: With the magic of electronics, I 

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1 got an update. We do have confirmation that that 

2 update study is underway to update the characterization 

3 volume. I don't have a completion date, but it is 

4 underway. So I've confirmed that for you. 

5 MR. BROOKMAN: So more to be revealed later. 

6 Okay. Thank you for that. That's helpful. 

7 I want to make sure we don't short-shrift -- 

8 this last bit of comment was very helpful. Additional 

9 and perhaps final comments on this segment here? 

10 (No response.) 

11 MR. BROOKMAN: So then I'm going to suggest 

12 we go to lunch. Before everybody bolts, it's now 

13 12:10. We'll resume at 1:10 here in this room. This 

14 room will be locked. Please make sure you wear your 

15 badges. 

16 (Whereupon, at 12:10 p.m., the meeting was 

17 recessed for lunch, to reconvene at 1:10 p.m.) 

18 / 

19 / 

20 / 

21 / 

22 / 

23 / 

24 / 

25 / 

26

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

2 1:14 p.m.

3 MR. BROOKMAN: Okay. Let’s resume. Thanks 

4 to all of you for being back on time. We are going to 

5 pick up where we left off. 

6 Let me make one announcement. The Department 

7 has gotten more careful about foreign nationals and so 

8 any of you in future meetings that might wish to bring 

9 company members that are also foreign nationals, please 

10 make sure you notify the Department in advance and get 

11 that all cleared and square and then it will be easier 

12 for them to attend these meetings. So if you would 

13 please think about that the next time early. 

14 So we are going to proceed with Michael Myer, 

15 Shipments Analysis. 

16 Shipments Analysis, National Impact Analysis,

17 and Life-Cycle Cost Subgroup Analysis

18 MR. MYER: Okay. Good afternoon. Welcome 

19 back from lunch. My name is Michael Myer. I’m with 

20 Pacific Northwest National Laboratory and we’ll be 

21 discussing Shipment Analysis and National Impact and 

22 other fun stuff. 

23 So the Department of Energy will conduct 

24 shipment analysis to get a sense of what the impacts 

25 are from potential changes, or actually in this case, 

26 amended energy efficiency standards. Methodology is 

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1 pretty straightforward. We will rely on a range of 

2 data sources. We will consider all these shipments of 

3 covered products. 

4 Two possible approaches would be based on 

5 historical data and then some future projected modeling 

6 based on what we know of equipment installed. 

7 The whole base case of shipments forecast 

8 work as this. We depict a situation where the 

9 standards are not amended. It depicts the current mix 

10 of balance efficiency sold in the absence of new 

11 regulation. 

12 Shipment forecasts looks at three areas: new 

13 construction, replacements of failed units and 

14 retrofits. And we’ll discuss what those terms mean in 

15 a second. And then we look at data requirements of 

16 historical shipments and the breakdown by market 

17 segment of new construction, replacement and retrofits. 

18 At this point this brings us to item 31. DOE 

19 welcomes recommendations on sources of data for 

20 shipments of metal halide lamp fixtures by product 

21 class. In addition DOE welcomes comments on how it 

22 might characterize long-term trends in the efficiency 

23 of metal halide lamp fixtures for the base-case 

24 shipment forecast. 

25 MR. BROOKMAN: Bob? 

26 MR. ERHARDT: Yeah, we already made a comment 

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1 about other technologies. We also -- if the Department 

2 of Energy chooses to regulate below 140 watts, we would 

3 point out that often low power metal halide are 

4 replacing halogen and not necessarily other metal 

5 halide luminaires. And so if you make the cost of the 

6 replacement metal halides too prohibitively high, you 

7 may be counterproductive by shifting back towards a 

8 less efficacious halogen product. And, again, keep in 

9 mind T5H0 fluorescents and solid-state lighting 

10 entering the market and affecting transit future sales 

11 and high pressure sodium. 

12 MR. BROOKMAN: His microphone is on. We’ll 

13 get him to be orbital or whatever that would be. Okay. 

14 Thank you. 

15 He was having a hard time hearing you. 

16 MR. ERHARDT: I see. 

17 MR. BROOKMAN: I think you got that, though, 

18 didn't you? 

19 MR. MYER: Yes. 

20 MR. BROOKMAN: Okay. We’ll make sure.

21 Thank you for that comment. We are referring 

22 back to item 31 which Michael just referred to. 

23 Additional comments on how to characterize long-term 

24 trends, metal halide lamp fixtures. 

25 Yes, Amanda. 

26 MS. STEVENS: Amanda Stevens for BGE. I 

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1 guess for the base-case forecast, I would also 

2 encourage DOE just to account for the fact that there 

3 is a new California standard going into effect in 2010. 

4 And so, by the time the standard -- the DOE’s standard

5 becomes effective in 2015, that will have had a pretty 

6 significant impact on the market. So those factors 

7 should be assesses and looked at. 

8 MR. BROOKMAN: Okay. Thank you. 

9 Other comments before we move on, base-case 

10 shipments forecast? 

11 (No response.) 

12 MR. MYER: Continuing on. Accounting 

13 methodology. A discussion on the three terms I 

14 mentioned earlier, new construction, replacements, and 

15 retrofits. 

16 New construction, these are new metal halide 

17 fixtures installed each year in new or remodeled 

18 buildings. They are not replacing a failed fixture. 

19 It’s a gut-rehab type of thing or a new building that 

20 never existed. 

21 Replacements, new metal halide fixtures that 

22 are installed each year to replace ballasts that have 

23 failed. We’ve heard comments about the ballasts or 

24 replacing fixtures to that might be adjusted. 

25 And retrofits, these are metal halide lamp 

26 fixtures that replace metal halide lamp fixtures during 

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1 renovation and repair of equipment. This may occur 

2 before the ballasts fail. 

3 That brings us to item 32. DOE welcomes 

4 comments on the accounting methodology described above 

5 for each of the metal halide lamp fixtures covered in 

6 this rulemaking. 

7 MR. BROOKMAN: Yes. Bill Bush? 

8 MR. BUSH: Are you expecting to get this 

9 breakdown from luminaire manufacturers? Because I 

10 don't believe our records are kept that way. We sell 

11 to electrical wholesalers for the most part and we 

12 don’t know where it’s going. 

13 MR. MYER: That’s understandable that you 

14 sell it to -- we’ve discussed this in supply chain and 

15 we would understand that through that supply chain that 

16 we wouldn’t be able to break it down by the segment. I

17 think we’ll have to review another method of breaking 

18 down this data into those segments by looking at other 

19 data sources that might look at new construction and 

20 other type metrics. Thank you for pointing that out, 

21 that manufacturers don’t have that type of data. 

22 MR. BROOKMAN: Pam? 

23 MS. HORNER: Pam Horner. I think taking Bob 

24 Erhardt’s previous comment again into this and pulling 

25 that into this one, these three would seem on the 

26 surface to exclude -- excuse me -- the situation 

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1 particularly in retail where metal halide luminaires 

2 save for accent lighting, et cetera, would replace 

3 today’s existing halogen types. And you might think 

4 it’s new construction or major retrofit, but sometimes 

5 just doing the lighting system isn’t a major retrofit. 

6 So if you don’t want to lose that, you either make a 

7 note -- 

8 (Laughter.) 

9 MS. HORNER: -- or you create some -- you 

10 know, a retrofit type B which is that you take out not 

11 just what’s called here a metal halide lamp fixture, 

12 but some other kind of fixture. So that way you 

13 wouldn’t lose that point that he made. 

14 MR. MYER: In a sense, retrofit A would be 

15 retrofits within this product category and retrofit B 

16 would be non-products being replaced. 

17 MS. HORNER: Right. Right. 

18 MR. MYER: Or non-covered or non-product 

19 parts. 

20 MS. HORNER: Because it is a huge trend, as 

21 Bob pointed out, especially in retail to move toward 

22 metal halide. 

23 MR. BROOKMAN: Okay. Thank you. Thank you. 

24 Yes, Dale. 

25 MR. SIMPSON: Dale Simpson. Thank you. 

26 Just to reiterate again the replacements 

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1 category which indicates that essential a luminaire is 

2 replaced when the ballast fails. We need to look at 

3 that differently. 

4 MR. BROOKMAN: Okay. 

5 MR. MYER: Continuing on. Standard impacts 

6 on ballast shipments. DOE will develop standards for 

7 case forecasts at the same time we do the base-case, 

8 standard-base forecasts. Look at purchase price 

9 increases and operating cost savings due to changes in 

10 estimate in shipments. 

11 DOE will also look at market–pull programs, 

12 rebates from energy-efficiency programs, the utilities 

13 that might shift towards something else. Impacts on 

14 the total amount of light produced by these ballasts in 

15 the commercial and industrial sector may also be 

16 considered. 

17 Item 33, DOE welcomes comments on how amended 

18 energy conservation standards might affect shipments of 

19 metal halide lamp fixtures. 

20 DOE also requests information about existing 

21 market-pull programs such as consumer rebate programs 

22 to promote the adoption of more efficacious ballasts. 

23 MR. BROOKMAN: Bob? 

24 MR. ERHARDT: Yeah, I think our comments on 

25 the previous item kind of address that too. The metal 

26 halide ballasts are looked at not as their own entity, 

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1 but against other technologies and increased the cost 

2 of the metal halide ballasts and increased the 

3 popularity of other technologies. 

4 MR. BROOKMAN: Are there a lot of market-pull 

5 programs? 

6 MR. ERHARDT: There -- maybe Pacific Gas and 

7 Electric can comment on the CEE rebate programs. 

8 MR. BROOKMAN: I don’t think you’re on, 

9 Amanda. 

10 MS. STEVENS: Sorry, this is Amanda Stevens. 

11 That’s information I could certainly help gather. I 

12 don't have that at my fingertips, but I know PG&E has 

13 various rebate programs that incent more efficient 

14 metal halide fixtures through a variety of different 

15 programs. 

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

17 Bill. 

18 MR. BUSH: Bill. A lot of these programs, 

19 though, as I mentioned before, are focusing on 

20 retrofits using fluorescent and a lot of them do not 

21 even address using any kind of HID to retrofit an 

22 existing HID. 

23 MR. BROOKMAN: So how do we capture that? 

24 MR. MYER: Are you saying that there are 

25 programs out there that are offering, let’s say, $50 to

26 replace a probe start with a pulse start? Or 

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1 situations where they’re saying replace a 360 watt for 

2 a 400? 

3 I agree that the HIF market is very much 

4 targeted, you know, fluorescents targeting certain 

5 markets. But I’m getting the sense you’re not saying 

6 that they’re not specifically saying replace probe 

7 start with pulse start or ballast efficiency? 

8 MR. BUSH: Well, that’s correct. I’ll give 

9 you an example just in terms of light output. To 

10 replace a 400 watt metal halide pretty much standard 

11 practice to replace it with pulse start is to use 320 

12 watt. But the rebate programs for most utilities don’t

13 even recognize that. They’ll pay you to replace it 

14 with a 6x54 fluorescent high-bay which is basically the 

15 same input watts as a 320 watt. But they ignore the 

16 possibility to use HID. Ad that’s just the way the 

17 specific utilities choose to write their programs. 

18 MR. BROOKMAN: And the incentive is so 

19 ordinarily cast you might not make the right efficiency 

20 choice. 

21 MR. BUSH: Correct. Or the right lamp choice 

22 application. 

23 MR. BROOKMAN: Yeah. 

24 MR. BUSH: And a lot of them pay per lamp. 

25 MR. BROOKMAN: Uh-huh. 

26 MR. BUSH: Some of them pay per luminaire. 

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1 MR. BROOKMAN: Uh-huh. 

2 MR. BUSH: Several years ago in the northeast 

3 they had rebate programs to install HID luminaires with 

4 high/low, two level. Those are pretty liberal. Those 

5 have kind of gone away. 

6 MR. BROOKMAN: Did you want to continue, Pam? 

7 MR. MYER: Please say your name. 

8 MR. LIS: Dave Lis at Northeast Energy 

9 Efficiency Partnerships. I can provide you with a 

10 summary of some of the incentive programs at Northeast. 

11 They do exist. I don't know the details of what the 

12 cutoffs are, but they are pretty common, actually, 

13 still. 

14 MR. BROOKMAN: Thank you. That will be good. 

15 Okay. 

16 MR. HANSEN: This is Dain Hansen really 

17 quick. There’s a really good website that can be used 

18 as general incentives for all states, various programs. 

19 It’s www.dsire -- dsireUSA.org. It’s very 

20 comprehensive and very extensive. So that’s a good 

21 listing and it’s very up to date.

22 MR. BROOKMAN: They must have expanded it 

23 because I thought it was utility-based stuff when I saw 

24 it previously. 

25 Thank you. 

26 MR. MYER: And one last thing. The HID 

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1 determination has also looked at these and that 

2 document will have some of them as well. That’s an 

3 additional resource. 

4 MR. BROOKMAN: Uh-huh. 

5 MR. MYER: Continuing on. National Impact 

6 Analysis. So we are going to look at the national 

7 impact analysis and here are a lot of the inputs. 

8 We’ll get shipments. This was previously discussed. 

9 We’ll look at the stock of metal halide lamp ballasts. 

10 This is calculated from the life of the ballast from 

11 previous analysis. The effective date of the standard 

12 is 2015 with a 30-year analysis period. 

13 Base-case forecasted efficiency will be a 

14 distribution of base-case shipments by efficiency over 

15 time. The standard-case forecast will be a 

16 distribution of efficiency for each of the standards 

17 case. And the unit of energy will be kilowatt-hours 

18 per year. And that was established earlier as well. 

19 Continuing on. We’ll look at the total 

20 installed cost which is established in Section 7 which 

21 we discussed earlier and 8, mark-ups and lifecycle 

22 costs. We also look at the electricity price forecast 

23 also previously discussed in the life-cycle cost 

24 section. 

25 We will also look at an electricity site-to26 source conversion. This varies yearly and is generated 

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1 by the Energy Information Agency their AEO report. 

2 We’ll also look at the potential for interior 

3 applications, heating, ventilation and air-conditioning 

4 impacts. And we’ll get some possible interactions 

5 there, either additional cooling benefits or additional 

6 heating changes. 

7 The discount rate will be 3 and 7 percent. 

8 The present year preliminary analysis will be 

9 discounted to 2010, the current year we’re in, and the 

10 rebound effect is the difference between the projected 

11 and the actual savings due to increase deficiency. 

12 Continuing on. Brings us to items 34 and 35. 

13 Item 34, DOE welcomes comments on the data sources 

14 that it anticipates using to develop the inputs for the 

15 National Impact Analysis. 

16 And Item 34, DOE welcomes comments from 

17 interested parties on whether a more efficient metal 

18 halide lamp fixture will be used more as a result of 

19 increased efficiency and whether such a rebound effect 

20 would be expected for this technology. 

21 MR. BROOKMAN: Bob? 

22 MR. ERHARDT: Just if you’re looking out from 

23 the period of 2015 to 2044, the impact of alternative 

24 technology is going to be dramatic. And I anticipate 

25 you will have a great deal of difficulty. If you look 

26 at the DOE projections and solid-state lighting, there 

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1 may not be metal halide by 2045. 

2 So we’re very interested in how you’re going 

3 to project beyond maybe 2020 with respect to 

4 alternative technologies. 

5 MR. BROOKMAN: Has the industry come up with 

6 any projections themselves? Maybe they’re proprietary.

7 Bob? 

8 MR. ERHARDT: Yeah, one comment. When you do 

9 talk to individual companies on a case-by-case 

10 proprietary basis, you may get some additional 

11 information. 

12 MR. BROOKMAN: Okay. Andrew? 

13 MR. deLASKI: Andrew deLaski, ASAP. It just 

14 strikes me that this is a sensitivity analysis, you 

15 know, because we can’t predict you’re going to have to 

16 run some scenarios in terms of where the shipments are 

17 going to go. Since I don’t think any of us can predict

18 with any kind of accuracy what the LED market share is 

19 going to be in 2025. 

20 I also wanted to ask the Department about 

21 item number 35. I’m not aware of any data, but others 

22 may be, on -- rebound effect on metal halide lighting. 

23 Are you aware of any data at this point that would -- 

24 are you in favor of a rebound -- support a rebound 

25 effect? 

26 MR. BROOKMAN: I’m not aware of any data at 

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1 this point. 

2 MR. deLASKI: Okay. Thanks. 

3 MR. BROOKMAN: Yes. 

4 MR. HARDING: And for those of us who are 

5 wanting to know what’s a rebound effect if we’re not 

6 talking about -- you know. 

7 MR. BROOKMAN: That was Tom. Thank you, Tom. 

8 Andrew, do you want to -- 

9 MR. deLASKI: I’ll let the Department do 

10 that. 

11 MR. MYER: Thanks. Well, it’s the difference 

12 between the projected and actual savings due to 

13 increased efficiency. My understanding is -- well, my 

14 understanding is going to be kind of what it is because 

15 that’s my loose grasp of it as well. Maybe Mimi will 

16 step in and save me. 

17 PARTICIPANT: (Off microphone.) So I think 

18 the way the rebound effect works is that and sometimes 

19 they do these analyses they try to take into account 

20 how increasing the efficiency -- might result in 

21 consumers using the products more -- see that they’re 

22 saving money -- 

23 MR. STAS: Eric Stas, DOE. For example, if 

24 you have an air conditioner in your room and your 

25 electricity bills are high, but then you buy a new 

26 super-efficient air conditioner, you say, wow, I’m 

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1 going to make my house cooler because I am much more 

2 comfortable. And it’s sort of like the payments will 

3 even out. 

4 (Simultaneous conversation.) 

5 MR. BROOKMAN: -- would not capture all those 

6 savings that they had anticipated. 

7 MR. MYER: We have to re-summarize what Mimi 

8 said because of a microphone snafu. Essentially it’s 

9 that there is an assumption by the general public that 

10 the energy -- the device is so efficient it’s okay to 

11 use it more. And actually you would have more energy 

12 use than actual saved. 

13 PARTICIPANT: (Off microphone.) Or reduce 

14 your energy savings. 

15 MR. MYER: Or, yes, reduce your savings 

16 because there’s more of a new use than the savings.

17 MR. deLASKI: Or the thing I would caution 

18 against is using rebound effect that have been measured 

19 for the residential sector and applying them to the 

20 commercial sector. I think that will be inappropriate. 

21 So, I think you can look for specific data that would 

22 support the existence of a rebound effect in the 

23 commercial lighting sector to be able to support using 

24 rebound effect in this analysis. 

25 MR. BROOKMAN: Okay. Other comments? 

26 (No response.) 

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1 MR. BROOKMAN: Okay. 

2 MR. MYER: Continuing on with the National 

3 Energy Savings. DOE intends to calculate national 

4 energy consumption for each year beginning with the 

5 expected effective date of the standards which is 2015. 

6 DOE will calculate national electricity consumption 

7 for the base case in each standard level analyzed. 

8 We’ll use a spreadsheet, the NES, the National Energy 

9 Savings spreadsheet developed in 1996. 

10 That brings us to Item 36. DOE welcomes 

11 comments from interested parties on the NES spreadsheet 

12 models that it plans to use for estimating national 

13 impacts on energy conservation standards for metal 

14 halide lamp fixtures. 

15 MR. BROOKMAN: No comments from industry? 

16 Amanda? 

17 MS. STEVENS: Amada Stevens for PG&E. This 

18 is just a general request I’ve been making, but in 

19 these spreadsheets, it would be really helpful for us 

20 to be able to see the energy savings, the annual energy 

21 savings, not just the cumulative energy savings over 

22 the 30 years. So if there’s a way that that -- 

23 sometimes it seems like those numbers are bundled 

24 together on a spreadsheet that’s hidden and you can’t 

25 view it. So it would be really great to see like a 

26 graph with the annual energy savings from the different 

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1 standard levels. 

2 MR. BROOKMAN: Thank you. 

3 Additional comments on Item No. 36? 

4 MR. deLASKI: Just a question for 

5 clarification. This is Andrew deLaski. So you said 

6 the NES spreadsheet develop -- okay. So the general 

7 approach has been used since 1996, is what you’re 

8 referencing here? 

9 MR. MYER: We’re not using 13-year-old data 

10 if that’s your question.

11 MR. deLASKI: Yes, that’s my question.

12 MR. MYER: It’s a spreadsheet that was

13 developed 13 years ago. 

14 MR. deLASKI: Okay. 

15 MR. BROOKMAN: Okay. 

16 MR. MYER: Continuing on to a fun diagram. 

17 So we have the shipment analysis up here at the top and 

18 feeding into both the base-case projection and the 

19 standards-case projection. As mentioned earlier, 

20 starting both at 2015 and extending out to the far 

21 future of 2044. We’ll look at the base case cumulative

22 energy usage, how it feeds into the site source energy, 

23 the standard case, and we’ll end up with a national 

24 energy savings. So graphic representation of what 

25 we’ve just been discussing.

26 Continuing on. Another analysis -- another 

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1 diagram of shipment analysis. So, again, you have 

2 feeding both into the base case and the standards case. 

3 Both of them they’re very similar with energy costs 

4 from 2015 to 2044, maintenance and installation costs 

5 and products costs. Those are both feeding into 

6 cumulative operating costs on both sides. Our total 

7 equipment cost increases and the discount rate and you 

8 get a net present value. 

9 Continuing on. DOE will calculate the net 

10 present value on a consumer saving resulting from 

11 energy conservation standards. This is the annual 

12 equipment expenditures by multiplying the price per 

13 unit. That’s the difference between base case and the 

14 standard case. For metal halide fixture making the 

15 differential will likely result in an NES offset 

16 against increased ballast expenditures. And the 

17 difference each year between the energy bill savings 

18 and the increased expenditures is the net savings or 

19 negative net costs. 

20 MR. BROOKMAN: Let’s just pause for a moment. 

21 I think many of you are familiar with this general 

22 framework. Questions or comments before we move along? 

23 (No response.) 

24 MR. BROOKMAN: Okay. 

25 MR. MYER: Okay. Moving into the NOPR 

26 analyses. We have a new diagram here. And looking at 

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1 the life-cycle costs subanalysis. So the purpose here 

2 is to look at the economic impacts of standards on 

3 consumers, people who might be disproportionately 

4 affected, elderly, ethnic minorities, low-income 

5 consumers, any subset that would be affected by this 

6 standard somehow. 

7 The method, you look at the LCC analysis and 

8 examine the impacts for the defined subgroups. DOE 

9 will evaluate variations of regional electricity 

10 prices, usage profiles and see what the effect on the 

11 NPV is for the differing consumer subgroups. 

12 Okay. Moving on to Item 37. DOE welcomes 

13 comments from interested parties on what if any 

14 consumer subgroup should be considered when developing 

15 standards for metal halide lamp fixtures. 

16 MR. BROOKMAN: You see a listing of groups 

17 that have been identified previously. Are there 

18 others? Pam? 

19 MS. HORNER: I’m on. Pam Horner. In our 

20 NEMA response we will likely include a list of 

21 suggestions. The current one that we’re rattling 

22 around would have some forms of -- shall I call it -- 

23 retail, different types. I’d loosely categorize the 

24 next one as community. There are certain community 

25 municipality types. And then finally an industrial 

26 segment that might include warehousing, et cetera. But 

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1 well include them in our written comments. 

2 MR. BROOKMAN: Thank you. 

3 MR. MYER: Continuing on to the Manufacturer 

4 Impact Analysis. And I’ll stop briefly and turn it 

5 over to Doug. 

6 Manufacturer Impact Analysis

7 MR. ROSSIN: Thanks, Michael. 

8 So, the Manufacturer Impact Analysis or MIA 

9 has three main purposes. The first main purpose is to 

10 assess the impacts of energy conservation standards on 

11 manufacturers of metal halide lamp fixtures and 

12 manufacturers of metal halide ballasts. 

13 The second main purpose of the MIA is to 

14 identify and estimate the impacts on manufacturing 

15 subgroups that may be more impactive than the industry 

16 as a whole. 

17 Now, in other DOE rulemakings an example of a 

18 small business manufacturer might be -- or sorry, 

19 example of a subgroup may be a small business 

20 manufacturer. 

21 Now, in other rulemakings DOE has identified 

22 those using a number of employees the company may have. 

23 And finally, the third main purpose of the 

24 MIA is to examine the impacts of cumulative regulatory 

25 burden on the industry. This is where DOE looks at 

26 other DOE regulation and federal regulation that may 

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1 impact the industry financially. And in terms of 

2 methodology DOE uses the government regulatory impact 

3 model or the GRIM to calculate the industry net present 

4 value at each efficiency level. Also DOE uses 

5 interviews for manufacturers and other interested 

6 parties to further develop a sub-analysis and also to 

7 address any qualitative issues. 

8 In terms of output DOE has the industry net 

9 present value, has the industry net present value for 

10 subgroups if its found applicable, and other impacts 

11 such as direct employment, community regulatory burden, 

12 and capacity. 

13 Now, here we see a picture that shows us the 

14 three phases of the MIA. In phase one which happens 

15 during the preliminary analysis DOE uses publicly 

16 available information such as manufacturers’ annual 

17 reports to develop an industry profile. It also uses 

18 this information to calculate manufacturers’ financial 

19 parameters and also to estimate the cost of complying 

20 with standards. 

21 Also in phase one DOE conducts preliminary 

22 MIA interviews in conjunction with the engineering 

23 interviews. This is a first chance for manufacturers 

24 to provide detailed information on possible impacts due 

25 to standards. 

26 In phase two DOE develops or sorry, in phase 

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1 two which happens during -- between the NOPR phase and 

2 the preliminary analysis, DOE develops the spreadsheets 

3 for the GRIM. Now, the GRIM outputs cash flows for the 

4 analysis period and calculates the INPV by summing the 

5 discounted cash flow over the analysis period. Now 

6 this is done for both a base case and standards case. 

7 The difference between both cases is a quantitative 

8 representation of the impacts on manufacturers. 

9 Also in phase two DOE develops interview 

10 guides that are used during interviews. 

11 In phase three which happens during the NOPR 

12 phase, DOE conducts the MIA interviews and uses the 

13 information to develop the subanalysis and also to 

14 revise any of the GRIM inputs. 

15 And during the final rule phase DOE revises, 

16 if applicable, the results. And I wanted to point out 

17 that information provided by manufacturers or other 

18 interested parties is kept confidential and made public 

19 only in an aggregate form. So no manufacturer’s 

20 specific data is made public. 

21 That concludes the MIA. But there’s two 

22 comments here that DOE seeks input, specifically on 

23 subgroups of metal halide lamp fixtures and ballast 

24 manufacturers and also on any pending regulation that 

25 could impact manufacturers. 

26 MR. BROOKMAN: That would constitute a 

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1 regulatory burden? 

2 MR. ROSSIN: Yes. 

3 MR. BROOKMAN: Dale. 

4 MR. SIMPSON: Thank you. Dale Simpson. 

5 As far as the Item 38, the manufacturer 

6 subgroups, I would argue that exterior luminaire 

7 manufacturers are disproportionately affected and 

8 should be analyzed as a subgroup as should 

9 manufacturers of luminaires that go into other what 

10 I’ll call extreme spaces like freezers and refineries, 

11 places of that sort should be looked at differently 

12 than the rest. And that’s all I have on that.

13 MR. BROOKMAN: Thank you. 

14 MR. SIMPSON: Oh, on Item 39, I did have one 

15 more thing. On Item 39 I would suggest definitely to 

16 consider California Title 20 and the pending outdoor 

17 lighting legislation in the regulatory burden. 

18 MR. BROOKMAN: Thank you. 

19 So your specific comments on how that’s 

20 affecting manufacturers that would help the Department. 

21 Ron Lewis? 

22 MR. LEWIS: As an extension of that, if the 

23 names of the specific manufacturers that might be 

24 included in that to get a flavor of both quantity and 

25 profile of those kinds of companies so how we would 

26 consider them would be helpful. 

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1 And as you brought up, special categories, it 

2 just occurred to me, there are things like hazardous 

3 locations, you know, explosion proof or dust proof, you 

4 know, kinds of things that the luminaires are rated 

5 for, you know, now does that fit in? Should that be a 

6 category of that. If that’s an application, it’s not a

7 manufacturer, so how do you, you know, go about -- is 

8 there a disproportionate somebody that just 

9 manufactures to that application, for instance? Any of 

10 that kinds of information that you can give us to help 

11 to educate us on the specifics would be much 

12 appreciated. 

13 MR. BROOKMAN: Thank you. 

14 Yes, Pekka. 

15 MR. HAKKARHNEN: I’m Pekka Hakkarhnen. Just 

16 asking for clarification on slide number 96, if you 

17 could go back to the page there. There’s a tick mark 

18 between phases two and three and above that tick mark 

19 is NOPR. Does that indicate that NOPR is published at 

20 that point or does it mean something else? 

21 MR. ROSSIN: I guess for clarification phase 

22 three happens just basic on the NOPR. So the 

23 publishing of the NOPR would be after phase three. 

24 MR. HAKKARHNEN: After phase three? 

25 MR. ROSSIN: Yes. 

26 MR. HAKKARHNEN: Okay. Thank you. 

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1 MR. BROOKMAN: That connotes the commencing; 

2 right? Yeah, that’s when that phase starts. 

3 Please, Jennifer.

4 MS. AMANN: Jennifer Amann. I just have some 

5 general comments about the Manufacturer Impact Analysis

6 and particularly the calculation of industry in that 

7 present value. In looking at your plans for the MIA, 

8 you examine the impact of the cumulative regulatory 

9 burden on industry which I think rightfully recognizes 

10 that these manufacturers are subjected to other lamp 

11 standards affecting different product lines. 

12 But in the case most recently of the lamp 

13 standards, the MIA and calculation of industry net 

14 present value focused only on losses associated with 

15 changes in the regulated product category. Not 

16 recognizing any benefit to the industry if changes in 

17 the product mix or changes in sales migration from 

18 covered product to other products would also -- would 

19 translate into continued sales for that industry 

20 because they make the alternative products as well. 

21 So we had quite a bit of discussion at the 

22 rulemaking stage for lamps about this kind of black box 

23 drawn just around the covered product category in 

24 determining industry net present value that didn't 

25 account for any of the benefit to industry or, you 

26 know, it only looked at losses from one product line 

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1 not gains and other product lines. And I think we 

2 would just encourage the Department to look more 

3 broadly at the industry in doing the NPV just as you’re

4 recognizing the cumulative impact of standards 

5 affecting other business lines. 

6 MR. BROOKMAN: Okay. Thank you. 

7 So you can see the questions that the 

8 Department is asking there in those two comment boxes. 

9 Any additional responses? 

10 (No response.) 

11 MR. BROOKMAN: Okay. 

12 MR. ROSSIN: So I’ll pass it back to my 

13 colleague Michael on Utility Impact Analysis. 

14 Utility Impact Analysis, Employment Impact Analysis, 

15 environmental assessment, and Regulatory Analysis

16 MR. MYER: Thanks, Doug. 

17 And we’ll finish with me the rest of the 

18 afternoon. So the Department of Energy will do a 

19 Utility Impact Analysis. The focus of this analysis is 

20 to look at the overall energy supplies and how they 

21 could be affected by amended or imposition of energy 

22 conservation standards. 

23 The methodology here uses a modeling program 

24 called NEMS-BT. NEMS stands for the National Energy 

25 Modeling System. In this case it would be a slightly 

26 modified version looking at building technologies. 

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1 It’s been used by DOE and the EIA on their annual 

2 report as the basis for the utility impact analysis. 

3 Outputs of utilities will also factor into this. 

4 Forecasted electricity generation, sales, price, and 

5 avoided capacity. 

6 DOE will model the energy savings impacts 

7 from amended conservation standards using NEMS-BT to 

8 generate forecasts. 

9 Item 40. DOE seeks inputs on its plans to 

10 use NEMS-BT to conduct the utility impact analysis on 

11 the equipment covered under this rulemaking. 

12 MR. BROOKMAN: No additional comment on NEMS? 

13 Andrew? 

14 MR. deLASKI: I don't know where this 

15 comment belongs, but I’ll make it here. It may have 

16 belonged back in the NES discussion. But the 

17 Department in other dockets recently has begun to 

18 analyze the impact of electricity savings on the 

19 overall price level of natural gas. I think that’s 

20 something you want to look at in this docket as well, 

21 if the savings levels are shown to have impacts. If 

22 you set up that model to do that, you can run it in 

23 this docket as well. And we recommend it elsewhere 

24 that you should do a similar analysis, an analogous 

25 analysis to look at impacts on price levels for 

26 electricity markets. So these are benefits that are 

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1 proven to all customers due to reduced demand for 

2 energy and how does that filter through -- filter 

3 through the economy. 

4 MR. BROOKMAN: Thank you. Additional 

5 comments on NEMS-BT And it’s application? Yes, Cheryl? 

6 MS. ENGLISH: Cheryl English. I think as you 

7 guys are well aware, for power use during the nighttime 

8 many times when there’s a power reduction or a reduce 

9 in demand the utilities will then shift back to that 

10 end user with a different rate structure because they 

11 expect to have a certain energy use or power use or 

12 power consumption during the nighttime. 

13 So I think as you do this modeling, you just 

14 need to make sure that you capture the cost impact on 

15 the end user relative to the potential that a demand 

16 reduction in energy could cause a rate increase for 

17 that end user. 

18 MR. BROOKMAN: Thank you. 

19 MR. MYER: Continuing on to the Employment 

20 Impact Analysis. The Department of Energy will conduct 

21 an employment impact analysis. This is looking at the 

22 effect of a national employment from the position of 

23 efficiency standards at differing levels. This is 

24 looking at both the indirect as well as the direct 

25 impacts. The direct employment impacts are estimated 

26 in the manufacturers’ impact analysis. The indirect 

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1 employment impacts result from shifting consumer 

2 expenditures among goods and services and change of 

3 equipment in energy costs. 

4 This method is using a modeling system known 

5 as IMBUILD or IMSET. Impact -- IMSET is the impact of 

6 sector energy technologies and it does the indirect 

7 employment impacts. 

8 Item 41, DOE requests feedback on its 

9 approach to assessing employment impacts on the 

10 equipment covered under this rulemaking. 

11 MR. BROOKMAN: Any comments on that approach? 

12 (No response.) 

13 MR. BROOKMAN: Okay. Yes, Rebecca. 

14 MS. RAINER: Rebecca Rainer. I think NEMA 

15 recommends that this should be addressed during the 

16 individual manufacturers’ meetings.

17 MR. BROOKMAN: Okay. Thank you. 

18 MR. MYER: Continuing on to the Environmental 

19 Assessment. So the purpose of this is to look at what 

20 happens to the environment under impossible amended 

21 energy conservation standards for metal halide lamp 

22 fixtures. 

23 The method here, DOE would use -- would look 

24 at environmental impacts predicted from the NEMS-BT 

25 modeling analysis done in the utility impact analysis. 

26 Carbon dioxide will be the primary emission 

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1 reported. Existing legislation caps on sulfur dioxide, 

2 nitrous oxide and mercury will play a role here. But 

3 because of their existing situation, that will have 

4 little effect in the energy conservation standard. 

5 Item 42 here, DOE seeks input on its plans to 

6 use NEMS-BT to conduct the Environmental Impact 

7 Analysis on the equipment covered by this rulemaking. 

8 DOE is particularly interested in whether there are any 

9 other approaches to the environmental assessment that 

10 should be considered and the advantages and 

11 disadvantages of this approach. 

12 MR. BROOKMAN: Additional thoughts on 

13 environmental assessment or analysis? 

14 (No response.) 

15 MR. MYER: Continuing on regulation. This 

16 slide deviates from the printed handout. There was a 

17 hiccup and some of the text in there got a little 

18 skewed. So the Clean Air Mercury Act, CAMR, text is, 

19 as I say, there was a hiccup and you have the wrong 

20 text there. So the screen has the correct text. 

21 So, CAIR which is the Clean Air Interstate 

22 Act, looks at sulfur dioxide. It sets a cap. Recently 

23 it was vacated in 2008 in the court case of North 

24 Carolina versus EPA. There was a similar legislation 

25 under CAMR which is the Clean Air Mercury Act. It 

26 would have capped mercury effectively -- there’s a typo

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1 there too. Effectively September 2010. This was 

2 recently vacated as well in the court case of New 

3 Jersey versus EPA. EPA has decided to develop emission 

4 standards for power plant. The NEMS-BT model will 

5 assume that both nitrous oxide and Mercury emissions 

6 would be subject to these rules. 

7 I believe the slides will be up on the 

8 website and this will be corrected on the website. So 

9 I understand you are quickly writing down, but it will 

10 be available rather quickly. 

11 I’m going to give you one more second and 

12 then move on to the next slide which ties into this. 

13 MR. BROOKMAN: Take a quick scan through that 

14 slide. 

15 MR. MYER: Okay. DOE is going to use the 

16 most current Social Cost of Carbon value developed 

17 through interagency consultations. The Social Cost of 

18 Carbon is intended to be a monetary measure of the 

19 incremental damage resulting from additional greenhouse 

20 gas. It looks at the effects on agriculture, health, 

21 human, possible damage, rising sea levels. 

22 CO2 estimates, the global benefit can vary in 

23 price. In 2008 dollars it can be anywhere from $5 up 

24 to $56 per metric ton. The domestic benefits 

25 approximately $1 per metric ton. 

26 So that brings us to Items 43, 44, and 45. 

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1 Item 43 DOE invites comments on how to estimate the 

2 monetary value associated with emission reductions or 

3 on any widely accepted values that might be used in 

4 DOE’s analyses.

5 Item 44, DOE invites comments on how to 

6 estimate the benefits of reduced sulfur dioxide 

7 emissions. 

8 In Item 45 DOE invites comments on the 

9 estimated range, anywhere from $370 to $3,800 in 2001 

10 dollars per ton of nitrous oxide for use in DOE’s 

11 analysis. 

12 (Pause.) 

13 MR. BROOKMAN: No additional comments? 

14 (No response.) 

15 MR. BROOKMAN: Okay. 

16 MR. MYER: Moving on to an additional set of 

17 comments. Items 46 through 48. In Item 46 DOE invites 

18 comments on the estimated range, anywhere from .75 

19 cents to 33 -- I’m sorry, I missed my millions place 

20 there. Anywhere from .745 to $33 million per ton of 

21 mercury in 2008 dollars for DOE’s analysis.

22 Item 47 DOE invites comments on the estimated 

23 social costs of carbon for use in DOE’s analysis.

24 And in Item 48 DOE seeks to put on the other 

25 environmental factors to considering this rulemaking. 

26 MR. BROOKMAN: I guess for all of these 

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1 comment boxes, if anyone here thinks that the 

2 Department should have an entirely different approach 

3 or if these estimates of price are entirely out of 

4 range, now would be a good time to say something. 

5 Yes, Pam? 

6 MS. HORNER: Pam Horner. Specific to Item 

7 47. 

8 MR. BROOKMAN: Uh-huh. 

9 MS. HORNER: I had the person in our company 

10 who actually knows this stuff look all of this over and 

11 she felt that 43 through 48 were, you know, typical. 

12 But on 47 she wanted me to make a couple of comments so 

13 that as NEMA companies we could actually answer the 

14 question better. 

15 So regarding social costs of carbon, I’m glad 

16 she knows what that is. It was unclear as to how it 

17 was derived specifically, for example, if they should 

18 use something else, it’s hard to know. It says, 

19 “interagency reviews.” We don’t know which agencies. 

20 So, is there a report somewhere we could look at? We 

21 don’t even know which agency to look at to know how the

22 values were derived. 

23 MR. BROOKMAN: Let’s just pause for a second. 

24 Do you know the answer, Michael? 

25 MR. MYER: I don’t think they’re entirely 

26 completed yet between different agencies. 

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1 MS. HORNER: Are they new? 

2 MR. BROOKMAN: Ron Lewis? 

3 MR. LEWIS: There is an active discussion 

4 amongst several agencies. There is not a final report 

5 on it. It’s been a -- I’ll say an evolutionary 

6 discussion that has taken into consideration several 

7 things including there have been lawsuits based on the 

8 marketization of carbon. There have been things as far 

9 as the negotiations or discussions globally on global 

10 warming and different issues. There are all kinds of 

11 things that go far beyond just a DOE focus. So there 

12 are multiple agencies and I don’t want to be pointing 

13 you towards specific ones because there is not a final 

14 outcome report at this point. 

15 It is an active dialogue that’s underway. So 

16 we’ve been trying to be responsive to that as we get 

17 new input and feedback on the coordination of that 

18 activity. We are only one of the players and look 

19 forward to much more discussion as the months go on 

20 that there will be much more specificity. And I just 

21 foresee a lot more discussion on that area in the 

22 future. 

23 But it’s nowhere near close to finalization. 

24 It’s an active discussion. And I don’t attend those 

25 meetings it’s way above my grade. But we do get the 

26 direction as outcomes of some of those discussions of 

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1 what to put in here, of what the valuations, the things 

2 that have been agreed to that are government wide where 

3 there’s something that there’s been great discussion 

4 and consideration of multiple obligations and 

5 administrative -- administration goals. And so we’ll 

6 try to keep you in tuned with that and encourage that 

7 you will watch those discussions in these documents as 

8 they move forward. There will be, I think, much more 

9 dialogue or narrative in that section in the future. 

10 MR. BROOKMAN: Pam? 

11 MS. HORNER: Pam Horner. Thank you. I think 

12 this was more -- it wasn’t a criticism, it was, you 

13 know, we’re very fortunate to among the NEMA companies 

14 to have at least one, I know of, maybe there are more 

15 that has an expertise in this stuff. So, as it affects 

16 us, and you want to know, are these appropriate, we 

17 happen to have someone who can say, yes, no, or here’s 

18 a change you should make. You know, people are 

19 involved in this climate change initiatives and 

20 calculating carbon footprints and doing all that stuff. 

21 I wouldn’t know how to do it myself. 

22 MR. LEWIS: There is a person in the 

23 administration who is noted and part of the reason he 

24 was brought in is because of his reputation as being 

25 the expert in this area. And so he’s overseeing the 

26 conversations. So we’re asking for input. We’re 

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1 always interested in input that the actual expertise is 

2 not really coming from us, but we want to be sensitive 

3 to input that others might have. 

4 MS. HORNER: So we want to know who to give 

5 the input to, I guess. 

6 MR. LEWIS: You can give the input to us and 

7 we will make sure that the people that attend the -- 

8 MS. HORNER: We don’t know. Like where did 

9 the global benefits of the $5 the $10 -- where did it 

10 all come from? 

11 MR. BROOKMAN: Yes. 

12 MR. deLASKI: If I could get in here. I 

13 would just -- I believe in some other document -- and 

14 this is a framework document, and some of the other 

15 recent dockets which aren’t lighting dockets, there’s a

16 write up in some of the proposed rules that goes far 

17 more in depth than here. And I don't know whether you 

18 all can think of some other dockets you might point 

19 folks to here -- 

20 MR. BROOKMAN: Thank you, Andrew. 

21 MR. deLASKI: -- where they can have a more 

22 complete discussion. Because there has been more 

23 complete discussion elsewhere. 

24 MR. LEWIS: Yeah, I think there are a couple 

25 of things that are in their final phases, heating 

26 products, things that are on our web page. I’m trying 

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1 to think of the most current, I think, was heating 

2 products. And we can probably give you a website to 

3 look at that document. It’s something that is -- like 

4 the values, it’s not by accident, it’s not something 

5 that’s random. There’s a large -- much larger 

6 international activity and they’re reviewing all the 

7 literature and all the studies. In fact, that range of 

8 values came from a study of studies of all the studies 

9 that they could find. 

10 MS. HORNER: I can appreciate that very much. 

11 It’s just that when you ask us for input, we’d like to

12 give it. And if we don’t know enough to give it, we 

13 just want to know where it came from. 

14 MR. BROOKMAN: I just want to make sure, Pam, 

15 were you finished? 

16 MS. HORNER: Yes. 

17 MR. BROOKMAN: We’ll move then to -- 

18 MR. ERHARDT: It’s on the same topic. I 

19 guess my question is, is there a national or 

20 international body that is focusing on this that has 

21 public access or something? You’re talking about 

22 discussions between agencies, and is that a public 

23 process? Is that just within the government? How is 

24 this working? 

25 MR. BROOKMAN: Well, Eric? 

26 MR. STAS: Eric Stas, DOE. Trying to discuss 

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1 it, you know, generally, but obviously the UN has done 

2 a lot of work in this area, the UNEP program. And I 

3 know that we cite some studies in that when we’re 

4 discussing the Social Cost of Carbon. And as Andrew 

5 said in some of the NOPRs you’ll get a more full 

6 discussion. This is pared down, I think, because it’s 

7 just a framework document. But go into the Federal 

8 Register website and look at some of our more recent 

9 rules and get further explanation. 

10 But there’s, you know, generally, these rules 

11 go through OMB, there’s general interagency -- a chance 

12 for interagency comment on different rules of agencies 

13 across the government too. And so the carbon issue 

14 obviously affects the whole government, right, so you 

15 don’t want different agencies coming up with different 

16 values. This is really an area that’s the whole 

17 country. You know, you want the government to speak 

18 with one voice, so it makes sense to have this kind of 

19 coordination. 

20 So to the extent that you’re going to have 

21 your experts provide comments, it’s all the more 

22 important to try to be kind of data driven and give 

23 targeted comments so that -- because it could have an 

24 impact beyond DOE’s efficiency rulings.

25 MR. BROOKMAN: Okay. Thank you. 

26 Pekka. 

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1 MR. HAKKARHNEN: Pekka Hakkarhnen. Let me 

2 just preface this by saying that what I’m about to say,

3 I’m by no means an expert on this topic. But it 

4 relates to the issue of CO2 and global warming. 

5 I’ve heard that if you look at the earth’s 

6 emission spectrum from outer space the resonant CO2

7 line is already missing. So if that’s true, then 

8 relative to CO2 affecting global warming, if we add 

9 more CO2 in the atmosphere there won’t be any effect. 

10 So the Department certainly, I believe, has access to 

11 people who are expert in this matter. I would want 

12 that analysis to be included. 

13 MR. BROOKMAN: Okay. Thank you. 

14 I’m certain that the intergovernmental group 

15 and many other groups will be looking at this very 

16 vague subject. Thank you. 

17 Yes, Dale. 

18 MR. SIMPSON: Dale Simpson from outer space 

19 to something a little more mundane here. 

20 (Laughter.) 

21 MR. SIMPSON: There’s a subtle effect going 

22 on that may play into your analysis. And that has to 

23 do with the shifting metal halide market. You have 

24 quartz metal halide that has a certain amount of 

25 mercury in it. You have ceramic metal halide that has 

26 a whole lot less mercury. In fact it has less mercury 

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1 than most high pressure sodiums do. 

2 You have the potential impact of a change in 

3 the regulations moving away from metal halide to high 

4 pressure sodium. So you need to understand all the 

5 shifting patterns of the market particularly when you 

6 start looking at it in 2015 could drastically affect 

7 the amount of mercury that is taken and put into or 

8 taken out of the marketplace. And that’s just a 

9 general comment. 

10 MR. BROOKMAN: Thank you. That’s helpful. 

11 I’m for that.

12 Yes. 

13 MR. MYER: This is not the first time we’ve 

14 heard this comment about the shift from metal halide to 

15 HPS. But I would say that it can only work in outdoor 

16 applications. And the applications that are currently 

17 not already HPS could you possibly estimate the 

18 existing metal halide market that could shift easily to 

19 HPS in the event of an overly stringent standard? 

20 MR. BROOKMAN: Dale. 

21 MR. SIMPSON: Dale Simpson. Yes, I can 

22 respond to that to a certain degree. Specific data 

23 that we were able to analyze where there’s large 

24 volumes involved included parking garages. And these 

25 were in, for instance, the state of California who put 

26 the 175 pulse start ban or 175 watt probe start ban 

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1 into effect the 1st of January 2008. In 2008 and 2009, 

2 we saw that 175 watt probe start volume which had been 

3 the overwhelming part of the volume prior to the change 

4 split between 150 watt metal halide and 150 watt high 

5 pressure sodium. 

6 So basically for every hundred units that had 

7 been sold in the 175 watt metal halide, 50 units were 

8 sold in 150 metal halide and 50 units were sold in 150 

9 watt high pressure sodium. 

10 MR. MYER: That’s for parking -- 

11 MR. SIMPSON: That’s just the one case that I 

12 can look at and site specific to you. 

13 MR. MYER: That we would have a limited -- I 

14 would go so far to say that most roadway applications 

15 are HPS. Most area lighting, it’s roughly a 50/50 

16 split is -- 

17 MR. SIMPSON: Oh, no, it’s more like an 80/20 

18 split. 

19 MR. MYER: And the 80 is on which side? 

20 MR. SIMPSON: Metal halide. 

21 MR. MYER: Okay. That -- 

22 MR. SIMPSON: So there’s significant 

23 potential in parking garages, area lighting, façade 

24 lighting, flood lighting to switch from metal halide to 

25 high pressure sodium. 

26 And the one case that was dramatic where we 

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1 saw that and we have enough data to substantiate it is 

2 the case of parking garage luminaires in California. 

3 MR. BROOKMAN: So that’s so helpful, that 

4 kind of representation, for you to be able to provide 

5 specific market segment data and trend line data, boy, 

6 that would be very helpful to the Department. 

7 MR. SIMPSON: Sure. 

8 MR. BROOKMAN: Okay. Thank you. 

9 So other comments on this whole cluster of 

10 environmental impact analyses and also figures or 

11 loadings. 

12 (No response.) 

13 MR. BROOKMAN: Nothing additional on those? 

14 (No response.) 

15 MR. BROOKMAN: Okay. Moving on. 

16 MR. MYER: Moving on to the last analysis 

17 which is the regulatory impact analysis. DOE will 

18 explore the potential for non-regulatory alternatives 

19 to new manufacturing efficiency standards. DOE 

20 recognizes that voluntary and other non-regulatory 

21 efforts by manufacturers, utilities, and other 

22 interested parties could result in substantial energy 

23 improvements. 

24 DOE will base this assessment on the actual 

25 impact of such initiatives to date. We will also 

26 consider information presented regarding possible 

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1 initiatives that might be in the future. Notably we’ve

2 already talked about a couple and would love to hear 

3 more comments on specifically the pending outdoor 

4 legislation that we’ve talked about many times or the 

5 HID lamp determinations, another one that we’ve talked 

6 about many times already during this meeting. 

7 MR. BROOKMAN: Yes, Bob. 

8 MR. ERHARDT: Bob Erhardt. Just a comment 

9 that when you have your one-on-one conversations with 

10 manufacturers some companies -- well, many companies 

11 are already increasing the efficiency of their products 

12 without regulation. And when you talk to individual 

13 companies we can give you permission. 

14 MR. BROOKMAN: Okay. Thank you. That would 

15 be their voluntary contribution or something or their 

16 marketing efforts, whatever. Yes, thank you. 

17 Other Issues and Comments; Closing Remarks

18 So I think that is the last substantive slide 

19 for presentation. Then we’ll have a closing slide that

20 talks about how to submit comments and the like. But 

21 as reflected in the agenda, now is an opportunity for 

22 any person to raise additional issues, cover ground 

23 that needs to be recovered, raise anything additional 

24 that was pertinent to this phase in the framework 

25 consideration. 

26 So any additional issues? Pekka? 

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1 MR. HAKKARHNEN: Yes. Pekka Hakkarhnen. I 

2 think this goes back all the way back to item one 

3 perhaps. I made a comment about being cautious about 

4 applying the system approach to a larger group of 

5 products than what we have in the outdoor legislation 

6 proposal that’s before Congress right now. And Andrew 

7 deLaski stopped me in the hallway during the break and 

8 asked what I meant by that. So I thought I would just 

9 state here what I meant in more detail. 

10 I’m in particular concerned about the effect 

11 of control that is in the outdoor legislation proposal. 

12 As we’ve heard today, the electronic ballasts and 

13 metal halide lamp combinations have to be -- and 

14 removed on an individual basis. And when it comes to 

15 operation at a dim level, we don’t know how complicated

16 that is going to be yet. 

17 So that was -- my concern is before we go to 

18 the system approach, we should start somewhere in a 

19 limited application and see how that goes so we have 

20 that outdoor application now underway. It is likely 

21 that this is going to result in a very large number of 

22 product categories and standards between lamps and 

23 ballasts that need to be classified under the control 

24 condition. So that’s just my caution and explanation 

25 of what I was concerned about. Thank you. 

26 MR. BROOKMAN: Okay. Thank you, Pekka. 

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1 Okay. Brenda. 

2 MR. deLASKI: Thank you for that explanation, 

3 Pekka. I appreciate you clearing up our -- or filling 

4 out that comment from earlier. 

5 And I guess the comment I wanted to make is 

6 that there may be something in between what Pekka is 

7 raising and what the Department has flushed out in this 

8 initial framework document looking just at the 

9 ballasts. And I think Jennifer in her comments this 

10 morning indicated a desire to look a little more 

11 broadly. I think there may be a way to look more 

12 broadly, doesn’t entail moving all the way to a system 

13 approach. And I just want to make sure the Department 

14 -- I just want to draw your attention to the very last 

15 page, since we’re at the end here, of the packet today 

16 which is on page 63 of the packet. So it’s at the very

17 end of -- actually it’s at the end of the framework 

18 document. And this is from statute. 

19 In the middle of that page there’s a 

20 paragraph four called “Design and Performance 

21 Requirements” which reads: “Notwithstanding any other 

22 provision of law any standard that’s established 

23 pursuant to this subsection may contain both design and 

24 performance requirements” which is an unusual clause in

25 the statute. And it creates an opportunity for the 

26 Department to -- all of the Departments at this point 

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1 to say, we’re looking at performance requirements for 

2 ballasts, but it hasn’t availed itself of this clause 

3 in the law. So the authority here to look at something 

4 in between what Pekka has talked about and what the 

5 Department has sketched out in the framework document I 

6 think is real. And when they could, you know, 

7 potentially considerably more savings depending on what 

8 sort of options might be developed based on the inputs. 

9 So I just wanted to make sure that particular 

10 clause comes to your attention and I think it does 

11 create a lot more opportunity. 

12 MR. BROOKMAN: Thank you, Andrew. Thank you. 

13 Brenda? 

14 MS. EDWARDS: Yes. 

15 MR. BROOKMAN: Why don’t you distribute those 

16 Xerox copies? The Department has made a copy of the 

17 business cards of the attendees for everybody that 

18 would want one of those. 

19 So now is, again, an opportunity for anybody 

20 to make closing remarks, additional comments, raise 

21 additional issues for consideration for the record. 

22 Ron Lewis? 

23 MR. LEWIS: I’ve got a couple people working 

24 frantically to get the link to the heating products, 

25 NOPR, because I promised to give you insight into some 

26 of that more expansive language. I also want to 

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1 announce the request this morning to extend the comment 

2 period. We are going to extend that comment period by 

3 a week to a week from Friday, February 5th, for you to 

4 get your comments together. 

5 So we are hesitant to extend comment periods. 

6 We have so many deadlines and it’s so difficult to 

7 coordinate and synchronize all these things. So it was 

8 with some reluctance, but we did hear -- we did hear 

9 and we’re responsive. So you’ve got an extra week on 

10 that. 

11 MR. BROOKMAN: Thank you. I don’t want to 

12 short shrift anybody. Additional comments as we move 

13 toward the end of this public meeting today? 

14 I think right now we are pulling up the URL 

15 that Ron was referring to. Are you going to do the 

16 last page? 

17 If you will look at the final page in your 

18 slides, this would be slide 112. Linda Graves is going 

19 to discuss this. 

20 MS. GRAVES: Yeah, if you would all just 

21 notice that there’s actually -- there’s four different 

22 ways you can submit written comments. And all the 

23 addresses are there on that last page of your 

24 presentation. But if you would also refer to the very 

25 first page, the notice that we published in the Federal 

26 Register, it was the four different ways to do it 

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1 including the through the portal through the DOE e2 mail, through snail mail or even what to do if you want 

3 to do it by courier. 

4 Brenda is the contact person, if you go 

5 through courier. Also, elsewhere if anybody wants to 

6 review the docket, see the comments that have been 

7 coming in, Brenda Edwards here is also the contact 

8 person for that. We have a resource room. Make an 

9 appointment with her and she can let you in to review 

10 the comments. 

11 We also have -- here’s the list I think you 

12 all found our website for this rule. But we’re also 

13 typing in the links. Okay. So you go to appliance 

14 standards, I guess for the transcript if you could 

15 type, add these please into the transcript. We’ll give

16 it to you. It’s a page.

17 Access denied. Whoops. That happens a lot. 

18 (Pause.) 

19 MS. GRAVES: So you scan down through the 

20 list of products, click on heating products. 

21 (Pause.) 

22 MS. GRAVES: You probably can’t read that 

23 from there, can you? The heading at the top? 

24 MR. LEWIS: (Off microphone.) Anybody who 

25 wants to record that before you leave, it’s right up 

26 here on the screen. We’ll leave it on the screen. 

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1 It’s an excellent link to the document. Up here in the 

2 URL for the web page at the top where it says, address, 

3 then this link right here, PDF, right here, that would 

4 be a copy of the NOPR -- on the environmental factors 

5 and questions that you were asking, it’s much more 

6 expansive. 

7 MS. GRAVES: Okay. I guess I can read it 

8 off. So it’s 

9 www1.eere.energy.gov/buildings/appliance_standards/resi

10 dential/water_pool_heaters_nopr.html. 

11 MR. LEWIS: Now that you’ve all been slashed 

12 thoroughly, I just got an idea. We are just handing 

13 out a copy of the business cards for everybody. As 

14 long as your e-mail address is on there, we’ll e-mail 

15 that to you; how’s that? Okay. Sorry we didn't think 

16 of that sooner. We were trying desperately to be 

17 responsive. 

18 MS. GRAVES: And I just want to really thank 

19 everyone for your participation. I appreciate the tone 

20 and the spirit in which comments were offered. I also 

21 think that there was some very useful discussion, 

22 useful clarification. My team is grateful for your 

23 input. We will be even more grateful for fast response 

24 when submitting data to us. And we look forward to 

25 getting any additional comments you might want to 

26 submit to us in writing. And with that, thank you very 

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1 much, everyone. 

2 MR. BROOKMAN: Please fill out the evaluation 

3 form. The Department is always looking for your 

4 thoughts and comments on ways to improve these 

5 meetings. And it’s at the final page in your packet. 

6 Each person’s got it.

7 So safe travels to all of you. Best wishes. 

8 Thanks for a very productive day. 

9 (Whereupon, at 2:21 p.m., the meeting was 

10 adjourned.) 

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REPORTER'S CERTIFICATE

 This is to certify that the attached proceedings 

before:

U.S. DEPARTMENT OF ENERGY 

In the Matter of:

PUBLIC MEETING ON ENERGY CONSERVATION STANDARDS FOR 

METAL HALIDE LAMP FIXTURES 

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.

Wendy Greene

 Official Reporter 

Dated: December 27, 2009 

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