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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

+ + + + +

TU ESDAY 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, Publi c 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 A lliance JACK STROK, GE Lighting VICTOR VARGA, GE Lighting DANIEL YOUNG, Energy Solutions/California Investor Owned Utilities

### NEAL R. GROSS
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### ALSO PRESENT:
MICHEL ANDRE CHABANEIX, Navigant Consulting, Inc. MATT CHESTER, Navigant Consulting, Inc. NATASHA COLLINS, Pacifi c 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

ENGINE ERING 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

### NEAL R. GROSS
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### P

- R

- O

- C

- E

- E

- D

- I

- N

- G

- S 1



### (9:03 a.m.) 2


### MR. BROOKMAN: Good morning, 3


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


### of Energy's public meeting on Energy 5


### Conservation Standards: Interim Analysis for 6


### High

- Intensity Discharge Lamps. T oday is 7


### Tuesday, April 2 nd 

### , 2013 here in the Forrestal 8


### Building in Washington, D.C. 9


### My name is Doug Brookman from Public 10


### Solutions in Baltimore, glad to have you here. 11


### Welcome, glad you could make it. 12


### We're going to start with welcoming 13



### remarks from L ucy deButts. 14


### MS. deBUTTS: Good morning, everyone. 15


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


### Doug mentioned the Interim Analysis for HID 17


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


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



### faces , and we'd li ke to

-- we've done a lot of 20


### analyses over this year and want to present the 21



### results that we have and secure remarks on 22

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### that. 1


### And now Doug can go through the 2


### agenda. 3


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


### with introductions. You can get used to turning 5


### these microphones on and off. The little green 6


### diode needs to be illuminated. Please say your 7



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


### and organizational affiliation. 9


### MR. YOUNG: Daniel Young representing 10



### the California Investor

- Owned Utilities. 11



### MR. BROOKMAN: Thank you. 12


### MS. MAUER: Joanna Mauer, Appliance 13


### Standards Awareness Project. 14


### MS. LOWERS: Gina Lowers representing 15


### Eye Lighting International. 16



### MS. CALLAHAN: Susan Callahan 17


### representing OSRAM SYLVANIA and NEMA. 18


### MR. STROK: Jack Strok represen ting 19


### General Electric Company. 20


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


### also representing General Electric. 22

### NEAL R. GROSS
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### MR. ROSENSTOCK: Steve Rosenstock, 1



### Edison Electric Institute. 2


### MS. TIEDEMAN: Jennifer Tiedeman, DOE 3



### General Counsel. 4


### MR. COOK: This is Hayden Cook with 5


### Navigant Consulting. 6



### MR. CHESTER: Matt Chester also with 7


### Navigant Consulting. 8



### MR. WALKER: Matthew Walker with 9


### Navigant. 10


### MS. COLLINS: Natasha Collins, 11


### Pacific Northwest National Laboratory. 12


### MR. MYER: Michael Myer, Pacific 13



### Northwest National La boratory. 14


### MR. BROOKMAN: Again, thank you all 15


### of you for joining us and welcome to those that 16


### are joining us via the web. 17


### All of you received a packet of 18


### information when you checked in this morning. 19


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



### Immediat ely following this agenda review, 21


### there's an opportunity for anybody that wishes 22

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### to make an opening remark or two, brief 1


### statements, summary statements about issues 2


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


### to have an overview and statute, and contex t, 4


### scope, and market assessment, technology 5


### assessment, and then screening analysis, the 6


### format being presentation followed by the 7


### opportunity for question and comment. 8


### We'll take a break midmorning around 9


### about 10:30 or so. Following the midmorning 10



### brea k, engineering analysis, equipment price 11


### determination, and then following on energy use 12


### analysis, markup analysis, lunch midday around 13


### about 11:45 or noonish, and then immediately 14


### following lunch life

- cycle cost and payback 15


### period analysis, shipments anal ysis, national 16


### impacts analyses, interim manufacturer impact 17


### analysis, and then NOPR analyses looking 18



### forward. And then as

-- when we get to it, 19


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


### remarks and then another opportunity for 21


### anybody that wants to make ad ditional comments, 22

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### make sure their issues get covered sufficiently 1



### and on the record. 2


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


### Questions, comments on the agenda? 4


### I'd ask for your consideration, 5


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


### please say your n ame for the record each time 7


### you speak. You don't need to say you r 8


### organizational affiliation name, it's up to 9


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


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


### your cell phones on silent mode, limit sidebar 12



### conversat ions. There'll be a complete 13


### transcript of this meeting available for you 14


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


### you could be concise, share the air time, 16


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


### want to waste anyone's time. 18


### I'll be queuing ind ividuals by name 19


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


### wish to encourage follow

- on comments; that is, 21


### back and forth between individuals in the room, 22

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### sometimes that's very helpful for the 1


### Department to sort through what they want to 2



### find out. 3



### An d for those joining us via the 4


### webinar, glad you could join us. The Department 5


### of Energy is trying hard to make these meetings 6


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


### hope you find this convenient and useful. 8


### If you'd keep your telephones on 9



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


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


### you wish to participate in the conversation 12


### here, either raise a question or offer a 13



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



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


### So, that I believe is the opening 16


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



### deButts. 18


### MS. deBUTTS: All right. So, Doug 19


### went through webinar access. Don't really have 20


### anything to add to that. 21


### So, the purpose of today's public 22

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### meeting is to pre sent the HID Standards

-- 1


### present the standards DOE is considering for 2


### HID Lamps. We also have

-- want your input on 3


### the analysis that we are going to be 4


### presenting. 5


### We're going to show you the next 6


### steps that the Department is planning on 7


### taking, and the n, of course, invite your 8


### comments and any data you have to help us to 9


### better our analyses. That would be great. 10


### Throughout the presentation you will 11


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


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



### issues that ar e most relevant. 14



### The entire document is available 15


### online. The presentation is available online. 16


### If you

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


### of course, I just wanted to highlight the fact 18


### that we extended the public

-- the submission 19


### of the comment per iod. The document was signed 20


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


### Federal Register shortly but, you know, it's 22

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### been signed, so May 17 th 

### is the new date for 1


### submitting public comments. So, the request 2


### came in and we accommodated the request. 3



### Hope fully, it's going to be useful for 4



### everyone. 5


### And on the next slide you can see 6


### how you can submit the public comments. We ask 7


### you that you mention the rulemaking by title, 8



### also include docket number and RIN number in 9


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


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


### by Post Office or courier to Department of 12


### Energy. And, once again, May 17 th 

### is the new 13



### deadline. 14


### And that's basically it for me. Back 15



### to Doug. 16


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


### outset, now is a n opportunity for anybody that 18


### wants to make opening remarks, zeroing in on 19


### issues that matter to you here at the outset. 20



### Steve Rosenstock. 21



### MR. ROSENSTOCK: Steve Rosenstock, 22

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### Edison Electric Institute. Sorry I won't be 1


### able to stay for the whole day, jus t massive 2


### numbers of meetings and other projects going 3


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


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


### couple of issues out. 6


### Edison Electric Institute represents 7



### investor

- owned utilities throughout the United 8



### States, some of which you have outdoor lighting 9


### programs. And we are using advanced 10


### technologies for these outdoor lighting 11


### fixtures that we own, operate, and maintain for 12



### localities. 13


### One thing I noticed throughout the 14


### technical support document and the present ation 15


### is the thought or the

-- I'll say the 16


### assumption that mercury vapor as a valid 17


### baseline for many wattage categories. 18


### I think that as we go through this, 19


### mercury vapor tech lamps, especially, in my 20


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



### baseline t echnology for the following reason. 22

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### Federal law, EPAct 2005 banned the manufacture 1


### and import of mercury vapor ballast since 2


### January 1 st 

### , 2007, except for the specialty 3


### applications that you've listed in this 4


### document. Therefore, at least from utilities' 5



### p erspective, none of them are spec

- ing out 6


### mercury vapor fixtures for their streetlights. 7


### When an old mercury vapor fixture burns out, 8


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


### halide, or high

- pressure sodium, or LED. 10


### So, I've looked through the docum ent 11


### and it seems like mercury vapor is seen as a 12


### "baseline" in various wattage categories, and 13


### from a market, and from an economic point of 14


### view that really doesn't make sense because of 15



### other federal laws. 16


### I think by using mercury vapor as a 17



### baseline it will distort the economic analysis, 18



### it will distort the results because it's 19


### clearly

-- except for the specialty 20


### applications, it is not an option for any end

21


### user. The only thing you use mercury vapor 22

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### lamps for is for replacements of old fixtures. 1



### Once t he old ballasts die, the end

- user, 2


### regardless of the application will have to 3


### replace it with a new type of high efficacy 4


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


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


### discussed later today, but I just want to pu t 7


### that on the table because, unfortunately, I 8


### have to leave early. Thank you very much for 9


### your time. 10


### MR. BROOKMAN: Thank you, Steve. 11



### Other comments here at the outset? No 12


### additional comments. Okay. 13


### All of you received the packet of 14



### information. As I s aid, these PowerPoint slides 15


### provide the basis for both presentation and to 16


### queue specific comments, so let's proceed with 17



### the slides. 18


### MS. deBUTTS: All right. So, Navigant 19



### Consult ing and PNNL are going to be helping us 20


### with the presentation. Currently, Matt Chester 21


### will be presenting on the scope and the 22

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### overview of this rulemaking. 1


### MR. CHESTER: Good morning. Once 2


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


### Navigant. 4


### As regulatory background, the Energy 5


### Policy Conservation Act of 1975 or EPCA 6



### estab lished the Energy Conservation Standards 7


### Program. The Energy Policy Act of 1992, or 8


### EPAct 1992, amended EPCA and added HID Lamps as 9


### covered equipment, and required DOE to 10


### determine if standards for HID Lamps would be 11



### beneficial. 12


### A positive final determin ation that 13


### standards for HID Lamps would likely result in 14


### significant energy savings began the rulemaking 15



### process. 16


### A rulemaking has four main stages. 17


### DOE began the process for HID Lamps in February 18


### 2012 with the publication of the framework 19



### document. The n on February 28 th 

### , 2013, DOE 20


### published a Federal Register Notice announcing 21


### this Interim Analysis meeting wherein DOE 22

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### presents its initial analytical results. Later 1


### this year, DOE plans to publish a notice 2


### proposing a standard and hold another meeting 3



### to receive feedback on that proposal. The 4


### projected final rule arrives in July 2014 with 5


### a projected compliance date of July 2017. 6


### Between now and completion of the final 7


### rule in 2014, DOE will consider these seven 8


### factors in its analysis. Economic impacts on 9



### individual consumers are considered in the 10



### Life

- Cycle Cost Analysis. Economic and energy 11


### savings impacts to the nation as a whole are 12


### considered in the National Impact Analysis, and 13


### economic impacts on manufacturers are 14



### considered in the Manufacturer Im pact Analysis. 15


### DOE also considers impacts on utility or 16


### performance and any other factors the Secretary 17



### considers relevant. 18


### I'm going to start with looking at 19


### the scope which describes the HID Lamps for 20



### which DOE will consider standards. When 21


### referring to high

- intensity discharge lamps, we 22

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### are talking about the family of lamps that 1


### include mercury vapor, high

- pressure sodium, 2


### and metal halide. Within these lamp types, DOE 3


### assessed which lamps had potential for 4


### significant energy savings and for which 5



### st andards were both technologically feasible 6


### and economically justified. 7


### Since not every subset of HID Lamps 8


### will meet these criteria, DOE is considering 9


### only certain ranges of commercially available 10


### wattages and correlated color temperatures, or 11



### CCTs. The wattages and CCTs for which DOE is 12


### not considering standards are chosen because 13


### they represent a small market share and, thus, 14


### do not represent significant potential energy 15


### savings. 16


### This table shows the summary of the 17


### wattage and CCT ranges for which DO E is 18


### considering energy conservation standards. In 19


### addition, DOE has identified subsets of HID 20


### Lamps that while they fall into these wattages 21


### and CCTs, DOE has specifically chosen not to 22

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### consider standards for them. 1


### Most of these lamps for which DOE is 2



### n ot considering standards are the same types of 3


### lamps mentioned in the framework document. DOE 4


### is not considering standards for directional 5


### HID Lamps, self

- ballasted HID Lamps, HID Lamps 6


### advertised as an intended for use exclusively 7



### with electronic ballasts , pulse

- start metal 8


### halide lamps with a CRI greater than or equal 9


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


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


### specialty application mercury vapor lamps, and 12


### electrodeless HID lamps. 13



### DOE now invites comment on the 14


### following topics. For metal halide lamps, DOE 15


### found that lamps with a CRI greater than or 16


### equal to 95 could not reach the same levels of 17


### efficacy as lower CRI lamps. DOE did not 18


### consider lamps for

-- standards for pulse

- start 19


### metal halide lamps wit h a CRI greater than or 20


### equal to 95, and DOE requests comment on this 21



### determination. 22

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### MR. BROOKMAN: Yes, please. Susan. 1



### MS. CALLAHAN: Susan Callahan. NEMA 2


### supports high CRI product exemption

-- 3


### MR. BROOKMAN: Susan, would you move 4


### that just a little closer? Thank you. 5


### MS. CALLAHAN: NEMA supports high CRI 6


### product exemptions to harmonize and parallel 7


### with the GSFL rulemaking. NEMA supports not 8


### having efficiency standards for metal halide 9


### lamps with CRI greater or equal to 87 rather 10



### than 95. 11



### MR. BR OOKMAN: Okay, thank you. Steve 12



### Rosenstock. 13



### MR. ROSENSTOCK: Steve Rosenstock, 14



### EEI. I think that

-- well, first a question, 15



### then a comment. 16


### What kind of efficacy levels were 17


### you finding with those lamps, just out of 18


### technical curiosity? 19



### MR. CHESTER: I don't remember the 20


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


### do know it was significant enough that any 22

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### potential efficacy level we set, the high CRI 1


### lamps would have fallen underneath it. 2


### MR. ROSENSTOCK: Right. 3


### MR. CHESTER: So, we were just hopi ng 4


### to preserve the utility of those high CRI 5


### lamps. 6



### MR. ROSENSTOCK: Steve Rosenstock, 7


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


### that that does raise an issue, especially 9


### because of product competition. And I 10


### appreciate the comment from NEMA, is that wh en 11


### you look at the marketplace and you look at the 12


### features, think about it from a customer 13


### perspective, especially from a retail point of 14


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


### desirable feature, especially in retail, 16


### specialty retail, and general retai l 17


### applications. 18


### And I think that as these products 19


### get on the marketplace, I think that, 20


### obviously, because of what

-- the competitive 21


### issues, it is going to be an issue. But the 22

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### other thing, also, to consider, also, is even 1



### at their

-- I'll say their re duced efficacy 2


### levels compared to other high

- pressure -- 3



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


### higher efficacy than other technologies that 5


### they're competing with, such as incandescent, 6


### such as halogen, such as possibly compact 7


### fluorescent dependin g on where that lumen per 8


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


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



### because of the fact that it is a feature that 11


### should not be eliminated from the marketplace. 12


### Thank you. 13


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



### Add itional comments on issue number one? 15



### MR. WALKER: This is Matthew Walker 16


### from Navigant. Sorry about the scratchy 17


### microphone. 18


### I would just ask

-- curious if, 19


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


### reasoning for the 87 CRI limit that would be 21



### usefu l for going forward with DOE's rulemaking. 22

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### MS. CALLAHAN: That will be addressed 1



### in our written comments. 2


### MR. BROOKMAN: But just to clarify, 3


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


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



### up. 6



### MS. CALLAHAN : Yes, it is. 7


### MR. BROOKMAN: Thank you. Okay. Just 8


### to clarify. Daniel. 9


### MR. YOUNG: Daniel Young, California 10


### Utilities. Did DOE consider maybe using CRI as 11


### a product class delineator to set reduced 12


### standards for these lamps? 13



### MR. CHESTER: We did look at that as 14


### a possibility but found that

-- I mean, this 15


### instance of pulse

- start metal halide lamps with 16


### a CRI greater than 95 was sort of the only 17



### instance we saw that the CRI affected the 18


### efficacy, so we found it more appropriate at 19


### this point just to not co nsider standards for 20


### those lamps. 21


### MR. BROOKMAN: Okay? 22

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### MR. YOUNG: Thanks. 1


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


### MR. CHESTER: Okay. Next, DOE 3


### considered adopting the EU definition of white 4


### light, but instead determined that a colored 5



### metal halide la mp could be effectively defined 6


### by its CRI. DOE requests comment on this 7


### conclusion and whether using the EU definition 8



### would be beneficial. 9



### MR. BROOKMAN: Susan. 10



### MS. CALLAHAN: Harmonization with 11


### international standards is always preferable, 12



### and NEMA r ecommends the adoption of the EU 13


### definition of white light in this case. 14


### MR. BROOKMAN: And can you say is it 15


### just harmonization alone, or are there other 16



### issues? 17


### MS. CALLAHAN: It's mostly 18



### harmonization. 19


### MR. BROOKMAN: Okay, thank you. 20



### Additional comm ents here? 21


### MR. CHESTER: Okay. Lastly, DOE is 22

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### aware of specialty applications that can only 1


### be served with mercury vapor lamps and not any 2



### other HID or solid

- state technologies because 3


### of the UV light output of mercury vapor lamps. 4



### DOE requests comment on excluding individually 5


### labeled specialty application mercury vapor 6


### lamps from consideration for standards. 7



### MR. BROOKMAN: Steve Rosenstock. 8



### MR. ROSENSTOCK: Steve Rosenstock, 9



### EEI. To follow

- up on my earlier comments, these 10


### are the only types of mercury vapor fixtures 11



### that can include new ballasts because of 12



### federal law. That was E I SA 2007. 13


### With many of these applications I 14


### think you have it right that these are 15


### specialty applications. In many cases, they're 16


### going to be limited times of use except for the 17


### ultraviolet curing, possibly, with water 18


### treatment type of plants. Many of these will 19


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


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


### so any efficacy standard will have a very, very 22

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### long payback. And I think this makes a lot of 1



### sense. 2


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


### to receive affirmative comments, as well. 4



### Susan. 5


### MS. CALLAHAN: Thank you. NEMA agrees 6


### with DOE on excluding specialty and mercury 7


### vapor lamps from the scope of this rulemaking. 8



### However

-- 9


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


### your microphone on? 11


### MS. CALLAHAN: Yes, it is now. 12


### MR. BROOKMAN: Okay, thank you. 13



### Please. 14


### MS. CALLAHAN: Okay. NEMA agrees with 15


### DOE on excluding specialty mercury vapor lamps 16


### from the scope of this rulemaking. Howe ver, we 17


### disagree with DOE's assertion that the 18


### specialty lamps are currently labeled for the 19


### intended application. Manufacturers have 20


### limited to no knowledge of who the end

- user is, 21


### or the intended application so that the label 22

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### cannot be a determining fact or here. 1


### MR. CHESTER: Could you then comment 2


### on maybe how you would define the specialty 3


### application, because this is sort of where 4


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


### the specialty application and had what that 6


### application was, and that was ho w we would 7


### potentially define those lamps. 8


### MS. CALLAHAN: Well, I guess our 9


### point would be that for a given number of end

10


### users that a particular lamp could be used for 11


### a UV curing application. It could be used for 12


### photo resist, it could be used for any 13



### a ppropriate type of technology. And when we 14


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


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


### other types of lamps, you know, the display 17


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


### it may be a little more obviou s, but for some 19


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


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


### specialty application label you wouldn't know 22

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### where it might end up, and what the use would 1



### be. 2



### MS. CALLAHAN: Correct. 3


### MR. BROOKMAN: I see. So, in tha t 4


### respect the specialty application label would 5



### not be sufficient. 6



### MS. CALLAHAN: Correct. 7


### MR. BROOKMAN: Okay. Additional 8


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


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


### and hopefully we can hear you in the room. 11


### MR. LEE: Hi, I was just requesting 12


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


### really inaudible on the webinar. MR. 14


### BROOKMAN: Susan, hit your button again and try 15



### -- say something to us. 16


### MS. CALLAHAN: Good morning. 17



### MR. BROOKMAN: Can you hear her now 18



### because she's

-- we can hear her in the room. 19


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


### much, much lower than everyone else who's 21


### speaking. 22

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



### on that, John. Thanks for cu e ing us to that 2


### since she's speaking on beha lf of NEMA. Okay, 3


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


### we're going to proceed. 5



### MR. CHESTER: DOE also invites 6


### comment on these topics. DOE determined that 7


### electrodeless HID Lamps meet the EPCA 8


### definition of an HID Lamp. However, based on 9



### their small market share and lack of test 10


### method, DOE is not considering standards for 11


### electrodeless HID Lamps. 12


### DOE requests comment on this 13



### determination and whether additional 14


### information is necessary to define this 15



### exclusion. 16


### MR. BROOKMAN: I'm just catching up 17


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


### mouth. Yes, thank you. 19



### MS. CALLAHAN: See if this works 20



### better. 21



### MR. BROOKMAN: Yes. 22

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### MS. CALLAHAN: NEMA agrees with DOE 1


### on excluding electrodeless HID Lamps from the 2


### scope of this rulemaking, that they truly are a 3


### niche product. 4


### MR. BROOKMAN: Thank you. No 5



### additional comments. 6


### MR. CHESTER: Okay. And then overall, 7


### DOE welcomes comment on any other aspect of the 8



### scope. 9



### MR. BROOKMAN: Susan. 10


### MS. CALLAHAN: NEMA agrees with DOE 11


### on excluding directional HID Lamps, self

12


### ballasted HID Lamps, HID Lamps for use with 13


### electronic ballast only, pulse

- start metal 14


### halide lamps with CRI greater than 87, colored 15


### metal halide lamps, and HID Lamps intended for 16


### specialty applications, and electrodeless HID 17


### Lamps from the s cope of this rulemaking. 18


### However, HPS Lamps with CCT greater than or 19


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



### 2700 Kelvin should be excluded from the 21


### rulemaking. These lamps only operate during 22

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### off

- peak load times. There are currently no 1


### lamp techno logies with higher efficacies in 2


### production, and the technology option proposed 3


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


### meet DOE's screening criteria. 5


### We've already talked about the 6


### labeling comments. We would suggest that at a 7


### minimum the lamps produced for use in specialty 8


### applications would be the following products, 9


### and be exempt due to their specialty nature; UV 10


### curing, photoprinting, pet, aquarium, 11


### aquiculture, solar panel processing, materials 12


### testing, horticultural, high

- definition 13



### televi sion, sports, film, institutional and 14


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


### which is not quite an exhaustive list, but 16



### close. 17


### MR. BROOKMAN: And in your written 18



### comments. 19



### MS. CALLAHAN: We will be more 20


### exhaustive, yes. 21


### MR. BROOKMAN: Yes, good. Thank you. 22

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### Joanna. 1



### MS. MAUER: Joanna Mauer. Just a 2


### question related to the possible exemption for 3


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


### not familiar with how the current exemption is 5


### working for the specialty mercury vapor 6



### ballasts. Are those

- - are mercury vapor -- are 7


### those exempted ballasts labeled for a specific 8


### application? 9


### MS. CALLAHAN: I know that they are 10



### labeled, but I could not

-- I can't speak to 11


### exactly how they're labeled. 12



### MR. BROOKMAN: I see that Michael 13


### Myer is ready. 14



### MR. M YER: Michael Myer, Pacific 15


### Northwest National Laboratory. I believe the 16


### word is they're labeled specialty application 17


### period, not what the defined application is. 18


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


### said, they could be used for

-- the same lamp 20



### coul d be used for two different specialty 21


### applications, so it's not predefined what it 22

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### is. It just says "specialty application," and 1


### that's how it's exempted. 2



### MR. BROOKMAN: Additional comments 3



### here? 4


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


### move on to looking at the market and technology 6


### assessment and the screening analysis. Here is 7


### an expansion of the interim analysis stage, our 8


### current stage, and the analyses that comprise 9


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



### assessment. 11


### The market and technology as sessment 12


### serves two main functions, to determine 13


### equipment classes and to identify technology 14


### options that improve efficacy. The screening 15


### analysis takes the technology options 16


### identified in the technology assessment and 17


### screens out options that DOE will n ot consider 18


### in the engineering analysis. Those that do not 19


### get screened out proceed to get analyzed as 20


### design options in the engineering analysis. 21


### Equipment classes are the first 22

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### output of the market and technology assessment. 1


### An equipment class establi shes a category of 2


### lamps that will be subject to the same 3


### standard. In considering how to group equipment 4


### classes, DOE considers the type of energy used, 5


### the capacity of the product, and other 6


### performance

- related features that affect 7


### consumer utility. 8



### In the framework document, DOE 9


### outlined equipment classes on the basis of CCT 10


### and initial light output. Based on stakeholder 11


### feedback and further analysis, DOE has instead 12


### decided to separate equipment classes in the 13


### interim analysis on the basis of CCT, wat tage, 14


### bulb finish, and luminaire characteristic. 15


### The first equipment class

- setting 16



### factor we'll discuss is correlated color 17


### temperature or CCT. Customers purchase specific 18


### color temperature lamps for their desired 19


### application. For example, high

- pressure sodium 20


### lamps have the lowest CCT among HID Lamps, and 21


### are thus used in applications where the color 22

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### appearance of objects may be less important. 1


### DOE has also found that changes in 2


### CCT correspond with efficacy; that is, lamps 3


### with lower CCT typically ha ve higher efficacy. 4



### Because DOE was able to conclude that CCT 5


### impacted both consumer utility and efficacy, 6


### DOE is considering establishing separate 7


### equipment classes for different CCT ranges. 8


### Next, DOE looked at the potential of 9


### using wattage as a class

- setting factor. When 10


### considering lamp input powers and light 11


### outputs, DOE found that increased wattage was 12


### directly correlated with increased light 13


### output. Because an increase in one directly 14


### indicates an increase in the other, DOE found 15


### it necessary to o nly use one of these 16


### characteristics as a potential class

- setting 17



### factor. 18


### In deciding between the two, DOE 19


### found that manufacturers use wattage to 20


### categorize their product families and catalogs 21


### instead of light output. This distinction makes 22

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### wattage the more suitable equipment class

1


### setting factor. 2


### Consumer preferences vary by 3


### application, but the light output and, thus, 4


### wattage needs are often dictated by the 5


### distance between the HID Lamp and the surface 6



### to be lit. 7


### Manufacturer catalog data also 8



### in dicated that an increase in wattage directly 9


### correlated with increased efficacy. Because DOE 10


### was able to conclude that wattage impacted both 11


### consumer utility and efficacy, DOE is 12


### considering separating equipment classes based 13



### on wattage. 14



### DOE also examine d using bulb finish 15


### as an equipment class

- setting factor. When 16


### analyzing manufacturer catalogs, we found that 17


### commercially available HID Lamps were available 18


### with a clear bulb finish, or a variety of 19



### finishes that were not clear. The terms used 20



### for non

- cle ar lamps included coated, diffused, 21


### frosted, white, and deluxe white. In our 22

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### analysis, we decided to look at clear versus 1



### non - clear lamps with all non

- clear lamps 2



### considered under the term coated. 3


### When lamps are coated, it is to 4


### reduce glare. Coated lam ps are used in the 5


### specific applications where glare would be 6


### undesirable. The other result of a lamp being 7


### coated, however, is that they are less 8


### efficacious because the coating blocks some of 9


### the visible light from passing through the 10


### outer bulb envelope . Due to this impact on both 11


### consumer utility and lamp efficacy, DOE is 12


### considering establishing separate equipment 13


### classes for clear versus coated lamps. 14


### The last equipment class

- setting 15


### factor we'll be discussing is luminaire 16



### characteristic. Luminaire characteristic 17


### indicates if a lamp is tested for and approved 18


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



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


### only in closed fixtures, thus making it an 21



### enclosed

- rated lamp. 22

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### In order to be approved as open

1



### r ated a lamp must, among other things, contain 2


### a glass shroud around the arc tube as 3


### protection in the event of arc tube rupture. 4


### While an open

- rated lamp has a distinct utility 5


### that it can be used in open fixtures the glass 6


### shroud also reduces lamp efficac y by blocking 7


### some of the lamp's visible light. 8


### Because of the impact that luminaire 9


### characteristic has on consumer utility and lamp 10


### efficacy, DOE is considering establishing 11


### separate equipment classes for these two 12



### luminaire characteristics. 13



### This table summarizes the 28 14


### equipment classes that result when separating 15


### lamps based on the class

- setting factors 16


### discussed. Each of these equipment classes 17


### could be subject to different standards. All 18


### commercially available high

- pressure sodium 19


### lamps that DOE fou nd are in the 1900 to 2800 20


### Kelvin CCT range. The metal halide and mercury 21


### vapor lamps are virtually all found in the 22

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### higher two CCT ranges. 1


### The division of wattage ranges shown 2


### here reflects the availability of certain lamp 3


### technologies. For example, ce ramic metal halide 4


### lamps are predominantly found in the 50 to 400 5


### watt range, and probe

- start metal halide lamps 6


### are the only ones found above 1000 watts. 7


### After establishing the CCT and wattage ranges, 8


### DOE created an equipment class for each 9



### combination o f bulb finish and luminaire 10


### characteristic within each wattage and CCT 11



### combination. 12


### With that said, DOE invites comment 13


### on several issues specific to equipment 14


### classes. DOE is defining coated lamps as all 15


### lamps that are not clear, since the terms 16



### coated , diffused, frosted, white, and deluxe 17


### white all typically represent the same or 18


### nearly the same bulb finish within a lamp type. 19



### DOE invites comment on this definition of 20


### coated lamps. 21



### MR. BROOKMAN: Susan. 22

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### MS. CALLAHAN: NEMA agrees with DOE's 1



### definitio n of coated lamps. 2


### MR. BROOKMAN: Thank you. Additional 3


### comments here? Okay. 4


### MR. CHESTER: Okay. Next, when 5


### separating metal halide lamp equipment classes 6


### according to luminaire characteristic, DOE 7


### considered open

- rated, en closed

- rated, and S

8


### rated lamp s. DOE requests comment on the 9


### separation of equipment classes by luminaire 10


### characteristic, as well as the application of 11



### F

- rated lamps and how they should be 12


### categorized within this equipment class 13



### structure. 14



### MR. BROOKMAN: Susan. 15



### MS. CALLAHAN: NEMA ag rees with DOE's 16


### proposal to separate equipment classes by 17


### luminaire characteristic, and to put the /E and 18


### /S lamps together. NEMA membership includes 19


### manufacturers of /F luminaire code lamps. NEMA 20


### believes that lamps with the /F luminaire code 21



### should be ex cluded from the rulemaking. 22

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### MR. CHESTER: Can you explain why 1


### they should be excluded? 2


### MS. CALLAHAN: The /F

- rated lamps are 3



### double

- ended lamps. They're a specialty lamp 4


### usually used in sports lighting fixtures. They 5



### are double

- ended. The fixture that is required 6


### of them is both mechanically and electrically 7


### interlocked because these lamps have no outer 8


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


### MR. BROOKMAN: Okay. Additional 10



### comments on item on number 9? 11


### MR. CHESTER: All right. Lastly, DOE 12



### invite s any other comments on equipment 13



### classes. 14



### MR. BROOKMAN: Susan. 15


### MS. CALLAHAN: Again, NEMA believes 16


### that HPS Lamps with CCT greater than or equal 17


### to 1900 and less than or equal to 2700 Kelvin 18


### should be excluded from the rulemaking. This

-- 19



### the concern i s about the testing and reporting 20


### burden of this large number of very long

- life 21


### lamps. 22

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### MR. BROOKMAN: You can see the 1


### equipment classes listed there in issue number 2


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



### Joanna. 4


### MS. MAUER: Joanna Mauer. Susan, i f I 5


### could ask you a question. The F

- rated lamps 6


### that you were mentioning, is there some 7


### inherent difference in efficacy compared to the 8


### other types of lamps? 9



### MR. BROOKMAN: Susan. 10


### MS. MAUER: Or could they

-- are they 11



### not able to achieve the same efficac y as other 12



### -- 13


### MS. CALLAHAN: I would have to go and 14


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


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


### DOE have any information on shipments of those 17



### F

- rated lamps? 18


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



### on that, but we would welcome any data that 20


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


### MR. BROOKMAN: Yes, Daniel. 22

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### MR. YOUNG: Daniel Young. Another 1


### question for Susan. So, the

-- you're proposing 2


### to exempt the HPS product class, basically, and 3


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


### difference at all in efficacy between lamps of 5


### different manufacturers or different quality 6


### lamps that

-- where there might actually be a 7


### difference in efficacy for the same kind of 8


### technology class. 9



### MR. BROOKMAN: Susan. 10



### MS. CAL LAHAN: I'm not sure that 11


### that's something that NEMA would be able to 12


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


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



### Michael. 15


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


### want to clarify the definition for mercury 17


### vapor specialt y ballast for Joanna. I looked it 18


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


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


### marketed for operation of mercury vapor lamps 21


### used in quality inspection, industrial 22

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### processing, or scientific use, including 1



### fluorescent microscopy and UV curing. And, two, 2


### in the case of a specialty mercury vapor 3


### ballast, the label which, one, provides that 4


### the specialty application is for specialty 5


### purposes, not for general illumination. And, 6


### two, specifies the specific application for 7



### wh ich the ballast is defined." 8



### MR. BROOKMAN: Joanna. 9


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



### MR. BROOKMAN: Me, too. 11


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


### I think the critical detail that I was trying 13


### to provide you is that I think in the second 14


### part of that definition it says it does have to 15


### specify, at least the sub

-- Roman Numeral 16



### 2 (i i ) says "specifies the specific application 17



### for which the ballast is defined." 18


### MS. MAUER: Okay. 19


### MR. MYER: But I would refer you to 20


### the Code of Federal Regulations for the exact 21


### wording as I read it here, but it is a lot of 22

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### words. 1



### MS. MAUER: This is Joanna. If I 2


### could ask a simple question. These mercury 3


### vapor ballast designed for these specialty 4


### applications, is there any physical difference 5


### compared to other mercury vap or ballasts for 6


### general applications? In other words, is it 7


### just the intended application, not anything

-- 8


### not any difference

-- the physical ballast 9


### could be used in a general mercury vapor 10


### application. 11


### MR. WALKER: I think this did come up 12



### in the framewo rk meeting also, and I think the 13


### feedback was that the ballasts are very 14



### similar. 15


### MR. BROOKMAN: That was Matt. Right? 16


### MR. WALKER: Sorry, this is Matthew 17


### Walker from Navigant. Right. 18


### MR. BROOKMAN: Okay. 19



### MR. WALKER: The ballasts are similar 20



### but the y're labeled differently. 21


### MR. BROOKMAN: You may have stumped 22

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### our panel. We'll see. 1


### MS. MAUER: If I could just ask one 2



### more follow

- up question. Does DOE have any 3


### information on kind of how this exemption has 4


### worked in practice, and whether there's

-- it's 5


### been a loophole at all, whether there are 6


### customers that are purchasing these ballasts 7


### that are designed and marketed for specialty 8


### applications that are being used in general 9


### lighting applications? 10


### MR. MYER: This is Michael Myer. I 11


### don't want to pr eview my slide too much, but 12


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


### decline, and you can actually see a little bit 14


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


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


### been declining for

-- since the mid `9 0s, but 17


### you can kind of see a change in trajectory from 18



### when the rule went into effect. 19


### MS. MAUER: Thank you. 20



### MR. BROOKMAN: Additional comments 21


### here? Okay. 22

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### MR. CHESTER: DOE identified a number 1


### of technology options that can be used to 2


### improve effica cy. Mercury vapor lamps are 3


### already being phased out by manufacturers and 4


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


### reasons, the technology options available for 6


### mercury vapor lamps simply consist of changing 7



### t o high

- pressure sodium or metal halide 8



### tec hnology. 9


### For metal halide lamps, DOE found 10


### that the three available technology options 11


### were to change from quartz arc tubes to ceramic 12


### arc tubes, to optimize the shape of the arc 13


### tubes to increase efficacy, or to change from 14


### probe

- start technology to pul se - start 15


### technology. 16


### When looking at the technology 17


### options for high

- pressure sodium lamps, DOE 18


### found that all high

- pressure sodium lamps 19


### commercially available were using the same 20


### technology and did not find any variation in 21


### technology or design that wa rranted a 22

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### technology option. 1


### Due to this, DOE investigated other 2


### options and found that in the past, there have 3


### been lamps manufactured with arc tubes made out 4


### of sapphire instead of the standard 5


### polycrystalline alumina. The improved light 6



### transmission c haracteristics of the sapphire 7


### material would result in increased efficacy. 8


### DOE is considering whether this option might be 9


### a feasible means of improving the efficacy of 10


### high

- pressure sodium lamps. All these 11


### technology options are considered further in 12



### the screening analysis. 13


### DOE invites comment on the following 14


### issues with regard to the market and technology 15


### assessment. DOE requests comment on the 16


### technology options presented, in particular, 17


### the high

- pressure sodium sapphire arc tube 18


### technology. 19



### MR. B ROOKMAN: Susan. 20


### MS. CALLAHAN: In regard to the 21


### technological feasibility, yes, sapphire lamps 22

### NEAL R. GROSS
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### were evaluated by industry in the 1970s. It is 1


### not obvious at this point in time how those arc 2


### tubes were fabricated, but they may have been 3



### cored from a bull r ather than continuously 4


### pulled. From a lamp perspective, the technology 5



### was deemed not to be feasible. From the 6


### practicability to manufacturer install and 7


### service, commercially available sapphire tubing 8


### has limited selections of ID/OD combinations 9



### which ar e not necessarily amenable to lamp 10


### design and fabrication. 11


### Changing the draw axis is not 12


### technologically feasible because the tube 13


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


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


### but not an O. New sealing technologie s would 16


### need to be developed and the probable use of 17


### PCA end plugs would reduce the light output. 18


### In terms of the adverse impacts on 19


### product utility or product availability, the 20


### draw axis is not mechanically stable, twinning 21


### will occur with respect to lamp operation. 22

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### Twinning can result in catastrophic failure of 1


### the lamp during operation. Also, these are very 2


### long

- lived lamps which would require 3


### significant life testing before being brought 4



### to market. 5


### Adverse impacts on health or safety. 6



### Metal halid e lamps have the possibility of arc 7


### tube rupture. Sapphire arc tubes have the 8


### probability of rupture, as well as cracking due 9


### to manufacturing defects, especially 10


### inclusions, voids, and low

- angle grain 11


### boundaries. Additionally, HPS lamps today are 12


### /O

- rate d, leading either to a safety issue with 13


### direct replacement with unprotected sapphire 14


### technology, or a containment construction which 15


### increases lamp cost and reduces lumen output. 16


### MR. BROOKMAN: Thank you. 17


### MR. CHESTER: Okay. DOE also requests 18


### any othe r comments on the market and technology 19



### assessment. 20



### MR. BROOKMAN: Joanna. 21


### MS. MAUER: Joanna Mauer. Maybe if I 22

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### could just pose Daniel's question to DOE, which 1


### was did DOE evaluate whether there's any 2


### significant difference in efficacy, for 3


### example, with in currently available HPS lamps, 4


### or within currently available pulse

- start metal 5


### halide lamps? 6


### MR. CHESTER: Within the high

7


### pressure sodium lamps we didn't find any 8


### notable difference in efficacy across 9


### manufacturers when looking at the data, which 10



### is w hy we went to looking for the other 11


### technology options possible. 12


### MS. MAUER: And within metal halide, 13


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


### you look at within

-- I don't know how to

-- 15



### non - quartz

-- 16


### MR. CHESTER: The quartz arc tubes? 17



### MS. MAUER : Yes. 18


### MR. CHESTER: Yes. Well, the only 19


### technology options we found there were to go 20


### from probe

- start lamps to pulse

- start lamps, 21


### and then specifically designing the arc tube to 22

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### increase the efficacy of the fill gas. It's 1


### found to increase the efficacy, but those three 2


### options that we presented are

-- including the 3



### ceramic arc tube are the three that we found. 4


### MS. MAUER: Okay. 5



### MR. BROOKMAN: No additional 6



### comments. 7


### MR. CHESTER: Okay. In the screening 8


### analysis, technology options are screened on 9



### the basis of four criteria; technological 10


### feasibility, practicability to manufacture, 11


### install, and service; adverse impacts on 12


### product utility or availability to customers; 13


### and adverse impacts to health and safety. 14


### With the exception of the sapphire 15



### arc tube high

- pressure sodium lamps, DOE has 16


### determined that all of the technology options 17


### meet the screening criteria and, thus, will not 18


### be screened out. Sapphire arc tube high

19


### pressure sodium lamps have previously been 20


### manufactured at a commercial scale, though they 21


### are not made today. Because DOE has thus far 22

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### been unable to ascertain the reason for the 1


### discontinuance of sapphire arc tubes, DOE is 2


### still considering them as a potential design 3


### option. 4



### DOE invites comment on whether the 5


### technology options and, i n particular, sapphire 6


### arc tube technology meet DOE's screening 7



### criteria. 8


### MR. BROOKMAN: I guess we've already 9


### heard a fair amount about sapphire technology 10


### but, Susan, do you want to continue to 11


### illuminate further, to use

-- a word. You said 12


### what you wa nt to say about sapphire arc tube 13


### technology. 14


### MS. CALLAHAN: I would just like to 15


### reiterate the safety aspect of sapphire arc 16


### tubes in terms of lamp operation. 17


### MR. BROOKMAN: Okay. Additional 18


### thoughts, comments here? 19


### MR. CHESTER: I think we originally 20



### had a break scheduled here. 21


### MR. BROOKMAN: We're going to keep 22

### NEAL R. GROSS
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### going right now. 1


### MR. CHESTER: Keep going? 2



### MR. BROOKMAN: Yes. 3


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


### introduce and pass of to my colleague, Matthew 5



### Walker. 6


### MR. WALKER: All right. Good morn ing, 7


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


### from Navigant. 9


### I'm going to get started with the 10


### Engineering and Equipment Price Determination. 11


### So, in short, the engineering analysis 12


### establishes potential standard levels and lamp 13


### performance at those levels, setting a 14


### framework for analyzing lamp prices and the 15


### equipment price determination. And then later 16


### analyzing impacts on customers, manufacturers, 17


### and the nation, and the later downstream 18


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


### So, this sli de gives an overview of 20


### the methodology used in the engineering 21


### analysis. DOE begins by choosing equipment 22

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### classes to be directly analyzed which it calls 1


### representative equipment classes. 2


### Next, DOE defines characteristics of 3


### baseline lamps in each equip ment class. This is 4


### followed by identifying more efficacious 5


### substitute lamps for each baseline lamp, and 6


### then developing candidate standard levels that 7


### correspond to the range of efficacy from 8


### baseline to maximum technologically feasible. 9


### And then, finall y, DOE scales its results to 10


### the equipment classes that were not directly 11


### analyzed. 12


### All right. So, as Matt described 13


### earlier, DOE is considering standards for 28 14


### equipment classes, but from this list, DOE 15


### plans to focus its analytical effort on the 16



### four equipment classes on the table in this 17



### slide. 18



### So, these classes are chosen on the 19


### basis of them having high market volumes or 20


### unique performance characteristics. So, just as 21


### a little reminder, the high

- pressure sodium 22

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### lamps fall in that first row in the 1900 to 1


### 2800 Kelvin range. Metal halide lamps are 2


### primarily in the bottom three rows, in the 2800 3


### to 4500 Kelvin range, and then we have mercury 4


### vapor lamps that fall in the middle two rows, 5


### because they're generally only found from 50 to 6



### 1000 watts. 7



### So , then in the following slides 8


### with the engineering analysis we'll keep coming 9


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


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


### example for the rest of the engineering. So, 12


### here in issue 13, DOE requests comment o n the 13


### use of these four equipment classes as 14


### representative for the rulemaking. 15



### MR. BROOKMAN: Susan. 16



### MS. CALLAHAN: NEMA still believes 17


### that HPS lamps with CCTs greater than or equal 18


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



### Kelvin should be exclud ed from the rulemaking. 20


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


### bad to repeat yourself at the appropriate times 22

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### here. That's a good thing. 1



### Additional comments here on this 2


### equipment classes? This is important. 3


### (No response.) 4


### MR. BROOKMAN: Okay, no addit ional 5


### comments. We're moving on. 6


### MR. WALKER: All right. So, next 7



### we'll talk a little bit about the baseline 8


### lamps. A baseline lamp generally represents the 9


### most common, least efficacious lamp model on 10



### the market. DOE then identified more 11



### efficacious subs titute lamps for each of the 12


### baseline lamps, and collectively referred to 13


### that group, the baseline, and its more 14


### efficacious substitutes as a representative 15


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


### there are several of these representative lamp 17


### types in cluded within a single equipment class. 18


### And this is to help analyze the wide variety of 19


### wattages in lamps that you find within a single 20


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


### baseline is included for each representative 22

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### lamp type, but in cases where two lamp 1


### technologies are included in one representative 2


### lamp type, DOE analyzed multiple baselines to 3



### consider the life

- cycle cost changes relative 4


### to lamps with different technology. 5


### So, the table lists the baselines 6


### for one of the representative equi pment 7


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


### middle row, the 250 watt mercury vapor 9


### representative lamp type uses a 250 watt 10


### mercury vapor lamp as its first baseline 11


### because it was the least efficacious, but then 12


### we acknowledge that most of the market h as 13


### already adopted the probe

- start metal halide 14


### technology, so the 175 watt probe

- start metal 15


### halide lamp was also analyzed as a baseline, so 16


### this grouping had two baselines. 17


### DOE requests comments on the 18



### baseline units selected. 19



### MR. BROOKMAN: Susan. 20



### MS. CALLAHAN: NEMA requests 21


### clarification as to how a lamp can be a 22

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### baseline and a CSL 1? 1


### MR. WALKER: Sure, I can speak a 2


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


### to start with the baseline concept, the 4


### baseline basically establishes a reference 5



### po int in the life

- cycle cost analysis, which is 6


### the analysis of an individual customer's 7


### response and economic impact to standards. So, 8


### designating a particular lamp a baseline means 9



### that the life

- cycle cost will use that as a 10


### reference point. So, the reason

-- I guess the 11



### way -- all right. 12


### Looking at some of these, they'll be 13


### designated as a CSL 1 and a baseline. The 14


### reason that can happen is because when you're 15


### looking at the impact of standards using that 16


### mercury vapor lamp as a reference point, the 17



### pro be

- start metal halide lamp is a CSL 1 in 18


### that scenario, but if you're considering the 19


### probe

- start metal halide lamp as the starting 20


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


### referred to as a baseline. So, it's not really 22

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### both at the same time. It depends on the 1


### scenario, and the particular snapshot that 2


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



### MS. CALLAHAN: No. 4


### (Laughter.) 5


### MR. WALKER: I mean, is there 6


### something else more specific that i s troubling 7



### you? 8


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



### come ou t both in our written comments and in

-- 10


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


### especially of probe

- start metal halides that 12


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


### you have not picked the least efficacious lamp 14



### available. 15



### MR. WALKER: Ri ght. Okay. I mean

- 16


### MS. CALLAHAN: That's part of our 17



### confusion. 18


### MR. WALKER: Right. I guess I can 19


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


### just reiterate that the labeling of baseline 21


### supports the life

- cycle cost analysis, but then 22

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### when you look at the impacts of the rulemaking 1


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


### standard is going to be applied to a particular 3


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



### matter what was labeled the baseline. In that 5


### case, you look at the shipments that wo uld have 6


### been going towards the mercury vapor lamp, and 7


### the probe

- start metal halide lamp. And as 8


### Michael and Natasha will speak to later, those 9


### shipments would shift up to the CSL 2, or 10


### perhaps some other lamp that's compliant. 11


### I guess what I'm trying to say is 12


### that the baseline designation really only 13



### affects the life

- cycle cost and when you're 14


### looking at the impact of the rulemaking 15


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


### that's less efficacious than that lamp would 17


### then need to be replaced by som ething that is 18


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


### of shipments assigned to those less efficacious 20


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


### MR. BROOKMAN: Additional thoughts, 22

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### questions, comments? 1



### MS. CALLAHAN: NEMA does have one 2



### comment, and that is that we would propose that 3


### the baseline lamps in this category greater 4



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


### to actually 1000 watts would be mercury vapor 6


### only, and not metal halide at all. 7


### MR. WALKER: Okay. 8


### MR. BROOKMAN: Thank you . Additional 9


### thoughts on baseline models? 10


### (No response.) 11


### MR. BROOKMAN: Okay. 12


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


### from baselines, DOE then seeks to identify more 14


### efficacious substitute lamps for each of the 15


### baselines that have been decided on previou sly. 16


### So, this table shows the lamps that comprise 17


### the 250 watt mercury vapor representative lamp 18


### type, so that was that middle row on the 19


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


### through this. 21


### You can see that wattage decreases 22

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### as you move from baseli ne, the top row, down to 1


### CSL 3. So, wattage is decreasing while initial 2


### efficacy is increasing. DOE sought to keep mean 3


### lumens as close to the baseline as possible, so 4


### within 10 percent of the baseline whenever 5


### possible. So, as you can see in the table, CS L 6


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


### not. And that is because of lamp availability 8


### at that wattage with that technology. 9


### DOE also aimed to keep a variety of 10


### other factors as consistent as possible with 11


### the baseline, including initial lumen output, 12


### lamp operating orientation, rated life, CRI, 13


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


### orientation, whenever possible, DOE selected 15


### universal orientation lamps as the basis of the 16


### engineering analysis to e nsure that that 17


### feature in those lamp s would not be precluded 18


### by standards. 19


### All right. So, DOE requests comment 20


### on the criteria used in selecting more 21


### efficacious substitute lamps, as well as the 22

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### specific units selected. 1


### MR. BROOKMAN: Maybe you could go 2


### back to the preceding slide. 3



### MR. WALKER: Sure. 4



### MR. BROOKMAN: Susan. 5


### MS. CALLAHAN: NEMA is going to 6



### address this in its written comments. 7


### MR. BROOKMAN: Okay, thank you. 8



### Additional comments here? 9


### (No response.) 10


### MR. BROOKMAN: Nothing additional, 11


### okay. 12


### MR. WALKER: All right. So, this 13


### slide goes over the concept of an HID system. 14


### To analyze

-- HID lamps are used in lighting 15


### systems that include a ballast, so to analyze a 16


### lamp energy conservation standards impact on 17


### system performance, a ballast is paired with 18


### each representative la mp. DOE used manufacturer 19


### input, as well as independent research to 20


### identify the ballast type and ballast 21


### efficiency that's most commonly used with each 22

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### lamp. 1


### Oh, I think I went too far, sorry 2


### about that. Yes, so this slide discussed the 3


### ballast componen t of the HID system. I advanced 4



### one slide too far. 5


### So, you can see in this table that 6


### all of the lamps with the exception of ceramic 7


### metal halide use a magnetic ballast, but the 8


### ceramic metal halide was paired with an 9



### electronic ballast. 10


### All right. S o, this slide reviews 11


### the fixture component of the HID system. DOE 12


### preliminarily determined that standards

- induced 13


### lamp changes also require the use of a new

-- 14



### or the installation of a new HID fixture. This 15


### is because the existing fixture is going to be 16



### u nlikely to properly physically fit a new lamp 17


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


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


### result in suboptimal optics. And, additionally, 20


### retrofitting old fixtures has the potential to 21


### create safety concerns th at could and can 22

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### result in the decertifying of the fixture's UL 1


### rating. 2


### All right. So, here in issue 18, 3


### we're looking for comments on the ballast types 4


### and ballast efficiency selected for each lamp 5


### type to calculate lamp and ballast system 6


### performance, so that was what was on the 7


### previous slide. And, as well, requesting 8


### comment on the concept of standards induced 9


### fixture replacement. 10



### MR. BROOKMAN: Daniel. 11


### MR. YOUNG: Daniel Young, California 12


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



### are a lot o f products that are marketed as lamp 14



### and ballast retrofit kits for metal halides or 15


### HIDs, and it's our understanding these are 16


### designed to exactly serve this purpose when you 17


### could upgrade your ballast and lamp and still 18


### keep the existing fixture. Is that something 19



### that DOE considered? 20


### MR. WALKER: Right, so you bring a 21


### point. There is this product that would provide 22

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### this retrofit capability, and we're definitely 1


### looking for feedback on this particular issue. 2



### But based on the determination made in the 3



### inte rim analysis, it was that the expected 4


### majority response, I guess, to standards would 5


### not be to follow that retrofit pathway due to 6


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


### most helpful on the topic of the retrofit 8


### product is to have some sense of s hipments or 9


### some sort of usage pattern associated with that 10


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


### don't know if any of the other manufacturers 12


### have any insight into the usage of retrofit 13


### kits that they can share here at the meeting. 14



### MR. BROOKMAN: No? 15


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


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


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


### considering using equations to define potential 19


### standard levels. These equations would define a 20


### continuous relationship be tween lamp input 21


### power and initial lamp efficacy. 22

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### Sort of the process for developing 1


### these equations was by establishing the shape 2


### of the equation using regression curves 3


### specific to data sets for each equipment class. 4


### And then I can give an example of a CSL 5


### equation based on a power function on the next 6



### slide. 7


### So, here you can see three CSL 8


### equations, blue, red, and green that correspond 9


### to probe

- start, pulse

- start, and ceramic metal 10


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


### used the power functio n relationship to 12


### establish equations that separated the 13


### representative lamps corresponding to the three 14


### technologies. 15


### So, let's walk through the 16


### highlighted region of the chart. That's that 17


### yellow diagonal band that you see going through 18



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


### 250 watt representative lamp type that we keep 20


### coming back to. And this kind of provides a 21


### good visual of the energy savings pathway that 22

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### is analyzed in the rule. 1


### So, beginning at the bottom, the 2



### black dot is a 250 watt m ercury vapor lamp. 3


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


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


### diamond which is a 175 watt probe

- start metal 6


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


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


### lamp that DOE is also designating as a second 9


### baseline for this grouping. 10


### And then as we continue again up and 11


### to the left reducing wattage even further, we 12


### get to the 150 watt pulse

- start metal halide 13


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



### 100 watt ceramic metal halide lamp. So, that 15


### kind of goes through this representative lamp 16


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


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



### sort of

-- to highlight the concept. 19


### The next slide will then expand the 20



### watt age range to show all three equipment 21



### classes that are included in this 2800 to 4500 22

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### Kelvin range. So, I'll just hop over there. 1


### Right. So, this plot shows the CSL 2


### equations for these three equipment classes. To 3


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


### three CSL equations that we just looked at on 5


### the previous slide for the 50 to 400 watt 6


### range. And, again, they represented the three 7


### technology

-- the metal halide technologies 8


### that were available for that equipment class. 9


### Then moving to the righ t in the 400 10


### to 1000 watt range, ceramic metal halide 11


### technology was not available, so CSL 3 was not 12


### analyzed. And we just have the blue and red 13


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


### range, only probe

- start metal halide lamps were 15


### available, so D OE analyzed only one CSL. 16


### All right. So, this brings us to a 17


### request for comment on the CSL equations 18


### developed in each of the representative 19


### equipment classes. 20



### MR. BROOKMAN: Susan. 21


### MS. CALLAHAN: NEMA agrees generally 22

### NEAL R. GROSS
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### with the approach to use power functions and 1


### power function regression curves to best fit 2


### this; however, we are still exploring those 3


### exact coefficients and exponents, and they will 4



### be included in our written remarks. 5


### MR. BROOKMAN: Okay. Daniel. 6


### MR. YOUNG: Daniel Young. Just a 7



### quest ion, do you know if the unavailability of 8



### ceramic metal halide above 400 watts is a 9


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


### lack of existing demand? 11


### MR. WALKER: I might defer to some of 12


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



### metal halide sort of got its footing in the low 14


### wattage retail market I think is a good 15


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


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


### able to look to some of the other experts in 18


### the room for future trends, but maybe not. 19



### M R. YOUNG: Okay. 20


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


### the last slide of the engineering analysis, the 22

### NEAL R. GROSS
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### scaling. So, once CSLs are established for each 1


### representative equipment class, DOE developed 2


### scaling relationships those apply those CSLs to 3



### the remaini ng equipment classes that weren't 4


### analyzed directly. So, this process involved 5


### comparison of lamps that differed only by the 6


### parameter under consideration for scaling. So, 7


### for the interim analysis scaling factors 8



### accounted for the difference in initial 9



### eff icacy due to bulb finish, luminaire 10


### characteristic, and CCT, which you probably 11


### notice are the same as the equipment class

12


### setting factors. 13


### So, for bulb finish, DOE found that 14


### coated lamps were about 6 percent less 15


### efficacious than clear lamps for the m iddle and 16


### high CCT ranges, and about 8 percent less 17


### efficacious for the low CCT lamps. And low CCT 18


### lamps was the high

- pressure sodium grouping 19


### which we talked about quite a bit today. 20


### Then looking at luminaire 21


### characteristic, we found that open

- rated la mps 22

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### were about 5 percent less efficacious than 1



### enclosed

- rated lamps. And then, finally, with 2


### CCT the 4500 to 7000 Kelvin lamps were about 12 3


### percent less efficacious than the middle CCT 4



### range. 5


### At this time, DOE requests comment 6


### on the scaling methodology and, in particular, 7


### whether the scaling factor between CCT ranges 8


### should be a function of wattage. 9



### MR. BROOKMAN: Comments here? Susan. 10


### MS. CALLAHAN: NEMA supports the use 11


### of scaling factors and we are currently working 12


### on evaluating member data to see whether

-- 13


### what we would propose those scaling factors to 14


### be, and they will be included in our written 15



### comments. 16


### MR. BROOKMAN: Thank you. Additional 17


### thoughts on issue 19? 18


### (No response.) 19


### MR. BROOKMAN: All right. 20


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


### DOE invites comment on the impact of reporting 22

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### requirements and variation on compliance with 1


### the CSLs under consideration. So, DOE is 2


### looking for feedback on whether or not an 3


### adjustment would be needed to the CSLs 4


### described here in the interim analysis to 5


### account for the impact of reporting and 6



### variation. 7



### MR. BROOKMAN: Susan. 8



### MS. CALLAHAN: NEMA stresses that HID 9



### tolerances be referenced to NEMA LSD 63 10


### measurement methods and performance variation 11


### for verification testing of general purpose 12


### lamps and s ystems which is based on NIST 13


### Technical Note 1297. And we ask DOE to clearly 14


### acknowledge this. 15


### MR. BROOKMAN: Okay, thank you. No 16


### additional comments on reporting requirements? 17


### (No response.) 18


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


### wrap things

-- in issue 20, DOE requests 20


### comments on all aspects of the engineering 21


### analysis, and anything else that hasn't been 22

### NEAL R. GROSS
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### covered yet. 1



### MR. BROOKMAN: Additional comments on 2


### engineering analysis? Nothing additional? 3


### (No response.) 4



### MR. BROOKMAN: We can either take a 5



### br eak now or we can keep plugging on ahead. I 6


### suspect at our current pace that

-- 7


### MR. WALKER: We actually have one 8


### more equipment pricing slide. 9


### MR. BROOKMAN: Oh, one more slide. 10



### Sorry. 11


### MR. WALKER: May have gotten a little 12


### overeager with my wrapping up comments. 13



### MR. BROOKMAN: Yes. 14


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


### cover the equipment price determination. 16


### Beginning with lamps, DOE analyzed the end user 17


### price directly rather than developing 18


### manufacturer selling prices because HID lamps 19



### are difficult to reverse

- engineer, unlike a 20



### ballast or fixture which would have discrete 21


### solid components. The arc tube solids and fill 22

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### gases would be impractical to assess. So, 1


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


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



### user s depending on the distribution channel. 4


### By developing three discount factors 5


### off of blue books or retail price lists, DOE 6


### calculated three sets of prices, low, medium, 7


### and high that ultimately corresponded to the 8


### price associated with a state procureme nt 9


### contract, a large distributor, or internet 10



### retailer. 11



### Then for the ballast and fixture 12


### component of the HID system, DOE did use a 13



### combination of tear

- down retail data to 14


### estimate the manufacturer production cost. The 15


### manufacturer production costs were then marked 16


### up to the manufacturer selling price using a 17


### manufacturer markup that accounted for non

18


### production costs and manufacturer profit. 19


### So, this brings us to the final 20


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


### comments on the methodology and results for 22

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### estimating end user prices for HID lamps. 1



### MR. BROOKMAN: Susan. 2



### MS. CALLAHAN: NEMA is unable to 3


### comment on this subject and defers to 4



### individual members. 5


### MR. BROOKMAN: Okay, thank you. No 6



### additional comments. 7


### MR. WALKER: All right. And t hen, 8


### finally, DOE invites comment on its methodology 9


### and results for estimating manufacturer selling 10


### prices for the ballast and fixture component. 11



### MR. BROOKMAN: Susan. 12



### MS. CALLAHAN: NEMA is unable to 13


### comment on this subject and defers to 14



### individual mem ber comments. 15


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


### that concludes the Engineering and Equipment 17


### Price Determination segment. Let's take a break 18


### now. It's 10:15, so we'll take a 15

- minute 19


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


### Please wear your badge, som e form of 21


### identification while you're in the Forrestal 22

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### Building. There are restrooms on both ends of 1


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


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


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



### we've covered a lo t of ground already. We'll 5


### see you back here at 10:30. 6


### (Whereupon, the above

- entitled 7


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



### resumed at 10:31 a.m.) 9



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


### Jack, how many folks are joining us via the 11


### web? I'm happy t o report 14 individuals joining 12


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


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


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


### Michael Myer. 16


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


### introduction and queuing up the topic s. 18


### Moving into the rulemaking maps 19


### lighting, you'll see that the markups analysis 20


### and the energy use analysis, they feed together 21


### and they provide inputs into the life

- cycle 22

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### cost and payback period analysis. 1


### Energy use analysis, we all know 2


### that energ y is power times time so we're going 3


### to take the system input power, factoring in 4


### the power of the draw of the ballast, multiply 5


### it by annual operating hours. 6


### As mentioned earlier in previous 7


### slides in engineering analysis, the input power 8


### is developed there, and we're using their 9


### numbers. DOE then developed annual operating 10


### hours. We used data from the 2010 Lighting 11


### Market Characterization, abbreviated here as 12


### the LMC 2010, and it captures variations across 13


### building types and applications. 14


### So, essenti ally, for commercial 15


### sectors you're about just under 4000 hours a 16


### year, for industrial sectors you're just over 17


### 6000 hours a year, and for outdoor lighting 18


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


### cases you have stadium lighting, which operates 20



### very s mall fraction of the year, and you're at 21


### roughly 778 hours per year. 22

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### I'm going to now move into item 23, 1


### request for comment on operating hours. 2


### Basically, we used the Lighting Market 3



### Characterization 2010 which the most current. 4


### DOE assumed that all equ ipment analyzed could 5


### be used in three evaluated sectors, commercial, 6


### industrial, and outdoor, and applied average 7


### annual operating hours based on each sector. We 8


### welcome comment on the basis and the assignment 9


### of these, and the operating profiles. 10



### MR. BROOKMAN: No comment at this 11



### time? No comment at this time from manufacturer 12


### types. What about

-- 13


### MR. MYER: Other types? 14



### MR. BROOKMAN: What about others? 15


### Yes, please. Say your name. 16


### MR. STARR: Louis Starr, Northwest 17


### Energy Efficiency Alliance. For t he ballast 18


### factor, how is that working into your power 19


### input? What are you using for that? 20


### MR. MYER: Well, as mentioned 21


### earlier, they do review the ballast efficiency, 22

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### so typically HID lamps ballasts have a ballast 1


### factor approaching one, so there aren't 2


### multiple ballast factors that we can use, but 3


### they are using a variety of different ballast 4


### efficiencies for the different lamp types that 5


### are covered. It would depend on whether or not 6


### it's a probe

- start versus a pulse

- start, and 7


### the ballast efficiency w ould be factored into 8


### the input power. 9


### MR. STARR: Okay. And one other 10



### comment on the burn hours. I notice on the 11


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


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


### makes sense. The only other aspect of that is 14


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


### commercial aspect which they usually run their 16


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



### kind of wondered

-- I expected maybe a little 18


### more on the commercial side or something on the 19



### outdoor hours. 20



### MR. MYE R: I would refer to the 21


### Lighting Market Characterization by the mixture 22

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### of lamp types used in different sectors. I 1


### agree that retail sectors often operate 12 to 2



### 24

-- actually, some are operating 24 hours a 3


### day, but the mixture of HID lamps and retail 4



### sect ors is not, proportionally compared to 5


### fluorescent or incandescent, is not as high. I 6


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


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



### of environments that are not industrial 9


### manufacturing. It just happens to be the way 10


### that the averages all work out. But thank you 11


### for asking. 12



### MR. BROOKMAN: Additional comments 13


### here? Okay. 14


### MR. MYER: Now, moving back into the 15


### stage slide, so we just discussed energy use 16


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


### analysis

. 18


### Slight difference between the 19


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


### separated differently. So, for the interim 21


### stage, markups were not used for lamp prices as 22

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### they were developed as end user prices. Markups 1


### were developed for ballast and fixtur es since 2


### manufacturer selling prices were supplied in 3


### engineering analysis. DOE used SEC 10

- K forms 4



### and did not differentiate between baseline 5


### incremental. And then we came up with a final 6


### markup which is the average wholesale markup 7



### times the contractor m arkup or essentially 1.24 8


### times 1.13 equals 1.39. 9


### For the NOPR stage, it will be 10


### differentiated a little bit. We do plan to get 11


### markups for the MIA analysis to estimate lamp 12


### manufacturer selling prices from end user 13


### prices. And we will also consider a lo w markup 14



### to differentiate the different distribution 15



### channels. 16


### I'm now going to introduce my 17


### colleague

-- oh, do you have a question, 18



### Joanna? 19



### MS. MAUER: No. 20


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


### sorry. I am now going to introduce my 22

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### colleague, Natasha Col lins, who will discuss 1



### the life

- cycle cost and payback analysis. 2


### MS. COLLINS: Good morning. I am 3



### Natasha Collins with Pacific Northwest National 4


### Laboratory, and I'm going to present today 5



### life

- cycle cost and payback period analysis, as 6



### well as national impact analysis. 7


### So, as most of us know, life

- cycle 8


### cost analysis looks at the financial 9


### implications for individual consumers or end 10


### users of the lighting fixtures from moving to 11


### less efficacious to more efficient ones, as 12


### well as payback period analysi s. While together 13


### with shipment analysis, this provides us enough 14


### inputs to evaluate the fact of the standard

-- 15


### of a possible standard on the nation, and 16


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


### national impact analysis later on. 18


### So, just to repeat my self, in life

19


### cycle cost analysis, we are calculating the 20


### total cost of operating a fixture over the 21


### analysis period, which includes installed cost 22

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### and discounted operating cost and replacement 1


### costs. So, we basically calculate life

- cycle 2



### cost for the base fixtures and for more 3


### efficacious fixtures, and take the difference 4


### to find out what the savings are. 5


### Simple payback period, DOE uses as a 6


### quick method to calculate how many years it is 7


### going to take for a more efficacious fixture to 8


### pay itself back in terms of energy savings, in 9


### terms of lower electricity use as usual. Any 10


### questions so far? 11


### MR. BROOKMAN: Yes, please. 12


### MR. STARR: Louis Starr, Northwest 13


### Energy Efficiency Alliance. Is the lifetime 14


### cost 70 percent of the life or the

-- what's 15



### the life of the fixture or the lamp? 16


### MS. COLLINS: We have been setting 17


### the analysis period equal usually to the 18


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



### limitations on how it works because for a lot 20


### of baseline fixtures that we have, mercury 21


### vapor baseline f ixtures, for instance, they 22

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### have very limited lifetime that's left in them 1



### because the new fixtures could not be installed 2


### any more, and the ballast shipments are 3


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


### only about six years of the analysis period 5



### th at is left. If we take a look at the 6


### beginning of the analysis period in 2017, 7


### that's when the standard becomes effective, we 8



### estimated that the fixtures will last 9


### approximately to 2022. 10


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



### the fixtures then are assumed to have roughly 12


### the same lifetime, or do the fixtures have a 13


### greater lifetime than the lamp? 14


### MS. COLLINS: They have greater 15


### lifetime than the lamp. This is for the mercury 16


### vapor baselines. Then there is also probe metal 17


### halide that have different lifetimes, so 18



### whenever we had a baseline fixture available 19


### for replacement we used the entire fixture 20



### lifetime. 21


### MR. BROOKMAN: Okay? 22

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### MS. COLLINS: Any other questions? 1


### So, this slide just visually represents how the 2


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


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


### breaks down into the lamp replacement cost, 5


### ballast replacement and annual operating cost. 6


### So, full lamp replacement, ballast 7


### replacements, we have lifetimes of those 8


### components. We have their prices. For annual 9


### operating cost there is electricity price, 10


### there are operating hours, there are projection 11


### how electricity prices going to change over 12


### time. And those annual ownership costs are 13


### discounted and together they comprise

-- 14


### together with installed cost compris e life

15


### cycle cost. 16


### So, we have analyzed three different 17


### triggering events, and those events stem from 18


### three different times when the lamp can be 19


### exchanged. It's either lamp failure or ballast 20


### failure and lamp is replaced with a ballast, or 21



### entire fixtur e is being replaced. Those three 22

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### triggering events apply to the baseline because 1


### we know that once the standard is established, 2


### all those three triggering events will require 3


### fixture change because we cannot fit a more 4


### efficacious lamp with the old ballast , or we 5


### cannot fit a more efficacious ballast and lamp 6


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


### (No response.) 8


### So, a little bit more detail on our 9


### inputs for the installed costs. End user prices 10



### for lamps, ballast, and fixtures that are 11


### floating fro m engineering analysis mostly, 12


### sales tax by state we estimated with data from 13


### Sales Tax Clearinghouse, just a little bit over 14


### 7 percent nationwide, and installation cost 15


### that we estimated from RS Means. They include 16


### labor cost and servicing equipment cost, and 17


### those costs vary significantly based on the 18


### application of the lamp, based on the 19


### environment, and based on the wattage. So, 20


### fixture cost from $160

- 535. This is fixture 21


### installation cost only, excluding the cost of 22

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### the fixture itself. Ballast $147

- 297 , and lamp 1


### from $94

- 254. 2


### On the operating cost side, we use 3


### EIA's form 826 to evaluate the electricity 4


### prices, and we used AEO 2012 to estimate the 5


### price trend into the future. Discount rate was 6


### calculated using the formula for weighted 7


### average cost of capital, and you can see that 8


### for outdoor stationary that the discount rate 9



### is lower than for the two other sectors. It 10


### reflects higher government ownership in that 11



### sector. 12


### Lifetime for fixtures, we assumed 20 13


### years for interior and 25 for exterior. Bal last 14


### for magnetic 50,000 hours, and for electronic 15


### 40,000 hours. 16


### On the replacement cost side, we 17


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


### bringing up lamp lifetimes because they vary 19


### significantly by technology, by product class, 20


### and by efficien cy level. We also estimated 21


### equipment price trend based on AEO 2011 22

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### deflators to reflect the declining real price 1


### of the equipment over time. 2


### MR. BROOKMAN: Yes, please. 3



### MR. STARR: Louis Starr with NEEA. 4


### Actually, I have a question on the previous 5



### one, the life

- cycle analysis of the installed 6


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


### general idea of what the split between the cost 8


### of the fixture, to install a fixture and how 9



### much labor it was? Is it 50

- 50? Is it

-- a 10


### general idea. I mean, there's kin d of a rule of 11



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


### of want to see what your idea was. 13


### MS. COLLINS: Yes. Actually, the cost 14



### of the fixture sometimes is even lower than the 15



### installation costs themselves. But 50

- 50 would 16



### be safe to assume. 17



### MR. STARR: Okay. 18


### MS. COLLINS: It's usually lower than 19



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



### MR. STARR: Then I would also mention 21


### like on high

- pressure sodium, a lot of 22

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### municipalities have very fixed numbers, so they 1


### exactly know how much it is to replace a l amp 2


### fixture because they'll sub out that work to 3


### firms and they'll have a

-- they'll know 4


### exactly what the fixture cost is, and they 5


### provide a certain price to replace lamp 6


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


### out there. Municipalities have a lot of that 8


### for replacing like outdoor lamps. 9


### MR. BROOKMAN: Do you have a source, 10


### a specific source? 11


### MR. STARR: City of Seattle has some 12


### information, but I would say every 13


### municipality. I bet you California IOUs would 14



### have a lot of data in terms of

-- you know, it 15


### can get you a very particular split

- out of what 16


### the fixture costs are and what the lamps are. 17


### MR. BROOKMAN: Daniel, do you have 18



### access to that? 19


### MR. YOUNG: Possibly. 20


### MR. BROOKMAN: Okay. 21


### MR. YOUNG: But yes, we'll try and 22

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### find that and prov ide that. 1


### MR. BROOKMAN: That'd be great. 2


### MS. COLLINS: Thank you. 3



### MR. BROOKMAN: Now we're finishing up 4



### on 57. 5



### MS. COLLINS: More comments? I can 6


### proceed? 7



### MR. BROOKMAN: Yes. 8



### MS. COLLINS: We're finished with 9


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



### results because we have modeled three different 11


### events, and we have so many product classes 12


### with so many baselines. Here I am presenting 13


### the results for the lamps with light 14


### temperature between 2800 and 4500 Kelvin, and 15


### with wattages between 50 and 400 watts. 16


### As you can see, in a lot of cases 17


### there are negative LCC savings, and a lot of 18


### that due to the very high installed cost at the 19


### very beginning of the analysis period. Payback 20


### periods are also significant. In one of the 21


### product classes where the p ayback period is not 22

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### applicable, it's actually over 100 years. 1


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


### And when we're switching from one 3


### level of metal halide technology to higher 4


### levels of metal halide, we actually realize 5


### some positive savings. There are ac tually some 6


### savings there. Any questions here? No 7


### questions? 8


### So, at this point, DOE invites 9


### comments on the lifetimes of the equipment. So, 10


### we assumed 20 years for interior fixtures, 25 11


### years for exterior fixtures, 50,000 hours for 12


### magnetic ballast, 40,0 00 hours for electronic 13


### ballast. We also assumed average values, and we 14



### would like to know how the failure rates 15



### distributed around those average lifetimes. We 16


### also seek comments on the lamp lifetimes that 17



### we have used. 18



### MR. BROOKMAN: Daniel. 19



### MR. YOUNG: Daniel Young, California 20


### IOUs. I'm trying to understand how you 21



### accounted for the incremental cost of the 22

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### fixture at the beginning of the replacement, so 1


### if I understand correctly, you assumed maybe a 2



### 7

- year analysis period for switching out a 3



### mercury vap or based on the current fixture's 4



### lifetime. Correct? 5



### MS. COLLINS: Yes. 6


### MR. YOUNG: And then do you incur the 7



### full incremental cost of the new fixture? 8



### MS. COLLINS: You incur the full cost 9


### of installing a new fixture. 10



### MR. YOUNG: But the benefits are only 11


### accrued over seven years? 12


### MS. COLLINS: Yes, because you have 13


### to tailor the analysis period to how long your 14


### baseline is going to last. And that also 15


### represents the true cost that the end user will 16


### be facing. We tried to model the situation to 17



### be as close to reality as possible. 18



### MR. YOUNG: But then that doesn't 19


### consider that at the end of that seven years 20


### you would have had to replace that fixture 21



### anyways. Correct? 22

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### MS. COLLINS: Yes, it doesn't incur 1



### that

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



### can not make a choice what kind of fixture the 3


### end user would pick at that time. They could 4


### have picked LED fixture which happens a lot of 5


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


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


### example, if there was only one year of 8


### remaining life on the fixture and you were 9


### trying to evaluate the cost effectiveness of 10


### this measure, then you're essentially saying 11


### that you would incur the full cost of the brand 12


### new fixture one year before it would be 13


### replaced anyway, so

-- 14



### MS. COLLI NS: That's why we didn't 15


### use extreme examples. That's why we averaged 16


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


### lifetime period. We calculate that on average 18


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


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


### longer. 21


### MR. YOUNG: Okay. 22

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### MS. COLLINS: Because we tried to 1


### estimate averages and weight it so

-- to come 2


### up with some mythical representative consumer 3



### end user. 4


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


### guess, discounting the price by the fraction of 6



### year s that you're covering that's overlapping? 7


### MS. COLLINS: Yes, we have considered 8


### different discounting, and we have considered 9


### adding back some cost, but you will incur that 10


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


### or you cannot recoup over the tim e. So, it's 12


### basically the sunk cost that you will be 13


### incurring regardless. 14


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


### we'll provide a comment to that. 16


### MR. BROOKMAN: Okay. 17


### MS. COLLINS: Thank you. 18


### MR. BROOKMAN: Thank you. 19


### MS. COLLINS: We will definitely 20


### appreciate your comments. 21



### MR. BROOKMAN: So, now we're back to 22

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### issue 24, and asking for comment on the 1


### lifetimes that you see here in this box. 2



### MS. COLLINS: No comments? 3



### MR. BROOKMAN: No comment at this 4



### time. Michael? 5


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


### the gentleman from the Northwest, when he said 7


### to me about 70 percent, are you suggesting that 8


### either lamps or fixtures are prematurely 9


### retired? I just want to

-- because it does 10


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


### to understand your pote ntial question. 12


### MR. STARR: I was talking about 13


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


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


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


### often they're replacing the lamps are, because 17


### it's not really t he lifetime of the lamp, it's 18


### 70 percent of the lamp lifetime. Then you re

19


### lamp them. 20


### MR. MYER: Okay, so you're asking C

21


### Michael Myer, Pacific Northwest National 22

### NEAL R. GROSS
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### Laboratory. Just so I understand, you're saying 1



### -- you were asking whether or not we use

-- if 2


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


### 10,000 hour value versus the 7,000 hour

-- 4


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


### the 70 percent is the IOUs recommendation for 6



### it? 7


### MR. STARR: Right, right. Correct. 8


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


### MR. BROOKMAN: Take a peek at issue 10


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



### MS. COLLINS: Then we are back to 12


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


### analysis. 14


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


### moving into the next two phase, t he shipments 16


### analysis along with some of the economics that 17


### Natasha just briefly touched on both are inputs 18


### for the national impact analysis. 19


### Shipment analysis essentially tries 20


### to predict what the technology somewhat has 21


### done historically, but then als o what it will 22

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### do into the future. And it's good to know the 1


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


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


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



### The base case assumes no shifts related to a 5



### standard, an d the base case

-- the standards 6


### case assumes that things would shift in result. 7


### As I've mentioned before, DOE has 8


### historical data from NEMA. We actually have a 9


### pretty good treasure trove, in my opinion, of 10


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


### insight to Joanna's question. We also reviewed 12


### industry forecasts related to technologies. We 13


### also developed the base case and the standards 14


### case based on lamp lifetimes, replacement and 15


### demand growth, decline cycles, and then also 16


### the retirement and emerg ing technology 17


### penetration, whether certain fluorescent or LED 18


### technologies will replace HID. 19


### So, so this graph is what

-- on the 20


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


### roughly historic data. Actually, it's historic 22

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### data before the green line, and then the green 1


### line indicates the start of the analysis period 2


### moving forward from 2017 to 2046. Everything up 3


### to 2010 is actually historic data. 4



### You'll see that overall most 5


### technologies are in a decline. HID as a family 6


### is in a decline overall. It appe ars that 7


### roughly 2005 was the overall zenith for HID 8


### lamp shipments, but only time will tell. And 9


### just to walk through all the colors, the top 10


### line is orange which is high

- pressure sodium, 11


### together metal halide actually represents 12


### larger segment share than high

- pressure sodium 13


### but we broke them out by technologies just to 14


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


### which is ceramic metal halide, the red which is 16


### pulse

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


### then the green which is pulse

- start metal 18



### halide. An d the lower one which is teal is 19


### mercury vapor, and the data point that I 20


### alluded to earlier is if you look at the 2008 21


### to 2010 data range for mercury vapor, you'll 22

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### see kind of a marked decline since the EPAct. 1



### Yes? 2


### MR. STARR: Louis Starr, Northwest 3



### Ene rgy Efficiency Alliance. Since it seems like 4


### you have lots of data on the mercury vapor and 5


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


### you have a split out of before 2008, you 7


### probably know how many mercury vapor ballasts 8


### shipped, and maybe you know al so the amount of 9


### mercury lamp and ballast combinations. What I 10


### was wondering if you can figure out if the 11


### amount of replacement ballast, because if 12


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


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


### a replacemen t. If you can kind of see if that 15


### same trend and the amount of quantity of 16


### ballasts that are being shipped pre

- 2008 and 17



### post

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


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


### are actually just replacing ballast rather tha n 20


### replacing lamp and ballast. In other words, 21


### they might be trying to find a loophole, and 22

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### I'm wondering if there's a way to take those 1


### three pieces of information and overlap them to 2


### see whether there are loopholes being created 3


### by having specialty ballas t for mercury vapor. 4



### MR. MYER: Yes, based on from where 5


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


### disagree with that methodology. At the moment, 7


### we do not have that data for mercury vapor 8


### ballast shipments, which is the critical 9


### detail, and I would act ually ask NEMA and 10



### manufacturers if there

-- if anyway possible to 11


### provide any insight on manufacture of ballast 12


### shipments. We do have another rule where we 13


### have leveraged some data related to metal 14


### halide fixtures, but since mercury vapor with 15



### ballast was actually an act of Congress, we 16


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


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


### Ultimately, rather than historic 19


### data which may not be as easy to get because 20


### manufacturers may purge it, the approach I 21



### woul d suggest is also what

-- how many mercury 22

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### vapor ballast shipments have there been since 1


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


### we have an idea of the lamp shipments since 3


### 2008, so we could correlate roughly how many 4


### are going to specialty applica tions versus 5


### general applications. 6


### MR. STARR: Is that something the 7


### manufacturer would be willing to provide, 8


### perhaps? 9



### MS. CALLAHAN: I will take that back 10


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


### MR. BROOKMAN: Thank you, Susan. 12


### Okay? Joanna. 13



### MS. M AUER: Joanna Mauer. Just a 14


### question. So, the line showing projected 15


### shipments of probe

- start metal halide lamps, is 16



### that

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


### reflecting that some portion of metal halide 18


### fixtures will have a much longer lifetime than 19



### th e average lifetime of 20 to 25 years? 20


### MR. MYER: Well, probe

- start, I think 21



### -- I'm going to

-- well, I guess my question is 22

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### are you asking because of the E I SA 2007

-- 1


### okay. So, E I SA 2007, just so I'm putting this 2



### o n the record that everyone is aware, only 3


### affected 150 to 500 watt probe

- start fixtures, 4


### so you can still sell today a probe

- start 5


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


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


### shipments. 8


### Two, it didn't restrict

-- it didn't 9


### put any restrictions related t o the sale of 10


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


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


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


### replacement ballast, it only affected ballast 14


### shipped with the fixtures at the time, so you 15



### could bu y a replacement ballast let's say in 16


### 2028 or 2035 for the 250 watt probe

- start 17


### fixture, and then also have a new lamp 18


### servicing, as well. So, the projections that 19


### you're seeing for probe

- start technology are 20



### two

- fold. One is high wattage lamps that are 21



### not affected by any current regulations related 22

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### to probe

- start technology. And, two, the 1


### replacement of either the lamps or the ballast 2



### that can continue into the future. 3


### MS. MAUER: Thank you. So, the 4


### average lifetime assumed for new fixtures is 20 5


### to 25 ye ars, so any -- on average any new 6


### fixture, new probe

- start fixture, the last ones 7


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


### to 500 watt range. 9


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


### general impression from my understanding from 11


### industry and as a lightin g practitioner that 12


### while 94 percent ballast is technically 13


### achievable, most manufacturers are not

-- I 14



### think we all

-- I think

-- I've not seen data 15


### on it, but most people do not expect probe

16


### start 150 to 500 to be shipped since 2009, 17


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


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


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


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


### would agree with you, in my impression here, 22

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### yes, that nobody is shipping a 94 percen t 1


### greater efficient ballast at this time. 2


### MR. BROOKMAN: Yes, Louis. 3


### MR. STARR: One last question, and 4


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


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


### because other technologies coming to market, 7


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


### explain how that shaped the

-- how you used 9


### that information to shape those curves? 10


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


### heard in different other rulemakings, the metal 12


### halide lamp fixture as well as the HID, that 13



### fluoresce nt technology in interior applications 14


### is displacing metal halide, so we did look at 15



### if

-- what the penetration rate. We also looked 16


### at Lighting Market Characterization 2010 and 17


### 2001 to get a sense of what technologies are 18


### currently being used by percentag es, and just 19


### what the longevities were. We also looked at 20


### other DOE reports of what technologies, what 21


### penetration rates are expected, so we tried to 22

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### use those all to forecast at some point

-- some 1


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



### are fixtur es that were installed maybe in 2016 3


### that will be prematurely retired before their 4



### 20

- year life or 25

- year life because another 5


### technology is replacing it. 6


### MR. BROOKMAN: Okay? Yes. 7



### MR. MYER: Takes me into issue 25. 8


### Basically, just talking about histor ic 9


### shipments. We based it on NEMA data from 2002 10


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


### request comments on this approach, and we 12


### welcome any additional lamp shipments that we 13


### can for historic data in most recent years. 14


### Right now, the model is in a crit ical spot. 15


### Anything in the near

-- you know, from 2010 to 16


### 2013, any new data points are very helpful 17


### because of just the way the current trends are 18


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


### request comment on this methodology, and any 20



### additional data. 21



### MR. BROOKMAN: We've heard from NEMA 22

### NEAL R. GROSS
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### already that they'll try

-- they'll take that 1


### back. What about the methodology? No additional 2


### comments at this time. Okay. 3


### MR. MYER: That brings us to issue 4


### 26. So, DOE modeled lamp purchasing events, 5


### replacement and n ew construction, as well as 6


### applied growth and replacement rate assumptions 7


### to develop shipments. 8


### We did base these lamp future 9


### shipments on the 2010 HID Lamps Determination. 10


### We also assumed that these trends integrate 11


### various regulatory and non

- regulat ory 12


### initiatives in Lighting Market Place. 13


### We request comment on the magnitude 14


### and timing of its projected shipments, whether 15


### rise and declining is accurate or a plateau 16


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


### current regulatory initiatives on fu ture HID 18


### shipments. So, just more comments on the way 19


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


### they should be sharper, or steeper. 21


### MR. BROOKMAN: Additional thoughts on 22

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### these trends for shipments? 1


### MR. MYER: And, also, a critical 2



### detail is that whil e this is a lamp rule, any 3


### thoughts on shipments of fixtures which is not 4



### covered under this rule also affects

-- if you 5


### don't buy a lamp

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


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


### any future growth

-- future ideas on fixtu re 8


### shipments is also appreciated. 9


### MR. BROOKMAN: Nothing additional at 10


### this time. Okay. 11


### MR. MYER: Brings me to the last 12


### issue, issue 27, standards

- induced market 13


### shifts. So, in the shipments analysis, DOE 14


### assumes that a portion of the market shifts to 15



### LED , induction , and linear fluorescent sources. 16


### DOE requests comments on this assumption as 17


### well as on the likelihood magnitude of an 18



### additional market shift to non

- HID technologies 19


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



### second. 21



### If a standard

- indu ced shift 22

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### expected, DOE requests further comments on 1


### which equipment classes would be affected, 2


### applications or fixture types, which non

- HID 3


### technologies would replace HID, and on what 4


### basis would an equivalent non

- HID replacement 5


### be specified; specificall y, would it be fixture 6


### light output, lamp mean lumens, those type of 7


### things. 8


### MR. BROOKMAN: Yes, Daniel. 9


### MR. YOUNG: Daniel Young, California 10


### IOUs. Just a question for the Department, are 11


### you considering to account for savings from a 12



### standards

- induced ma rket shift to more 13


### efficient technologies? 14



### MR. MYER: At this time it's 15


### something we are considering, yes. 16


### MR. YOUNG: Could you talk about how 17


### you might do that? 18



### MR. MYER: We welcome comment on 19


### proposed methodology. It's really a lot of

-- 20


### the third p art of that question is what feeds 21


### some of that, so, you know, obviously energy

-- 22

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### you know, the operating hours would be one 1


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



### other one. How we select non

- HID technologies 3


### is the critical detail. You know, is i t lumen 4


### output, is it mean output, how do we

-- what 5


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


### first two parts are just as important. Do 7


### people expect shipments

-- shifts away from 8


### lower wattage, or medium wattage, or high 9


### wattage? Those would, ultimately , affect what 10



### any energy -- any energy calculations. 11


### MR. BROOKMAN: The last part of issue 12


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


### those trend lines, those shifts that might be 14



### standards

- induced? Susan. 15


### MS. CALLAHAN: NEMA requests that the 16


### publi shed analysis made available before the 17


### NOPR include the effects of the anticipated 18


### shifts. And if the shipment trends indicate a 19


### decrease in product, factor this into the 20


### energy savings and the financial impact 21


### analysis. 22

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### And to someone else's point, the 1


### current trends show many categories shifting 2


### away from HID, so the corresponding reduction 3


### in energy savings potential should be factored 4


### into this analysis for us. Thank you. 5


### MR. BROOKMAN: Okay, thank you. 6


### Additional thoughts here? The Department reall y 7


### appreciate s detailed written comments on points 8


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


### others who are in the room. Okay. 10


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


### I will return the presentation back to Natasha 12


### Collins for national impact analysis. 13


### MS. COLLINS: As I mentioned earlier, 14


### together with shipments analysis, LCC provides 15


### us enough inputs to estimate national energy 16


### savings, and net present values resulting from 17


### possible standard. So, for energy savings we 18


### estimated the stock of lamps every year, and in 19


### the base case and in the standards case, and 20


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


### 1, CSL 2 provide lower level of energy savings 22

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### as opposed to CSL 3, where we model shifting to 1


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



### of the sa vings is coming from. 3


### I wanted to point out that the 4


### savings have a dwindling effect, reflecting the 5


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


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


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



### our estimat es are. 9


### As for NIA results, they're largely 10


### negative both for 3 percent discount rate and 7 11


### percent discount rate which reflects very high 12



### installation cost and install cost for the 13


### fixtures at the very beginning of the analysis 14


### period. So, both for CSL 1

-- both for 3 15


### percent and 7 percent discount rates. 16


### So, CSL 1, negative $12 billion 17


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


### CSL 2 roughly $16 billion negative, CSL 3 19


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


### same magnitude for 7 percent discount, $9.4 21


### billion CSL 1, CSL 2 $12.5 billion, and CSL 3 22

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### about $14 billion negative. Yes, Joanna? 1



### MR. BROOKMAN: Joanna. 2


### MS. MAUER: One question I had, 3


### looking at the LCC and NPV results for 4


### individual representative product categories, 5



### it looks lik e there are some cases, for 6


### example, the 400 watt mercury vapor 7


### representative product where it looks like the 8



### LCC results for the different

-- you know, both 9


### the lamp and ballast events are positive, and 10


### then the NPVs are negative for that same 11



### category. Could you explain why that's the 12



### case? 13



### MS. COLLINS: Yes, that occurred a 14



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


### proportion of fixtures that are shipped under 16


### the standards case is a lot higher than in 17


### general proportion of shipments. And that's 18



### wh at affects the increase

-- that's what 19


### affects a very high

-- that's what results in a 20


### very high installed cost, a lot higher install 21


### cost in the standards case as opposed to base 22

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### case. So, on average it's maybe 30 percent of 1


### lamp shipments associated with fixture 2


### shipments for the new fixture. While after the 3


### standard is introduced it's about 70 percent or 4


### maybe even more. We have

-- does that make 5



### sense? 6


### MS. MAUER: So, the LCC is just

-- I 7


### understand is just looking at shipments in

-- 8



### or a customer who' s purchasing

-- in the base 9


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


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


### the first year the standard takes effect. So, 12


### you found that for some cases those customers 13


### would see positive, and large positive saving s? 14


### But customers purchasing lamps or lamps and 15


### ballast or fixtures in later years would see

-- 16


### would not see positive savings. Is that what 17


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


### showing these positive savings for shipments in 19


### 2017, but then the NP V is showing

-- which is 20


### taking into account, of course, 30 years of 21


### shipments, is showing negative. 22

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### MS. COLLINS: Yes. So, let me show 1


### you one graph here that will probably make my 2


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


### analysis we see the mixture of things being 4


### shipped. 5


### (Off mic comments.) 6


### MS. COLLINS: So, we usually have a 7


### mixture of LCC results in every product class. 8


### And when we have a lot of fixture shipments 9


### that are replacing just lamps, then those LCC 10


### results tend to turn negative, so ther e are a 11


### lot more fixtures that are shipped in the 12


### standards cases. As you can see here, like 13



### five

- fold increase in fixture shipments in 2017 14


### in standards case as opposed to base case. 15


### MS. MAUER: I guess where I'm 16


### confused is even just in 2017, the assump tion 17


### is that a lot of those customers are having to 18


### buy a whole new fixture. 19



### MS. COLLINS: Yes. 20



### MS. MAUER: In the standards case, 21


### even though they would just be buying a lamp, 22

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### or a lamp and ballast in the base case. 1


### MS. COLLINS: Right. 2



### MS. MAUER: An d, yet, it looks like 3


### you're finding that those consumers have 4


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


### negative. 6



### MS. COLLINS: We can look in the 7


### calculations in more detail, if you would like. 8


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


### could just follow

- up with another question. 10


### Maybe kind of piggybacking on what

-- on 11


### Daniel's questions before. Just to understand, 12


### now in the NPV how you're taking into account

- 13



### - kind of the difference between base case and 14


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



### case of a mercury vapor baseline where the 16


### standard is I think having the effect of kind 17


### of accelerating a fixture replacement that 18


### would take place anyway, even absent a 19


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


### a new fixture in response to the standard sa y 21


### in 2017, but in the base case they would also 22

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### have to purchase a new fixture, say a metal 1


### halide fixture to replace the mercury vapor 2


### fixture. That purchase would occur, you know, 3



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


### So, you're accounting for t hat fixture 5


### replacement cost in the baseline, but in a 6


### different year than in the standards case? 7


### MS. COLLINS: So, LCC analysis is a 8


### little different from NIA analysis. It's 9



### ext ends for a longer period. Right? And we're 10


### trying to take into account the li fetimes of 11



### the

-- of a lot of ballasts and fixtures that 12


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


### because there are fixtures that are shipped in 14


### different years, there are ballasts that are 15


### shipped in different years. So, we kept the 16


### shipments of lamps th e same in both base case 17



### and standards case in order to be conservative 18


### in estimating what energy savings the rule is 19


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


### to other technologies and savings from the 21


### shift to that of technology, but because we 22

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### kept the lamp shipments the same that allowed 1


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


### not completely unaccounted for, they are 3


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


### shipments question part. 5


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


### to understand, so i n the base case customers 7


### that currently have mercury vapor probe

- start 8


### metal halide fixtures, at some point are going 9


### to have to replace those fixtures with a new

-- 10


### another technology. 11



### MS. COLLINS: Yes. We estimated that 12


### it will be replaced with anothe r HID 13


### technology. 14



### MS. MAUER: So, the costs of 15


### replacing their fixture, those are accounted 16



### for in the base case? 17



### MS. COLLINS: Yes. 18


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


### they're just occurring in different

-- 20


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



### mor e. It's not that a lot of fixtures are going 22

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### to be replaced in 2017. It's spread out across 1


### the years. 2


### MS. MAUER: Okay. 3


### MS. COLLINS: It's that either lamp 4


### or ballast exchange would bring about the 5


### entire fixture exchange. That's what drives the 6


### very hi gh installed cost in the very beginning 7


### of the analysis period because you cannot 8


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


### do that. And we are forcing everybody to 10


### exchange a fixture whenever they need just a 11


### lamp replacement for an old fixture. 12



### MS . MAUER: Even though then five 13


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


### then that same customer doesn't need to replace 15


### the fixture, then they're just replacing their 16


### lamp, or their lamp and ballast. 17


### MS. COLLINS: Yes, it's not 18


### everybody, it's just that particular

-- you 19


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


### MR. BROOKMAN: Okay? Daniel. 21


### MR. YOUNG: So, I'm just looking at 22

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### your graph here, and I guess I would expect 1


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


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


### years from then there would be that same spike 4


### to replace all those again? 5


### MS. COLLINS: That probably would be 6


### not really

-- it will be more gradual because 7


### there is a distribution of the lifetime, so it 8


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



### bei ng replaced by other technologies, so you 10


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



### MR. YOUNG: Sure. But I guess my 12


### point really is that I would expect that since 13


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


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


### some point you're going to be shipping fewer 16



### than in the base case. 17


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



### the

-- we could not project the increase in the 19


### lamp shipments to service all those new 20


### fixtures because this is, in general, a 21


### declining market, so some of those fixtures 22

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### will be retired earlier. So, as I mentioned 1


### earlier, we kept the lamp shipments the same in 2


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


### to service the influx of the fixtures, you 4


### would have to increase the lamp shipment 5


### signif icantly, and that would assume that they 6


### would be operational for a very long time, and 7


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


### So, this also implies that some of the fixtures 9


### would be retired prematurely; otherwise, this 10


### market would just be explo ding. That's 11


### definitely a limitation of the analysis, but we 12


### tried to fit the model to represent the reality 13



### as best as we can. 14


### MR. BROOKMAN: Additional thoughts 15



### here? Susan. 16



### MS. CALLAHAN: Susan Callahan from 17



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


### just looking for a little understanding here, 19


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


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


### looking at this going okay, I'm changing 22

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### essentially

-- I'm assuming you're using a CSL 1



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


### user of a 250 watt probe

- start lamp, why would 3


### I change to anything but a 250 watt pulse

- start 4


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


### they are equally efficacious when I put them in 6


### the fixture, assuming equal fixture. So, 7



### exac tly how am I saving money in all of this, 8


### especially since

-- I mean, as a lamp maker I 9


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


### one product to another, but I

-- part of me is 11


### trying to figure out where the cost payback is 12


### in this in the energy savin gs, because I don't 13


### understand the consumer changing to a lower 14


### wattage going from probe

- start to pulse

- start. 15


### MS. COLLINS: I think I might need to 16


### direct that question to the engineering 17


### analysis team. 18


### MR. MYER: Well, this is Michael 19



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


### opinion is that

-- Michael Myer from PNNL, by 21


### the way, that lumen output is not

-- the 22

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### driving market is wattage, where if they could 1


### get the same number of lumens for a lower 2


### wattage, and it was

-- they would not shift 3



### that w ay. 4


### MS. CALLAHAN: Right, but I get 250 5


### watts of probe

- start, 250 watts of pulse

- start. 6


### MR. MYER: I understand the wattages 7


### are the same, but they wouldn't

-- 8


### MS. CALLAHAN: But I get the same 9



### lumens. 10


### MR. MYER: But you could also get the 11



### same lumen s at 175 watts. 12


### MS. CALLAHAN: Not necessarily. I 13


### mean, I've got 40,000

-- or I've got lumens, 14


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


### guess my point is that there's no difference 16


### between 250 watts of pulse

- start lumens, and 17


### 250 watts of probe

- start lumens, so I'm going 18


### to force into a fixture change for which, where 19


### is my energy payback? 20



### MR. WALKER: This is Matthew Walker 21


### from Navigant. So, I'm hearing you say that 22

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### pulse

- start and probe

- start metal halide of the 1


### same wattage have the same light out put. Is 2



### that what

-- 3


### MS. CALLAHAN: Pretty much, their 4


### initial lumens, yes. 5



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



### we'll take that as feedback under advisement 7


### for the next stage. 8


### MS. CALLAHAN: Okay. 9



### MR. WALKER: The reason we were 10


### talking about energy sa vings right now is that 11


### the assumption was that when you move from 12


### probe to pulse, the efficacy was increasing, so 13



### the 250 watt

-- or the pulse

- start metal halide 14


### had higher light output, so you were able to 15


### reduce wattage. So, our

-- the pathway put 16



### forwa rd to engineering analysis was equal lumen 17


### reduced wattage replacement, and so we would 18


### certainly be wanting feedback on whether or not 19


### you think something else makes more sense. It 20


### seems like you're saying equal wattage, equal 21


### lumens. Perhaps there's even equal wattage, 22

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### increased lumens. So, I mean, we're certainly 1


### looking for feedback on that, on the expected 2


### customer response to an efficacy standard. 3


### MS. CALLAHAN: Thank you. 4


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



### if there are final comments on the NIA results. 6



### Louis. 7


### MR. STARR: Louis Starr, Northwest 8


### Energy Efficiency Alliance. I think the point 9


### she was trying to make is that the factory or 10


### whoever is not going to red o signs or lighting 11


### layout in order to accommodate the lower 12


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


### they're equal. It's just not

-- they're not 14


### going to redesign their system in order to 15


### accommodate a different layout, is probably 16


### more what the point is. Is that more what 17


### you're getting at? 18


### MS. CALLAHAN: The rearranging the 19



### ceil ing tiles is definitely part of it, but I 20



### think a closer examination of manufacturer's 21


### catalogues would indicate a greater similarity 22

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### in probe

- start, i n pulse

- start lamp initial 1


### efficacies than has been implied. 2


### MR. BROOKMAN: Thank you, Susan. 3



### MS. MAU ER: Susan, if I could just C

4

5



### MR. BROOKMAN: Joanna. 6


### MS. MAUER: Whereas, if you looked at 7


### mean efficacy, there may be a significant 8


### difference. Do you have a sense for what 9



### customers

-- do they pay more attention to 10


### initial lumens as opposed to mean lu mens? 11



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


### that's one of those things that

-- and I always 13


### defer to the marketing people, but yes, mean 14


### lumens are important, but I don't

-- I honestly 15



### don't know what drives that decision more. 16


### MR. BROOKMAN: Yes, please. 17


### MR. STARR: Louis Starr, N EEA. 18


### Typically, you're going to design your space 19


### based upon what your mean lumen output is. You 20


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


### operation and then not care what it's going to 22

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### be like in a year, so they are going to design 1


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


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



### it does

-- the initial is not really important 4


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


### output lumen is going to be over the lifetime 6


### of the thing, and what you anticipate your use 7


### is going to fall to. 8


### MR. BROOKMAN: Yes, please. Victor. 9


### MR. VARGA: This is Victor Varga from 10


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



### lots of customers to define what is a cost

12


### effective way to reduce energy in th eir 13


### facilities. And it is very interesting that it 14


### really depends on case

- by

- case basis, and 15



### customer

- by

- customer basis. Customers are very 16


### sensitive of what is their initial cash layout 17


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


### they do is they look at i t as what is my 19


### payback, return on investment, if you wish to 20


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


### they come back with numbers, you know, that 22

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### tells them that the return on investment maybe 1


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



### in the ev eryday business life, you know, we 3


### actually would like to have a payback of one or 4


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


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


### initiatives, and you would look at three and 7


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


### you really want to force the customer to make 9


### something to invest into that they are not 10


### going to see the return for another five years? 11



### And that's

-- I just wanted to put that thought 12



### in the discussion because it relates back to 13



### what is reall y the difference between a probe

14


### start and a pulse

- start lamp. It's very, very 15


### little, but if you think about you have to 16


### replace the ceiling tiles, or you have to 17


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


### large initial investment for the customer, and 19


### they might not actually see the payback. 20


### MR. BROOKMAN: Thank you. Okay. 21



### Susan, yes. 22

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### MS. CALLAHAN: To Louis' comment 1


### about mean lumens, I would be remiss in not 2


### admitting that the reason that pulse

- start 3


### lamps exist is because they do have superior 4



### lume n maintenance and higher mean lumens. 5


### MR. BROOKMAN: Okay. And I think we 6



### heard

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


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


### results here and see if there's any additional 9


### comments before we move on. Okay. 10



### MS. CO LLINS: Then I would like to 11


### introduce Hayden Cook, who will present interim 12



### MIA results. 13


### MR. BROOKMAN: Louis, yes. Hayden, 14


### hang on. 15


### MR. STARR: This is Louis Starr, 16


### Northwest Energy Efficiency Alliance. I was 17


### actually looking for a way to insert this 18



### c omment. This is more on the cost analysis when 19


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


### a lot of reliance on RS Means for coming up 21


### with the cost of labor and things, and I might 22

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### encourage you to look at other estimation of 1



### labor costs. I used to re view a lot of change 2


### orders and things, and the rule of thumb was 3


### that they would use Means for change orders, 4


### and they'd use another cost estimating for 5


### getting the job. The implication is that by 6


### using the Means it may over

- estimate the cost. 7



### It's a cons ervative way of estimating your 8


### labor cost, so you might consider looking at 9


### some different sources, or a variety of sources 10


### for estimating your labor. It will change your 11


### analysis, you know, not necessarily positive or 12


### negatively, but I think it will tend to 13


### increase your labor costs more as a proportion 14


### of the analysis than the equipment cost, which 15


### then can change your decisions on how cost

16


### effective things are. 17


### MR. BROOKMAN: In competitive 18


### environments, they're under

- bidding to win the 19



### contract. 20



### MR. STARR: Right. Well, in general 21


### it's just that yes, once you have something, 22

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### then you can

-- it's harder in a change order 1


### you are committed to a certain contractor; 2


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


### something, then it

-- and it typically see ms to 4



### be on the labor side a lot of times. 5


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


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


### MS. COLLINS: Natasha Collins. Louis, 8


### could you please refer us to the data sources 9


### for the labor costs that you mentioned? 10



### MR. S TARR: Yes, I can maybe talk to 11


### you later about some things to consider. 12


### MS. COLLINS: Thank you. 13


### MR. BROOKMAN: Hayden. 14


### MR. COOK: Hi, my name is Hayden 15


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


### briefly speaking with you about the 17



### manufacturer im pact analysis, or MIA. 18


### The main purpose of the MIA is to 19


### quantitatively assess the financial impact of 20


### energy conservation standards on manufacturers 21


### of HID Lamps. The MIA also attempts to identify 22

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### any potential manufacturer subgroups whose cost 1



### structur e differs significantly from the 2


### industry average. One such common subgroup is 3



### small business manufacturers. 4


### And, finally, the MIA attempts to 5


### quantitatively and qualitatively examine other 6



### non - direct financial impacts of energy 7



### conservation standards on manufacturers. These 8


### could include direct employment impact, 9


### manufacturing capacity impact, and a cumulative 10


### regulatory burden impact on manufacturers of 11



### HID Lamps. 12


### The methodology for the MIA is 13


### typically performed in three stages which are 14


### explained o n this slide. However, the key 15


### output of the MIA is the change in industry net 16


### present value, or INPV which results from 17


### energy conservation standards. 18


### Also during the manufacturer impact 19


### analysis we identified key issues that are 20



### central to manufacture rs of HID Lamps, and 21


### during our initial research in the interim 22

### NEAL R. GROSS
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### analysis we discovered these four key issues 1


### that are important to manufacturers. 2


### The first manufacturers question, 3


### the actual energy savings from replacement HID 4


### Lamps. Manufacturers believ e that new HID Lamp 5


### energy conservation standards may not lead to 6


### significant energy savings, since customers may 7


### replace a failed lamp with a more luminous but 8


### equal wattage lamp, therefore, not reducing the 9


### actual amount of energy consumed. 10



### Next, manuf acturers are concerned 11


### with the testing burden that could result from 12


### standards. Manufacturers expect new standards 13



### to increase the burden associated with 14


### compliance testing. 15


### Third, manufacturers believe that 16


### alternative technologies such as LEDs and 17



### fl uorescent lighting are already eroding the 18


### HID market, and higher prices for HID lamps may 19



### even hasten the switch to these alternative 20


### technologies. 21



### And on a related note, manufacturers 22

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### believe that standards for HID Lamps have a 1


### high opportunity cost, a nd by forcing resources 2


### toward upgrading existing product lines, 3



### manufacturers will have to divert resources 4


### away from products, from product innovation and 5


### emerging technologies such as these LEDs. 6


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


### floor to any comment s on the key issues that 8


### manufacturers face for HID energy conservation 9


### standards, or if there's any additional key 10


### issues that would like to be brought up at this 11



### time. 12


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


### to 74, just to refresh everyone's thinking 14



### about what the Department has identified as key 15


### issues. Additional thoughts on this? Daniel. 16


### MR. YOUNG: Daniel Young, California 17


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


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


### that is, indeed, the case, the Depart ment 20


### should try and account for the savings that 21


### come from a technology shift due to standards. 22

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### MR. BROOKMAN: Okay, thank you. 1



### Susan. 2


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



### NEMA. The

-- NEMA will make comments, will 4


### address testing burden in their writte n 5


### comments, especially in light of there not 6


### being a test rule. 7


### MR. BROOKMAN: Okay, thank you. 8



### MR. COOK: So, and then one more 9


### comment that DOE is seeking comment on. At this 10


### time, DOE is requesting comment on any 11


### potential small business manufacture rs of HID 12


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


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


### know of potential small business manufacturers 15


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


### DOE's analysis to identify those players. 17



### MR. BROOKMAN: No additional 18



### comments. 19


### MR. COOK: Okay. 20


### MR. BROOKMAN: Okay. 21


### MR. COOK: At this time, I would like 22

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### to turn it back over to Michael Myer to finish 1


### up with the NOPR analyses. 2


### MR. MYER: We spent most of the 3


### morning discussing the interim analysis. This 4



### s lide shows what we'll be doing in the NOPR 5


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


### stands for Notice of Proposed Rulemaking. It's 7


### the next phase. We'll obviously revise the 8


### interim analysis based on the feedback that we 9


### get today, as well as in writ ten comments, but 10



### then we also do a series of additional 11


### analyses, a customer subgroup analysis, 12


### manufacturer impact analysis which Hayden just 13


### discussed, the utility impact analysis, the 14


### employment impact analysis, the environmental 15



### assessment and emissio ns monetization, and then 16


### finally a regulatory impact analysis. 17


### This slide walks through all the 18


### same things again, just provides a little more 19


### detail, so the customer subgroup analysis, this 20


### looks at what the potential of customers that 21



### could be affecte d. Th e s e are end

- users who 22

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### could be disproportionately affected by a 1


### standard, and we'll discuss their item for 2



### comment in a second. 3


### Then we also look at utility impact 4


### analysis, and this looks at the effects on 5


### generation capacity of the utilities as th e 6



### effect of a standard. Then we also move into 7


### the employment impact analysis. MIA looks at 8


### the direct employment effects, employment 9


### impact analysis looks at the indirect 10


### employment effects on national employment. 11



### We then move into environmental 12



### assess ment which actually looks at the effects 13


### on airborne pollutant emissions as a result of 14


### the standard, that's closely related to the 15


### monetization of those pollutants, including 16


### carbon dioxide and nitrogen oxides. 17


### And, finally, we'll do a regulatory 18


### impac t analysis which looks at the potential 19



### for non

- regulatory approaches to saving

-- 20


### issue number 28, customer subgroups. We've 21


### currently identified a large number of 22

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### potential subgroups. The final analysis in the 1


### NOPR will be a smaller number of potential 2



### s ubgroups, but we've listed a bunch here, and 3


### we'd also like any feedback of any potential 4


### subgroups that could be disproportionately 5



### affected. These include

-- we tend to be 6


### identified high

- end retail, grocery, big

- box 7


### retail, schools, owners of roadway an d street 8


### lighting, et cetera. And I will pause for 9



### comment. 10


### MR. BROOKMAN: Thoughts on adversely 11


### affected subgroups? 12


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


### valuing of airborne emission reductions. TSD is 14


### pretty thorough in this chapter and how the 15



### monetiz ation comes about. Essentially, the 16


### middle section provides a good example. For 17


### carbon dioxide, the most recent interagency 18


### estimates range anywhere from $6.2 to $78.7 per 19


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


### the approaches for monetizing the em ission 21


### savings due to energy conservation standards. 22

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### MR. BROOKMAN: Any thoughts on 1


### monetization? No thoughts here, okay. 2


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


### the presentation to Lucy deButts. 4



### MR. BROOKMAN: Daniel? 5


### MS. deBUTTS: I just wanted to close 6


### basically by saying thank you to everyone who 7


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


### of meetings going on and a lot of industry 9


### events right now. 10


### We do appreciate all of the input 11


### that we heard today, your interesting ideas, 12


### and any data or any citations to the data 13


### sources that you could provide us with would be 14


### great. Back to Doug. 15


### MR. BROOKMAN: Yes, just so thanks to 16


### all of you, a very productive meeting, and 17


### really appreciate the sense of cooperation and 18


### disclosure. Safe travels. I'll see y ou in the 19



### future. Take care. 20


### (Whereupon, the proceedings went off 21



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

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