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U.S. DEPARTMENT OF ENERGY

ENERGY EFFICIENCY & RENEWABLE ENERGY

BUILDING TECHNOLOGIES PROGRAM

+ + + + +

PUBLIC MEETING ON

ENERGY CONSERVATION STANDARDS

+ + + + +

INTERIM ANALYSIS FOR 

HIGH-INTENSITY DISCHARGE LAMPS

+ + + + +

TUESDAY

APRIL 2, 2013

+ + + + +

The public meeting was held in 

Conference Room 8E-089 in the U.S. Department 

of Energy, 1000 Independence Avenue S.W., 

Washington, D.C., at 9:00 a.m., Doug Brookman, 

Facilitator, presiding.

PRESENT:

DOUG BROOKMAN, Public Solutions, Inc.,

Meeting Facilitator

SUSAN CALLAHAN, OSRAM SYLVANIA/NEMA

GINA LOWERS, EYE Lighting International

JOANNA MAUER, Appliance Standards Awareness

Project

STEVE ROSENSTOCK, Edison Electric Institute

LOUIS STARR, Northwest Energy Efficiency

Alliance

JACK STROK, GE Lighting

VICTOR VARGA, GE Lighting

DANIEL YOUNG, Energy Solutions/California

Investor Owned Utilities
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ALSO PRESENT:

MICHEL ANDRE CHABANEIX, Navigant Consulting,

Inc.

MATT CHESTER, Navigant Consulting, Inc.

NATASHA COLLINS, Pacific Northwest National

Laboratory

HAYDEN COOK, Navigant Consulting, Inc.

LUCY deBUTTS, DOE

ALI McDONALD, Navigant Consulting, Inc.

MICHAEL MYER, Pacific Northwest National

Laboratory

JULIE PIERCE, Navigant Consulting, Inc.

JENNIFER TIEDEMAN, DOE, Office of the General

Counsel

MATTHEW WALKER, Navigant Consulting, Inc.
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A G E N D A

WELCOME; INTRODUCTIONS, AGENDA REVIEW;

AND OPENING STATEMENTS ...................... 4

OVERVIEW, STATUTE, AND CONTEXT; SCOPE;

MARKET ASSESSMENT; TECHNOLOGY 

ASSESSMENT; SCREENING ANALYSIS ............. 10

ENGINEERING ANALYSIS; EQUIPMENT PRICE

DETERMINATION .............................. 54

BREAK ..................................... 78

ENERGY USE ANALYSIS; MARKUP ANALYSIS ....... 79

LIFE-CYCLE COST AND PAYBACK PERIOD

ANALYSIS; SHIPMENTS ANALYSIS; AND

NATIONAL IMPACT ANALYSIS ................... 84

INTERIM MANUFACTURER IMPACT ANALYSIS ...... 132

NOPR ANALYSES ............................. 139

CLOSING REMARKS ........................... 142
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1 P-R-O-C-E-E-D-I-N-G-S

2 (9:03 a.m.)

3 MR. BROOKMAN: Good morning, 

4 everyone. Welcome. This is the U.S. Department 

5 of Energy's public meeting on Energy 

6 Conservation Standards: Interim Analysis for 

7 High-Intensity Discharge Lamps. Today is 

Tuesday, April 2nd 8 , 2013 here in the Forrestal 

9 Building in Washington, D.C.

10 My name is Doug Brookman from Public 

11 Solutions in Baltimore, glad to have you here. 

12 Welcome, glad you could make it. 

13 We're going to start with welcoming 

14 remarks from Lucy deButts.

15 MS. deBUTTS: Good morning, everyone. 

16 Good to see you here. We are presenting just as 

17 Doug mentioned the Interim Analysis for HID 

18 Lamps. A framework was presented a while ago. I 

19 think it was almost a year ago that I saw the 

20 faces, and we'd like to -- we've done a lot of 

21 analyses over this year and want to present the 

22 results that we have and secure remarks on 
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1 that. 

2 And now Doug can go through the 

3 agenda.

4 MR. BROOKMAN: Thank you. Let's start 

5 with introductions. You can get used to turning 

6 these microphones on and off. The little green 

7 diode needs to be illuminated. Please say your 

8 -- get it closer to your face. Say your name 

9 and organizational affiliation.

10 MR. YOUNG: Daniel Young representing 

11 the California Investor-Owned Utilities.

12 MR. BROOKMAN: Thank you.

13 MS. MAUER: Joanna Mauer, Appliance 

14 Standards Awareness Project.

15 MS. LOWERS: Gina Lowers representing 

16 Eye Lighting International.

17 MS. CALLAHAN: Susan Callahan 

18 representing OSRAM SYLVANIA and NEMA.

19 MR. STROK: Jack Strok representing 

20 General Electric Company.

21 MR. VARGA: This is Victor Varga. I'm 

22 also representing General Electric.
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1 MR. ROSENSTOCK: Steve Rosenstock, 

2 Edison Electric Institute.

3 MS. TIEDEMAN: Jennifer Tiedeman, DOE 

4 General Counsel.

5 MR. COOK: This is Hayden Cook with 

6 Navigant Consulting.

7 MR. CHESTER: Matt Chester also with 

8 Navigant Consulting.

9 MR. WALKER: Matthew Walker with 

10 Navigant.

11 MS. COLLINS: Natasha Collins, 

12 Pacific Northwest National Laboratory.

13 MR. MYER: Michael Myer, Pacific 

14 Northwest National Laboratory.

15 MR. BROOKMAN: Again, thank you all 

16 of you for joining us and welcome to those that 

17 are joining us via the web. 

18 All of you received a packet of 

19 information when you checked in this morning. 

20 I'm going to do a very brief agenda review. 

21 Immediately following this agenda review, 

22 there's an opportunity for anybody that wishes 
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1 to make an opening remark or two, brief 

2 statements, summary statements about issues 

3 that matter to you. Following that, we're going 

4 to have an overview and statute, and context, 

5 scope, and market assessment, technology 

6 assessment, and then screening analysis, the 

7 format being presentation followed by the 

8 opportunity for question and comment.

9 We'll take a break midmorning around 

10 about 10:30 or so. Following the midmorning 

11 break, engineering analysis, equipment price 

12 determination, and then following on energy use 

13 analysis, markup analysis, lunch midday around 

14 about 11:45 or noonish, and then immediately 

15 following lunch life-cycle cost and payback 

16 period analysis, shipments analysis, national 

17 impacts analyses, interim manufacturer impact 

18 analysis, and then NOPR analyses looking 

19 forward. And then as -- when we get to it, 

20 whether it's at 2:00 or earlier, closing 

21 remarks and then another opportunity for 

22 anybody that wants to make additional comments, 
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1 make sure their issues get covered sufficiently 

2 and on the record.

3 Okay, so that's the plan for today. 

4 Questions, comments on the agenda?

5 I'd ask for your consideration, 

6 please speak one at a time, if you would, and 

7 please say your name for the record each time 

8 you speak. You don't need to say your

9 organizational affiliation name, it's up to 

10 you, but each time you speak, please do say 

11 your name. If you keep the focus here, turn 

12 your cell phones on silent mode, limit sidebar 

13 conversations. There'll be a complete 

14 transcript of this meeting available for you 

15 and we'll describe how you can access it. If 

16 you could be concise, share the air time, 

17 there's certainly a lot to be said. We don't 

18 want to waste anyone's time.

19 I'll be queuing individuals by name 

20 as best I can as we go along here today. Also, 

21 wish to encourage follow-on comments; that is, 

22 back and forth between individuals in the room, 
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1 sometimes that's very helpful for the 

2 Department to sort through what they want to 

3 find out.

4 And for those joining us via the 

5 webinar, glad you could join us. The Department 

6 of Energy is trying hard to make these meetings 

7 accessible, and that's one way to do it. So, we 

8 hope you find this convenient and useful.

9 If you'd keep your telephones on 

10 mute while you're listening in, you can raise 

11 your hand via the software that you're in if 

12 you wish to participate in the conversation 

13 here, either raise a question or offer a 

14 comment. We've been able to work that most of 

15 the time. We'll see if we can work it today.

16 So, that I believe is the opening 

17 stuff that I have to do. Then back to Lucy 

18 deButts.

19 MS. deBUTTS: All right. So, Doug 

20 went through webinar access. Don't really have 

21 anything to add to that. 

22 So, the purpose of today's public 
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1 meeting is to present the HID Standards --

2 present the standards DOE is considering for 

3 HID Lamps. We also have -- want your input on 

4 the analysis that we are going to be 

5 presenting.

6 We're going to show you the next 

7 steps that the Department is planning on 

8 taking, and then, of course, invite your 

9 comments and any data you have to help us to 

10 better our analyses. That would be great.

11 Throughout the presentation you will 

12 see the comment boxes. They are not going to be 

13 in order. We're just going to present the 

14 issues that are most relevant. 

15 The entire document is available 

16 online. The presentation is available online. 

17 If you -- but we're welcoming your input and, 

18 of course, I just wanted to highlight the fact 

19 that we extended the public -- the submission 

20 of the comment period. The document was signed 

21 yesterday, so it's going to be published in the 

22 Federal Register shortly but, you know, it's 
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been signed, so May 17th 1 is the new date for 

2 submitting public comments. So, the request 

3 came in and we accommodated the request. 

4 Hopefully, it's going to be useful for 

5 everyone.

6 And on the next slide you can see 

7 how you can submit the public comments. We ask 

8 you that you mention the rulemaking by title, 

9 also include docket number and RIN number in 

10 there. You can email your comments to us. If 

11 you don't have internet access, you can send it 

12 by Post Office or courier to Department of 

Energy. And, once again, May 17th 13 is the new 

14 deadline.

15 And that's basically it for me. Back 

16 to Doug.

17 MR. BROOKMAN: So, as we said at the 

18 outset, now is an opportunity for anybody that 

19 wants to make opening remarks, zeroing in on 

20 issues that matter to you here at the outset. 

21 Steve Rosenstock. 

22 MR. ROSENSTOCK: Steve Rosenstock, 
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1 Edison Electric Institute. Sorry I won't be 

2 able to stay for the whole day, just massive 

3 numbers of meetings and other projects going 

4 on, so I'm leaving early. It's nothing 

5 personal. I'm sorry, I just wanted to throw a 

6 couple of issues out. 

7 Edison Electric Institute represents 

8 investor-owned utilities throughout the United 

9 States, some of which you have outdoor lighting 

10 programs. And we are using advanced 

11 technologies for these outdoor lighting 

12 fixtures that we own, operate, and maintain for 

13 localities.

14 One thing I noticed throughout the 

15 technical support document and the presentation 

16 is the thought or the -- I'll say the 

17 assumption that mercury vapor as a valid 

18 baseline for many wattage categories.

19 I think that as we go through this, 

20 mercury vapor tech lamps, especially, in my 

21 view, in our view, should not be used as 

22 baseline technology for the following reason. 
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1 Federal law, EPAct 2005 banned the manufacture 

2 and import of mercury vapor ballast since 

January 1st 3 , 2007, except for the specialty 

4 applications that you've listed in this 

5 document. Therefore, at least from utilities' 

6 perspective, none of them are spec-ing out 

7 mercury vapor fixtures for their streetlights. 

8 When an old mercury vapor fixture burns out, 

9 they use a new technology, whether it's metal 

10 halide, or high-pressure sodium, or LED.

11 So, I've looked through the document 

12 and it seems like mercury vapor is seen as a 

13 "baseline" in various wattage categories, and 

14 from a market, and from an economic point of 

15 view that really doesn't make sense because of 

16 other federal laws.

17 I think by using mercury vapor as a 

18 baseline it will distort the economic analysis, 

19 it will distort the results because it's 

20 clearly -- except for the specialty 

21 applications, it is not an option for any end22 user. The only thing you use mercury vapor 
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1 lamps for is for replacements of old fixtures. 

2 Once the old ballasts die, the end-user, 

3 regardless of the application will have to 

4 replace it with a new type of high efficacy 

5 fixture. So, that one of my main concerns I 

6 wanted to put on the table. I know it will be 

7 discussed later today, but I just want to put 

8 that on the table because, unfortunately, I 

9 have to leave early. Thank you very much for 

10 your time.

11 MR. BROOKMAN: Thank you, Steve. 

12 Other comments here at the outset? No 

13 additional comments. Okay.

14 All of you received the packet of 

15 information. As I said, these PowerPoint slides 

16 provide the basis for both presentation and to 

17 queue specific comments, so let's proceed with 

18 the slides. 

19 MS. deBUTTS: All right. So, Navigant 

20 Consulting and PNNL are going to be helping us 

21 with the presentation. Currently, Matt Chester 

22 will be presenting on the scope and the 
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1 overview of this rulemaking.

2 MR. CHESTER: Good morning. Once 

3 again, my name is Matt Chester, and I'm with 

4 Navigant. 

5 As regulatory background, the Energy 

6 Policy Conservation Act of 1975 or EPCA 

7 established the Energy Conservation Standards 

8 Program. The Energy Policy Act of 1992, or 

9 EPAct 1992, amended EPCA and added HID Lamps as 

10 covered equipment, and required DOE to 

11 determine if standards for HID Lamps would be 

12 beneficial.

13 A positive final determination that 

14 standards for HID Lamps would likely result in 

15 significant energy savings began the rulemaking 

16 process.

17 A rulemaking has four main stages. 

18 DOE began the process for HID Lamps in February 

19 2012 with the publication of the framework 

document. Then on February 28th 20 , 2013, DOE 

21 published a Federal Register Notice announcing 

22 this Interim Analysis meeting wherein DOE 
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1 presents its initial analytical results. Later 

2 this year, DOE plans to publish a notice 

3 proposing a standard and hold another meeting 

4 to receive feedback on that proposal. The 

5 projected final rule arrives in July 2014 with 

6 a projected compliance date of July 2017. 

7 Between now and completion of the final 

8 rule in 2014, DOE will consider these seven 

9 factors in its analysis. Economic impacts on 

10 individual consumers are considered in the 

11 Life-Cycle Cost Analysis. Economic and energy 

12 savings impacts to the nation as a whole are 

13 considered in the National Impact Analysis, and 

14 economic impacts on manufacturers are 

15 considered in the Manufacturer Impact Analysis. 

16 DOE also considers impacts on utility or 

17 performance and any other factors the Secretary 

18 considers relevant. 

19 I'm going to start with looking at 

20 the scope which describes the HID Lamps for 

21 which DOE will consider standards. When 

22 referring to high-intensity discharge lamps, we 
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1 are talking about the family of lamps that 

2 include mercury vapor, high-pressure sodium, 

3 and metal halide. Within these lamp types, DOE 

4 assessed which lamps had potential for 

5 significant energy savings and for which 

6 standards were both technologically feasible 

7 and economically justified.

8 Since not every subset of HID Lamps 

9 will meet these criteria, DOE is considering 

10 only certain ranges of commercially available 

11 wattages and correlated color temperatures, or 

12 CCTs. The wattages and CCTs for which DOE is 

13 not considering standards are chosen because 

14 they represent a small market share and, thus, 

15 do not represent significant potential energy 

16 savings.

17 This table shows the summary of the 

18 wattage and CCT ranges for which DOE is 

19 considering energy conservation standards. In 

20 addition, DOE has identified subsets of HID 

21 Lamps that while they fall into these wattages 

22 and CCTs, DOE has specifically chosen not to 
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1 consider standards for them.

2 Most of these lamps for which DOE is 

3 not considering standards are the same types of 

4 lamps mentioned in the framework document. DOE 

5 is not considering standards for directional 

6 HID Lamps, self-ballasted HID Lamps, HID Lamps 

7 advertised as an intended for use exclusively 

8 with electronic ballasts, pulse-start metal 

9 halide lamps with a CRI greater than or equal 

10 to 95, colored metal halide lamps which we're 

11 defining as those with a CRI of less than 40, 

12 specialty application mercury vapor lamps, and 

13 electrodeless HID lamps. 

14 DOE now invites comment on the 

15 following topics. For metal halide lamps, DOE 

16 found that lamps with a CRI greater than or 

17 equal to 95 could not reach the same levels of 

18 efficacy as lower CRI lamps. DOE did not 

19 consider lamps for -- standards for pulse-start 

20 metal halide lamps with a CRI greater than or 

21 equal to 95, and DOE requests comment on this 

22 determination. 
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1 MR. BROOKMAN: Yes, please. Susan. 

2 MS. CALLAHAN: Susan Callahan. NEMA 

3 supports high CRI product exemption --

4 MR. BROOKMAN: Susan, would you move 

5 that just a little closer? Thank you.

6 MS. CALLAHAN: NEMA supports high CRI 

7 product exemptions to harmonize and parallel 

8 with the GSFL rulemaking. NEMA supports not 

9 having efficiency standards for metal halide 

10 lamps with CRI greater or equal to 87 rather 

11 than 95. 

12 MR. BROOKMAN: Okay, thank you. Steve 

13 Rosenstock.

14 MR. ROSENSTOCK: Steve Rosenstock, 

15 EEI. I think that -- well, first a question, 

16 then a comment.

17 What kind of efficacy levels were 

18 you finding with those lamps, just out of 

19 technical curiosity?

20 MR. CHESTER: I don't remember the 

21 number difference off the top of my head, but I 

22 do know it was significant enough that any 
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1 potential efficacy level we set, the high CRI 

2 lamps would have fallen underneath it.

3 MR. ROSENSTOCK: Right.

4 MR. CHESTER: So, we were just hoping 

5 to preserve the utility of those high CRI 

6 lamps.

7 MR. ROSENSTOCK: Steve Rosenstock, 

8 EEI. Thank you for that remark, and I think 

9 that that does raise an issue, especially 

10 because of product competition. And I 

11 appreciate the comment from NEMA, is that when 

12 you look at the marketplace and you look at the 

13 features, think about it from a customer 

14 perspective, especially from a retail point of 

15 view, a high CRI is seen as a very, very 

16 desirable feature, especially in retail, 

17 specialty retail, and general retail 

18 applications.

19 And I think that as these products 

20 get on the marketplace, I think that, 

21 obviously, because of what -- the competitive 

22 issues, it is going to be an issue. But the 
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1 other thing, also, to consider, also, is even 

2 at their -- I'll say their reduced efficacy 

3 levels compared to other high-pressure --

4 HID Lamps, excuse me, it's still going to be a 

5 higher efficacy than other technologies that 

6 they're competing with, such as incandescent, 

7 such as halogen, such as possibly compact 

8 fluorescent depending on where that lumen per 

9 watt number comes down. So, again, I agree with 

10 this, and I think it's a good thing to do 

11 because of the fact that it is a feature that 

12 should not be eliminated from the marketplace. 

13 Thank you.

14 MR. BROOKMAN: Okay, thank you. 

15 Additional comments on issue number one?

16 MR. WALKER: This is Matthew Walker 

17 from Navigant. Sorry about the scratchy 

18 microphone. 

19 I would just ask -- curious if, 

20 Susan, you're able to provide any more like 

21 reasoning for the 87 CRI limit that would be 

22 useful for going forward with DOE's rulemaking.
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1 MS. CALLAHAN: That will be addressed 

2 in our written comments.

3 MR. BROOKMAN: But just to clarify, 

4 Susan, you're speaking on behalf of NEMA here. 

5 This is an issue that NEMA as a body has taken 

6 up.

7 MS. CALLAHAN: Yes, it is.

8 MR. BROOKMAN: Thank you. Okay. Just 

9 to clarify. Daniel.

10 MR. YOUNG: Daniel Young, California 

11 Utilities. Did DOE consider maybe using CRI as 

12 a product class delineator to set reduced 

13 standards for these lamps?

14 MR. CHESTER: We did look at that as 

15 a possibility but found that -- I mean, this 

16 instance of pulse-start metal halide lamps with 

17 a CRI greater than 95 was sort of the only 

18 instance we saw that the CRI affected the 

19 efficacy, so we found it more appropriate at 

20 this point just to not consider standards for 

21 those lamps. 

22 MR. BROOKMAN: Okay?
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1 MR. YOUNG: Thanks.

2 MR. BROOKMAN: Okay, we're moving on.

3 MR. CHESTER: Okay. Next, DOE 

4 considered adopting the EU definition of white 

5 light, but instead determined that a colored 

6 metal halide lamp could be effectively defined 

7 by its CRI. DOE requests comment on this 

8 conclusion and whether using the EU definition 

9 would be beneficial. 

10 MR. BROOKMAN: Susan.

11 MS. CALLAHAN: Harmonization with 

12 international standards is always preferable, 

13 and NEMA recommends the adoption of the EU 

14 definition of white light in this case.

15 MR. BROOKMAN: And can you say is it 

16 just harmonization alone, or are there other 

17 issues?

18 MS. CALLAHAN: It's mostly 

19 harmonization. 

20 MR. BROOKMAN: Okay, thank you. 

21 Additional comments here?

22 MR. CHESTER: Okay. Lastly, DOE is 
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1 aware of specialty applications that can only 

2 be served with mercury vapor lamps and not any 

3 other HID or solid-state technologies because 

4 of the UV light output of mercury vapor lamps. 

5 DOE requests comment on excluding individually 

6 labeled specialty application mercury vapor 

7 lamps from consideration for standards.

8 MR. BROOKMAN: Steve Rosenstock.

9 MR. ROSENSTOCK: Steve Rosenstock, 

10 EEI. To follow-up on my earlier comments, these 

11 are the only types of mercury vapor fixtures 

12 that can include new ballasts because of 

13 federal law. That was EISA 2007. 

14 With many of these applications I 

15 think you have it right that these are 

16 specialty applications. In many cases, they're 

17 going to be limited times of use except for the 

18 ultraviolet curing, possibly, with water 

19 treatment type of plants. Many of these will 

20 have instead of 1,000 hours per year, might be 

21 hundreds of hours, or tens of hours per year, 

22 so any efficacy standard will have a very, very 
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1 long payback. And I think this makes a lot of 

2 sense.

3 MR. BROOKMAN: Thank you. It's nice 

4 to receive affirmative comments, as well. 

5 Susan.

6 MS. CALLAHAN: Thank you. NEMA agrees 

7 with DOE on excluding specialty and mercury 

8 vapor lamps from the scope of this rulemaking. 

9 However --

10 MR. BROOKMAN: Is she on? Susan, is 

11 your microphone on?

12 MS. CALLAHAN: Yes, it is now. 

13 MR. BROOKMAN: Okay, thank you. 

14 Please.

15 MS. CALLAHAN: Okay. NEMA agrees with 

16 DOE on excluding specialty mercury vapor lamps 

17 from the scope of this rulemaking. However, we 

18 disagree with DOE's assertion that the 

19 specialty lamps are currently labeled for the 

20 intended application. Manufacturers have 

21 limited to no knowledge of who the end-user is, 

22 or the intended application so that the label 
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1 cannot be a determining factor here. 

2 MR. CHESTER: Could you then comment 

3 on maybe how you would define the specialty 

4 application, because this is sort of where 

5 we're going with it, is if it was labeled as 

6 the specialty application and had what that 

7 application was, and that was how we would 

8 potentially define those lamps.

9 MS. CALLAHAN: Well, I guess our 

10 point would be that for a given number of end11 users that a particular lamp could be used for 

12 a UV curing application. It could be used for 

13 photo resist, it could be used for any 

14 appropriate type of technology. And when we 

15 sell the lamps, we don't necessarily know what 

16 the end use is going to be. With some of the 

17 other types of lamps, you know, the display 

18 optic, the stage studio, those types of lamps, 

19 it may be a little more obvious, but for some 

20 of the other mercury vapor lamps we don't know.

21 MR. BROOKMAN: So, even if you had a 

22 specialty application label you wouldn't know 
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1 where it might end up, and what the use would 

2 be.

3 MS. CALLAHAN: Correct.

4 MR. BROOKMAN: I see. So, in that 

5 respect the specialty application label would 

6 not be sufficient.

7 MS. CALLAHAN: Correct.

8 MR. BROOKMAN: Okay. Additional 

9 comments on this point? John Lee who's joining 

10 us via the web. John, speak clearly and loudly, 

11 and hopefully we can hear you in the room.

12 MR. LEE: Hi, I was just requesting 

13 that Susan speak up a little bit because she's 

14 really inaudible on the webinar. MR. 

15 BROOKMAN: Susan, hit your button again and try 

16 -- say something to us.

17 MS. CALLAHAN: Good morning.

18 MR. BROOKMAN: Can you hear her now 

19 because she's -- we can hear her in the room.

20 MR. LEE: Yes, her volume is much, 

21 much, much lower than everyone else who's 

22 speaking.
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1 MR. BROOKMAN: Okay. So, we'll work 

2 on that, John. Thanks for cueing us to that 

3 since she's speaking on behalf of NEMA. Okay, 

4 great. We'll work on it. Thanks. Okay, now 

5 we're going to proceed.

6 MR. CHESTER: DOE also invites 

7 comment on these topics. DOE determined that 

8 electrodeless HID Lamps meet the EPCA 

9 definition of an HID Lamp. However, based on 

10 their small market share and lack of test 

11 method, DOE is not considering standards for 

12 electrodeless HID Lamps.

13 DOE requests comment on this 

14 determination and whether additional 

15 information is necessary to define this 

16 exclusion.

17 MR. BROOKMAN: I'm just catching up

18 here. Susan, get that nice and close to your 

19 mouth. Yes, thank you.

20 MS. CALLAHAN: See if this works 

21 better.

22 MR. BROOKMAN: Yes.
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1 MS. CALLAHAN: NEMA agrees with DOE 

2 on excluding electrodeless HID Lamps from the 

3 scope of this rulemaking, that they truly are a 

4 niche product. 

5 MR. BROOKMAN: Thank you. No 

6 additional comments.

7 MR. CHESTER: Okay. And then overall, 

8 DOE welcomes comment on any other aspect of the 

9 scope.

10 MR. BROOKMAN: Susan.

11 MS. CALLAHAN: NEMA agrees with DOE 

12 on excluding directional HID Lamps, self13 ballasted HID Lamps, HID Lamps for use with 

14 electronic ballast only, pulse-start metal 

15 halide lamps with CRI greater than 87, colored 

16 metal halide lamps, and HID Lamps intended for 

17 specialty applications, and electrodeless HID 

18 Lamps from the scope of this rulemaking. 

19 However, HPS Lamps with CCT greater than or 

20 equal to 1900 Kelvin, and less than or equal to 

21 2700 Kelvin should be excluded from the 

22 rulemaking. These lamps only operate during 
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1 off-peak load times. There are currently no 

2 lamp technologies with higher efficacies in 

3 production, and the technology option proposed 

4 by DOE, namely the sapphire arc tubes, does not 

5 meet DOE's screening criteria. 

6 We've already talked about the 

7 labeling comments. We would suggest that at a 

8 minimum the lamps produced for use in specialty 

9 applications would be the following products, 

10 and be exempt due to their specialty nature; UV 

11 curing, photoprinting, pet, aquarium, 

12 aquiculture, solar panel processing, materials 

13 testing, horticultural, high-definition 

14 television, sports, film, institutional and 

15 educational, R&D, and stage and theater lamps, 

16 which is not quite an exhaustive list, but 

17 close.

18 MR. BROOKMAN: And in your written 

19 comments.

20 MS. CALLAHAN: We will be more 

21 exhaustive, yes.

22 MR. BROOKMAN: Yes, good. Thank you. 
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1 Joanna.

2 MS. MAUER: Joanna Mauer. Just a 

3 question related to the possible exemption for 

4 the specialty mercury vapor lamps. I guess I'm 

5 not familiar with how the current exemption is 

6 working for the specialty mercury vapor 

7 ballasts. Are those -- are mercury vapor -- are 

8 those exempted ballasts labeled for a specific 

9 application?

10 MS. CALLAHAN: I know that they are 

11 labeled, but I could not -- I can't speak to 

12 exactly how they're labeled.

13 MR. BROOKMAN: I see that Michael 

14 Myer is ready. 

15 MR. MYER: Michael Myer, Pacific 

16 Northwest National Laboratory. I believe the 

17 word is they're labeled specialty application 

18 period, not what the defined application is. 

19 It's just a blanket term because, as Susan 

20 said, they could be used for -- the same lamp 

21 could be used for two different specialty 

22 applications, so it's not predefined what it 
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1 is. It just says "specialty application," and 

2 that's how it's exempted. 

3 MR. BROOKMAN: Additional comments 

4 here?

5 MR. CHESTER: Next, we're going to 

6 move on to looking at the market and technology 

7 assessment and the screening analysis. Here is 

8 an expansion of the interim analysis stage, our 

9 current stage, and the analyses that comprise 

10 it. We'll start with the market and technology 

11 assessment.

12 The market and technology assessment 

13 serves two main functions, to determine 

14 equipment classes and to identify technology 

15 options that improve efficacy. The screening 

16 analysis takes the technology options 

17 identified in the technology assessment and 

18 screens out options that DOE will not consider 

19 in the engineering analysis. Those that do not 

20 get screened out proceed to get analyzed as 

21 design options in the engineering analysis.

22 Equipment classes are the first 
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1 output of the market and technology assessment. 

2 An equipment class establishes a category of 

3 lamps that will be subject to the same 

4 standard. In considering how to group equipment 

5 classes, DOE considers the type of energy used, 

6 the capacity of the product, and other 

7 performance-related features that affect 

8 consumer utility.

9 In the framework document, DOE 

10 outlined equipment classes on the basis of CCT 

11 and initial light output. Based on stakeholder 

12 feedback and further analysis, DOE has instead 

13 decided to separate equipment classes in the 

14 interim analysis on the basis of CCT, wattage, 

15 bulb finish, and luminaire characteristic. 

16 The first equipment class-setting 

17 factor we'll discuss is correlated color 

18 temperature or CCT. Customers purchase specific 

19 color temperature lamps for their desired 

20 application. For example, high-pressure sodium 

21 lamps have the lowest CCT among HID Lamps, and 

22 are thus used in applications where the color 
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1 appearance of objects may be less important. 

2 DOE has also found that changes in

3 CCT correspond with efficacy; that is, lamps 

4 with lower CCT typically have higher efficacy. 

5 Because DOE was able to conclude that CCT 

6 impacted both consumer utility and efficacy, 

7 DOE is considering establishing separate 

8 equipment classes for different CCT ranges. 

9 Next, DOE looked at the potential of 

10 using wattage as a class-setting factor. When 

11 considering lamp input powers and light 

12 outputs, DOE found that increased wattage was 

13 directly correlated with increased light 

14 output. Because an increase in one directly 

15 indicates an increase in the other, DOE found 

16 it necessary to only use one of these 

17 characteristics as a potential class-setting 

18 factor.

19 In deciding between the two, DOE 

20 found that manufacturers use wattage to 

21 categorize their product families and catalogs 

22 instead of light output. This distinction makes 
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1 wattage the more suitable equipment class2 setting factor. 

3 Consumer preferences vary by 

4 application, but the light output and, thus, 

5 wattage needs are often dictated by the 

6 distance between the HID Lamp and the surface 

7 to be lit. 

8 Manufacturer catalog data also 

9 indicated that an increase in wattage directly 

10 correlated with increased efficacy. Because DOE 

11 was able to conclude that wattage impacted both 

12 consumer utility and efficacy, DOE is 

13 considering separating equipment classes based 

14 on wattage.

15 DOE also examined using bulb finish 

16 as an equipment class-setting factor. When 

17 analyzing manufacturer catalogs, we found that 

18 commercially available HID Lamps were available 

19 with a clear bulb finish, or a variety of 

20 finishes that were not clear. The terms used 

21 for non-clear lamps included coated, diffused, 

22 frosted, white, and deluxe white. In our 
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1 analysis, we decided to look at clear versus 

2 non-clear lamps with all non-clear lamps 

3 considered under the term coated. 

4 When lamps are coated, it is to 

5 reduce glare. Coated lamps are used in the 

6 specific applications where glare would be 

7 undesirable. The other result of a lamp being 

8 coated, however, is that they are less 

9 efficacious because the coating blocks some of 

10 the visible light from passing through the 

11 outer bulb envelope. Due to this impact on both 

12 consumer utility and lamp efficacy, DOE is 

13 considering establishing separate equipment 

14 classes for clear versus coated lamps. 

15 The last equipment class-setting 

16 factor we'll be discussing is luminaire 

17 characteristic. Luminaire characteristic 

18 indicates if a lamp is tested for and approved 

19 for use in an open fixture, meaning the lamp is 

20 open-rated, or if it was required to be used 

21 only in closed fixtures, thus making it an 

22 enclosed-rated lamp. 
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1 In order to be approved as open2 rated a lamp must, among other things, contain 

3 a glass shroud around the arc tube as 

4 protection in the event of arc tube rupture. 

5 While an open-rated lamp has a distinct utility 

6 that it can be used in open fixtures the glass 

7 shroud also reduces lamp efficacy by blocking 

8 some of the lamp's visible light.

9 Because of the impact that luminaire 

10 characteristic has on consumer utility and lamp 

11 efficacy, DOE is considering establishing 

12 separate equipment classes for these two 

13 luminaire characteristics. 

14 This table summarizes the 28 

15 equipment classes that result when separating 

16 lamps based on the class-setting factors 

17 discussed. Each of these equipment classes 

18 could be subject to different standards. All 

19 commercially available high-pressure sodium 

20 lamps that DOE found are in the 1900 to 2800 

21 Kelvin CCT range. The metal halide and mercury 

22 vapor lamps are virtually all found in the 
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1 higher two CCT ranges. 

2 The division of wattage ranges shown 

3 here reflects the availability of certain lamp 

4 technologies. For example, ceramic metal halide 

5 lamps are predominantly found in the 50 to 400 

6 watt range, and probe-start metal halide lamps 

7 are the only ones found above 1000 watts. 

8 After establishing the CCT and wattage ranges, 

9 DOE created an equipment class for each 

10 combination of bulb finish and luminaire 

11 characteristic within each wattage and CCT 

12 combination. 

13 With that said, DOE invites comment 

14 on several issues specific to equipment 

15 classes. DOE is defining coated lamps as all 

16 lamps that are not clear, since the terms 

17 coated, diffused, frosted, white, and deluxe 

18 white all typically represent the same or 

19 nearly the same bulb finish within a lamp type. 

20 DOE invites comment on this definition of 

21 coated lamps.

22 MR. BROOKMAN: Susan.
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1 MS. CALLAHAN: NEMA agrees with DOE's 

2 definition of coated lamps. 

3 MR. BROOKMAN: Thank you. Additional 

4 comments here? Okay.

5 MR. CHESTER: Okay. Next, when 

6 separating metal halide lamp equipment classes 

7 according to luminaire characteristic, DOE 

8 considered open-rated, enclosed-rated, and S9 rated lamps. DOE requests comment on the 

10 separation of equipment classes by luminaire 

11 characteristic, as well as the application of 

12 F-rated lamps and how they should be 

13 categorized within this equipment class 

14 structure.

15 MR. BROOKMAN: Susan.

16 MS. CALLAHAN: NEMA agrees with DOE's 

17 proposal to separate equipment classes by 

18 luminaire characteristic, and to put the /E and 

19 /S lamps together. NEMA membership includes 

20 manufacturers of /F luminaire code lamps. NEMA 

21 believes that lamps with the /F luminaire code 

22 should be excluded from the rulemaking.
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1 MR. CHESTER: Can you explain why 

2 they should be excluded?

3 MS. CALLAHAN: The /F-rated lamps are 

4 double-ended lamps. They're a specialty lamp 

5 usually used in sports lighting fixtures. They 

6 are double-ended. The fixture that is required 

7 of them is both mechanically and electrically 

8 interlocked because these lamps have no outer 

9 jacket. And it's done that way for UV safety. 

10 MR. BROOKMAN: Okay. Additional 

11 comments on item on number 9?

12 MR. CHESTER: All right. Lastly, DOE 

13 invites any other comments on equipment 

14 classes.

15 MR. BROOKMAN: Susan.

16 MS. CALLAHAN: Again, NEMA believes 

17 that HPS Lamps with CCT greater than or equal 

18 to 1900 and less than or equal to 2700 Kelvin 

19 should be excluded from the rulemaking. This --

20 the concern is about the testing and reporting 

21 burden of this large number of very long-life 

22 lamps.
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1 MR. BROOKMAN: You can see the 

2 equipment classes listed there in issue number 

3 10. Take a peek. Any additional comments here? 

4 Joanna.

5 MS. MAUER: Joanna Mauer. Susan, if I 

6 could ask you a question. The F-rated lamps 

7 that you were mentioning, is there some 

8 inherent difference in efficacy compared to the 

9 other types of lamps?

10 MR. BROOKMAN: Susan.

11 MS. MAUER: Or could they -- are they 

12 not able to achieve the same efficacy as other 

13 --

14 MS. CALLAHAN: I would have to go and 

15 look them up. Right now, I would be guessing. 

16 MS. MAUER: Okay, thank you. And does 

17 DOE have any information on shipments of those 

18 F-rated lamps?

19 MR. CHESTER: We don't have any data 

20 on that, but we would welcome any data that 

21 NEMA would be able to provide, or anybody else.

22 MR. BROOKMAN: Yes, Daniel.
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1 MR. YOUNG: Daniel Young. Another 

2 question for Susan. So, the -- you're proposing 

3 to exempt the HPS product class, basically, and 

4 I was just wondering if you're aware of any 

5 difference at all in efficacy between lamps of 

6 different manufacturers or different quality 

7 lamps that -- where there might actually be a 

8 difference in efficacy for the same kind of 

9 technology class.

10 MR. BROOKMAN: Susan.

11 MS. CALLAHAN: I'm not sure that 

12 that's something that NEMA would be able to 

13 speak to, so I would like to pass on that. 

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

15 Michael.

16 MR. MYER: Michael Myer, PNNL. I just 

17 want to clarify the definition for mercury 

18 vapor specialty ballast for Joanna. I looked it 

19 up for 10 CFR 431.282. It's a lengthy 

20 definition but it says, "One, is designed and 

21 marketed for operation of mercury vapor lamps 

22 used in quality inspection, industrial 
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1 processing, or scientific use, including 

2 fluorescent microscopy and UV curing. And, two, 

3 in the case of a specialty mercury vapor 

4 ballast, the label which, one, provides that 

5 the specialty application is for specialty 

6 purposes, not for general illumination. And, 

7 two, specifies the specific application for 

8 which the ballast is defined."

9 MR. BROOKMAN: Joanna.

10 MS. MAUER: Sorry, that was a lot.

11 MR. BROOKMAN: Me, too.

12 MR. MYER: Michael Myer, PNNL, again. 

13 I think the critical detail that I was trying 

14 to provide you is that I think in the second 

15 part of that definition it says it does have to 

16 specify, at least the sub -- Roman Numeral 

17 2(ii) says "specifies the specific application 

18 for which the ballast is defined."

19 MS. MAUER: Okay.

20 MR. MYER: But I would refer you to 

21 the Code of Federal Regulations for the exact 

22 wording as I read it here, but it is a lot of 
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1 words.

2 MS. MAUER: This is Joanna. If I 

3 could ask a simple question. These mercury 

4 vapor ballast designed for these specialty 

5 applications, is there any physical difference 

6 compared to other mercury vapor ballasts for 

7 general applications? In other words, is it 

8 just the intended application, not anything --

9 not any difference -- the physical ballast 

10 could be used in a general mercury vapor 

11 application.

12 MR. WALKER: I think this did come up 

13 in the framework meeting also, and I think the 

14 feedback was that the ballasts are very 

15 similar. 

16 MR. BROOKMAN: That was Matt. Right?

17 MR. WALKER: Sorry, this is Matthew 

18 Walker from Navigant. Right.

19 MR. BROOKMAN: Okay. 

20 MR. WALKER: The ballasts are similar 

21 but they're labeled differently. 

22 MR. BROOKMAN: You may have stumped 
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1 our panel. We'll see. 

2 MS. MAUER: If I could just ask one 

3 more follow-up question. Does DOE have any 

4 information on kind of how this exemption has 

5 worked in practice, and whether there's -- it's 

6 been a loophole at all, whether there are 

7 customers that are purchasing these ballasts 

8 that are designed and marketed for specialty 

9 applications that are being used in general 

10 lighting applications?

11 MR. MYER: This is Michael Myer. I 

12 don't want to preview my slide too much, but 

13 when you get to shipments you'll see a general 

14 decline, and you can actually see a little bit 

15 of, I don't want to say hiccup, but you can see 

16 a change in trend. After 2008, even still it's 

17 been declining for -- since the mid `90s, but 

18 you can kind of see a change in trajectory from 

19 when the rule went into effect. 

20 MS. MAUER: Thank you.

21 MR. BROOKMAN: Additional comments 

22 here? Okay.
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1 MR. CHESTER: DOE identified a number 

2 of technology options that can be used to 

3 improve efficacy. Mercury vapor lamps are 

4 already being phased out by manufacturers and 

5 new R&D is not being put into them. For those 

6 reasons, the technology options available for 

7 mercury vapor lamps simply consist of changing 

8 to high-pressure sodium or metal halide 

9 technology.

10 For metal halide lamps, DOE found 

11 that the three available technology options 

12 were to change from quartz arc tubes to ceramic 

13 arc tubes, to optimize the shape of the arc 

14 tubes to increase efficacy, or to change from 

15 probe-start technology to pulse-start 

16 technology.

17 When looking at the technology 

18 options for high-pressure sodium lamps, DOE 

19 found that all high-pressure sodium lamps 

20 commercially available were using the same 

21 technology and did not find any variation in 

22 technology or design that warranted a 
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1 technology option.

2 Due to this, DOE investigated other 

3 options and found that in the past, there have 

4 been lamps manufactured with arc tubes made out 

5 of sapphire instead of the standard 

6 polycrystalline alumina. The improved light 

7 transmission characteristics of the sapphire 

8 material would result in increased efficacy. 

9 DOE is considering whether this option might be 

10 a feasible means of improving the efficacy of 

11 high-pressure sodium lamps. All these 

12 technology options are considered further in 

13 the screening analysis.

14 DOE invites comment on the following 

15 issues with regard to the market and technology 

16 assessment. DOE requests comment on the 

17 technology options presented, in particular, 

18 the high-pressure sodium sapphire arc tube 

19 technology. 

20 MR. BROOKMAN: Susan.

21 MS. CALLAHAN: In regard to the 

22 technological feasibility, yes, sapphire lamps 
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1 were evaluated by industry in the 1970s. It is 

2 not obvious at this point in time how those arc 

3 tubes were fabricated, but they may have been 

4 cored from a bull rather than continuously 

5 pulled. From a lamp perspective, the technology 

6 was deemed not to be feasible. From the 

7 practicability to manufacturer install and 

8 service, commercially available sapphire tubing 

9 has limited selections of ID/OD combinations 

10 which are not necessarily amenable to lamp 

11 design and fabrication.

12 Changing the draw axis is not 

13 technologically feasible because the tube 

14 simply won't close. You'll end up with 

15 something that looks like a U, or at best a C, 

16 but not an O. New sealing technologies would 

17 need to be developed and the probable use of 

18 PCA end plugs would reduce the light output. 

19 In terms of the adverse impacts on 

20 product utility or product availability, the 

21 draw axis is not mechanically stable, twinning 

22 will occur with respect to lamp operation. 
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1 Twinning can result in catastrophic failure of 

2 the lamp during operation. Also, these are very 

3 long-lived lamps which would require 

4 significant life testing before being brought 

5 to market. 

6 Adverse impacts on health or safety. 

7 Metal halide lamps have the possibility of arc 

8 tube rupture. Sapphire arc tubes have the 

9 probability of rupture, as well as cracking due 

10 to manufacturing defects, especially 

11 inclusions, voids, and low-angle grain 

12 boundaries. Additionally, HPS lamps today are 

13 /O-rated, leading either to a safety issue with 

14 direct replacement with unprotected sapphire 

15 technology, or a containment construction which 

16 increases lamp cost and reduces lumen output. 

17 MR. BROOKMAN: Thank you. 

18 MR. CHESTER: Okay. DOE also requests 

19 any other comments on the market and technology 

20 assessment.

21 MR. BROOKMAN: Joanna.

22 MS. MAUER: Joanna Mauer. Maybe if I 
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1 could just pose Daniel's question to DOE, which 

2 was did DOE evaluate whether there's any 

3 significant difference in efficacy, for 

4 example, within currently available HPS lamps, 

5 or within currently available pulse-start metal 

6 halide lamps?

7 MR. CHESTER: Within the high8 pressure sodium lamps we didn't find any 

9 notable difference in efficacy across 

10 manufacturers when looking at the data, which 

11 is why we went to looking for the other 

12 technology options possible.

13 MS. MAUER: And within metal halide, 

14 there's ceramic metal halide, of course. Did 

15 you look at within -- I don't know how to --

16 non-quartz --

17 MR. CHESTER: The quartz arc tubes?

18 MS. MAUER: Yes.

19 MR. CHESTER: Yes. Well, the only 

20 technology options we found there were to go 

21 from probe-start lamps to pulse-start lamps, 

22 and then specifically designing the arc tube to 
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1 increase the efficacy of the fill gas. It's 

2 found to increase the efficacy, but those three 

3 options that we presented are -- including the 

4 ceramic arc tube are the three that we found.

5 MS. MAUER: Okay. 

6 MR. BROOKMAN: No additional 

7 comments.

8 MR. CHESTER: Okay. In the screening 

9 analysis, technology options are screened on 

10 the basis of four criteria; technological 

11 feasibility, practicability to manufacture, 

12 install, and service; adverse impacts on 

13 product utility or availability to customers; 

14 and adverse impacts to health and safety.

15 With the exception of the sapphire 

16 arc tube high-pressure sodium lamps, DOE has 

17 determined that all of the technology options 

18 meet the screening criteria and, thus, will not 

19 be screened out. Sapphire arc tube high20 pressure sodium lamps have previously been 

21 manufactured at a commercial scale, though they 

22 are not made today. Because DOE has thus far 
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1 been unable to ascertain the reason for the 

2 discontinuance of sapphire arc tubes, DOE is 

3 still considering them as a potential design 

4 option. 

5 DOE invites comment on whether the 

6 technology options and, in particular, sapphire 

7 arc tube technology meet DOE's screening 

8 criteria. 

9 MR. BROOKMAN: I guess we've already 

10 heard a fair amount about sapphire technology 

11 but, Susan, do you want to continue to 

12 illuminate further, to use -- a word. You said 

13 what you want to say about sapphire arc tube 

14 technology.

15 MS. CALLAHAN: I would just like to 

16 reiterate the safety aspect of sapphire arc 

17 tubes in terms of lamp operation. 

18 MR. BROOKMAN: Okay. Additional 

19 thoughts, comments here?

20 MR. CHESTER: I think we originally

21 had a break scheduled here.

22 MR. BROOKMAN: We're going to keep 
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1 going right now.

2 MR. CHESTER: Keep going?

3 MR. BROOKMAN: Yes.

4 MR. CHESTER: All right. Then, I'll 

5 introduce and pass of to my colleague, Matthew 

6 Walker.

7 MR. WALKER: All right. Good morning, 

8 everyone. My name is Matthew Walker, and I'm 

9 from Navigant. 

10 I'm going to get started with the 

11 Engineering and Equipment Price Determination. 

12 So, in short, the engineering analysis 

13 establishes potential standard levels and lamp 

14 performance at those levels, setting a 

15 framework for analyzing lamp prices and the 

16 equipment price determination. And then later 

17 analyzing impacts on customers, manufacturers, 

18 and the nation, and the later downstream 

19 analyses that we'll get to later in the day. 

20 So, this slide gives an overview of 

21 the methodology used in the engineering 

22 analysis. DOE begins by choosing equipment 
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1 classes to be directly analyzed which it calls 

2 representative equipment classes. 

3 Next, DOE defines characteristics of 

4 baseline lamps in each equipment class. This is 

5 followed by identifying more efficacious 

6 substitute lamps for each baseline lamp, and 

7 then developing candidate standard levels that 

8 correspond to the range of efficacy from 

9 baseline to maximum technologically feasible. 

10 And then, finally, DOE scales its results to 

11 the equipment classes that were not directly 

12 analyzed.

13 All right. So, as Matt described 

14 earlier, DOE is considering standards for 28 

15 equipment classes, but from this list, DOE 

16 plans to focus its analytical effort on the 

17 four equipment classes on the table in this 

18 slide. 

19 So, these classes are chosen on the 

20 basis of them having high market volumes or 

21 unique performance characteristics. So, just as 

22 a little reminder, the high-pressure sodium 
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1 lamps fall in that first row in the 1900 to 

2 2800 Kelvin range. Metal halide lamps are 

3 primarily in the bottom three rows, in the 2800 

4 to 4500 Kelvin range, and then we have mercury 

5 vapor lamps that fall in the middle two rows, 

6 because they're generally only found from 50 to 

7 1000 watts.

8 So, then in the following slides 

9 with the engineering analysis we'll keep coming 

10 back to the second row on the slide, the 2800 

11 to 4500, 50 to 400 watt equipment class as an 

12 example for the rest of the engineering. So, 

13 here in issue 13, DOE requests comment on the 

14 use of these four equipment classes as 

15 representative for the rulemaking.

16 MR. BROOKMAN: Susan.

17 MS. CALLAHAN: NEMA still believes 

18 that HPS lamps with CCTs greater than or equal 

19 to 1900 Kelvin, and less than or equal to 2700 

20 Kelvin should be excluded from the rulemaking.

21 MR. BROOKMAN: Thank you. It's not 

22 bad to repeat yourself at the appropriate times 
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1 here. That's a good thing.

2 Additional comments here on this 

3 equipment classes? This is important. 

4 (No response.)

5 MR. BROOKMAN: Okay, no additional 

6 comments. We're moving on.

7 MR. WALKER: All right. So, next 

8 we'll talk a little bit about the baseline 

9 lamps. A baseline lamp generally represents the 

10 most common, least efficacious lamp model on 

11 the market. DOE then identified more 

12 efficacious substitute lamps for each of the 

13 baseline lamps, and collectively referred to 

14 that group, the baseline, and its more 

15 efficacious substitutes as a representative 

16 lamp type. So, as you can see in the table, 

17 there are several of these representative lamp 

18 types included within a single equipment class. 

19 And this is to help analyze the wide variety of 

20 wattages in lamps that you find within a single 

21 equipment class. So, you can see at least one 

22 baseline is included for each representative 
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1 lamp type, but in cases where two lamp 

2 technologies are included in one representative 

3 lamp type, DOE analyzed multiple baselines to 

4 consider the life-cycle cost changes relative 

5 to lamps with different technology.

6 So, the table lists the baselines 

7 for one of the representative equipment 

8 classes. So, for example, in that sort of 

9 middle row, the 250 watt mercury vapor 

10 representative lamp type uses a 250 watt 

11 mercury vapor lamp as its first baseline 

12 because it was the least efficacious, but then 

13 we acknowledge that most of the market has 

14 already adopted the probe-start metal halide 

15 technology, so the 175 watt probe-start metal 

16 halide lamp was also analyzed as a baseline, so 

17 this grouping had two baselines.

18 DOE requests comments on the 

19 baseline units selected.

20 MR. BROOKMAN: Susan.

21 MS. CALLAHAN: NEMA requests 

22 clarification as to how a lamp can be a 
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1 baseline and a CSL 1?

2 MR. WALKER: Sure, I can speak a 

3 little bit to that. So, the main purpose, just 

4 to start with the baseline concept, the 

5 baseline basically establishes a reference 

6 point in the life-cycle cost analysis, which is 

7 the analysis of an individual customer's 

8 response and economic impact to standards. So, 

9 designating a particular lamp a baseline means 

10 that the life-cycle cost will use that as a 

11 reference point. So, the reason -- I guess the 

12 way -- all right. 

13 Looking at some of these, they'll be 

14 designated as a CSL 1 and a baseline. The 

15 reason that can happen is because when you're 

16 looking at the impact of standards using that 

17 mercury vapor lamp as a reference point, the 

18 probe-start metal halide lamp is a CSL 1 in 

19 that scenario, but if you're considering the 

20 probe-start metal halide lamp as the starting 

21 point for a customer, it's in that case 

22 referred to as a baseline. So, it's not really 
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1 both at the same time. It depends on the 

2 scenario, and the particular snapshot that 

3 you're looking at. Does that help you at all?

4 MS. CALLAHAN: No.

5 (Laughter.)

6 MR. WALKER: I mean, is there 

7 something else more specific that is troubling 

8 you?

9 MS. CALLAHAN: Our concern, and it'll 

10 come out both in our written comments and in --

11 as the meeting goes on, is that the selection, 

12 especially of probe-start metal halides that 

13 are CSL 1s and having them as baselines is that 

14 you have not picked the least efficacious lamp 

15 available. 

16 MR. WALKER: Right. Okay. I mean -

17 MS. CALLAHAN: That's part of our 

18 confusion. 

19 MR. WALKER: Right. I guess I can 

20 maybe say one other thing. So, I think I'll 

21 just reiterate that the labeling of baseline 

22 supports the life-cycle cost analysis, but then 
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1 when you look at the impacts of the rulemaking 

2 overall, and say, you're considering a CSL 2 

3 standard is going to be applied to a particular 

4 equipment class, in that case it doesn't really 

5 matter what was labeled the baseline. In that 

6 case, you look at the shipments that would have 

7 been going towards the mercury vapor lamp, and 

8 the probe-start metal halide lamp. And as 

9 Michael and Natasha will speak to later, those 

10 shipments would shift up to the CSL 2, or 

11 perhaps some other lamp that's compliant. 

12 I guess what I'm trying to say is 

13 that the baseline designation really only 

14 affects the life-cycle cost and when you're 

15 looking at the impact of the rulemaking 

16 overall, when a CSL 2 is selected, any lamp 

17 that's less efficacious than that lamp would 

18 then need to be replaced by something that is 

19 compliant. So, the key, I guess, is the number 

20 of shipments assigned to those less efficacious 

21 lamps, be it a baseline or a baseline/CSL 1.

22 MR. BROOKMAN: Additional thoughts, 
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1 questions, comments?

2 MS. CALLAHAN: NEMA does have one 

3 comment, and that is that we would propose that 

4 the baseline lamps in this category greater 

5 than 2800 K, less than or equal to 4500 K, 50 

6 to actually 1000 watts would be mercury vapor 

7 only, and not metal halide at all.

8 MR. WALKER: Okay.

9 MR. BROOKMAN: Thank you. Additional 

10 thoughts on baseline models?

11 (No response.)

12 MR. BROOKMAN: Okay.

13 MR. WALKER: All right. So, moving on 

14 from baselines, DOE then seeks to identify more 

15 efficacious substitute lamps for each of the 

16 baselines that have been decided on previously. 

17 So, this table shows the lamps that comprise 

18 the 250 watt mercury vapor representative lamp 

19 type, so that was that middle row on the 

20 previous slide. So, let's just kind of walk 

21 through this.

22 You can see that wattage decreases 
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1 as you move from baseline, the top row, down to 

2 CSL 3. So, wattage is decreasing while initial 

3 efficacy is increasing. DOE sought to keep mean 

4 lumens as close to the baseline as possible, so 

5 within 10 percent of the baseline whenever 

6 possible. So, as you can see in the table, CSL 

7 1 and CSL 2 are within 10 percent, but CSL 3 is 

8 not. And that is because of lamp availability 

9 at that wattage with that technology. 

10 DOE also aimed to keep a variety of 

11 other factors as consistent as possible with 

12 the baseline, including initial lumen output, 

13 lamp operating orientation, rated life, CRI, 

14 and other factors. So, on the note of operating 

15 orientation, whenever possible, DOE selected 

16 universal orientation lamps as the basis of the 

17 engineering analysis to ensure that that 

18 feature in those lamps would not be precluded 

19 by standards.

20 All right. So, DOE requests comment 

21 on the criteria used in selecting more 

22 efficacious substitute lamps, as well as the 
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1 specific units selected.

2 MR. BROOKMAN: Maybe you could go 

3 back to the preceding slide.

4 MR. WALKER: Sure.

5 MR. BROOKMAN: Susan.

6 MS. CALLAHAN: NEMA is going to 

7 address this in its written comments.

8 MR. BROOKMAN: Okay, thank you. 

9 Additional comments here?

10 (No response.)

11 MR. BROOKMAN: Nothing additional, 

12 okay. 

13 MR. WALKER: All right. So, this 

14 slide goes over the concept of an HID system. 

15 To analyze -- HID lamps are used in lighting 

16 systems that include a ballast, so to analyze a 

17 lamp energy conservation standards impact on 

18 system performance, a ballast is paired with 

19 each representative lamp. DOE used manufacturer 

20 input, as well as independent research to 

21 identify the ballast type and ballast 

22 efficiency that's most commonly used with each 
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1 lamp.

2 Oh, I think I went too far, sorry 

3 about that. Yes, so this slide discussed the 

4 ballast component of the HID system. I advanced 

5 one slide too far. 

6 So, you can see in this table that 

7 all of the lamps with the exception of ceramic 

8 metal halide use a magnetic ballast, but the 

9 ceramic metal halide was paired with an 

10 electronic ballast. 

11 All right. So, this slide reviews 

12 the fixture component of the HID system. DOE 

13 preliminarily determined that standards-induced 

14 lamp changes also require the use of a new --

15 or the installation of a new HID fixture. This 

16 is because the existing fixture is going to be 

17 unlikely to properly physically fit a new lamp 

18 and ballast, or a different lamp and ballast, I 

19 guess is what I mean. And, as well, would 

20 result in suboptimal optics. And, additionally, 

21 retrofitting old fixtures has the potential to 

22 create safety concerns that could and can 
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1 result in the decertifying of the fixture's UL 

2 rating. 

3 All right. So, here in issue 18, 

4 we're looking for comments on the ballast types 

5 and ballast efficiency selected for each lamp 

6 type to calculate lamp and ballast system 

7 performance, so that was what was on the 

8 previous slide. And, as well, requesting 

9 comment on the concept of standards induced 

10 fixture replacement.

11 MR. BROOKMAN: Daniel.

12 MR. YOUNG: Daniel Young, California 

13 IOUs. I guess it's our understanding that there 

14 are a lot of products that are marketed as lamp 

15 and ballast retrofit kits for metal halides or 

16 HIDs, and it's our understanding these are 

17 designed to exactly serve this purpose when you 

18 could upgrade your ballast and lamp and still 

19 keep the existing fixture. Is that something 

20 that DOE considered?

21 MR. WALKER: Right, so you bring a 

22 point. There is this product that would provide 
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1 this retrofit capability, and we're definitely 

2 looking for feedback on this particular issue. 

3 But based on the determination made in the 

4 interim analysis, it was that the expected 

5 majority response, I guess, to standards would 

6 not be to follow that retrofit pathway due to 

7 these concerns. And, I guess, what would be the 

8 most helpful on the topic of the retrofit 

9 product is to have some sense of shipments or 

10 some sort of usage pattern associated with that 

11 pathway. That would be very, very helpful. I 

12 don't know if any of the other manufacturers 

13 have any insight into the usage of retrofit 

14 kits that they can share here at the meeting. 

15 MR. BROOKMAN: No?

16 MR. WALKER: All right. I guess we'll 

17 move on the next slide. So, this goes over 

18 candidate standard levels, or CSLs. So, DOE is 

19 considering using equations to define potential 

20 standard levels. These equations would define a 

21 continuous relationship between lamp input 

22 power and initial lamp efficacy. 
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1 Sort of the process for developing 

2 these equations was by establishing the shape 

3 of the equation using regression curves 

4 specific to data sets for each equipment class. 

5 And then I can give an example of a CSL 

6 equation based on a power function on the next 

7 slide.

8 So, here you can see three CSL 

9 equations, blue, red, and green that correspond 

10 to probe-start, pulse-start, and ceramic metal 

11 halide technology. So, like I was saying, DOE 

12 used the power function relationship to 

13 establish equations that separated the 

14 representative lamps corresponding to the three 

15 technologies.

16 So, let's walk through the 

17 highlighted region of the chart. That's that 

18 yellow diagonal band that you see going through 

19 the middle of the chart. So, this again is that 

20 250 watt representative lamp type that we keep 

21 coming back to. And this kind of provides a 

22 good visual of the energy savings pathway that 
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1 is analyzed in the rule.

2 So, beginning at the bottom, the 

3 black dot is a 250 watt mercury vapor lamp. 

4 It's the highest wattage lamp. Then as you move 

5 sort of up and to the left, you reach the blue 

6 diamond which is a 175 watt probe-start metal 

7 halide lamp. It's like we were talking about 

8 before, and we've received comment about, is a 

9 lamp that DOE is also designating as a second 

10 baseline for this grouping.

11 And then as we continue again up and 

12 to the left reducing wattage even further, we 

13 get to the 150 watt pulse-start metal halide 

14 lamp. And, finally, with the green triangle, a 

15 100 watt ceramic metal halide lamp. So, that 

16 kind of goes through this representative lamp 

17 type grouping, and there's many of these that 

18 are analyzed in the rule but we've used this to 

19 sort of -- to highlight the concept.

20 The next slide will then expand the 

21 wattage range to show all three equipment 

22 classes that are included in this 2800 to 4500 
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1 Kelvin range. So, I'll just hop over there. 

2 Right. So, this plot shows the CSL 

3 equations for these three equipment classes. To 

4 the far left side of the chart, those are those 

5 three CSL equations that we just looked at on 

6 the previous slide for the 50 to 400 watt 

7 range. And, again, they represented the three 

8 technology -- the metal halide technologies 

9 that were available for that equipment class.

10 Then moving to the right in the 400 

11 to 1000 watt range, ceramic metal halide 

12 technology was not available, so CSL 3 was not 

13 analyzed. And we just have the blue and red 

14 lines. And then moving to the 1000 to 2000 watt 

15 range, only probe-start metal halide lamps were 

16 available, so DOE analyzed only one CSL.

17 All right. So, this brings us to a 

18 request for comment on the CSL equations 

19 developed in each of the representative 

20 equipment classes. 

21 MR. BROOKMAN: Susan.

22 MS. CALLAHAN: NEMA agrees generally 
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1 with the approach to use power functions and 

2 power function regression curves to best fit 

3 this; however, we are still exploring those 

4 exact coefficients and exponents, and they will 

5 be included in our written remarks.

6 MR. BROOKMAN: Okay. Daniel.

7 MR. YOUNG: Daniel Young. Just a 

8 question, do you know if the unavailability of 

9 ceramic metal halide above 400 watts is a 

10 technical issue or is it just, I don't know, 

11 lack of existing demand?

12 MR. WALKER: I might defer to some of 

13 the experts in the room but, I mean, ceramic 

14 metal halide sort of got its footing in the low 

15 wattage retail market I think is a good 

16 example. So, certainly, this is where the lamps 

17 exist right now. But yes, I think we might be 

18 able to look to some of the other experts in 

19 the room for future trends, but maybe not. 

20 MR. YOUNG: Okay.

21 MR. WALKER: All right. Let's come to 

22 the last slide of the engineering analysis, the 
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1 scaling. So, once CSLs are established for each 

2 representative equipment class, DOE developed 

3 scaling relationships those apply those CSLs to 

4 the remaining equipment classes that weren't 

5 analyzed directly. So, this process involved 

6 comparison of lamps that differed only by the 

7 parameter under consideration for scaling. So, 

8 for the interim analysis scaling factors 

9 accounted for the difference in initial 

10 efficacy due to bulb finish, luminaire 

11 characteristic, and CCT, which you probably 

12 notice are the same as the equipment class13 setting factors. 

14 So, for bulb finish, DOE found that 

15 coated lamps were about 6 percent less 

16 efficacious than clear lamps for the middle and 

17 high CCT ranges, and about 8 percent less 

18 efficacious for the low CCT lamps. And low CCT 

19 lamps was the high-pressure sodium grouping 

20 which we talked about quite a bit today. 

21 Then looking at luminaire 

22 characteristic, we found that open-rated lamps 
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1 were about 5 percent less efficacious than 

2 enclosed-rated lamps. And then, finally, with 

3 CCT the 4500 to 7000 Kelvin lamps were about 12 

4 percent less efficacious than the middle CCT 

5 range.

6 At this time, DOE requests comment 

7 on the scaling methodology and, in particular, 

8 whether the scaling factor between CCT ranges 

9 should be a function of wattage.

10 MR. BROOKMAN: Comments here? Susan.

11 MS. CALLAHAN: NEMA supports the use 

12 of scaling factors and we are currently working 

13 on evaluating member data to see whether --

14 what we would propose those scaling factors to 

15 be, and they will be included in our written 

16 comments.

17 MR. BROOKMAN: Thank you. Additional 

18 thoughts on issue 19? 

19 (No response.)

20 MR. BROOKMAN: All right.

21 MR. WALKER: Okay. So, in issue 17, 

22 DOE invites comment on the impact of reporting 
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1 requirements and variation on compliance with 

2 the CSLs under consideration. So, DOE is 

3 looking for feedback on whether or not an 

4 adjustment would be needed to the CSLs 

5 described here in the interim analysis to

6 account for the impact of reporting and 

7 variation. 

8 MR. BROOKMAN: Susan.

9 MS. CALLAHAN: NEMA stresses that HID 

10 tolerances be referenced to NEMA LSD 63 

11 measurement methods and performance variation 

12 for verification testing of general purpose 

13 lamps and systems which is based on NIST 

14 Technical Note 1297. And we ask DOE to clearly 

15 acknowledge this. 

16 MR. BROOKMAN: Okay, thank you. No 

17 additional comments on reporting requirements?

18 (No response.)

19 MR. WALKER: All right. Well, we'll 

20 wrap things -- in issue 20, DOE requests 

21 comments on all aspects of the engineering 

22 analysis, and anything else that hasn't been 
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1 covered yet.

2 MR. BROOKMAN: Additional comments on 

3 engineering analysis? Nothing additional?

4 (No response.)

5 MR. BROOKMAN: We can either take a 

6 break now or we can keep plugging on ahead. I 

7 suspect at our current pace that --

8 MR. WALKER: We actually have one 

9 more equipment pricing slide.

10 MR. BROOKMAN: Oh, one more slide. 

11 Sorry. 

12 MR. WALKER: May have gotten a little 

13 overeager with my wrapping up comments.

14 MR. BROOKMAN: Yes.

15 MR. WALKER: All right. So, let's 

16 cover the equipment price determination. 

17 Beginning with lamps, DOE analyzed the end user 

18 price directly rather than developing 

19 manufacturer selling prices because HID lamps 

20 are difficult to reverse-engineer, unlike a 

21 ballast or fixture which would have discrete 

22 solid components. The arc tube solids and fill 
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1 gases would be impractical to assess. So, 

2 there's a variety of HID lamp end users and 

3 there's a range of prices paid by those end 

4 users depending on the distribution channel. 

5 By developing three discount factors 

6 off of blue books or retail price lists, DOE 

7 calculated three sets of prices, low, medium, 

8 and high that ultimately corresponded to the 

9 price associated with a state procurement 

10 contract, a large distributor, or internet 

11 retailer. 

12 Then for the ballast and fixture 

13 component of the HID system, DOE did use a 

14 combination of tear-down retail data to 

15 estimate the manufacturer production cost. The 

16 manufacturer production costs were then marked 

17 up to the manufacturer selling price using a 

18 manufacturer markup that accounted for non19 production costs and manufacturer profit.

20 So, this brings us to the final 

21 slide for my portion. In issue 21, DOE invites 

22 comments on the methodology and results for 
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1 estimating end user prices for HID lamps.

2 MR. BROOKMAN: Susan.

3 MS. CALLAHAN: NEMA is unable to 

4 comment on this subject and defers to 

5 individual members.

6 MR. BROOKMAN: Okay, thank you. No 

7 additional comments.

8 MR. WALKER: All right. And then, 

9 finally, DOE invites comment on its methodology 

10 and results for estimating manufacturer selling 

11 prices for the ballast and fixture component.

12 MR. BROOKMAN: Susan.

13 MS. CALLAHAN: NEMA is unable to 

14 comment on this subject and defers to 

15 individual member comments.

16 MR. BROOKMAN: Okay, thank you. So, 

17 that concludes the Engineering and Equipment 

18 Price Determination segment. Let's take a break 

19 now. It's 10:15, so we'll take a 15-minute 

20 break, which means we'll resume at 10:30. 

21 Please wear your badge, some form of 

22 identification while you're in the Forrestal 
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1 Building. There are restrooms on both ends of 

2 the hall. There's a coffee shop on the ground 

3 floor. If you wish to have coffee, please go 

4 quickly and do that. A good start on the day, 

5 we've covered a lot of ground already. We'll 

6 see you back here at 10:30.

7 (Whereupon, the above-entitled 

8 matter went off the record at 10:16 a.m., and 

9 resumed at 10:31 a.m.)

10 MR. BROOKMAN: So, let's resume. And, 

11 Jack, how many folks are joining us via the 

12 web? I'm happy to report 14 individuals joining 

13 us via the web. Glad to have you with us. And 

14 we're going to now take up Energy Use and 

15 Markups Analysis, and we're going to hear from 

16 Michael Myer. 

17 MR. MYER: Thank you, Doug, for the 

18 introduction and queuing up the topics. 

19 Moving into the rulemaking maps 

20 lighting, you'll see that the markups analysis 

21 and the energy use analysis, they feed together 

22 and they provide inputs into the life-cycle 
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1 cost and payback period analysis.

2 Energy use analysis, we all know 

3 that energy is power times time so we're going 

4 to take the system input power, factoring in 

5 the power of the draw of the ballast, multiply 

6 it by annual operating hours. 

7 As mentioned earlier in previous 

8 slides in engineering analysis, the input power 

9 is developed there, and we're using their 

10 numbers. DOE then developed annual operating 

11 hours. We used data from the 2010 Lighting 

12 Market Characterization, abbreviated here as 

13 the LMC 2010, and it captures variations across 

14 building types and applications.

15 So, essentially, for commercial 

16 sectors you're about just under 4000 hours a 

17 year, for industrial sectors you're just over 

18 6000 hours a year, and for outdoor lighting 

19 you're about 4500 hours per year, and in some 

20 cases you have stadium lighting, which operates 

21 very small fraction of the year, and you're at 

22 roughly 778 hours per year.
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1 I'm going to now move into item 23, 

2 request for comment on operating hours. 

3 Basically, we used the Lighting Market 

4 Characterization 2010 which the most current. 

5 DOE assumed that all equipment analyzed could 

6 be used in three evaluated sectors, commercial, 

7 industrial, and outdoor, and applied average 

8 annual operating hours based on each sector. We 

9 welcome comment on the basis and the assignment 

10 of these, and the operating profiles. 

11 MR. BROOKMAN: No comment at this 

12 time? No comment at this time from manufacturer 

13 types. What about --

14 MR. MYER: Other types?

15 MR. BROOKMAN: What about others? 

16 Yes, please. Say your name.

17 MR. STARR: Louis Starr, Northwest 

18 Energy Efficiency Alliance. For the ballast 

19 factor, how is that working into your power 

20 input? What are you using for that?

21 MR. MYER: Well, as mentioned 

22 earlier, they do review the ballast efficiency, 
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1 so typically HID lamps ballasts have a ballast 

2 factor approaching one, so there aren't

3 multiple ballast factors that we can use, but 

4 they are using a variety of different ballast 

5 efficiencies for the different lamp types that 

6 are covered. It would depend on whether or not 

7 it's a probe-start versus a pulse-start, and 

8 the ballast efficiency would be factored into 

9 the input power. 

10 MR. STARR: Okay. And one other 

11 comment on the burn hours. I notice on the 

12 commercial there's 3900 and then if you look at 

13 the outdoor there's 4400, which is more, which 

14 makes sense. The only other aspect of that is

15 there's a good deal of retail involved in the 

16 commercial aspect which they usually run their 

17 lights even when it's dark outside, so just 

18 kind of wondered -- I expected maybe a little 

19 more on the commercial side or something on the 

20 outdoor hours.

21 MR. MYER: I would refer to the 

22 Lighting Market Characterization by the mixture 
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1 of lamp types used in different sectors. I 

2 agree that retail sectors often operate 12 to 

3 24 -- actually, some are operating 24 hours a 

4 day, but the mixture of HID lamps and retail 

5 sectors is not, proportionally compared to 

6 fluorescent or incandescent, is not as high. I 

7 mean, it is factored in, retail is a mixture in 

8 there, as well as office, as well as other type 

9 of environments that are not industrial 

10 manufacturing. It just happens to be the way 

11 that the averages all work out. But thank you 

12 for asking.

13 MR. BROOKMAN: Additional comments 

14 here? Okay. 

15 MR. MYER: Now, moving back into the 

16 stage slide, so we just discussed energy use 

17 analysis, now we'll be moving into the markups 

18 analysis.

19 Slight difference between the 

20 interim stage and the NOPR stage, and they're 

21 separated differently. So, for the interim 

22 stage, markups were not used for lamp prices as 
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1 they were developed as end user prices. Markups 

2 were developed for ballast and fixtures since 

3 manufacturer selling prices were supplied in 

4 engineering analysis. DOE used SEC 10-K forms 

5 and did not differentiate between baseline 

6 incremental. And then we came up with a final 

7 markup which is the average wholesale markup 

8 times the contractor markup or essentially 1.24 

9 times 1.13 equals 1.39.

10 For the NOPR stage, it will be 

11 differentiated a little bit. We do plan to get 

12 markups for the MIA analysis to estimate lamp 

13 manufacturer selling prices from end user 

14 prices. And we will also consider a low markup 

15 to differentiate the different distribution 

16 channels.

17 I'm now going to introduce my 

18 colleague -- oh, do you have a question, 

19 Joanna?

20 MS. MAUER: No.

21 MR. MYER: Okay. I saw your hand, 

22 sorry. I am now going to introduce my 
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1 colleague, Natasha Collins, who will discuss 

2 the life-cycle cost and payback analysis. 

3 MS. COLLINS: Good morning. I am 

4 Natasha Collins with Pacific Northwest National 

5 Laboratory, and I'm going to present today 

6 life-cycle cost and payback period analysis, as 

7 well as national impact analysis.

8 So, as most of us know, life-cycle 

9 cost analysis looks at the financial 

10 implications for individual consumers or end 

11 users of the lighting fixtures from moving to 

12 less efficacious to more efficient ones, as 

13 well as payback period analysis. While together 

14 with shipment analysis, this provides us enough 

15 inputs to evaluate the fact of the standard --

16 of a possible standard on the nation, and 

17 that's what we are going to be covering in 

18 national impact analysis later on.

19 So, just to repeat myself, in life20 cycle cost analysis, we are calculating the 

21 total cost of operating a fixture over the 

22 analysis period, which includes installed cost 
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1 and discounted operating cost and replacement 

2 costs. So, we basically calculate life-cycle 

3 cost for the base fixtures and for more 

4 efficacious fixtures, and take the difference 

5 to find out what the savings are.

6 Simple payback period, DOE uses as a 

7 quick method to calculate how many years it is 

8 going to take for a more efficacious fixture to 

9 pay itself back in terms of energy savings, in 

10 terms of lower electricity use as usual. Any 

11 questions so far?

12 MR. BROOKMAN: Yes, please.

13 MR. STARR: Louis Starr, Northwest 

14 Energy Efficiency Alliance. Is the lifetime 

15 cost 70 percent of the life or the -- what's 

16 the life of the fixture or the lamp?

17 MS. COLLINS: We have been setting 

18 the analysis period equal usually to the 

19 lifetime of the fixture, but there are a lot of 

20 limitations on how it works because for a lot 

21 of baseline fixtures that we have, mercury 

22 vapor baseline fixtures, for instance, they 
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1 have very limited lifetime that's left in them 

2 because the new fixtures could not be installed 

3 any more, and the ballast shipments are 

4 limited. So, for a mercury vapor it's actually 

5 only about six years of the analysis period 

6 that is left. If we take a look at the 

7 beginning of the analysis period in 2017, 

8 that's when the standard becomes effective, we 

9 estimated that the fixtures will last 

10 approximately to 2022.

11 MR. STARR: Okay. So, the lamp and 

12 the fixtures then are assumed to have roughly 

13 the same lifetime, or do the fixtures have a 

14 greater lifetime than the lamp?

15 MS. COLLINS: They have greater 

16 lifetime than the lamp. This is for the mercury 

17 vapor baselines. Then there is also probe metal 

18 halide that have different lifetimes, so 

19 whenever we had a baseline fixture available 

20 for replacement we used the entire fixture 

21 lifetime.

22 MR. BROOKMAN: Okay? 
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1 MS. COLLINS: Any other questions? 

2 So, this slide just visually represents how the 

3 analysis flows. So, we've got installed fixture

4 cost, we've got annual ownership cost. That 

5 breaks down into the lamp replacement cost, 

6 ballast replacement and annual operating cost. 

7 So, full lamp replacement, ballast 

8 replacements, we have lifetimes of those 

9 components. We have their prices. For annual

10 operating cost there is electricity price, 

11 there are operating hours, there are projection 

12 how electricity prices going to change over 

13 time. And those annual ownership costs are 

14 discounted and together they comprise --

15 together with installed cost comprise life16 cycle cost. 

17 So, we have analyzed three different 

18 triggering events, and those events stem from 

19 three different times when the lamp can be 

20 exchanged. It's either lamp failure or ballast 

21 failure and lamp is replaced with a ballast, or 

22 entire fixture is being replaced. Those three 
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1 triggering events apply to the baseline because 

2 we know that once the standard is established, 

3 all those three triggering events will require 

4 fixture change because we cannot fit a more 

5 efficacious lamp with the old ballast, or we 

6 cannot fit a more efficacious ballast and lamp 

7 into the fixture that's old. Any questions?

8 (No response.)

9 So, a little bit more detail on our 

10 inputs for the installed costs. End user prices

11 for lamps, ballast, and fixtures that are 

12 floating from engineering analysis mostly, 

13 sales tax by state we estimated with data from 

14 Sales Tax Clearinghouse, just a little bit over 

15 7 percent nationwide, and installation cost 

16 that we estimated from RS Means. They include 

17 labor cost and servicing equipment cost, and 

18 those costs vary significantly based on the 

19 application of the lamp, based on the 

20 environment, and based on the wattage. So, 

21 fixture cost from $160-535. This is fixture 

22 installation cost only, excluding the cost of 
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1 the fixture itself. Ballast $147-297, and lamp 

2 from $94-254. 

3 On the operating cost side, we use 

4 EIA's form 826 to evaluate the electricity 

5 prices, and we used AEO 2012 to estimate the 

6 price trend into the future. Discount rate was 

7 calculated using the formula for weighted 

8 average cost of capital, and you can see that 

9 for outdoor stationary that the discount rate 

10 is lower than for the two other sectors. It 

11 reflects higher government ownership in that 

12 sector. 

13 Lifetime for fixtures, we assumed 20 

14 years for interior and 25 for exterior. Ballast 

15 for magnetic 50,000 hours, and for electronic 

16 40,000 hours. 

17 On the replacement cost side, we 

18 also used lamp and ballast lifetimes. We're not 

19 bringing up lamp lifetimes because they vary 

20 significantly by technology, by product class, 

21 and by efficiency level. We also estimated 

22 equipment price trend based on AEO 2011 
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1 deflators to reflect the declining real price 

2 of the equipment over time.

3 MR. BROOKMAN: Yes, please.

4 MR. STARR: Louis Starr with NEEA. 

5 Actually, I have a question on the previous 

6 one, the life-cycle analysis of the installed 

7 cost of fixtures and the labor. Do you have a 

8 general idea of what the split between the cost 

9 of the fixture, to install a fixture and how 

10 much labor it was? Is it 50-50? Is it -- a 

11 general idea. I mean, there's kind of a rule of 

12 thumb in industry what that would be, so I kind 

13 of want to see what your idea was.

14 MS. COLLINS: Yes. Actually, the cost 

15 of the fixture sometimes is even lower than the 

16 installation costs themselves. But 50-50 would 

17 be safe to assume.

18 MR. STARR: Okay. 

19 MS. COLLINS: It's usually lower than 

20 -- on average it's lower than 50.

21 MR. STARR: Then I would also mention 

22 like on high-pressure sodium, a lot of 
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1 municipalities have very fixed numbers, so they 

2 exactly know how much it is to replace a lamp 

3 fixture because they'll sub out that work to 

4 firms and they'll have a -- they'll know 

5 exactly what the fixture cost is, and they 

6 provide a certain price to replace lamp 

7 fixtures. So, there's some very fine cost data 

8 out there. Municipalities have a lot of that 

9 for replacing like outdoor lamps.

10 MR. BROOKMAN: Do you have a source, 

11 a specific source?

12 MR. STARR: City of Seattle has some 

13 information, but I would say every 

14 municipality. I bet you California IOUs would 

15 have a lot of data in terms of -- you know, it 

16 can get you a very particular split-out of what 

17 the fixture costs are and what the lamps are.

18 MR. BROOKMAN: Daniel, do you have 

19 access to that?

20 MR. YOUNG: Possibly. 

21 MR. BROOKMAN: Okay.

22 MR. YOUNG: But yes, we'll try and 
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1 find that and provide that.

2 MR. BROOKMAN: That'd be great.

3 MS. COLLINS: Thank you. 

4 MR. BROOKMAN: Now we're finishing up 

5 on 57.

6 MS. COLLINS: More comments? I can 

7 proceed?

8 MR. BROOKMAN: Yes.

9 MS. COLLINS: We're finished with 

10 that one. So, here is just a sample of the 

11 results because we have modeled three different 

12 events, and we have so many product classes 

13 with so many baselines. Here I am presenting 

14 the results for the lamps with light 

15 temperature between 2800 and 4500 Kelvin, and 

16 with wattages between 50 and 400 watts. 

17 As you can see, in a lot of cases 

18 there are negative LCC savings, and a lot of 

19 that due to the very high installed cost at the 

20 very beginning of the analysis period. Payback 

21 periods are also significant. In one of the 

22 product classes where the payback period is not 
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1 applicable, it's actually over 100 years. 

2 That's why we just put N/A there. 

3 And when we're switching from one 

4 level of metal halide technology to higher 

5 levels of metal halide, we actually realize 

6 some positive savings. There are actually some 

7 savings there. Any questions here? No 

8 questions?

9 So, at this point, DOE invites 

10 comments on the lifetimes of the equipment. So, 

11 we assumed 20 years for interior fixtures, 25 

12 years for exterior fixtures, 50,000 hours for 

13 magnetic ballast, 40,000 hours for electronic 

14 ballast. We also assumed average values, and we 

15 would like to know how the failure rates 

16 distributed around those average lifetimes. We 

17 also seek comments on the lamp lifetimes that 

18 we have used.

19 MR. BROOKMAN: Daniel.

20 MR. YOUNG: Daniel Young, California 

21 IOUs. I'm trying to understand how you 

22 accounted for the incremental cost of the 
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1 fixture at the beginning of the replacement, so 

2 if I understand correctly, you assumed maybe a 

3 7-year analysis period for switching out a 

4 mercury vapor based on the current fixture's 

5 lifetime. Correct?

6 MS. COLLINS: Yes.

7 MR. YOUNG: And then do you incur the 

8 full incremental cost of the new fixture?

9 MS. COLLINS: You incur the full cost 

10 of installing a new fixture.

11 MR. YOUNG: But the benefits are only 

12 accrued over seven years?

13 MS. COLLINS: Yes, because you have 

14 to tailor the analysis period to how long your 

15 baseline is going to last. And that also 

16 represents the true cost that the end user will 

17 be facing. We tried to model the situation to 

18 be as close to reality as possible. 

19 MR. YOUNG: But then that doesn't 

20 consider that at the end of that seven years 

21 you would have had to replace that fixture 

22 anyways. Correct?
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1 MS. COLLINS: Yes, it doesn't incur 

2 that -- it doesn't account for that, but we 

3 cannot make a choice what kind of fixture the 

4 end user would pick at that time. They could 

5 have picked LED fixture which happens a lot of 

6 times, and that's why we made that choice.

7 MR. YOUNG: So, I guess in an extreme 

8 example, if there was only one year of 

9 remaining life on the fixture and you were 

10 trying to evaluate the cost effectiveness of 

11 this measure, then you're essentially saying 

12 that you would incur the full cost of the brand 

13 new fixture one year before it would be 

14 replaced anyway, so --

15 MS. COLLINS: That's why we didn't 

16 use extreme examples. That's why we averaged 

17 that out because, in fact, it could be a longer 

18 lifetime period. We calculate that on average 

19 that it will be that long, at least six years, 

20 but it could last into 10 years, it could be 

21 longer. 

22 MR. YOUNG: Okay.
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1 MS. COLLINS: Because we tried to 

2 estimate averages and weight it so -- to come 

3 up with some mythical representative consumer 

4 end user.

5 MR. YOUNG: Sure. Did you consider, I 

6 guess, discounting the price by the fraction of 

7 years that you're covering that's overlapping?

8 MS. COLLINS: Yes, we have considered 

9 different discounting, and we have considered 

10 adding back some cost, but you will incur that 

11 labor cost that you can't really discount back, 

12 or you cannot recoup over the time. So, it's 

13 basically the sunk cost that you will be 

14 incurring regardless. 

15 MR. YOUNG: I'm not sure I agree, but 

16 we'll provide a comment to that.

17 MR. BROOKMAN: Okay.

18 MS. COLLINS: Thank you.

19 MR. BROOKMAN: Thank you.

20 MS. COLLINS: We will definitely

21 appreciate your comments. 

22 MR. BROOKMAN: So, now we're back to 
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1 issue 24, and asking for comment on the 

2 lifetimes that you see here in this box. 

3 MS. COLLINS: No comments?

4 MR. BROOKMAN: No comment at this 

5 time. Michael?

6 MR. MYER: Yes, I just wanted to ask 

7 the gentleman from the Northwest, when he said 

8 to me about 70 percent, are you suggesting that 

9 either lamps or fixtures are prematurely 

10 retired? I just want to -- because it does 

11 affect shipments later on, so I'm just trying 

12 to understand your potential question. 

13 MR. STARR: I was talking about 

14 degrading the lamp life at 70 percent, so it's 

15 more to do with the lamp. But since the fixture 

16 is living past the lamp, it's kind of more how 

17 often they're replacing the lamps are, because 

18 it's not really the lifetime of the lamp, it's 

19 70 percent of the lamp lifetime. Then you re20 lamp them.

21 MR. MYER: Okay, so you're asking C22 Michael Myer, Pacific Northwest National 
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1 Laboratory. Just so I understand, you're saying 

2 -- you were asking whether or not we use -- if 

3 a lamp is rated for 10,000 hours, do we use the 

4 10,000 hour value versus the 7,000 hour --

5 thank you. And the reason why you're asking 

6 the 70 percent is the IOUs recommendation for 

7 it?

8 MR. STARR: Right, right. Correct.

9 MR. MYER: Okay. Thank you very much.

10 MR. BROOKMAN: Take a peek at issue 

11 box 24, see if you have any comment here. Okay. 

12 MS. COLLINS: Then we are back to 

13 Michael Myer, and he's going to cover shipment 

14 analysis. 

15 MR. MYER: Thank you, Natasha. So, 

16 moving into the next two phase, the shipments 

17 analysis along with some of the economics that 

18 Natasha just briefly touched on both are inputs 

19 for the national impact analysis. 

20 Shipment analysis essentially tries 

21 to predict what the technology somewhat has 

22 done historically, but then also what it will 
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1 do into the future. And it's good to know the 

2 historic to predict, as I said. And we also do 

3 two types of projections; one is, as I said, 

4 the standards case, and one is the base case. 

5 The base case assumes no shifts related to a 

6 standard, and the base case --the standards 

7 case assumes that things would shift in result.

8 As I've mentioned before, DOE has 

9 historical data from NEMA. We actually have a 

10 pretty good treasure trove, in my opinion, of 

11 data, and that's why I was able to provide some 

12 insight to Joanna's question. We also reviewed 

13 industry forecasts related to technologies. We 

14 also developed the base case and the standards 

15 case based on lamp lifetimes, replacement and 

16 demand growth, decline cycles, and then also 

17 the retirement and emerging technology 

18 penetration, whether certain fluorescent or LED 

19 technologies will replace HID.

20 So, so this graph is what -- on the 

21 left hand side before the green line, that's 

22 roughly historic data. Actually, it's historic 
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1 data before the green line, and then the green 

2 line indicates the start of the analysis period 

3 moving forward from 2017 to 2046. Everything up 

4 to 2010 is actually historic data.

5 You'll see that overall most 

6 technologies are in a decline. HID as a family 

7 is in a decline overall. It appears that 

8 roughly 2005 was the overall zenith for HID 

9 lamp shipments, but only time will tell. And 

10 just to walk through all the colors, the top 

11 line is orange which is high-pressure sodium, 

12 together metal halide actually represents 

13 larger segment share than high-pressure sodium 

14 but we broke them out by technologies just to 

15 make it easier. So, then we have the purple 

16 which is ceramic metal halide, the red which is 

17 pulse -- I'm sorry, probe metal halide, and 

18 then the green which is pulse-start metal 

19 halide. And the lower one which is teal is 

20 mercury vapor, and the data point that I 

21 alluded to earlier is if you look at the 2008 

22 to 2010 data range for mercury vapor, you'll 
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1 see kind of a marked decline since the EPAct. 

2 Yes?

3 MR. STARR: Louis Starr, Northwest 

4 Energy Efficiency Alliance. Since it seems like 

5 you have lots of data on the mercury vapor and 

6 shipments in general, what I'm wondering is if 

7 you have a split out of before 2008, you 

8 probably know how many mercury vapor ballasts 

9 shipped, and maybe you know also the amount of 

10 mercury lamp and ballast combinations. What I 

11 was wondering if you can figure out if the 

12 amount of replacement ballast, because if 

13 someone is buying a ballast, they're not buying 

14 the lamp at the same time, means they're buying 

15 a replacement. If you can kind of see if that 

16 same trend and the amount of quantity of 

17 ballasts that are being shipped pre-2008 and 

18 post-2008, if those are matching up or not? 

19 What I'm trying to get at is to see if people 

20 are actually just replacing ballast rather than 

21 replacing lamp and ballast. In other words, 

22 they might be trying to find a loophole, and 
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1 I'm wondering if there's a way to take those 

2 three pieces of information and overlap them to 

3 see whether there are loopholes being created 

4 by having specialty ballast for mercury vapor.

5 MR. MYER: Yes, based on from where 

6 I'm hearing your approach here, I would not 

7 disagree with that methodology. At the moment, 

8 we do not have that data for mercury vapor 

9 ballast shipments, which is the critical 

10 detail, and I would actually ask NEMA and 

11 manufacturers if there -- if anyway possible to 

12 provide any insight on manufacture of ballast 

13 shipments. We do have another rule where we 

14 have leveraged some data related to metal 

15 halide fixtures, but since mercury vapor with 

16 ballast was actually an act of Congress, we 

17 don't have that data. It's not gone through the 

18 normal rulemaking process, so I don't have it. 

19 Ultimately, rather than historic 

20 data which may not be as easy to get because 

21 manufacturers may purge it, the approach I 

22 would suggest is also what -- how many mercury 
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1 vapor ballast shipments have there been since 

2 2008, which would give us a rough idea, because 

3 we have an idea of the lamp shipments since 

4 2008, so we could correlate roughly how many 

5 are going to specialty applications versus 

6 general applications.

7 MR. STARR: Is that something the 

8 manufacturer would be willing to provide, 

9 perhaps?

10 MS. CALLAHAN: I will take that back 

11 to a NEMA meeting and see what we can do.

12 MR. BROOKMAN: Thank you, Susan. 

13 Okay? Joanna.

14 MS. MAUER: Joanna Mauer. Just a 

15 question. So, the line showing projected 

16 shipments of probe-start metal halide lamps, is 

17 that -- that goes out to 2044, 2046. Is that 

18 reflecting that some portion of metal halide 

19 fixtures will have a much longer lifetime than 

20 the average lifetime of 20 to 25 years?

21 MR. MYER: Well, probe-start, I think 

22 -- I'm going to -- well, I guess my question is 
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1 are you asking because of the EISA 2007 --

2 okay. So, EISA 2007, just so I'm putting this 

3 on the record that everyone is aware, only

4 affected 150 to 500 watt probe-start fixtures, 

5 so you can still sell today a probe-start 

6 fixture that's greater than 500 watts. So, 

7 that's one answer. That's why we have lamp 

8 shipments.

9 Two, it didn't restrict -- it didn't 

10 put any restrictions related to the sale of 

11 lamps, so if you had a working lamp and you had 

12 a working fixture, let's say you bought it in 

13 2008 the ballast, and it also does not affect a 

14 replacement ballast, it only affected ballast 

15 shipped with the fixtures at the time, so you 

16 could buy a replacement ballast let's say in 

17 2028 or 2035 for the 250 watt probe-start 

18 fixture, and then also have a new lamp 

19 servicing, as well. So, the projections that 

20 you're seeing for probe-start technology are 

21 two-fold. One is high wattage lamps that are 

22 not affected by any current regulations related 
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1 to probe-start technology. And, two, the 

2 replacement of either the lamps or the ballast 

3 that can continue into the future.

4 MS. MAUER: Thank you. So, the 

5 average lifetime assumed for new fixtures is 20 

6 to 25 years, so any -- on average any new 

7 fixture, new probe-start fixture, the last ones 

8 were installed in 2009 or so. Sorry, in the 150 

9 to 500 watt range.

10 MR. MYER: That is, I believe, the 

11 general impression from my understanding from 

12 industry and as a lighting practitioner that 

13 while 94 percent ballast is technically 

14 achievable, most manufacturers are not -- I 

15 think we all -- I think -- I've not seen data 

16 on it, but most people do not expect probe17 start 150 to 500 to be shipped since 2009, 

18 fixtures, fixtures. Yes, I would say that would 

19 be the last rough date. And, actually, I think 

20 if we're wrong, we're saying 2009, I think it's 

21 2008, but I'm speaking off the cuff here. But I 

22 would agree with you, in my impression here, 
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1 yes, that nobody is shipping a 94 percent 

2 greater efficient ballast at this time.

3 MR. BROOKMAN: Yes, Louis.

4 MR. STARR: One last question, and 

5 that is, I notice in general it looks like the 

6 shipments are moving down, and I assume that's 

7 because other technologies coming to market, 

8 maybe LED. If that's the case, can you maybe 

9 explain how that shaped the -- how you used 

10 that information to shape those curves?

11 MR. MYER: Yes. Essentially, we've 

12 heard in different other rulemakings, the metal 

13 halide lamp fixture as well as the HID, that 

14 fluorescent technology in interior applications 

15 is displacing metal halide, so we did look at 

16 if -- what the penetration rate. We also looked 

17 at Lighting Market Characterization 2010 and 

18 2001 to get a sense of what technologies are 

19 currently being used by percentages, and just 

20 what the longevities were. We also looked at 

21 other DOE reports of what technologies, what 

22 penetration rates are expected, so we tried to 
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1 use those all to forecast at some point -- some 

2 of these are premature. You know, some of these 

3 are fixtures that were installed maybe in 2016 

4 that will be prematurely retired before their 

5 20-year life or 25-year life because another 

6 technology is replacing it. 

7 MR. BROOKMAN: Okay? Yes.

8 MR. MYER: Takes me into issue 25. 

9 Basically, just talking about historic 

10 shipments. We based it on NEMA data from 2002 

11 to 2010, as well as market trend. We just 

12 request comments on this approach, and we 

13 welcome any additional lamp shipments that we 

14 can for historic data in most recent years. 

15 Right now, the model is in a critical spot. 

16 Anything in the near -- you know, from 2010 to 

17 2013, any new data points are very helpful 

18 because of just the way the current trends are 

19 working. It's a good data point, so we just 

20 request comment on this methodology, and any 

21 additional data.

22 MR. BROOKMAN: We've heard from NEMA 
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1 already that they'll try -- they'll take that 

2 back. What about the methodology? No additional 

3 comments at this time. Okay.

4 MR. MYER: That brings us to issue 

5 26. So, DOE modeled lamp purchasing events, 

6 replacement and new construction, as well as 

7 applied growth and replacement rate assumptions 

8 to develop shipments. 

9 We did base these lamp future 

10 shipments on the 2010 HID Lamps Determination. 

11 We also assumed that these trends integrate 

12 various regulatory and non-regulatory 

13 initiatives in Lighting Market Place. 

14 We request comment on the magnitude 

15 and timing of its projected shipments, whether 

16 rise and declining is accurate or a plateau 

17 should be modeled in, as well as the effects of 

18 current regulatory initiatives on future HID 

19 shipments. So, just more comments on the way 

20 the graphs look, if they look correct, or if 

21 they should be sharper, or steeper.

22 MR. BROOKMAN: Additional thoughts on 
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1 these trends for shipments? 

2 MR. MYER: And, also, a critical 

3 detail is that while this is a lamp rule, any 

4 thoughts on shipments of fixtures which is not 

5 covered under this rule also affects -- if you 

6 don't buy a lamp -- if you don't buy a fixture, 

7 there's no lamp to service it, so if there's 

8 any future growth -- future ideas on fixture 

9 shipments is also appreciated. 

10 MR. BROOKMAN: Nothing additional at 

11 this time. Okay.

12 MR. MYER: Brings me to the last 

13 issue, issue 27, standards-induced market 

14 shifts. So, in the shipments analysis, DOE 

15 assumes that a portion of the market shifts to 

16 LED, induction, and linear fluorescent sources. 

17 DOE requests comments on this assumption as 

18 well as on the likelihood magnitude of an 

19 additional market shift to non-HID technologies 

20 in response to the standards. I'll wait for a 

21 second.

22 If a standard-induced shift 
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1 expected, DOE requests further comments on 

2 which equipment classes would be affected, 

3 applications or fixture types, which non-HID 

4 technologies would replace HID, and on what 

5 basis would an equivalent non-HID replacement 

6 be specified; specifically, would it be fixture 

7 light output, lamp mean lumens, those type of 

8 things.

9 MR. BROOKMAN: Yes, Daniel.

10 MR. YOUNG: Daniel Young, California 

11 IOUs. Just a question for the Department, are 

12 you considering to account for savings from a 

13 standards-induced market shift to more 

14 efficient technologies?

15 MR. MYER: At this time it's 

16 something we are considering, yes.

17 MR. YOUNG: Could you talk about how 

18 you might do that?

19 MR. MYER: We welcome comment on 

20 proposed methodology. It's really a lot of --

21 the third part of that question is what feeds 

22 some of that, so, you know, obviously energy --
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1 you know, the operating hours would be one 

2 factor, and energy is the other, power is the 

3 other one. How we select non-HID technologies 

4 is the critical detail. You know, is it lumen 

5 output, is it mean output, how do we -- what 

6 are the comparisons? But, also, again, the 

7 first two parts are just as important. Do 

8 people expect shipments -- shifts away from 

9 lower wattage, or medium wattage, or high 

10 wattage? Those would, ultimately, affect what 

11 any energy -- any energy calculations.

12 MR. BROOKMAN: The last part of issue 

13 27 is pretty specific. Any thoughts, though, on 

14 those trend lines, those shifts that might be 

15 standards-induced? Susan.

16 MS. CALLAHAN: NEMA requests that the 

17 published analysis made available before the 

18 NOPR include the effects of the anticipated 

19 shifts. And if the shipment trends indicate a 

20 decrease in product, factor this into the 

21 energy savings and the financial impact 

22 analysis.
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1 And to someone else's point, the

2 current trends show many categories shifting 

3 away from HID, so the corresponding reduction 

4 in energy savings potential should be factored 

5 into this analysis for us. Thank you.

6 MR. BROOKMAN: Okay, thank you. 

7 Additional thoughts here? The Department really 

8 appreciates detailed written comments on points 

9 like this, especially I'm looking at NEMA and 

10 others who are in the room. Okay. 

11 MR. MYER: Thank you. At this point, 

12 I will return the presentation back to Natasha 

13 Collins for national impact analysis.

14 MS. COLLINS: As I mentioned earlier, 

15 together with shipments analysis, LCC provides 

16 us enough inputs to estimate national energy 

17 savings, and net present values resulting from 

18 possible standard. So, for energy savings we 

19 estimated the stock of lamps every year, and in 

20 the base case and in the standards case, and 

21 compared the energy used. As you can see, CSL 

22 1, CSL 2 provide lower level of energy savings 
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1 as opposed to CSL 3, where we model shifting to 

2 ceramic metal halide, and that's where the bulk 

3 of the savings is coming from.

4 I wanted to point out that the 

5 savings have a dwindling effect, reflecting the 

6 declining HID market. So, savings for CSL 1 are 

7 .63 of a quad of source BTUs, CSL 2, 1.16 quads 

8 of BTUs, and for CSL 3 it's 4.67. That's what 

9 our estimates are. 

10 As for NIA results, they're largely 

11 negative both for 3 percent discount rate and 7 

12 percent discount rate which reflects very high 

13 installation cost and install cost for the 

14 fixtures at the very beginning of the analysis 

15 period. So, both for CSL 1 -- both for 3 

16 percent and 7 percent discount rates. 

17 So, CSL 1, negative $12 billion 

18 roughly for CSL 1, and the 3 percent discount, 

19 CSL 2 roughly $16 billion negative, CSL 3 

20 roughly $14 billion. And the figures are of the 

21 same magnitude for 7 percent discount, $9.4 

22 billion CSL 1, CSL 2 $12.5 billion, and CSL 3 
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1 about $14 billion negative. Yes, Joanna?

2 MR. BROOKMAN: Joanna.

3 MS. MAUER: One question I had, 

4 looking at the LCC and NPV results for 

5 individual representative product categories, 

6 it looks like there are some cases, for 

7 example, the 400 watt mercury vapor 

8 representative product where it looks like the 

9 LCC results for the different -- you know, both 

10 the lamp and ballast events are positive, and 

11 then the NPVs are negative for that same 

12 category. Could you explain why that's the 

13 case?

14 MS. COLLINS: Yes, that occurred a 

15 lot. And the main reason for that is that the 

16 proportion of fixtures that are shipped under 

17 the standards case is a lot higher than in 

18 general proportion of shipments. And that's 

19 what affects the increase -- that's what 

20 affects a very high -- that's what results in a 

21 very high installed cost, a lot higher install 

22 cost in the standards case as opposed to base 
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1 case. So, on average it's maybe 30 percent of 

2 lamp shipments associated with fixture 

3 shipments for the new fixture. While after the 

4 standard is introduced it's about 70 percent or 

5 maybe even more. We have -- does that make 

6 sense?

7 MS. MAUER: So, the LCC is just -- I 

8 understand is just looking at shipments in --

9 or a customer who's purchasing -- in the base 

10 case would purchase a new lamp. I guess, or 

11 ballast or fixture in the first year, in 2017, 

12 the first year the standard takes effect. So, 

13 you found that for some cases those customers 

14 would see positive, and large positive savings? 

15 But customers purchasing lamps or lamps and 

16 ballast or fixtures in later years would see --

17 would not see positive savings. Is that what 

18 you're saying? I guess, so the LCC analysis is 

19 showing these positive savings for shipments in 

20 2017, but then the NPV is showing -- which is 

21 taking into account, of course, 30 years of 

22 shipments, is showing negative.
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1 MS. COLLINS: Yes. So, let me show 

2 you one graph here that will probably make my 

3 point a little bit clearer. So, in the NI 

4 analysis we see the mixture of things being 

5 shipped.

6 (Off mic comments.)

7 MS. COLLINS: So, we usually have a 

8 mixture of LCC results in every product class. 

9 And when we have a lot of fixture shipments 

10 that are replacing just lamps, then those LCC 

11 results tend to turn negative, so there are a 

12 lot more fixtures that are shipped in the 

13 standards cases. As you can see here, like 

14 five-fold increase in fixture shipments in 2017 

15 in standards case as opposed to base case.

16 MS. MAUER: I guess where I'm 

17 confused is even just in 2017, the assumption 

18 is that a lot of those customers are having to 

19 buy a whole new fixture.

20 MS. COLLINS: Yes.

21 MS. MAUER: In the standards case, 

22 even though they would just be buying a lamp, 
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1 or a lamp and ballast in the base case.

2 MS. COLLINS: Right.

3 MS. MAUER: And, yet, it looks like 

4 you're finding that those consumers have 

5 positive LCC savings. And, yet, the NPV is 

6 negative. 

7 MS. COLLINS: We can look in the 

8 calculations in more detail, if you would like.

9 MS. MAUER: Okay. And I guess if I 

10 could just follow-up with another question. 

11 Maybe kind of piggybacking on what -- on 

12 Daniel's questions before. Just to understand, 

13 now in the NPV how you're taking into account -

14 - kind of the difference between base case and 

15 the standards case. So, for example, in the 

16 case of a mercury vapor baseline where the 

17 standard is I think having the effect of kind 

18 of accelerating a fixture replacement that 

19 would take place anyway, even absent a 

20 standard. So, now the customer is having to buy 

21 a new fixture in response to the standard say 

22 in 2017, but in the base case they would also 
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1 have to purchase a new fixture, say a metal 

2 halide fixture to replace the mercury vapor 

3 fixture. That purchase would occur, you know, 

4 some -- a few years later rather than in 2017. 

5 So, you're accounting for that fixture 

6 replacement cost in the baseline, but in a 

7 different year than in the standards case?

8 MS. COLLINS: So, LCC analysis is a 

9 little different from NIA analysis. It's 

10 extends for a longer period. Right? And we're 

11 trying to take into account the lifetimes of 

12 the -- of a lot of ballasts and fixtures that 

13 are operating. So, it's more gradual here 

14 because there are fixtures that are shipped in 

15 different years, there are ballasts that are 

16 shipped in different years. So, we kept the 

17 shipments of lamps the same in both base case 

18 and standards case in order to be conservative 

19 in estimating what energy savings the rule is 

20 going to bring about. We didn't model shifting 

21 to other technologies and savings from the 

22 shift to that of technology, but because we 
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1 kept the lamp shipments the same that allowed 

2 us to capture some of those savings. They're 

3 not completely unaccounted for, they are 

4 accounted for that way. That's to address your 

5 shipments question part.

6 MS. MAUER: I guess what I'm trying 

7 to understand, so in the base case customers 

8 that currently have mercury vapor probe-start 

9 metal halide fixtures, at some point are going 

10 to have to replace those fixtures with a new --

11 another technology.

12 MS. COLLINS: Yes. We estimated that 

13 it will be replaced with another HID 

14 technology.

15 MS. MAUER: So, the costs of 

16 replacing their fixture, those are accounted 

17 for in the base case?

18 MS. COLLINS: Yes.

19 MS. MAUER: So, it's the same costs, 

20 they're just occurring in different --

21 MS. COLLINS: Yes, it's just spread out 

22 more. It's not that a lot of fixtures are going 
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1 to be replaced in 2017. It's spread out across 

2 the years.

3 MS. MAUER: Okay.

4 MS. COLLINS: It's that either lamp 

5 or ballast exchange would bring about the 

6 entire fixture exchange. That's what drives the 

7 very high installed cost in the very beginning 

8 of the analysis period because you cannot 

9 replace just the lamp, and it's very costly to 

10 do that. And we are forcing everybody to 

11 exchange a fixture whenever they need just a 

12 lamp replacement for an old fixture.

13 MS. MAUER: Even though then five 

14 years later or 10 years later, whenever it is, 

15 then that same customer doesn't need to replace 

16 the fixture, then they're just replacing their 

17 lamp, or their lamp and ballast.

18 MS. COLLINS: Yes, it's not 

19 everybody, it's just that particular -- you 

20 know, it's spread out in time more.

21 MR. BROOKMAN: Okay? Daniel.

22 MR. YOUNG: So, I'm just looking at 
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1 your graph here, and I guess I would expect 

2 that if there's a big spike of a million 

3 shipments in 2016, you know, 30 years, or 25 

4 years from then there would be that same spike 

5 to replace all those again?

6 MS. COLLINS: That probably would be 

7 not really -- it will be more gradual because 

8 there is a distribution of the lifetime, so it 

9 won't be the spike. And then HID technology is 

10 being replaced by other technologies, so you 

11 probably won't see a big spike. It depends.

12 MR. YOUNG: Sure. But I guess my 

13 point really is that I would expect that since 

14 you've shipped, you know, five times as many in 

15 2016 as you would have in the base case, at 

16 some point you're going to be shipping fewer 

17 than in the base case.

18 MS. COLLINS: Yes, but we had to keep 

19 the -- we could not project the increase in the 

20 lamp shipments to service all those new 

21 fixtures because this is, in general, a 

22 declining market, so some of those fixtures 
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1 will be retired earlier. So, as I mentioned 

2 earlier, we kept the lamp shipments the same in 

3 both base case and standards case. So, in order 

4 to service the influx of the fixtures, you 

5 would have to increase the lamp shipment 

6 significantly, and that would assume that they 

7 would be operational for a very long time, and 

8 they won't be replaced by any other technology. 

9 So, this also implies that some of the fixtures 

10 would be retired prematurely; otherwise, this 

11 market would just be exploding. That's 

12 definitely a limitation of the analysis, but we 

13 tried to fit the model to represent the reality 

14 as best as we can. 

15 MR. BROOKMAN: Additional thoughts 

16 here? Susan.

17 MS. CALLAHAN: Susan Callahan from 

18 OSRAM SYLVANIA. This is different. Because I'm 

19 just looking for a little understanding here, 

20 and we're assuming in 2015 we are going to have 

21 a change in the lighting technology. And I'm 

22 looking at this going okay, I'm changing 
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1 essentially -- I'm assuming you're using a CSL 

2 1 as the base case to a CSL 2, and why as a 

3 user of a 250 watt probe-start lamp, why would 

4 I change to anything but a 250 watt pulse-start 

5 lamp, because I want the same light levels? And 

6 they are equally efficacious when I put them in 

7 the fixture, assuming equal fixture. So, 

8 exactly how am I saving money in all of this, 

9 especially since -- I mean, as a lamp maker I 

10 sort of love this but, you know, I switch from 

11 one product to another, but I -- part of me is 

12 trying to figure out where the cost payback is 

13 in this in the energy savings, because I don't 

14 understand the consumer changing to a lower 

15 wattage going from probe-start to pulse-start.

16 MS. COLLINS: I think I might need to 

17 direct that question to the engineering 

18 analysis team. 

19 MR. MYER: Well, this is Michael 

20 Myer. So, I guess your -- as a manufacturer's 

21 opinion is that -- Michael Myer from PNNL, by 

22 the way, that lumen output is not -- the 
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1 driving market is wattage, where if they could 

2 get the same number of lumens for a lower 

3 wattage, and it was -- they would not shift 

4 that way. 

5 MS. CALLAHAN: Right, but I get 250 

6 watts of probe-start, 250 watts of pulse-start.

7 MR. MYER: I understand the wattages 

8 are the same, but they wouldn't --

9 MS. CALLAHAN: But I get the same 

10 lumens.

11 MR. MYER: But you could also get the 

12 same lumens at 175 watts.

13 MS. CALLAHAN: Not necessarily. I 

14 mean, I've got 40,000 -- or I've got lumens, 

15 and I've got lumens, and they're the same. I 

16 guess my point is that there's no difference 

17 between 250 watts of pulse-start lumens, and 

18 250 watts of probe-start lumens, so I'm going 

19 to force into a fixture change for which, where 

20 is my energy payback?

21 MR. WALKER: This is Matthew Walker 

22 from Navigant. So, I'm hearing you say that 
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1 pulse-start and probe-start metal halide of the 

2 same wattage have the same light output. Is 

3 that what --

4 MS. CALLAHAN: Pretty much, their 

5 initial lumens, yes. 

6 MR. WALKER: So, I mean, I guess 

7 we'll take that as feedback under advisement 

8 for the next stage.

9 MS. CALLAHAN: Okay.

10 MR. WALKER: The reason we were 

11 talking about energy savings right now is that 

12 the assumption was that when you move from 

13 probe to pulse, the efficacy was increasing, so 

14 the 250 watt -- or the pulse-start metal halide 

15 had higher light output, so you were able to 

16 reduce wattage. So, our -- the pathway put 

17 forward to engineering analysis was equal lumen 

18 reduced wattage replacement, and so we would 

19 certainly be wanting feedback on whether or not 

20 you think something else makes more sense. It 

21 seems like you're saying equal wattage, equal 

22 lumens. Perhaps there's even equal wattage, 
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1 increased lumens. So, I mean, we're certainly 

2 looking for feedback on that, on the expected 

3 customer response to an efficacy standard.

4 MS. CALLAHAN: Thank you. 

5 MR. BROOKMAN: Okay. So, I should ask 

6 if there are final comments on the NIA results. 

7 Louis.

8 MR. STARR: Louis Starr, Northwest 

9 Energy Efficiency Alliance. I think the point 

10 she was trying to make is that the factory or 

11 whoever is not going to redo signs or lighting 

12 layout in order to accommodate the lower 

13 wattage bulbs, so she's not really saying that 

14 they're equal. It's just not -- they're not 

15 going to redesign their system in order to 

16 accommodate a different layout, is probably 

17 more what the point is. Is that more what 

18 you're getting at?

19 MS. CALLAHAN: The rearranging the 

20 ceiling tiles is definitely part of it, but I 

21 think a closer examination of manufacturer's 

22 catalogues would indicate a greater similarity 
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1 in probe-start, in pulse-start lamp initial 

2 efficacies than has been implied.

3 MR. BROOKMAN: Thank you, Susan. 

4 MS. MAUER: Susan, if I could just C5

6 MR. BROOKMAN: Joanna.

7 MS. MAUER: Whereas, if you looked at 

8 mean efficacy, there may be a significant 

9 difference. Do you have a sense for what 

10 customers -- do they pay more attention to 

11 initial lumens as opposed to mean lumens?

12 MS. CALLAHAN: I don't know. I mean, 

13 that's one of those things that -- and I always 

14 defer to the marketing people, but yes, mean 

15 lumens are important, but I don't --I honestly 

16 don't know what drives that decision more. 

17 MR. BROOKMAN: Yes, please.

18 MR. STARR: Louis Starr, NEEA. 

19 Typically, you're going to design your space 

20 based upon what your mean lumen output is. You 

21 couldn't design a space for the first day of 

22 operation and then not care what it's going to 
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1 be like in a year, so they are going to design 

2 to mean outputs, output lumens, so that's what 

3 sets up the fixture layout from that point. So, 

4 it does -- the initial is not really important 

5 at all in terms of design, it's what your mean 

6 output lumen is going to be over the lifetime 

7 of the thing, and what you anticipate your use 

8 is going to fall to. 

9 MR. BROOKMAN: Yes, please. Victor.

10 MR. VARGA: This is Victor Varga from 

11 GE. And, you know, we have been working with 

12 lots of customers to define what is a cost13 effective way to reduce energy in their 

14 facilities. And it is very interesting that it 

15 really depends on case-by-case basis, and 

16 customer-by-customer basis. Customers are very 

17 sensitive of what is their initial cash layout 

18 is going to be to make the change. So, what 

19 they do is they look at it as what is my 

20 payback, return on investment, if you wish to 

21 say. And in many cases what we are finding is 

22 they come back with numbers, you know, that 
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1 tells them that the return on investment maybe 

2 five years, six years, which if you look around 

3 in the everyday business life, you know, we 

4 actually would like to have a payback of one or 

5 two. Okay, three, thank you for the prompting. 

6 Yes, so maybe for strategic, you know, kind of 

7 initiatives, and you would look at three and 

8 four. But really when you do this analysis, do 

9 you really want to force the customer to make 

10 something to invest into that they are not 

11 going to see the return for another five years? 

12 And that's -- I just wanted to put that thought 

13 in the discussion because it relates back to 

14 what is really the difference between a probe15 start and a pulse-start lamp. It's very, very 

16 little, but if you think about you have to 

17 replace the ceiling tiles, or you have to 

18 rearrange the grade, that means it's a very 

19 large initial investment for the customer, and 

20 they might not actually see the payback.

21 MR. BROOKMAN: Thank you. Okay. 

22 Susan, yes.
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1 MS. CALLAHAN: To Louis' comment 

2 about mean lumens, I would be remiss in not 

3 admitting that the reason that pulse-start 

4 lamps exist is because they do have superior 

5 lumen maintenance and higher mean lumens. 

6 MR. BROOKMAN: Okay. And I think we 

7 heard -- okay, this has been useful. This has 

8 been good. I want you to now look at the NIA 

9 results here and see if there's any additional 

10 comments before we move on. Okay.

11 MS. COLLINS: Then I would like to 

12 introduce Hayden Cook, who will present interim 

13 MIA results.

14 MR. BROOKMAN: Louis, yes. Hayden, 

15 hang on. 

16 MR. STARR: This is Louis Starr, 

17 Northwest Energy Efficiency Alliance. I was 

18 actually looking for a way to insert this 

19 comment. This is more on the cost analysis when 

20 you're looking at replacement. I notice there's 

21 a lot of reliance on RS Means for coming up 

22 with the cost of labor and things, and I might 
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1 encourage you to look at other estimation of 

2 labor costs. I used to review a lot of change 

3 orders and things, and the rule of thumb was 

4 that they would use Means for change orders, 

5 and they'd use another cost estimating for 

6 getting the job. The implication is that by 

7 using the Means it may over-estimate the cost. 

8 It's a conservative way of estimating your 

9 labor cost, so you might consider looking at 

10 some different sources, or a variety of sources 

11 for estimating your labor. It will change your 

12 analysis, you know, not necessarily positive or 

13 negatively, but I think it will tend to 

14 increase your labor costs more as a proportion 

15 of the analysis than the equipment cost, which 

16 then can change your decisions on how cost17 effective things are.

18 MR. BROOKMAN: In competitive 

19 environments, they're under-bidding to win the 

20 contract.

21 MR. STARR: Right. Well, in general 

22 it's just that yes, once you have something, 
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1 then you can -- it's harder in a change order 

2 you are committed to a certain contractor; 

3 whereas, if you've got three or four bidding on 

4 something, then it -- and it typically seems to 

5 be on the labor side a lot of times.

6 MR. BROOKMAN: Okay. So, now back to 

7 Hayden. Yes, pardon me. Michael, go ahead.

8 MS. COLLINS: Natasha Collins. Louis, 

9 could you please refer us to the data sources 

10 for the labor costs that you mentioned?

11 MR. STARR: Yes, I can maybe talk to 

12 you later about some things to consider.

13 MS. COLLINS: Thank you.

14 MR. BROOKMAN: Hayden. 

15 MR. COOK: Hi, my name is Hayden 

16 Cook. I'm with Navigant Consulting, and I'll be 

17 briefly speaking with you about the 

18 manufacturer impact analysis, or MIA.

19 The main purpose of the MIA is to 

20 quantitatively assess the financial impact of 

21 energy conservation standards on manufacturers 

22 of HID Lamps. The MIA also attempts to identify 
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1 any potential manufacturer subgroups whose cost 

2 structure differs significantly from the 

3 industry average. One such common subgroup is 

4 small business manufacturers.

5 And, finally, the MIA attempts to 

6 quantitatively and qualitatively examine other 

7 non-direct financial impacts of energy 

8 conservation standards on manufacturers. These 

9 could include direct employment impact, 

10 manufacturing capacity impact, and a cumulative 

11 regulatory burden impact on manufacturers of 

12 HID Lamps.

13 The methodology for the MIA is 

14 typically performed in three stages which are 

15 explained on this slide. However, the key 

16 output of the MIA is the change in industry net 

17 present value, or INPV which results from 

18 energy conservation standards. 

19 Also during the manufacturer impact 

20 analysis we identified key issues that are 

21 central to manufacturers of HID Lamps, and 

22 during our initial research in the interim 
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1 analysis we discovered these four key issues 

2 that are important to manufacturers.

3 The first manufacturers question, 

4 the actual energy savings from replacement HID 

5 Lamps. Manufacturers believe that new HID Lamp 

6 energy conservation standards may not lead to 

7 significant energy savings, since customers may 

8 replace a failed lamp with a more luminous but 

9 equal wattage lamp, therefore, not reducing the 

10 actual amount of energy consumed.

11 Next, manufacturers are concerned 

12 with the testing burden that could result from 

13 standards. Manufacturers expect new standards 

14 to increase the burden associated with 

15 compliance testing. 

16 Third, manufacturers believe that 

17 alternative technologies such as LEDs and 

18 fluorescent lighting are already eroding the 

19 HID market, and higher prices for HID lamps may 

20 even hasten the switch to these alternative 

21 technologies.

22 And on a related note, manufacturers 
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1 believe that standards for HID Lamps have a 

2 high opportunity cost, and by forcing resources 

3 toward upgrading existing product lines, 

4 manufacturers will have to divert resources 

5 away from products, from product innovation and 

6 emerging technologies such as these LEDs.

7 At this time, I'd like to open the 

8 floor to any comments on the key issues that 

9 manufacturers face for HID energy conservation 

10 standards, or if there's any additional key 

11 issues that would like to be brought up at this 

12 time.

13 MR. BROOKMAN: Why don't you go back 

14 to 74, just to refresh everyone's thinking 

15 about what the Department has identified as key 

16 issues. Additional thoughts on this? Daniel.

17 MR. YOUNG: Daniel Young, California 

18 IOUs. I would just I guess say that that third 

19 bullet doesn't sound like a bad thing, and if 

20 that is, indeed, the case, the Department 

21 should try and account for the savings that 

22 come from a technology shift due to standards.
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1 MR. BROOKMAN: Okay, thank you. 

2 Susan.

3 MS. CALLAHAN: And now I'm back being 

4 NEMA. The -- NEMA will make comments, will 

5 address testing burden in their written 

6 comments, especially in light of there not 

7 being a test rule. 

8 MR. BROOKMAN: Okay, thank you. 

9 MR. COOK: So, and then one more 

10 comment that DOE is seeking comment on. At this 

11 time, DOE is requesting comment on any 

12 potential small business manufacturers of HID 

13 Lamps as this is an important part of DOE's 

14 analysis. So, if there's any manufacturers that 

15 know of potential small business manufacturers 

16 of HID Lamps, this would be a helpful time for 

17 DOE's analysis to identify those players.

18 MR. BROOKMAN: No additional 

19 comments.

20 MR. COOK: Okay. 

21 MR. BROOKMAN: Okay.

22 MR. COOK: At this time, I would like 
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1 to turn it back over to Michael Myer to finish 

2 up with the NOPR analyses.

3 MR. MYER: We spent most of the 

4 morning discussing the interim analysis. This 

5 slide shows what we'll be doing in the NOPR 

6 analysis. I don't know if we said it, but NOPR 

7 stands for Notice of Proposed Rulemaking. It's 

8 the next phase. We'll obviously revise the 

9 interim analysis based on the feedback that we 

10 get today, as well as in written comments, but 

11 then we also do a series of additional 

12 analyses, a customer subgroup analysis, 

13 manufacturer impact analysis which Hayden just 

14 discussed, the utility impact analysis, the 

15 employment impact analysis, the environmental 

16 assessment and emissions monetization, and then 

17 finally a regulatory impact analysis.

18 This slide walks through all the 

19 same things again, just provides a little more 

20 detail, so the customer subgroup analysis, this 

21 looks at what the potential of customers that 

22 could be affected. These are end-users who 
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1 could be disproportionately affected by a 

2 standard, and we'll discuss their item for 

3 comment in a second.

4 Then we also look at utility impact 

5 analysis, and this looks at the effects on 

6 generation capacity of the utilities as the 

7 effect of a standard. Then we also move into 

8 the employment impact analysis. MIA looks at 

9 the direct employment effects, employment 

10 impact analysis looks at the indirect 

11 employment effects on national employment. 

12 We then move into environmental 

13 assessment which actually looks at the effects 

14 on airborne pollutant emissions as a result of 

15 the standard, that's closely related to the 

16 monetization of those pollutants, including 

17 carbon dioxide and nitrogen oxides. 

18 And, finally, we'll do a regulatory 

19 impact analysis which looks at the potential 

20 for non-regulatory approaches to saving --

21 issue number 28, customer subgroups. We've 

22 currently identified a large number of 
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1 potential subgroups. The final analysis in the 

2 NOPR will be a smaller number of potential 

3 subgroups, but we've listed a bunch here, and 

4 we'd also like any feedback of any potential 

5 subgroups that could be disproportionately 

6 affected. These include -- we tend to be 

7 identified high-end retail, grocery, big-box 

8 retail, schools, owners of roadway and street 

9 lighting, et cetera. And I will pause for 

10 comment.

11 MR. BROOKMAN: Thoughts on adversely 

12 affected subgroups?

13 MR. MYER: Moving on to issue 29, the 

14 valuing of airborne emission reductions. TSD is 

15 pretty thorough in this chapter and how the 

16 monetization comes about. Essentially, the 

17 middle section provides a good example. For 

18 carbon dioxide, the most recent interagency 

19 estimates range anywhere from $6.2 to $78.7 per 

20 metric ton, a value, and DOE invites comment on 

21 the approaches for monetizing the emission 

22 savings due to energy conservation standards.
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1 MR. BROOKMAN: Any thoughts on 

2 monetization? No thoughts here, okay.

3 MR. MYER: At this time, I will turn 

4 the presentation to Lucy deButts.

5 MR. BROOKMAN: Daniel?

6 MS. deBUTTS: I just wanted to close

7 basically by saying thank you to everyone who 

8 managed to make it here. I know there's a lot 

9 of meetings going on and a lot of industry 

10 events right now. 

11 We do appreciate all of the input 

12 that we heard today, your interesting ideas, 

13 and any data or any citations to the data 

14 sources that you could provide us with would be 

15 great. Back to Doug.

16 MR. BROOKMAN: Yes, just so thanks to 

17 all of you, a very productive meeting, and 

18 really appreciate the sense of cooperation and 

19 disclosure. Safe travels. I'll see you in the 

20 future. Take care.

21 (Whereupon, the proceedings went off 

22 the record at 11:38 a.m.)
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