U.S. DEPARTMENT OF ENERGY

OFFICE OF ENERGY EFFICIENCY AND

RENEWABLE ENERGY

APPLIANCE AND EQUIPMENT ENERGY EFFICIENCY STANDARDS

PUBLIC WORKSHOP TO DISCUSS THE ENGINEERING ANALYSIS FOR ENERGY CONSERVATION STANDARDS FOR FLUORESCENT LAMP BALLASTS

FRIDAY, MARCH 17, 1995

U.S. Department of Energy Forrestal Building Room 1E-245 1000 Independence Avenue Washington, D.C. 1

TRANSCRIPTION SERVICES 1831 Ivy Oak Square Reston, Virginia 220902

PANEL: Terry Logee, Presiding Official Program Manager Office of Codes and Standards Carl Adams Director, Appliance Standards Division Office of Codes and Standards Cyrus Nasseri Program Manager Office of Codes and Standards Eugene Margolis Attorney Office of General Counsel Barbara Atkinson Lawrence Berkeley Laboratory Issac Turiel Lawrence Berkeley Laboratory3

ATTENDEES: Michael McCabe Department of Energy James Raba Department of Energy Bryan Berringer Department of Energy [Present via conference call hookup:] Francis Rubenstein Lawrence Berkeley Laboratory James Logan Lawrence Berkeley Laboratory William T. Black Copper Development Association, Inc. Peter Bleasby OSRAM Sylvania, Inc. David Brender Copper Development Association, Inc. Edwin Brush Copper Development Association, Inc. Wayne Causey Howard Industries, Inc. Lake Coulson NEMA4

ATTENDEES: Gene Foley Alliance to Save Energy Howard Geller ACEEE Ted Jones Alliance to Save Energy Don Leonard NEMA Mark Perlis NEMA Counsel J. Prideaux Valmont Electric Michael Stein MagneTek Dail L. Swanson Aromat Corporation Steve Treado NIST Don Widmayer Don Widmayer & Assoc., Inc. Steve Wilcox NEMA Bob Wisbey Advance Howard Wolfman Motorola Lighting5

I N D E X PAGE Introduction - Terry Logee 6 Speakers:

Isaac Turiel Introduction to LBL's engineering analysis 19 Barbara Atkinson Engineering/Economic analysis 58 Isaac Turiel Equal light output correction Sensitivity analysis General discussion items6

P R O C E E D I N G S 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 (9:39 a.m.) MR. LOGEE: Good morning, I'm Terry Logee, Program Manager in the Office of Codes and Standards. On behalf of the Department of Energy, I'd like to thank you for taking the time to participate in this public workshop concerning the Department's energy conservation program for lighting and appliances.

The purpose of this workshop is to discuss the fluorescent lamp ballast engineering analysis with stakeholders and persons who have an interest in fluorescent lamp ballast energy conservation. A public notice of this workshop was published in the Federal Register on Monday, March 6, 1995.

The comments received here today and those submitted during the written comment period will assist the Department in developing the proposed rule.

The written comment period for the engineering analysis ends March 31, 1995. All7

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 comments submitted on this analysis will be

considered before DOE publishes the final rule. Late comments will not be considered due to time limitations.

As the presiding official for this workshop, I will set the guidelines for conducting the workshop and provide other pertinent information.

In approximately one week, a complete of the transcript of the workshop will be available for inspection and copying at the Department of Energy's Freedom of Information Reading Room, located in Room 1E-190. Anyone wishing to purchase a copy of the transcript may make arrangements with the court reporter.

This workshop will be conducted in accordance with Section 553 of the Administrative Procedures Act, 5 USC Section 553 and Section 501 of the DOE Organization Act, 42 USC, Section 7191.

To provide the Department with as much pertinent information and as many views as can be reasonably obtained, and to enable interested8

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 persons to express their views, the workshop

will be conducted in accordance with the following procedures:

The focus of this workshop is on the analysis methodology, the maximum technologically feasible designs, the data and the ballast classes. We will not discuss what the energy conservation standards for ballast should be. That is the purview of the DOE policymakers.

We will discuss the agenda first and expand if necessary to provide everyone with an opportunity to discuss their topic. DOE topics will remain on the agenda as lead presentations in their respective areas.

We'll take an hour lunch break at a convenient time near 12 noon. It will reduce interruptions if everyone wants to speak waits to be recognized, and please remember to state your name first for the court reporter.

Side conversations should be kept to a minimum to avoid interrupting the presenter; if a lengthy private discussion is needed, move to9

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 a corner of the room or out of the room. It may be necessary to cut off debate on some topics to maintain the schedule. There will be some time at the end of the workshop to discuss burning issues. I encourage all persons present to participate as much as possible so that the Department may get a full spectrum of opinion on these topics.

This workshop is scheduled to end by 4 p.m. or sooner,-if all items have been completely discussed. Topics which have not been completely discussed by 4 p.m. can be addressed in the written comments. The written comments are due by March 31st 1995, and late comments will not be included in any revised analysis.All written comments will be available for public inspection at the DOE Freedom of Information Reading Room. Phone number 202/5866020. Written comments should be addressed to the Department of Energy as noted in the Federal Register notice for today's workshop.10

2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Eight copies of the comments are requested.In addition, the Department would appreciate an electronic copy of the comments. The Department is using WordPerfect 5.1. No faxed comments will be accepted.

Any person submitting information which he or she believes to be confidential and exempt by law from public disclosure should submit one complete copy and six copies from which information claimed to be confidential has been deleted. In accordance with the procedures established at 10 CFR 1004.11, the Department of Energy shall make its own determination as to whether the information shall be exempt from public disclosure.

In keeping with the regulations of these facilities, there is no smoking allowed in this room. Again, we appreciate the time and effort you have taken in preparing for this workshop, and are pleased to receive your comments and opinions.11

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 I would like to reiterate, the purpose

of the workshop is to discuss the fluorescent lamp ballast engineering analysis.

Today the DOE attendees are Eugene Margolis, on my right, from the Office of General Counsel; Carl Adams and Cyrus Nasseri from the Office of Codes and Standards; Dr. Steve Treado, from the National Institute of Standards and Technology; Barbara Atkinson and Dr. Isaac Turiel from the Lawrence Berkeley Laboratory.

Later, Jim Logan, Peter Biermier and Dr. Francis Rubenstein will join us via telephone link to Berkeley, California.

The engineering analysis is only part of the analysis supporting the eventual rulemaking.

The next analysis will provide the energy savings potential of the proposed standards levels after correcting for information from this workshop. We will also analyze the impacts of the proposed standards on manufacturers, utilities and consumers.12

2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 The analysis is completed with the

publication of a technical support document and the Federal Register Notice of Proposed Rulemaking for fluorescent lamp ballasts. A public hearing and written comment period will follow the Notice of Proposed Rulemaking.

At first, I would like to proceed around the room with introductions, and then we'll go to the agenda.

DR. TREADO: Steve Treado, National Institute of Standards.

MR. ADAMS: Carl Adams, the'Appliance Standards Division of DOE.

MR. WIDMAYER: Don Widmayer, of Don Widmayer & Associates, Incorporated.

MR. GELLER: Howard Geller with the American Council for an Energy Efficient Economy. MR. COULSON: Lee Coulson, NEMA Government Affairs.

MR. BLACK: Bill Black, Copper Development Association.

MR. BRUSH: Ned Brush, Consultant to13

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 the Copper Development Association. MR. BRENDER: David Brender, Copper Development Association.

MR. CAUSEY: Wayne Causey, Howard Industries.

MR. SWANSON: Dail Swanson, Aromat Corporation.

MR. PRIDEAUX: Jerry Prideaux, Valmont

MR. BLEASBY: Peter Bleasby, OSRAM

MR. PERLIS: I'm Mark Perlis, Counsel

MR. STEIN: I'm Mike Stein with MagneTek, and I chair the Ballast Section of NEMA. MR. WISBEY: Bob Wisbey, from Advance.

MR. WOLFMAN: Howard Wolfman, Motorola Lighting. DR. TURIEL: Isaac Turiel, Lawrence Berkeley Lab.

MS. ATKINSON: Barbara Atkinson, Lawrence Berkeley Laboratory.14

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 MR. NASSERI: Cyrus Nasseri, Office of

Codes and Standards.

MR. MARGOLIS: Eugene Margolis, DOE's Office of General Counsel.

MR. LOGEE: Thank you. Let's get to the agenda, and other changes -

Oh, the back row there. [From the audience]

MR. RABA: Jim Raba, Department of Energy, Appliance Standards Division.

MR. BERRINGER: Bryan Berringer, Department of Energy, Appliance Division.

MR. WILCOX: Steve Wilcox, NEMA's economics.

MR. LEONARD: Don Leonard, also NEMA economics.

MR. JONES: Ted Jones, the Alliance to Save Energy.

MR. FOLEY: Gene Foley, the Alliance to Save Energy.

MR. LOGEE: Thank you. Sorry for excluding you.

Now, the agenda.15

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Mike, did you want to do a very quick

presentation, because it impacts the agenda in the sense of items that you wanted to put on the agenda? MR. STEIN: These are the highlights that we wanted to get on; we didn't have a copy of your agenda, so we wanted to make sure that it's covered; and we'll cover this quickly and then we can make sure somehow these fit in.

[Overhead] As this light warms up -- we sort of broke the analylgis into three areas; one was the input data then the next is the efficiency data, and lastly the output data which is in the tables; and on the input data there were other things that were obviously included, but we want to make sure we talk about the energy costs and the operating hours and the rationalization for the operating hours.

It wasn't clear from us, trying to decipher the EIA information and the information that you had in the writeup where that came from. Discount"rates, we still have a problem16

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 with some of the low discount rates we're using, we'll discuss some reason why; and the rationalization for the ballast service life, which we think is the right approach, and we don't necessarily need some more comments except we agree with the particular approach. And if anyone else has-some input.

[Overhead] We had some problem with some of the efficiency data; the BEF numbers for energy saving lamps, we found some errors in some particular items; and that's probably our fault; we didn't think we had sufficient data because we only had a few data points rather than the reams of data we had for the standard lamps, so we didn't supply any data; and it looks like we should have supplied something.

So our'intention is, by the 31st, is to have the data, did we want to use it or not; we've actually -- you know, really five data points that we'll look at correcting; maybe a couple more if we get into a little more detail. We didn't have a chance to study everything.17

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 On the fixture watts, we made an

adjustment for operating a fixture for three and four lamp ballasts, but we didn't do it for one and two lamp ballasts.

The one and two lamp ballasts are used in the same fixtures as the three and four lamp ballasts.Most of the fixtures are two by four troughers and either three or four-lamp fixtures. So we think those should be adjusted for the one and two lamp four foot. The eight foot we have no problem with what you did.

[Overhead] Lastly, on the normalized watts, you may think there's a better way to do it; we're not sure it would impact on the results, but we just want to discuss that a little bit.

Lastly, on the output data we just try to do some reworking of -- we just table 110 as an example.

Our intention is to go through all the tables and supply information that we think should be corrected for not only as we showed in18

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 110, but we didn't think it was the time or

place to just dump a whole bunch on the table; we just wanted to show you some of the things we did. So we took 110 where we had to make some corrections on the BEF; we put the operating hours should be adjusted and we did that.

Then when we get to 4.10, its counterpart in the summary where you actually get into the payback in lifecycle costs, we added the corrections that we did in 110, and then we did some of the sensitivity analysis; we think there should be more done, but just as an example of some of the sensitivity analysis that can be done -- and these will be on the handouts when we get to those topics.

That's basically the things we think are important to discuss; and it looks like it melds into your.outline, and we'll hit them as we get to them.

MR. LOGEE: Okay. Thank you, Mike. Does anyone else have any other topics that they don't see that they would like addressed, so we can specifically place them on19

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 the agenda at this time? [No response.] MR. LOGEE: Okay, Ike, it's - DR. TURIEL: Should we contact LBL? MR. LOGEE: Is it time to contact Will be able? Do you think Jim will be there?

DR. TURIEL: It's close. They might be there early.

MR. LOGEE: Okay, let's try it, then. [Attempting phone connection to LBL.] MR. LOGEE: Barbara has asked me how we're going to integrate this, the NEMA presentations into what we have; and it's my thought that we would just put them in as naturally occurs. I think that will work.

If that doesn't seem to be working, maybe we'll just ask you to stand up there and make sure that we've got all of your points covered. MR. STEIN: I think it should fit in well with what your outline is.

DR. TURIEL: Barbara and I were going to take a very short amount of time, say a few20

2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 general comments that might stave off a lot of

questions, possibly.

MR. STEIN: What, five or ten minutes, maybe? DR. TURIEL: Sure. Because most of the time is for discussion, for asking questions and us trying to answer as best we can.

MS. ATKINSON: Also I wonder, were there questions just on the format of the tables; if people needed to walk through especially the Table 4 series, I could do that, but that's optional.

MR. LOGEE: Barbara is asking if anyone is having trouble understanding the tables; she can walk through the format of the tables at some point in this discussion.

I think that's probably a good idea just to do that when you get up there and you're doing your presentation; that won't take that long. Ike, can we, ran than wait for the telephone to be turned on, why don't you get started.21

2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 DR. TURIEL: Good morning. [Overhead] This seems a little more formal than the other two times we met -- we'll try and ignore all of these microphones after a while.

I was going to talk about three items, from the input, as you can see up here. Show you a little bit of how we got the BE and watts inputs, and something about the ballast prices, and third, what we mean by 1050 percentile on the BEFs. [Overhead]

In order to do the life cycle cost analysis, there.are quite a few inputs that are required. I'm just listing them here. I'm only going to talk, as I said, about some of those, the three I listed out of all those inputs. Barbara will probably mention some of the others; and as we get along I'm sure we will be talking about everything on that list.

[Overhead] I'm going to have to say something now about the methodology for getting essentially22

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 the watts input and the BEF values.We started out, for the energyefficient magnetic and cathode cutout ballasts, what we did was we took the average BEF; that's what was used in the tables that have been provided to you.

That's not true for the electronic ballasts; in that case, we have several possibilities that we looked at: What we called the 10 percentile, 50 percentile and the maximumefficiency. You notice we don't call it maxtech anymore, so I hope that pleases you. That's really a misnomer, anyway; we should have never really called it max-tech. Maximum efficiency.

What's the highest efficiency that can be achieved? We held a lot of discussions for those weren't at our first two meetings, about whether to call that max-tech or not. And we agreed that really it should just be maximum efficiency.

So the 10 percentile, when you choose that particular BEF and you see then your life23

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 cycle cost tables, it means that 90 percent of

the ballasts on the market have BEFs that are as good as that or better.

When we go to the 50 percent, you're right at the midpoint, and half the ballasts on the market have BEFs that are greater than that BEF. Of course when we get to max-tech, that's the best you can do.

So that's the explanation of what those mean, and once we chose the BEFs from various databases which we'll talk about, I'm sure as we go along, we then selected what BF should you use for each of the four technologies; being energy efficient magnetic, cathode cutout, rapid start electronic, instant start electronic. Those are the four categories.

After that was done, the next step was to use the equation that BEF is equal to the ballast factor divided by the watts input, to calculate the watts. That was the third quantity needed.

So that gave the watts input, which of course was the main number to be used when24

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 calculating the cost of operating the ballast

because of the life cycle cost and payback period. The other step we did was to normalize the input watts to equal light output of 95 percent; and the reason for doing that is that the ballast factor in most cases drops when you go from energy efficient magnetic down t electronics, typically from 95 percent maybe down to 88 percent. So we adjust it back up to 95 percent, on the electronic ballast.

The last bullet says where we got some of the data; a lot of it came from NEMA. Seattle has a big database, we used that for electronic ballasts, and we also looked at product literature and New York State Energy Office data when we got into magnetics and cathode cutout ballasts.

And also for the energy saver lamp ballasts which we were not provided. As Michael said a little earlier, we were not given any data from NEMA, so we had to go to those databases.25

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 MR. LOGEE: The telephone is on. MR. WISBEY: Bob Wisbey. One question; in some of the electronic ballasts, where you had data from NEMA and from the Seattle database, did you blend the two together?

DR. TURIEL: No. MR. WISBEY: Or did you chose one or the other, or?

DR. TURIEL: We didn't blend them; we chose one or the other; and I could go through the list, maybe after we do these, and say for which product classes we chose them. You can probably see it, I'm sure.

MR. WISBEY: How did you decide which one to choose?

DR. TURIEL: When we had a complete dataset from NEMA we chose it, but there were a lot of cases where there were not complete datasets from NEMA; in other words, it didn't cover all the technologies.

MR. WISBEY: Oh, okay. DR. TURIEL: They were missing. MR. WISBEY: Because I was going to26

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 say, what's the definition of complete to you? DR. TURIEL: Yes, it didn't cover all the technologies.

MR. WISBEY: In some cases we may have submitted 16 datapoints in a category, in other cases, only 2, or whatever; but your definition of complete was where all --

DR. TURIEL: All the technologies were covered, correct. I tried not to mix any particular product class with two different datasets. MR. WISBEY: Because I was going through and comparing, the BEF values that you used for the 10, 50 and maximum, and sometimes I'd find perfect correlation with the NEMA data and sometimes I wouldn't. So what you did is sometimes used the NEMA and sometimes the Seattle. DR. TURIEL: Right. And some other cases, too, I just remembered. There were some cases where the NEMA data didn't seem to be consistent in the sense that the BEF did not always go up as you went down through the higher27

2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 technologies into energy efficiencies. I think

we talked about that on the phone.

MR. WISBEY: Yes, we talked on the phone about -

DR. TURIEL: So that was another case where I would not use. it.

MR. WISBEY: -- a couple of the limited data point things that seemed to be a problem.

DR. TURIEL: Right. MR. STEIN: Before you leave this, one of the things we talked about as a group is normalizing -- we agreed upon and talked about in California. I'm not sure it necessarily is right to normalize up to 95 percent, and it actually may make sense to normalize down to something like 88 percent.

Because the reason that the electronic ballasts start out with a lower ballast factor is when you get a fixture, when you get the thermal effect of the fixture, the electromagnetic ballasts tend to heat the lamps a little more than the electronic ballasts that are on the downward side of the curve, and the28

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 light output drops off more from the magnetic

ballast than the electronic ballast; so we thought it would make more sense to drop it down than increase it up.

We didn't have a chance to do a study that, let's say maybe we do that ourselves in one of our submittals is -- let's normalize it to the 88 or whatever we think it should be, and see if it makes any difference.

Because if it doesn't make any difference, who cares? Because we're sort of putting it together, and I'm not sure how much of difference it will make.

DR. TURIEL: So you're bringing that up as a possible issue.

MR. STEIN: We may present that kind of data as one of the alternate proposals, and if it make a difference then we'll point it out, and if it doesn't make a difference we'll say it doesn't make a difference.

DR. TURIEL: I think it does make a 

### difference. And I think it makes a difference 23 1 in the ratio of the 88 to 95, that will affect29

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 your - MR. STEIN: When you get to the

quantitative numbers at the end of payback and lifecycle, if i€'s 5.1 years versus 5.2 years, something like that, that's not a big deal. But if it's five years versus seven years, then that's - DR. TURIEL: I think it's going to be, according to that ratio you just gave, about a 7 percent difference. But we can talk about that.

MR. STEIN: We'll look at some numbers, and if we think it's important then we'll point that out. MR. WISBEY: One of the variables that you don't have listed up there, one of the points you don't have listed up there, is the fixture effect -- I assume that's covered on a separate -

DR. TURIEL: Yes. MR. WISBEY: Because obviously that's a key variable.

DR. TURIEL: Yes. [Making telephone connection]30

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 [On the line:] MR. LOGAN: This is Jim

Logan. DR. TURIEL:

MR. LOGAN: DR. TURIEL: MR. LOGAN: MR. STEIN: MR. LOGAN: DR. TURIEL: Hello, Jim, this is Ike.

Hi, Ike. How are you. Good. Good. Francis is here with me. Hi, Francis. [Adjusting volume levels] DR. TURIEL: We kind of began; we had a little problem with the phone at first. So you lost about the first five minutes.

MR. LOGAN: Okay. [Overhead] DR. TURIEL: So speaking about equal light normalization, as Michael is doing, I have a vugraph about that. What I'm showing here is an example of what we did to try and make that clear, and maybe we can discuss the question that Michael Stein brought up.

The example I have here is for a magnetic ballast with an energy saver lamp. As31

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 I said, this is a case where we had to use data

from the New York State Energy Office and product literature to obtain data for energy saver lamps.

The general procedure we did was, again we chose the average BEFs for magnetic ballasts -- we're talking about, in this case, for magnetic ballasts, as an example. We then chose the BF and then calculated the watts input, then we normalized watts to 95 percent ballast factor.

Here's an example for ballasts operating 2F40 212, as you see here. And we'll look at two different cases, to see what happens if you start at.a BF of 90 percent, what happens if you start at a BF of 88 percent.

In case 1 -- first of all, the average BF for that set of data we looked at was 1.24, for energy-efficient magnetic ballasts. If we choose a BF of 95 percent in this example, calculate the watts, you get 76.6 watts. Suppose you were to take the same BF but now say, well, let's say BFs should be 88, as32

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Michael was suggesting, what would happen then? Well, then you calculate the watts and you find it's 71 watts; but then you normalize that watts up to 95 percent, and what do you get? You get 76.6. You end up with the same watts in this example whether you were starting out at 88. But in this example, we normalized to 95. So what I'm trying to show here is actually a little different than what you brought up, Michael.

I'm trying to show that if you start off at a different place but normalize up to the same place, you'll end up with the same watts.

MR. STEIN: We went through that calculation; we agree with that.

DR. TURIEL: Okay, but your example is a little different.

MR. STEIN: Actually with the energysaving lamps, a ballast that will have a 95 percent ballast factor on standard lamps is going to actually have about 89 percent ballast factor on energy saving lamps. And I agree, once you normalize things those things wash out33

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 with each other. DR. TURIEL: Right. MR. STEIN: It's just a matter of when you normalize the electronic ballast and the magnetic ballast to a different point you have differences in the energy consumed; and really the difference in energy consumed determines the payback. DR. TURIEL: Right.

MR. STEIN: And the magnitude of that difference is the kind of thing we're going to look at. DR. TURIEL: Correct.

It just happens I was thinking about that issue that you brought up, and made a vugraph right before I left, which will address that. [Overhead]

Here's a comparison of what you're talking about, I believe this will answer it: Here we're looking at 88 percent BF as to what we're going to normalize it to, rather than 95 percent. The numbers in this table are looking34

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 at the same ballast that we looked at a moment

ago; but here we're normalizing up to 88 percent. [Retrieving pointer]

So starting off with energy-efficient magnetic, this is cathode cutout electronic. Same BEF as I just showed you a moment ago, but here we're going back to the example of 88 BF and we have 71 watts, you might remember just a moment ago.

These are the BFs for these other two technologies, and here's your BF that you start with, and the watts you get; and again, the BF and the watts.

Now, if you normalize these wattages here to 88 percent ballast factor, you end up with these three numbers here for the watts; 71 watts, 66.15, 66.75. Now, on the right hand side this is delta watts, relative to 71 watts here at the baseline. So I'm taking 71 minus 66.15, gives me the 4.85; and 65 from 71 gives me 5.25. I'm looking at delta watts because that's the crucial number, as we all know.35

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 So this is the amount of watts saved

here, 4.85 watts in this case; this technology, 5.25. Now on the right hand last column, I'm looking at the delta watts for the case when we did at 95 percent. And as you see, it's 5.2, 5.6. It's a little higher, and that difference is really exactly the ratio of 95 to 88.

So to answer the question that you brought up earlier, Michael, yes, there will be an effect if we were to normalize everything to 88 instead of 95; the effect is exactly that ratio, 95:88.

So if we changed it to 88, we would have delta watts 7 percent lower, and therefore total energy use would be 7 percent lower, paybacks would go up 7 percent -- so it's not a giant effect, but yes, there is an effect.

MR. STEIN: Okay, so you're actually on the same -

DR. TURIEL: Yes, I was thinking about that 23 1 MR. STEIN: -- we are, and we have to36

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 crunch the numbers out to put them in the table.

See how the numbers come out.

DR. TURIEL: Right. We hadn't reached any conclusion as to whether this should be done, but it was something I was thinking about right before I left; you know, what would be the impact. MR. STEIN: Okay. Well, there are really two cases; one case to argue about is how the light drops off just for a 95 ballast factor on standard lamps; and then you have the fact that energy saving lamps on these same ballasts have a lower ballast factor to start with, and they maybe even should be normalized to a low level. So we'll do some what-ifs and we'll give you some feedback on what the numbers look like to us.

MR. CAUSEY: Ike, I was a little bit concerned about your normalizing there. You don't take in consideration the topology of the design. 23 1 MR. LOGEE: Could you identify37

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 MR. CAUSEY: Yes, Wayne Causey, Howard

Industries.

I was a little bit concerned about doing normalizing back and forth there, and of course you're looking not at lamp power but at ballast power.

DR. TURIEL: Input to the ballast. MR. CAUSEY: For instance, when you take a low ballast factor and then normalize it up to a higher ballast factor, you're not taking into consideration the I-squared-R laws; that the power really goes up considerably faster than linear.

DR. TURIEL: I'm not sure I get your statement.

MR. CAUSEY: Well, you're assuming if you take a certain ballast, and a low ballast factor of 8 3, and you want to know what the power is that -

DR. TURIEL: You mean this one here -- MR. CAUSEY: 8 8. DR. TURIEL: Right. MR. CAUSEY: So you're assuming, you're38

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 extrapolating through the ratio there, you're

not taking into consideration that the energy lost in the ballast goes up faster. It may go up to the I-squared-R.

So the loss that you come up with when you go from a ballast factor of 83 to a ballast factor of 88 is probably low.

MR. RUBENSTEIN: This is Francis here. I'm not sure that's true. If you listed all the ballasts out there with low ballast factors, are you saying that those would necessarily have higher BEFs than an equivalent product that has a normal ballast factor?

That's not my understanding, anyway. I hear what you're saying about the I-squared-R losses, but I don't see that actually happening in reality.

MS. ATKINSON: Because we held the BEF constant, as an assumption, for adjusting the wattage. DR. TURIEL: Right.

MR. CAUSEY: Yes, but the BEF is going to change as you run the ballast factor up, the39

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 system. You can't get around the fact, the more

copper wire you've got in the system there, and you're confronted with a limited volume to work in, as you try to run that ballast factor up, it's going to become less efficient, you're going to dissipate more energy in the windings. I don't see how you can get around it.

And energy goes up. If you drive to a higher ballast factor, that means that you're dumping more energy into the lamp, so that means the input current has got to be higher to the ballast, and you've got an I-squared-R loss there. It's going to go up faster than linear.

DR. TREADO: Steve Treado from NIST. I got in a little late on all this, I haven't been along with you on all of the discussion; but isn't this normalization -- you're not talking about physically changing an actual ballast.

Aren't you adjusting an entire lighting system for the fact that you would get less light from one ballast versus another? So you're not saying you're physically going to have them change the performance of a ballast.40

2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 DR. TURIEL: Well, this is something

that we discussed at the other two meetings. It's an issue, I guess, which not everybody necessarily agrees how you do this. The fact is that if your ballast factor is going down you have to somehow account for the fact that you have less light output. How do you do it?

One way to do it is, there are some ballasts, as you drive up the power to the ballast, you can get a higher BF and a higher watts; and in some cases you can see, if you look at that --

MR. CAUSEY: The problem is you're trying to compare apples and oranges, and you're trying to extrapolate to a level playing field, and you're not making that extrapolation properly. MR. STEIN: The reason we're doing it is to get equal light on the surface: And to get equal light on the surface, you want to somehow compensate for the fact he may need more fixtures and this is the way to compensate for more fixtures.41

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 But I don't necessarily agree with

Wayne if he's referencing magnetic ballasts, because there are two types of losses in magnetic ballasts; energy-efficient magnetic and the cathode cutout, and even some electronics have magnetics in there, and the I-squared-R loss may be a little bit of a factor, but the steel losses don't change.

We're not changing the voltage or the steel losses basically remain constant, so even though your I-squared-R loss goes up, probably the whole proportion is not going to be drastically different by changing the light output. MR. CAUSEY: I disagree with that. You've got about the same problems with magnetic as you've got with electronic. You've got copper windings and the magnetic ballasts I-squared-R come in play there, you're going to work the steel.

If you try to get a higher ballast factor, you're going to work the steel harder. You're going to dissipate, you're going to have42

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 greater losses. In particular the I-squared-R. You just can't take a given ballast that's got a ballast factor of 83 and run the input power up on that ballast until you get an 88 and use the calculation that you've got there to predict what the input watts is going to be. It's going to be higher than what you're predicting.

DR. TURIEL: So you're saying input watts would be higher than 66?

MR. CAUSEY: Sure. MR. WISBEY: I disagree with Wayne. We've done a lot of tests like this over the years; and for a given type of ballast design, as it's adjusted to different output levels the differences in efficiency are very minimal.

There are sometimes measurable differences, but they're very minimal. Really because for a given ballast -- and we'll use the magnetic as the example because it's the easiest example, there's less variables.

If you simply take a ballast and adjust the ballast factor by the simplest method, the43

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 active power that's being delivered to the lamp

arc goes up in direct proportion. Copper losses go up as a square function, as Wayne points out, but that's one of the consumptions of watts that doesn't make light.

The steel losses don't change, and the other thing that says constant is the FOMA power, which is-a power that's being consumed that does not change as a function of the level.

For the BEF changing as a function of the ballast factor for a given type design is very minimal.

DR. TURIEL: Okay. Wayne, do you want to-- MR. CAUSEY: I don't agree with the statement. You know, if you want to talk about the amount of power required that actually goes into the lamp to increase the ballast factor, you're absolutely right, you can use the equation you've got; it's essentially a linear relationship.

But unfortunately all the energy isn't going into the lamp, and a good bit of it is44

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 being dissipated in the ballast. The steel losses are not going to change substantially; but the I-squared-R losses are going to change.

DR. TURIEL: Wayne, can you provide some information about what you think that should be?

MR. CAUSEY: Yes. We would be happy 

### to. DR. TURIEL: Then we'll take a look at 

### that. MR. CAUSEY: It's a major consideration in designing ballasts and trying to maintain a high BEF. °

DR. TURIEL: Wayne, could you give some rough idea of what you think it might be, like 10 percent higher or 5 percent higher, 50 percent higher?

MR. CAUSEY: I'm not sure; I can definitely get you some data on it, though.

MS. ATKINSON: This was certainly something we considered; and in a sense to address your question, we didn't look at fixture45

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 effects in this context. We were looking at the

lamp ballast BEF. And we considered whether - in a sense it's a hypothetical ballast when you are adjusting for the ballast factor.

You're assuming that there could be a ballast on the market. that would have that ballast factor at the same BEF, and I think we did search through some of the lists.

For some product classes we found a ballast, in some we did not. So it is a question we do have to the industry. Whether we're being realistic assuming that BFs for some of the product classes could be .95.

DR. TURIEL: Any other comments, questions on this one?

I had one other vugraph on prices, I 17 thought. 18 I had one other transparency, but I 19 can't find it, so let me just -- it has to do 20 with the prices, essentially. I'll read off 21 what I have here. This is: Methodology to 22 Obtain the Ballast Prices. 

### 23 1 want to say that we got most of that46

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 data from the LRI survey, that those people that

have come to the meetings are familiar with. It's a subcontract that we had with LRI. And the data sources for that were ballast manufacturer, luminaire manufacturer, lighting management company.

The survey sent the questionnaire to a number of companies of those three types.

LRI also provided us with markups to use to get to the end user prices fox each of those categories, and the final prices were calculated by waiving two sets of ballast prices from two different approaches; one is going through lighting management companies to the end user; another one was through fixture OEM-type companies to the end user.

Unfortunately I don't have that vugraph, but I can tell you what the two markups

were. The markup for end user price from lighting management companies was 20.percent.

MR. LOGEE: Why don't we defer this just a couple minutes while we get it copied,47

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 and then we can discuss it with everybody looking at it.

DR. TURIEL: Oh, wait a second. It was here; it was underneath. I do have it.

[Overhead] I think I discussed the first couple bullets here in terms of an LRI survey, and I'll go right to here in terms of how we got the final prices. As I said, they were calculated by weighting two sets of balanced prices. end user price one weighted average.

End user price 1, we had a markup of 20 percent of lighting management company prices. End user price 2, we had a markup of 81 percent from the fixture OEM prices. So there were two ways these ballasts were getting to the end

user. Then we did a weighted average, to get the end user price for electronic ballasts and for magnetic ballasts, and there were different weighting factors that were provided to us from LRI from the survey they did, and equal weighting of electronics; you see 50-50 to get48

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 the price on electronics. So each one of these

sources was weighted equally.

In magnetics, that was not the case. The fixture OEM prices were weighted much more highly, and they were 80 percent compared to 20 percent weighting on end user price, lighting management company prices.

We have some late data that arrived after we did this whole analysis from LRI where they updated the data they gave us, where they got some more -- I guess some more people gave data into them.

What we found was that these ratios change; and you can see here, it says that for electronics, instead of 50-50, it's pretty small change; 44 to 56. There was a bigger change for the other source. For magnetics it's 3763 instead of 2080.

We took a look real quick at that right before we left for one to two product classes, and we found making those changes had very little impact on the results; extremely small. We will probably do that when we reanalyze for49

1 2 3 4 5 6

8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 the last time. Yes. MR. GELLER: I want to ask a more general question about pricing methodology.

DR. TURIEL: Yes. MR. GELLER: It seems in trying to

assesses prices in the marketplace today.

DR. TURIEL: Well, they are actually probably a year ago.

MR. GELLER: And I would think the more appropriate methodology in analysis would be to project prices in the future under a standards or a no standards scenario. So you would want to consider factors like this; the weightings between OEMs and lighting maintenance companies, assuming a standard that required electronic ballast.

In your electronic ballast case, you would want to assume economies of scale, increased competition, removal of magnetic ballasts from the marketplace and a consolidation of product offerings -- all these factors that you usually consider when analyzing50

2 3 4 5 6 7 8 9 10 11 12 13 .14 15 16 17 18 19 20 21 22 23 standards and other products. DR. TURIEL: That's a very difficult thing to do, as you know, to project what prices -- we're talking the year 2000. It's almost a little -- you're sort of saying "can we project what would happen if there were no more magnetics?" What we're actually trying to do here is get the difference between magnetics and electronics. So it's a very strange question in a way; it's because you're sort of doing away with half of what we're trying to analyze. There wouldn't be any more magnetics:

MR. GELLER: Right. DR. TURIEL: So to try to get the difference between the two to do the economics, I'm not sure how we'd do that.

MR. GELLER: Well, you've done it, for example, under water heater analysis; you don't just take the price of a heat pump water heater in the marketplace today; you do a projection of what the price is expected to be, should they produce three, four million a year.

DR. TURIEL: We have asked for51

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 manufacture cost prices, which is another way to get to this end user price, knowing what does it actually cost to produce it.

And you've gotten very little information so far on that, which will be another possible pathway to getting what, with a certain markup, what you might end up with as a price for electronics.

So that is an approach that we are looking at.

MR. GELLER: Would you agree with the conclusion that this methodology is conservative in terms of potentially overestimating the cost premium for electronic ballast by not taking into account the factors that I mentioned, should they be the norm under standards that -- all the experience with other products has been because of factors such as product consolidation, economies of scale, competition, experience.

DR. TURIEL: Yes, I would say all those factors you mentioned.

MR. GELLER: They would tend to bring52

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 down the prices. DR. TURIEL: All the factors you mentioned would, as far as I know, tend to make prices go lower. Whether there are other factors that make it go in the other direction, I'm not sure what those might be.

So as I said, the only way -- we're looking at it right now is trying to go - unless you have something to add on that.

MS. ATKINSON: No. We could have the survey, but I don't think people would have -- I think people have had a difficult time projecting future prices, even given.assumptions of zero rebates, for example. It's a volatile situation.MR. CAUSEY: I'd like to ask, along those lines, why do you think you have been having difficulties obtaining a manufacturer's cost? DR. TURIEL: I would have to direct that to NEMA, not to me.

MR. CAUSEY: I know in the case of Howard Industries, we have provided you with53

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 detailed schematics of all of it, all of our

designs. Building materials down to every part that's conceivably used in the ballast; offered to provide, to back our costs up with copies of the invoices for the components and also provide you details on all those manufacturing costs.

Are we the only company that's provided that information to you?

MS. ATKINSON: Is the answer to that question confidential?

MR. CAUSEY: We simply asked -- how could that possibly be confidential?

DR. TURIEL: The answer is, you are the only company who has provided that detail, yes, in terms of what it costs for the various components to produce a ballast.

MR. CAUSEY: You know, we reviewed your confidentiality form and thought it was a very legitimate form; and it provided all.the information that you guys have asked for. So to answer the question over here that the information, at least some information is available today.54

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 DR. TURIEL: For one particular type of

ballast, operating T8 lamps, we have information. But we have nothing to average it with, though; that presents a problem as you know. MR. CAUSEY: Well, we've also provided you with circuit diagrams on most of our competitors. With our analysis of their costs of the components and building materials. Along with circuit diagrams.

So your consultant should be in pretty good shape to come up with some of this cost that the gentlemen across the table is asking about. MS. ATKINSON: At the last meeting at LBL we discussed this issue; and I believe there was a proposal that the industry study, whether you could give estimates for the industry of these manufactured costs, and we discussed adjusting the MIM questionnaire somewhat. Has there been progress on that?

MR. STEIN: Well, I know for example our company, I know we have in fact provided55

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 cost data. In the study that you put out, you

indicated you didn't have it, but I didn't have a problem with that because I know the date of the data request for that and the date on which you printed this document certainly would have crossed. For example I know in the case of our company, we provided --

DR. TURIEL: We have some total numbers, yes.

MR. STEIN: Total cost numbers on the cost per ballast estimate basis.

DR. TURIEL: Right. He was talking about a detailed breakdown into different components. We do have one other submittal on total cost, correct.

MS. ATKINSON: But not with the breakdown of labor/tooling.

DR. TURIEL: But there are several other companies that we have not received anything as yet from.

But getting back to Howard Geller's question; that is one pathway that we're looking56

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 at. MR. McCABE: This is Michael McCabe,

Department of Energy. There are a number of elements to price, including the markup for the manufactured cost and to the consumer price. Given a standard, would you expect that the elements of the markup, the weighting, would change. If a standard were set to a point where it would mandate electronic ballast, would the marketplace change such that you would have a shift instead of the 44-56 percent weighting that would shift dramatically to affect it?

DR. TURIEL: Well, this weighting here is between magnetics and electronics. There would be no more magnetics.

MR. McCABE: You have two weightings there; you've got -- for electronics you've got the weighting as far as how those products are distributed in the marketplace.

DR. TURIEL: Right. MR. McCABE: If a standard was set that would mandate electronics, would the way57

2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 ballasts are marketed change? So if they do

not, then that weighting them that Isaac has here is correct, then you have to fall back as to what manufacture's costs would be. As to Howard's question is as far as the economies of scale, would that affect the manufacture's cost?

It seems to me you're mixing a couple of elements; and the first one is just the markup from cost to price, does that change; and if it doesn't then you focus on -

DR. TURIEL: Would the costs go down; That's right, Mike.

MR. CAUSEY: I think the answer to your question, if I understand your question properly is, as you increase the numbers of electronic ballasts that are built then yes, the costs for building the ballasts are going to come down. All the economies of scale come into play there, and especially in purchasing components. There's no question about it.

The same way, you know, why is the price so low now for a floppy disk drive on your 23 1 minicomputer or your PC? Economies of scale.58

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 If you cut the market down to 25 percent of what

it is today, you'd see the cost increase.

MR. McCABE: And the costs have changed the market such that, going with the end user price 1, the OMC, if that becomes the overwhelming predominant share of the market such as 80 percent, the price to the consumer on average will drop as well because of lower markup. So you've got two elements there in the question. My question is, what's happening to both of them?

MR. STEIN: I think those studies reflect current, the way the products are going into the marketplace. There's a lot of retrofit in the electronic ballast; and in the year 2000, I'm not sure how much retrofit will be available.The standard, the typical way ballast has been distributed is in fixtures. And even though theoretically we should be selling replacement ballast for the ballasts that were made 10, 15, 20 years ago in that volume, it59

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 doesn't work that way. They throw the fixtures

out, buy new fixtures. So it's more in the fixture. Most of the product eventually is going to get back to the historical way you sell lighting. When you sell lighting in new fixtures, there's not that much in retrofit. You have a time period where there are some ballasts that are out there to be replaced by a more efficient product, and it depends upon the economies, if it makes sense for people to make the retrofit, and they get a return on their investment, and the returns are one to two years, that's what we have to sell products for these days, not five, six, seven years.

That may be justified in some of the studies we saw, but you have to throw that into the equation, too; of, what's going to happen - we're not talking about what's happening in '95, '96, '97 but what's happening in 2000, and we're going to get back to the historical way lighting is sold. 23 1 MR. McCABE: You essentially have two60

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 factors working against each other; one is that as you increase the sales of electronic ballasts, the economies of scale, those costs to manufacturers are going to go down; but as more of those products are sold through the fixtures with the higher markup, they're both working against each other, and the average cost to consumers, the change there may be less than what would be envisioned with some of the other products that we've dealt with.

Lower cost to manufacturers, but with a higher markup in the marketing, in the distribution system, will offset that.

MR. GELLER: Why is the new data showing there isn't a lot of difference?

MR. McCABE: But accepting what Mike said as far as five, ten years from now, if that switches it to the point that you have 80 percent of the electronic ballasts ten years from now being marketed through the fixtures with that 81 percent markup, that's where you're going to see some of the --

MR. GELLER: I don't see the61

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 consistency between just how that is possible.

If this new data is correct, why would the marketplace all of a sudden shift from a situation where it's roughly 40 percent?

DR. TURIEL: I was going to ask that question, too, actually. Why. I wasn't sure why you were saying that you thought it was going to shift to more through the fixture route rather than through the lighting maintenance company route. I think you were saying that.

MR. STEIN: Right. Our experience of being in the business for a few years, the fixture manufacturers -- it's more economical to sell a whole fixture than to sell part of a fixture and part of a ballast and have an electrician put up there together; eventually you are going to get out of the amount of product that's retrofittable. And that's really what's driving that percentage.

And 3763, that's not our experience. Our experience has been 2080, and it's been 2080 for years, it's 2080 today, for magnetic. I'm not sure where the 3763 comes from, because the62

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 experience of the magnetic ballast manufacturers

reflects that 2080.

MS. ATKINSON: It's a combination of the responses to the surveys from lighting management companies, ballast manufacturers and OEMs, and actually the 37 percent is lighting management companies plus distributor. And the rest is OEM.

MR. RUBENSTEIN: This is Francis here. It would seem as though Mike's thesis is basically that there's going to be a shift in the market base. A shift in the market towards more retrofits and less fixture installations, that that's going to change.

I guess the one thing I'd point out is that, according to my understanding anyway, there's only perhaps 5 to 10 percent of the total commercial floor space out there actually has done the upgrade to electronic ballasts.

So it would seem as though in terms of the overall market potential there's still a lot to go before running out of steam in that particular area.63

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 I recognize the drivers are changing in

terms of utility DSM programs and things like that, but in terms of what's the raw market out there, there's still a lot of square footage out there that's not converted over to electronic ballast. MR. CAUSEY: Wayne Causey again. Of course the other thing is, I'd never assume for a minute that the technology that's driving the retrofits today is just going to stop. There will be a new technology on the rise and by the year 2000 there will be further energy savings and more reasons to do retrofits and•swapouts.

You put this electronic ballast in, in the next few years, a few years from now you're going to have a reason to take those out and put yet more efficient --

MR. GELLER: Demables. MR. CAUSEY: Demables, absolutely. Why would one think that the retrofits that we're talking about today are going to come to an end?

MR. LOGEE: Is that all you have, Ike?64

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 DR. TURIEL: Yes, that was the last. MR. LOGEE: Are we pretty much finished with this particular topic?

Mike, I wanted to ask you if NEMA had some parts of this that they wanted to address. Specifically if you all continue with what you have. DR. TURIEL: Let's continue; because I think the other things we want to address probably will be in Barbara's presentation.

MR. LOGEE: All right. MS. ATKINSON: What I'm going to talk about is an overview of the, which variables are key variables and which are fairly constant, in an effort to focus on the important ones; and then the fixture wattage corrections and the tandem wiring.

[Overhead] These, some of which we've already discussed are, and it's fairly obvious which ones are very important to the results on the payback on the lifecycle costs; and that would be wattage.65

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 We've talked about this, and we've

talked about fixture wattage corrections, prices, operating hours by sector and electricity prices by sector.

What are almost always constant are the lamp labor cost; since the product classes are defined by the lamp type that the ballasts drive, the lamp labor costs and the lamp equipment costs are constant for each product class except in the case of the F32 T8, because under the electronic ballast with rapid start, there's this instant start operation rated lifetime is different.

That's the only reason we include the lamp costs in the tables and study the present value of both of those.

So because the lamp is changed more frequently under instant operation than in a rapid start, you do incur additional equipment costs over the ballast lifetime, and labor costs over the ballast lifetime.

Likewise, ballast labor cost is identical for each ballast type except under the66

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 

### assumptions for the four line ballasts. I'll discuss that in my tandem wiring slide.

[Overhead] This is what we did on the fixture corrections, and then I think I'll say something about your suggestion for the one and two lamp. These are our terms for the various components of the calculation.

The wattage that Isaac described that was derived from the various datasets from NEMA and Seattle and other sources I'm calling ANSI watts, without any consideration for fixture effects. To make the corrections to these wattages that we selected from these large datasets, we used two sources: One was NEMA's LE5 which gives wattages in fixtures, and the other was the California Energy Commission's Advanced Lighting Guidelines 1992, which gives the same wattages. So I called those generic watts. From each reference source that we used 23 1 in the calculation, we chose the ANSI watts for67

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 each fixture type and the fixture watts. We selected three primary fixture types and we did the corrections just for the 4 foot ballast, the 4 foot fixtures. And these would be lensed troughers, recessed troughers, open louvered troughers and wraparound. And I can give you the percentages. I think in the documentation we have the percentages of each that we assumed for the market.

MR. STEIN: Barbara, we looked at those percentages, and we couldn't rationalize where you got them, so maybe somewhere along the line you can explain where you got the breakout of percentages, because it seemed like too much wraparound for our experience.

MS. ATKINSON: Sure, and in my notes I was looking at that also. Those were from actually a combination of sources, partly the Census and also some Lighting Research Institute projections. However, I looked at the 1993 Census data and the breakdown is different. So when I sit down I'll look at that.

Again, the projections, they were done68

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 in '92 projected to '95. Now we're using '93

data but still trying to project to the year 2000, our analysis is going to begin in the year 2000. And the question I think is how many of the parabolic fixtures are going to -- how is that going to increase.

MR. STEIN: Wasn't that part of the LRI questionnaire to the OEM fixture manufacturers?

MS. ATKINSON: Yes. MR. STEIN: We haven't seen that data. What did that data show?

MS. ATKINSON: I don't think they asked the breakdown of the wraparound versus lensed -- no, I don't think that's in the questionnaire.

MR. WISBEY: Bob Wisbey. The percentages that came out there do not agree with our experience. I don't know if we have any hard data on it. Also, I think that we're not certain that it really makes a lqt of difference in the end.

MS. ATKINSON: Right. That's the other question. 23 1 MR. WISBEY: So I don't think, at least69

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 from my perspective, that we've spent a lot of time challenging. But the data intuitively does not compare well with what we would expect.

MS. ATKINSON: If you have hard data, we'd like to have it.

MR. WISBEY: I don't have hard data. MS. ATKINSON: Okay. So what we did is basically adjust our LBL analysis of ANSI watts by multiplying by the ratio of the fixture watts and to the ANSI watts from the source document. And that produced the LBL fixture watts.

Now what we've done related to 1- and 2-lamp ballasts, for the 4-lamp ballast product classes, we assume electronic ballasts are 4- lamp ballasts, and the magnetic and cathode cutout ballasts are 2-lamp ballasts. So in that sense, for those product classes, we've done the adjustments.

For the 3-lamp product classes, we've assumed that the 3-lamp ballasts are tandem wire, and I'm going to discuss that. That assumption is, based on these LRI surveys may not be the majority of cases, but we've taken70

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 the wattages from the source documents for a

tandem wiring condition which is -- and so for some of the 2-lamp ballasts, then, we've done - the ones that are in 3-lamp fixtures, we've done the adjustment.

So perhaps you might want to make your statements now about why --.

MR. STEIN: We're making a study; it's a little contradictory to what we wanted done when we first sat down together a year ago and said, maybe we should look at systems rather than components.

But you're looking at a system in a component analysis, and the component is a 2- lamp ballast.

And the component, if you're making an adjustment in a 4-lamp fixture of a 2-lamp ballast, you should make an adjustment in the 2- lamp ballast category, because that's the only place that ballast appears.

You may have it in the analysis of the 4-lamp fixture, as compared to a 4-lamp ballast, but we really have -- really make, in the71

2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 magnetic world, 1-lamp and 2-lamp ballasts.

Even if we make 3-lamp and 4-lamp ballasts, we package two ballasts together in a can, for certain requirements.

So you can make the adjustment in a 4- lamp fixture and that's where most of the fixtures go in your analysis, the adjustment should be made for the 1- and 2-lamp ballasts because that's where those ballasts are used.

MS. ATKINSON: Right, although we should adjust for those ballasts in that fixture condition.

DR. TURIEL: In other words, when you're in a 4-lamp.

MR. STEIN: -- predominantly used. MS. ATKINSON: What we do have from the LRI survey is a way to do that; we have some information on lengths for fixture and other information on lamps per ballast, or number of lamps driven by the ballast.

So we could make some assumptions on weighting factors and assume that -- some of the 1- and 2-lamp ballasts are in single lamp and72

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 double lamp fixtures, and the rest are in the

larger number of lamp fixtures.

Have you done adjustments to their analysis to see -- again, the question is how much difference does that make? These corrections bring the wattage down; they always bring the wattage down. But they do it differently for electronic versus magnetic ballasts. MR. STEIN: We agree with that. We think it's important to have the 3- and 4-lamp fixtures to do it equivalently on the 1- and 2- lamp. MR. MARGOLIS: Can I make a comment? Eugene Margolis, General Counsel's Office, DOE.

I am not an engineer by profession, but it seems to me that we've had at least three meetings by now that I can count, maybe more. And it seems that the manufacturers or NEMA seem to have a questioning of a lot of the assumptions or how we arrived at certain figures, and they may have the data that would give us some of these answers.73

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 I just don't understand, why don't you

give us the data? We have said we'll keep it confidential. What is the problem? I'd like to address that to NEMA and to its counsel.

Why don't we get the data? Because if we had the data like was said before, one manufacturer supplied us or another manufacturer supplied some other numbers, why doesn't NEMA give us the numbers from the manufacturers under confidentiality or putting it in some sort of summary sheets that we could use without knowing who the manufacturers are?

Are you waiting until we come out with a rule and then attacking it, saying "insufficient information"? What's the answer. I'm not trying to be critical.

MR. STEIN: Let me answer this, because I think you're taking this comment out of the context that we're talking out now. You're introducing something that we talked about 15, 20 minutes ago, and all of a sudden decide to have discussion on it, and I think we're having a very good discussion now. But if you want,74

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 we'll talk about it, and -- MR. MARGOLIS: I'm only talking about this one. I mean -

MR. STEIN: The data we haven't supplied is on energy-saving lamps, and we admit that, and we explained the reason why we didn't do it, and we said we'll do it; it's not a problem doing that.

The other information has to do with the manufacturers impact model, it's a series of questions; and my management will not reply and answer those questions, and I've tried.

I think that's a problem with some of our other companies. And we'll go back and still work on it, but it's not a decision I could make and it's not something we could handle through NEMA because we're dealing with confidential information, and that's a problem with the management of our company and the decision they want to make; and I think I would talk for the other companies that didn't respond, also.

So two different situations here.75

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 We're having a discussion on fixture watts and

you throw this out. How about, let's get back to the story here of how do we come up with the right numbers, and I don't think we're -

MR. MARGOLIS: Don't you have the numbers on this also?

MR. WOLFMAN: This is a much more complex issue, Gene, and no, we do not have these numbers. There's all kinds of different interpretation and so forth involved, and there is not any set of numbers that we or anybody has, that we can just hand out the numbers and say "this is the number."

MR. STEIN: In fact, you're referencing some of the sources that we said to go to to get this information, and we think it's been done right for the 3- and 4-lamp; we haven't criticized that.

If I did it, I may have slightly different numbers than you came up with, but I'm not arguing those numbers. You said the numbers should be adjusted. You went to the sources that we thought were the right sources. What76

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 we're saying is, do the same thing for 1- and 2-

lamp fixtures. 1- and 2-lamp ballasts as they're operating in 3- and 4-lamp fixtures.

MS. ATKINSON: The data that I would use, and I don't know if you guys have had a chance to review what Jim Burke and Associates have sent the questionnaire respondents, but what he's giving is for number of lengths per luminaire, 1-lamp 4 percent, 2-lamp 20 percent, 3-lamp 25 percent, and 4-lamp 51 percent.

Does anybody think that sounds outrageous?

MR. WOLFMAN: Would you repeat those? MS. ATKINSON: Yes. We can make copies of this. MR. WOLFMAN: I have not seen yet Jim Burke's response -

MR. STEIN: We've been told that we're going to get the information back on the information we supplied.

MS. ATKINSON: Right. He sent it out March 10th.

MR. STEIN: But I don't think he was77

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 intending to send the ballast companies

information that the fixture people sent --

DR. TURIEL: That's right. MR. STEIN: -- or the lighting people sent. That's to be kept separate and confidential.

MS. ATKINSON: Some of them were summaries of all three. So --

MR. STEIN: The summary we got were only the summary of the information we supplied, and that's what I understood we -



### DR. TURIEL: That was my understanding, too. MR. STEIN: The breakout of the 5, 10, 25, 51 or something like that -

MS. ATKINSON: 4, 20, 25 and 51. And that's a composite of -- I don't think it's confidential because -

MR. STEIN: That sounds good to me. MS. ATKINSON: And then - MR. STEIN: It says three quarters of 3- and 4-lamp fixtures, which is what we would think as being --78

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 MS. ATKINSON: And then we have to map

onto the number of 1-lamp ballasts, 2-lamp ballasts, which predominate. 3-lamp and 4-lamp, which are only electronic.

MR. WOLFMAN: Barbara, was this information as of today's snapshot, or was it a projection into the future?

MS. ATKINSON: It was '93 shipments. MR. STEIN: And they also asked them to project out, what they thought the future would be. We saw a copy of the questionnaire; we haven't seen the results of the questionnaire, but I think we did ask to project some things out, too. MS. ATKINSON: I don't see it here on projection of the lamps/fixture. There was a projection of building types by ballast type.

MR. BLACK: Barbara, this is Bill Black at Copper Development. Could I ask you to go back to the previous slide just a second?

[Last slide] On your last point there, one of the subjects you kind of glossed over was the fact79

1 2 3 4

6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 that you assume that a very broad question that

an electronic ballast has the same life as an electromagnetic ballast. On what basis do you come to that conclusion? Because if we look at the shipment number, something like 80 percent of all the electronic ballasts ever installed have been in the last three years, yet you're assuming they last 12 years, 15 years, whatever.

MS. ATKINSON: This is an interesting question, and I think that in the future the answer might be different.

My understanding, and I think Francis Rubenstein might want to elaborate, is that the tests that have been done that indicate longer life for electronic ballasts have been done under accelerated life tests, and we'.re not sure that we can at this time state that the longer life for electronic ballast is accurate.

Francis, are you there? MR. RUBENSTEIN: I'm here. Yes, we were just trying to basically be reasonably conservative about that; I know that I think the electronic ballast manufacturers tend to project80

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 lifetimes on the order of say 45-50,000 hours,

and there's certainly been some talk about it being much longer.

But in order to be conservative, we knocked it at 45-50,000 hours to make it equivalent with the lifetimes that we expect from the older style magnetic ballasts.

MR. BLACK: Well, I don't have any data, but I think you're being unreasonably liberal, rather than reasonably conservative. Have you tried to develop any data on failure rates of electronic ballasts compared to magnetic in the three years that they have been heavily in service?

MR. RUBENSTEIN: We did not do any analysis along those lines; that data is not - data is hard to find, put it that way.

MR. BLACK: Shouldn't somebody do that? Should we, should you? Should somebody? Because especially when you start lowering your discount rates in order to optimize the value of future savings, you also optimize the cost of future replacements; and if in this 12 year life81

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 or whatever it is for some of these scenarios,

if you have to replace that electronic ballast three times and the electromagnetic ballast none, that changes the economics quite a bit.

MR. RUBENSTEIN: Well, I agree with you it changes the economics significantly, but I've certainly seen no information to date that electronic ballast manufacturers are quoting lifetimes of 12,000 hours. I would be extremely surprised to see that. I'm puzzled a little bit. MS. ATKINSON: Well, I think your point is that because of premature failure, unexpected failure the electronic ballast's rated service lifetime should be de-rated.

I'm sure that the electronic ballast manufacturers would disagree, and I think also we'd have to be, I suppose we're being optimistic that these early failure problems are being addressed, and that the second and third generations of the electronic ballast are performing better.

MR. RUBENSTEIN: I think also, the82

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 other thing, too, assuming that the mortality

curve of the electronic ballast form takes a similar shape, the typical bathtub shape that we're all familiar with for product mortality as a function of time.

It would seem to me as though the -- the problem with failures of electronic ballast primarily is the infant mortalities; it's not the long term duration of the product, it's the infant moralities.

MR. BLACK: How do you know? They've only been out there a couple of years; how do you know?MR. CAUSEY: Wayne Causey. I'd submit to you that there's ample documentation on all types of electronic appliances and computer hardware, you name it.

There's ample data out there to support the lifetime of projections for electronic ballasts. We'd be happy to run through our calculations and bring out data to compare with any that you want to bring to me.

MR. GELLER: My understanding of the83

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 market is it didn't just start three years ago;

there are sales that are back five, six, seven years ago for electronic ballasts; so there should be some empirical experience -

MR. BLACK: No, I said about 80 percent have been installed in the last 3 years.

MR. GELLER: But that still means there's quite a few that have been installed prior to that.

MR. BLACK: Been installed for 15 years, I think.

I just wondered if you'd done a study on it, and obviously you haven't.

MR. WISBEY: The projected lifetimes that are being used for everything in the study are 48,000 hours. I think the data would be that probably 90 to 95 percent of the installed, of the total historical sales of electronic ballasts at this point have still been in service less than 48,000 hours, so it's still an unanswered issue, if you will.

MS. ATKINSON: And yet there also have been, countering that, there have been claims of84

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 100,000 lifetimes. So in a sense, we have

assumptions that we're assuming have canceled each other out. That's a general assumption. We always welcome more data.

LRI surveyed lighting management companies, asking them in their experience the average lifetime of magnetic and electronic ballasts, and they did answer for magnetic, and electronic they did not; they said not enough experience. So we dropped that.

MR. WISBEY: Was the question asked or did they give any response on yearly failure rate during the first five years or anything like that? Was that a question asked?

MS. ATKINSON: The question was, from a lighting management company perspective, what do you estimate the average life to be, based on your experience over the past five years? And magnetics, the answers were in the 33-36,000 range, just for your information.

So we haven't decided what to do with that, because I had heard that also from NALCO 23 1 that this 12 year lifetime, they tend to change85

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 ballasts in less than that. I'll do my last slide on tandem wiring. [Overhead] As an overview we found very, very few 3- or 4-lamp magnetic and cathode cutout ballasts on the market. As I said before, for 4-lamp product classes, we made the simplifying assumption of two for the magnetic ballasts, two ballasts for a 4-lamp fixture, and the design option, electronic ballasts are all 4-lamp ballasts. The 3-lamp, the electronics are 3-lamp ballasts and we assumed tandem wiring. So there would be essentially one and a half ballasts per fixture. MR. FOLEY: Barbara, does NEMA agree with that assumption in terms of the fixtures that were shipped, that 3-lamp fixtures were shipped out with only one and a half ballasts apiece? DR. TURIEL: They'll have to comment. It's up to NEMA to comment.

MR. STEIN: We don't ship fixtures; so86

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 it's hard to tell. We know our customers wire

both ways; depends upon the requirements of the installation.

If you have fixtures that are adjacent that are easy to jumper, they actually have jumper sets that can be plugged in on the installation; however, they're tending to space fixtures further apart and that becomes more difficult, then we tend to have a 1-light and a 2-light ballast there.

MR. FOLEY: Wouldn't you say that that would be a safe assumption that most 3-lamp fixtures should have two ballasts in them?

MR. STEIN: One and a half. MR. WISBEY: I have an opinion on this; I do not have any facts on it, between whether the 3-lamp fixtures are tandem wired, meaning three 2-lamp ballasts per each two fixture versus 3-lamp fixtures that have a 1-lamp ballast and a 2-lamp ballast, and it is my opinion -- I'm careful to say it's only opinion -- that probably in a range of one-third to one-half of them are tandem wired with the87

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16

18 19 20 21 22 23 combination of two-lamp ballasts, and that onehalf to two-thirds of them have 1-lamp and 2- lamp ballasts per fixture; but that's purely an estimate, I do not have any facts on that.

MS. ATKINSON: What would your estimate be for 4-lamp fixtures, 4-lamp versus two 2-lamp electronic ballasts? We assume 4-lamp ballasts.

MR. STEIN: Where there are requirements for switching, they actually use two ballasts. And in a lot of retrofits, because of the nature of the DSM programs, paid them per ballast, they used two ballasts instead of one 4-lamp ballast.

So I don't think that makes sense, but certainly the switching requirement is not only going to be in California, it's eventually going to be across the country, with the new ASHRAE standard. So how do you solve the switching environment -- if you add an electronic ballast to say you're exempt, I'm not sure that's really the way this should be.

Other ways to control lighting, and88

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 it's up to the industry to come up with a good approach once it becomes a mandate of -- you know save energy, how do you turn off half the lights in a room, turn off half the fixtures -- obviously, the inside/outside is the old approach because you have two ballasts in there, but there is probably going to be a demand for product and can work on two levels and things like that.

MS. ATKINSON: Gene, the luminaire manufacturers, LRI surveyed them for'3-lamp luminaire systems, and they estimate only 20 percent of the luminaires are utilizing --

MR. WISBEY: I saw that just after I made my estimate, and I certainly defer to that, because they're the ones that are doing it.

MR. FOLEY: We're talking magnetic ballast, now. 20 percent to the magnetic ballast--

fixtures. MR. WISBEY: We're talking 3-lamp

MR. FOLEY: 20 percent of the 3-lamp 23 1 fixtures.89

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 MS. ATKINSON: The question was asked,

just 3-lamp fixtures; it didn't distinguish.

MR. FOLEY: Well, you make the distinction between electronic ballast and 3- lamp ballast. Given that assumption, then we're talking now of the design configuration of a magnetically-ballasted 3-lamp fixture.

MS. ATKINSON: Being tandem wire, you're right.

MR. FOLEY: Being tandem wired. And manufacturers said? MS. ATKINSON: That only the 20 percent. MR. FOLEY: That only 20 percent were tandem wired.

MS. ATKINSON: Now some of the factors you mentioned, especially codes, for example with California's code now and the ASHRAE coming up -- and when you talk to people in the profession, they'll say there are factors that it would be driving toward tandem wiring. So the luminaire OEMs were answering for 1993, we have to project for 2000, so we're going to have90

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 to have to settle on a percentage. For all of this we can certainly do sensitivity cases or alternate cases. What happens when you assume tandem wiring is it reduces equipment costs because you have one and 

### a half ballasts instead of two.

It does increase labor costs, from what NALCO tells me; there is an increased labor cost for the tandem wiring over simply a one and a two in the same fixture.

So we're starting to do those numbers, and this will be predominant. So this will give a net cost increase to the -- assuming single, 1-lamp and 2-lamp ballasts will get a net cost increase. MR. WISBEY: One of the basic points is that in a 3-lamp fixture with the choice of using a 1-lamp ballast and a 2-lamp ballast, is continuous to provide the switching option to the user.Using tandem wiring and using 2 3-lamp ballasts in each pair of fixtures continues to give the 1, 2, 3-lamp switching characteristic,91

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 using a 3-lamp ballast in the 3-lamp fixture on

the other hand does not provide the same level of performance, because now the switchability is no longer there.

So that's a factor that's not -- it is difficult to factor into the economic analysis because suddenly it's a noneconomic factor that has to be considered in some way.

The choice between tandem wiring or using a 1-lamp ballast and a 2-lamp ballast is purely an economic choice, and in both situations the usefulness of the fixture is not altered in any way. You're trading off labor costs of tandem wiring versus equipment costs of two ballasts per fixture versus one and a half ballasts per fixture.

MR. LOGEE: How critical, Bob, is that switching, that capability -- I can see energy savings resulting from it if it's automatically switched on and off, but is it used in a lot of cases, or is it.just something nice to have like here where we can switch off a couple rows of lights?92

1

3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 MR. WISBEY: It's becoming more and

more and more popular. It's required by many state and local codes, either directly or indirectly, and it certainly, in the new ASHRAE standards, if you will, that are being developed, certainly a major factor in there, the ability to switch to the lower levels.

So I think that there are many lighting applications in which that capability is required. And that number in which it is required is increasing.

MS. ATKINSON: Here are my notes on market shares from the LRI survey. Recessed lens, instead of 28 percent, are estimated at 52 percent. Open louvered, 27 rather than 42. Although again, projecting into the future with more VDT offices, I would say that that would go up and then wraparound is 30 in our assumptions and 21 in 1993.

That's Bureau of Census data. It's not LRI; it's Bureau of Census data. 52 27 21.

MR. WISBEY: That's much more93

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 consistent with what our -- MR. STEIN: In 2000, even if the wraparounds stay the same, you may get a switch between -- the lines are parabolic, but the overall mix of the trougher will probably stay relatively the same.

MS. ATKINSON: And these percentages I did just for those three processes.

MR. LOGEE: Your formal presentation is finished, Barbara?

MS. ATKINSON: Unless we want to walk through the tables for which I don't have an overhead because the print's so tiny. Again, that's optional.

MR. LOGEE: Let's go back and make sure that we've covered everything that NEMA wanted to cover. I really only checked off.one; that was ballast life, and have we covered that adequately?

MR. STEIN: You have the numbers; that's been handled.

MR. LOGEE: Then you had input data, you had energy costs and operating hours, and we94

2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 really didn't get into that very much. MR. STEIN: If this is an appropriate time, you want to --

MR. LOGEE: Sounds to me, unless someone else I'm opening it up for anyone here, particularly NEMA because they had put this on the agenda.

MR. WISBEY: In the economic analysis, obviously there are a number of variables and actual choices of variables to be used.

I don't know if Barbara or Isaac are going to discuss the variables they chose for electricity price, burning hours per year, et cetera, and then lead into a discussion of agreement with those, other thoughts on those or whether -- I didn't intend to get into that; I figured then we would want to bring it up.

DR. TURIEL: We didn't prepare vugraphs for those particular items, but we certainly can discuss them.

MR. LOGEE: Could you sort of introduce those two issues, then, the operating hours and the energy costs in the sense of what you used95

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 in the analysis? DR. TURIEL: Okay, we can talk about electricity price.

MR. LOGEE: That's good. DR. TURIEL: That should be in your writeup that was given.

MR. LOGEE: Check your errata sheet. MS. ATKINSON: Actually, there was only one errata. They were addenda.

MR. LOGEE: I mislabeled it; sorry. [Laughter] DR. TURIEL: As it says here on the errata sheet, or the addenda -- whatever you want to call it, we did get it from the Annual Energy Outlook, 1995, and we looked at projections for electricity prices in the year 2000. That's the year that we're projecting that any potential standard would take effect. That's why we chose the year 2000.

I'm not sure what the question is; we took average price for the commercial sector and projected it out in 1994 dollars to be 7.5 cents96

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 per kilowatt hour. Any question or comment? Discussion? That's how we got it. MR. STEIN: Is the reference information from which you got it, is that something that's available?

DR. TURIEL: Annual Energy Outlook? Yes. Published by EIA. There's probably even one here, in the library.

We're at DOE, right? MR. LOGEE: We should be able to find ; but I'm not -

MS. ATKINSON: It was just out; it was new. Get the '95 one. It's out.

MR. STEIN: We, not looking at that, but looking at some of the numbers we looked at when we did our'analysis last summer and provided some data, the numbers you picked seemed reasonable if you want to pick an average number. We thought we should do some sensitivity analysis. The data we presented, actually Bob's put together a 10 percent, a 5097

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 percent and 90 percent percentile of some data

we got out of Energy User News.

MR. WISBEY: That is an EIA source. I don't know if it's the same one or not.

MR. STEIN: And that changes every other month.

Just as an additional sensitivity analysis; but the thing we have to look to, and again it's trying to look into a crystal ball and, how do you project ballast prices in 1999 or 2000? I mean that's one of the things we talked about earlier; there was some good discussion on that.

I also have an environment of deregulation and utilities which is really an unknown for us, and if anyone can give a 99 percent "sure, we can all make a lot of money on some sort of bet" or something, because I think it's a tough thing to predict where energy prices are going to be in a deregulated environment.

We've heard some numbers from some utilities in presentations in several parts of98

1 the country where we're talking about possibly 2 four cents a kilowatt hour as being the rate in 3 a deregulated environment. 4 Someone was talking yesterday, in New 5 Zealand they're already in a deregulated 6 environment. They went cold turkey; they didn't 7 phase anything in, and that's what happened. 8 The prices did go down, so maybe you want to 9 verify that if there is any deregulation 10 anyplace in the world, what's happened to it. 11 I think somehow you have to project 12 what's going to be in the deregulated 13 environment and maybe do a couple what-ifs, what 14 you project for a utility price and maybe do 15 analysis of where those numbers would be. 16 DR. TURIEL: In terms of the average, I 17 think the EIA numbers, DOE may want to comment. 18 That's probably the ones we are going to use for 19 average, but we have done some sensitivities and 20 we have looked at what he provided. In fact, 21 that's on the agenda, is to look at 22 sensitivities; isn't that right, Terry? 23 MR. LOGEE: Yes.99 DR. TURIEL: Do you have stuff to hand 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 out? MR. LOGEE: I don't. Barbara had

mentioned that, and if you have --

DR. TURIEL: I have vugraphs. MR. LOGEE: You have vugraphs of this particular sensitivity to -

DR. TURIEL: Yes. Yes. MR. LOGEE: Well, then don't turn the projector off. Do it now.

DR. TURIEL: Yes. We have done that. MR. LOGEE: Why don't, if you have those vugraphs, you might want to put them on.

MR. ADAMS: We in the program office are depending upon the EIA to have done the forecasting of energy pricing, to have taken into account the sorts of things that you're speaking of.

MR. PERLIS: Carl, I don't believe EIA has assumed extensive deregulation in their existing projections because the deregulation framework has probably come about in a serious way subsequent to when their numbers were100

2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 gathered. The Federal Energy Regulatory

Commission only published their proposals at the very start of the federal deregulation this past fall, and California's proposal is still in gestation in California.

So I am very doubtful that the EIA office has projected the outyear prices based on any deregulation. They might be reflecting some perceived changers in efficiency of operations, and the mix between gas and coal and nuclear, but I'd be very doubtful that they've assumed deregulation. That perhaps could be-verified from the office.

MS. ATKINSON: And then they would have to project long term as well as short term price cuts. MR. PERLIS: Well, I assume that the Department of Energy internally is preparing extensive analysis on what the impact of all of the deregulation proposals are that are floating around right now.

I don't know this for a fact, but I'd101

2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 be very surprised if, for example, Department of

Energy hasn't studied what the impact of the California proposal would be if generalized throughout the country; or alternatively, what the impact of the current proposal of the Federal Energy Regulatory Commission would be, and that's only a limited part of deregulation, what the Federal Energy Regulatory Commission is doing right now.

I have to assume that this is the agency that is going to provide the forecasting for trying to figure out what this is all going to mean. Now, I've just begun to try to look for some of that, and I haven't found any of it yet. That's perhaps because the administration hasn't had to testify or put forward positions yet; there's no legislation in Congress that would require you to come out with all your numbers. But I assume there's an office, internal here in the Department that's spending a lot of time now trying to gather data on this.



### But I don't think that the EIA data102

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 that's published assumes widespread

deregulation. At most, it would assume some changes in efficiency of the generating facilities. That would be my guess. It's just a guess, I don't know for a fact.

MS. ATKINSON: There's also the issue of regional, widely varying regional electricity prices. Presently.

MR. PERLIS: Right. At present there's wide differences regionally. On the other hand, at present we don't have a national electricity market, and part of the trend in deregulation is to allow for much greater degree of nationalization of electricity, of commoditization.

There are already financial organizations that are offering futures contracts that are not based on where the electricity is delivered, and there are all sorts of developments going on right now.

In terms of projecting into what's going to happen to the year 2000, many forecasters expect the structure of the market103

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 to be radically different than it is today, even

by the year 2000. I think in California they hope to start it in '97 or '98, but undoubtedly that will be pushed back a little bit.

DR. TURIEL: That's not for the residential sector; it's going to start in the industrial sector and work its --

MR. PERLIS: In perhaps commercial. That's right, but as I say, that was just one step along the way. All the forecasters in the industry are looking at a radical restructuring of the electricity marketplace.

DR. TURIEL: I think we can all agree that nobody knows what will happen by the 2000. I think that's why we do sensitivity studies.

MR. PERLIS: And that's all that NEMA was proposing be done; not that you change the number and say flat out "Here's what"the prediction is going to be."

DR. TURIEL: It could go the other way, too; suppose there is an oil embargo or -- you can make arguments the other way.

MR. STEIN: What we're saying is, your104

2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 base numbers are as good as we can come up with,

run with those; but let's look at the sensitivity. If you want to look at an embargoenvironment or a deregulated one or whateverDR. TURIEL: I don't want to, no. [Laughter] MR. CAUSEY: Let me ask, whose numbers are we using for power?

DR. TURIEL: Right now we're using EIA, Energy Information Administration numbers.

MR. GELLER: Actually, it's a very recent update of their price forecast that was published, I believe in January of this year with modifications being made through the end of last year in terms of the key inputs.

DR. TURIEL: Okay. MR. WISBEY: Just a curiosity question to those who have read it; can you tell from the discussion of the companies, to what extent they might have considered the deregulation aspects for --? DR. TURIEL: I don't know. 23 1 [Overhead]105

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Okay, we did do some sensitivities, on

three different parameters. This particular sensitivity we did so far is just on payback periods, we haven't done any sensitivities yet on lifecycle costs; haven't gotten around to it yet, but we plan to.

The three parameters we looked at are: electricity price, operating hours, and ballast prices. The approach we took for right now in this first case is just one parameter of time; of course you can do multiple parameters, changing in time, we haven't done that yet.

[Overhead] We didn't do it for all product classes; we did it for a few selected product classes, the ones that most sales are for.

This first one here is for P12 lamps energy-saver and not energy-saver; and what I have in this first column here are the paybacks that you've seen already. Ones we've already done, the average electricity price, average operating hours.



### These are the ones you've already seen,106

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 these payback periods, and here we're looking at

a low electricity price and a high electricity price and seeing what the impact is on payback period. Down here in the bottom we have -- 10.5 cents. MR. WISBEY: Yes, 5 1/2, 7 1/2, those are very reasonable numbers.

DR. TURIEL: I think they're very close to what you had submitted.

MR. WISBEY: Yes, I would not quarrel with those numbers in any way.

DR. TURIEL: So that's the low and high that could be priced; 5 1/2 to 10 1/2 cents compared to the 7 1/2. And then in operating hours, the low is 2500 and 8000 is the high.

Now you might not agree on this last one, but this iS what I temporarily used, was the delta price -- I just put in here, as you can see, some low numbers in parens, and I need to get some high numbers.

Well, at the time, right now, it appears to me the numbers we have already seem like high numbers. I'm not convinced yet that107

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 these numbers are really good average numbers,

and I'm basing that on just some of the -- little bit of information that we have on manufacture cost numbers, and using some of the markups that were provided to us. It looks like we're running on pretty high delta costs already. I'm open to look at more information, that would lead us to put a high number in here, too. At this point, I'm not sure what that high number is.We could discuss that. That's what I have in here at the moment, is a low number, on delta price. I know that doesn't seem balanced, but as I said, let's discuss that. This is just our initial sensitivity.

Anyway, you can see the results here; that's the electricity price, the kind of variation that you're going to get as one example. If you can't read the back, it's 3.3 years. If you go to a low electricity price, it goes up to 4 1/2 years, and comes down; and a high price to 2•.4 years; there's that kind of108

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 variation.Operating hours, it's a little more.

The variation is the same 3.3 for a low operating hours, which might be equivalent to a school, let's say. You go up to 5.4 years, but if you go to high use, like let's say in a hospital, you'd.end up at 1.7 years.

MR. BLACK: Is that with the 7.5 cent price, then?

DR. TURIEL: Yes. This would go back to the average price, that's correct. The only thing changing is operating hours.

The last one, these numbers we tookhere in terms of the delta price from energyefficient magnetic to cathode cutout, and energy-efficient magnetic to electronic, are two and six dollars.

That actually came from a specifier report that Terry Logee found for us. And it really comes from just one distributor in one location in the country, providing that particular price.

However, that's definitely on the very109

2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 low end. No one's going to argue. That's

definitely a very low number. But it wasn't "a number" as to a possible low end of what it could possibly cost, in some situations.

Now I haven't put anything in here, but if you'd like to provide some information on what you think -- anybody in the audience might be high end delta prices, we'll be glad to look at them. Yes, Howard.

MR. GELLER: Could you possibly use the manufacturer cost data, the limited manufacturer cost data that you've had, that you have now to build up a sensitivity price?

DR. TURIEL: Yes. We're actually in the process of doing that. As I said, my initial look at it makes me think that we're already at a high price; that's what I'm basing it on. But we haven't looked through it thoroughly enough yet to make that definite conclusion.

MR. STEIN: The price information, the price you're talking about is the end user110

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 price, right? DR. TURIEL: Yes. MR. STEIN: And the end user price is very far removed from us; it depends upon how many different channels. If we go through the fixture manufacturer, you've got the distributor, the contractor and there may be another one between the contractor and end user.

If you go through the lighting maintenance people or distribution, you have again the contractors; you have a lot of markups that we have no control over, in the marketplace.

My question, though, has to do with the cathode cutout is only $2 more than the magnetic? Is that what the $2 means?

DR. TURIEL: Yes. MR. STEIN: Rather than whatever is in there now? The six dollars or whatever?

DR. TURIEL: Yes. The delta. MS. ATKINSON: About six and a half, or six. And sixteen for the electronics.

MR. STEIN: Okay, you crunch the delta111

2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 down -- you did it in terms of delta, now

absolute price..

DR. TURIEL: Right, because all that matters for a payback period --

MR. WISBEY: The delta dollars is the only -- DR. TURIEL: -- is the delta.

MR. STEIN: Are you going to provide copies of this information?

DR. TURIEL: Oh, yes, sure. MR. LOGEE: We can probably get those to you before you leave.

MR. PERLIS: Yes; we have a hard copy here. MR. LOGEE: And we'll put all of those, of course, in the reading room.

MR. PERLIS: One suggestion would be that all the LBL, and we can make available ours, I don't know if other people have handouts, could be attached somehow to the transcript, maybe?

MR. LOGEE: That's a good suggestion. We'll see if we can do that.112

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 MR. PERLIS: Or at least in the reading

room that we can send somebody over to copy them. MR. LOGEE: They will be in the reading

room. DR. TURIEL: We have a hard copy with us. But everybody would want a copy; not just NEMA. MR. MARGOLIS: Since this workshop is being recorded, the overviews are part of the discussion. They should be, when they're referred to in the oral testimony, they should be referred to it and attached as appendices to the back of the transcript. We just'have to make sure we provide the reporter with the overviews.DR. TURIEL: Okay, here I'm just showing another one that's for an 8 foot lam but the same idea. In this case we had an average hours of operation, 6500, which I think was a NEMA-suggested number if I remember right.

Electricity price, 7.5 cents on this one. And then we did some sensitivities on113

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 electricity price and operating hours, and again it's about 5.5 cents -- sorry, no, it's different operating hours -- a range suggested by NEMA, if I remember correctly, from 5000 to 8000 hours.

MR. WISBEY: Isaac, you're quoting back the numbers in the examples that we had done in advance last summer, and I guess I would comment that I don't really feel like the 6500 hour number as an average is very -- we gave an example of typical 12 hour days, retail outlets, which is where these are commonly used, at 5000 hours and typical 24-hour a day retail outlets, which is 8000 hours; to take the average of those would imply that the weighting of them in the marketplace is nearly equal, and I don't think that that's true.

I think that a more reasonable weighted average just of those two, which would probably much nearer to 5000 than it would be to 6500.

MS. ATKINSON: We did a survey, we had LSI survey both the lighting management companies and the OEMs for destination of the 4114

2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 foot magnetic, 4 foot electronic, 8 foot magnetic slimline, 8 foot electronic, and HO magnetic and electronic. And theirs, I'll give you some of the OEM numbers because they represent a larger volume.

They have got the 8 foot magnetic slimline retail 13 percent, grocery 13 percent, warehouse 24 percent, and then industrial combination of light and heavy, 44 percent.

So they don't predominate -- the 8 foot HO do, but again even those have some -- about 20 percent, 20 to 30 in the commercial sector.

DR. TURIEL: Actually, that's part of the reason we did this other --

MR. WISBEY: Right, because what you say, there are more of the 96 T12s used in, according to this survey, in industrial settings than what we had projected, is what you're saying. DR. TURIEL: Yes. Actually, we did another case here where we took -- let's say it's an industrial sector, industrial electricity price, 5 cents. And we did that115

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 also, hours of operation 4000 in this case. That's this side of the table here, if you see those numbers.

MR. GELLER: Where does the 4000 come from? DR. TURIEL: The 4000, for right now, is a number that we are using against an average number that NEMA provided, for the time being, on industrial. I think it was averaged between light industrial and medium --

MR. PERLIS: It's an average between two shift factors; 3000 hours or 5000 hours.

MR. GELLER: Sounds low to me. DR. TURIEL: Yes, it could be low. We don't have very much information on industrial sector hours of operation. I don't know if --

MS. ATKINSON: Yes. We are under the category of new data; we're going to compare - in fact, we'll discuss operating hours I guess next, but we're going to get some further information from, some data on energy audits.

DR. TURIEL: So hopefully we'll have 23 1 some core data, see how this compares to what we116

1 2 3 4 5 6 7 8

10 11 12 13 14 15 16 17 18 19 20 21 22 23 use. Anyway, you can see these paybacks are

quite a bit higher here, when you go.down to that 5 cents, obviously, and the lower operating hours. [Overhead]

So the last one we did was on the T8s. Here you see the original hours of operation, original electricity price, and we did pretty much the same thing we did for the first set you saw, on the T12.

Where these are the original paybacks, here you see the effect of changing electricity price, changing operating hours, and.the flow ballast, delta price.

So that's what we've done so far, and we certainly can make that available to everybody to take a look at those.

DR. TREADO: Have you considered the merits of going one step further and saying: Based upon the sensitivity analyses, one's general conclusions about the impact of some of these regulations would change significantly;117

1 2 3 4 5 6 7 8 i.e., the payback period would bring it down in to some reasonable range where they have been saying, two years worth of paybacks are the norm, or whatever, based upon a change in one of these parameters that might reasonably be expected to occur. Now I know that's a lot of extra work --.

DR. TURIEL: That's why we're doing the 9 payback period, just to be able to see. But 10 that's for DOE to decide and use that 11 information, how they want to use it. 12 But that's the reason for doing it, is 13 to see about what happens if you change some of 14 these parameters, and when does it look to be 15 like the paybacks are getting whatever out of 16 the bounds, however you define out of the 17 bounds; but we don't do that, we're just 18 providing the analysis to DOE for them to look 19 at, make those decisions. 20 The real problem here is to_really, in 21 my mind if you want to do it right, it's not 22 just to say "Well, look, gee, if I have a little 23 operating -- it's pretty bad; we're getting up118

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 into the ballast's lifetime, then, ten years." What we really need to know is, how often does that occur? That's the important question. If that's occurring a very small percentage of the time, or cases, we need to know that.Just the fact that you have one sensitivity that says "Gee, that looks bad" doesn't mean it's totally a bad thing to do. This requires much more analysis. We haven't done that analysis yet, and we're discussing exactly how we're going to treat that.

MR. WISBEY: And that's clearly an issue of -- and there's some information, you're collecting some information -- we've gotten ahold now of some of the data sources that, I think the same ones you're using, on burning hours and just got our hands on some of that yesterday.DR. TURIEL: Right. The question is where are these ballasts going, how does it break down to different buildings, what are their operating hours in those buildings?119

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 MR. STEIN: You do sensitivity analysis

of extremes here to show a point, which is good; that's part of what we want to do in sensitivity.

The other thing is to come up with -- typical installations, like a typical school. We gave you, actually, some of those typical installations. That was the purpose of showing you examples in the information we provided in our comments last year of a typical school, and we said that's like 2500 hours, and the 24-hour supermarket, that's like 8000 hours, just to show that there are not only sensitivities but there are actually environments that have those types of hours.

I think we should not only identify a bunch of what-ifs; try to tie them in to some real things, and then try to tie them in to -- and I think there's some data that says if there's this much square footage or this percentage of this type of lighting in that kind of installation, I think you're starting to gather that --120

1 2 3

5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 DR. TURIEL: Yes, we are. MR. STEIN: information from the surveys and some of the other data that's around. So a good sensitivity analysis will say, in this type of installation this is what you're going to see, and then in this type of installation this is the situation you can see.

DR. TURIEL: Right. And then what percent of all the ballasts are going to these different kinds of installations is the other thing you need to know.

MR. WISBEY: A suggestion I might make as far as methodology, as you get more of the data there; it refers back to some of the methodology we used and what we did last summer.

For example, in electricity prices where we had a continuing graph or table of percentile versus price, we used a 10 percent out point, a 15. percent out point and a 90 percent out point; and a logical methodology here, if you can get the data into a good enough form on burning hours, would be to do121

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 sensitivity analysis at identified 10 and 90 percentile points, or 20 and 80 or some definable number.

If you can get enough of the information of the mix of usage and type of applications to have, those burning hours in that form, if you will.

DR. TURIEL: Well,.one of things we're looking at, we haven't really decided, is to do this kind of thing; we put that before for some other products using BEMIS -- I don't know if you've seen it.

It's software that allows you to do like a Monte Carlo kind of analysis, where you put distributions on different parameters that affect the dependent variable. And then you can look and see what-- you know, do 1000 runs and see what's the distribution of outcomes.

Of course, it's very data-intensive; you have to know a lot about each of those input parameters to do that.

MR. WISBEY: That's right. DR. TURIEL: And that's what we're122

2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 trying to see if we can find that information. MR. WISBEY: Right, and that data was readily available, for example in historical electric prices, not so readily available in burning hours.

DR. TURIEL: Right. Or a percentage of ballasts going to each of these buildings. We have some information.

Are there other questions on this? Wayne. MR. CAUSEY: I just want to ask, looking at the chart here on the lamp and equipment costs, under the instant starts? I notice under the instant start you allowed $9 more there than the first four categories.

Is that due to the additional lamp-- DR. TURIEL: The life cycle cost table? Let me look along with you, then. Which table?

MR. CAUSEY: 4.14. DR. TURIEL: 4.14. MR. CAUSEY: Now, you're comparing which to which now?

MR. CAUSEY: Lamp equipment plus labor123

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 cost. I notice with the instant start, you've

got $40.05. With rapid start, you've got $31.01. MS. ATKINSON: Okay. Take a look over at the -- well, first of all, relamp life forthe rapid start and the magnetic, the ballastDR. TURIEL: He's on the bottom half of it, right?

MS. ATKINSON: Yes, the second half, right. DR. TURIEL: Bottom half of the table.

MS. ATKINSON: We have the relamp life of 14,000 hours, which represents 70 percent of the 20,000-hour.rated lifetime, assuming a group relamping situation.

MR. CAUSEY: So it costs differential, there is primarily the relamping?

MS. ATKINSON: I'll explain how this works, and that will answer your question. Then we take the 15,000 hour rated lifetime for the T8 lamp with an instant start operation, take 70 percent of that and get 1050, 10,500.124

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 How this calculation is done, the

assumption behind it is that we're studying the life cycle cost of the ballast and lamp over one ballast service lifetime; and the ballast service lifetime is your 48,000 hours divided by your annual lighting hours, whatever it is for that product class. In that case, this comes out to 11.71 years.

Over that 11.71 years, you have the lamp replaced several times, and dividing the ballast service life by the lamp service life would give you the number of replacements.

So the lamp service life will be different depending on the rapid start versus the instant start operation. You'd have the relamp life divided again by the annual lighting hours. So you would have -

MR. CAUSEY: I guess, Barbara, I can't understand where you're going there, and I guess the shorter hours for the instant start isprimarily based-on the number of starts, the oncycle. 23 1 MR. WISBEY: No. That's the rating125

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 based on - MR. CAUSEY: I guess if you talk to the manufacturers you find out -- at least I'm finding, that as long as the on cycle is greater than three hours, then they don't really distinguish between the instant start and the rapid start as far as the rated lamp hours.

So you're talking here about 4100 hours a year, and that's really a long on cycle. The number of start cycles there is going to be low enough that the lamp lifetime should be comparable for the rapid start and instant start. MS. ATKINSON: When I'm using the 20,000 and the 15,000 hours, those are at the three hour -- the test conditions of the three hours on, 20 minutes off.

MR. CAUSEY: That's right, but what I'm saying, in reality in use in the settings that we're talking about, the on cycle is going to be much longer than three hours.

So you're talking about here, for instance at the top of the paper, you say annual126

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 lighting hours of 4100 hours. That's a twoshift operation right there. So that's a long on period.So what I'm saying is that you probably should be using the same lamp life for the instant as you're using in the rapid start.

MS. ATKINSON: You could -- that's an argument, right.

MR. CAUSEY: See, how can you get 4100 hours with a person turning the light off in on the big one, and we've talked about industrial settings here, we've talked about commercial settings, and so you've got someone turning the lights off every three hours, turning them back

on. MS. ATKINSON: On the other.hand, you could have a -- this is commercial sector hours for this product class, predominantly, and you could have a occupancy sensor operation where you were turning those lights on and off more frequently.

MR. CAUSEY: We've probably got about 1.5 million square feet of main factory space127

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 all totaled, and I can assure you that we don't have occupancy sensors on even a few of our lamps. MS. ATKINSON: Do you have T8 lamps

MR. CAUSEY: In an industrial setting, they burn two shifts -- pardon?

MS. ATKINSON: Do you have T8 lamps in those settings,

MR. CAUSEY: We have lots of T8s. MS. ATKINSON: Okay. MR. CAUSEY: What I'm saying, in an industrial setting, you don't normally turn those lamps off. If you're burning 4100 hours annually --

MS. ATKINSON: You should have HID lamps in there.

[Laughter] MR. CAUSEY: We have those, too. DR. TURIEL: The 41 is meant to be average commercial.

MR. CAUSEY: Average commercial. I was going to say, on that.kind of average commercial, your on cycle is going to be128

1 2 3 4 5 6 7 8 9 10 11 12 13 14 much longer than three hours. DR. TURIEL: So you're saying, based on real field use data, you would have -- you say instant rapid to be the same, is what you're --

MR. CAUSEY: You have the same lifetime for the lamps on instant start as rapid start.

MR. LOGEE: Wayne, I think we at LBL would need to published data that would really state that, and we don't have that right now. So we've agreed pretty much to go with this 20 and 15,000 hours.

Go ahead, Gene. MR. FOLEY: There's data published on mortality curves based on starts. I think what 15 you all need to decide is what in fact is the 16 burn rate? 17 Is three hours really what you want to 18 base an operation on, or is it four hours, is it 19 five hours, is it six hours, is it eight hours? 20 You all come up with a number. There is data 21 that's published that says how long the lamp 22 will live, given those different lengths of 23 starts.129

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 It's just up to you guys to come up with how long everybody can agree upon that a lamp burns once it's put into a socket.

MS. ATKINSON: And then you do have to take into consideration the countereffect of the occupancy sensor operation. So I think that that's why we settled on the test, the lamp manufacturer test procedure that they used to rate the lamps.

MR. CAUSEY: If you're talking about a residential setting, or in a bathroom of a hotel is something I could probably agree with. But we're talking about industrial settings here, and commercial settings. And occupancy sensors are just not commonplace.

It will be a long time before they are, and the on cycle is going to be much longer than those three hours.



### DR. TURIEL: Francis, do you have any comment? MR. RUBENSTEIN: As a matter of fact, I was just going through one of the EIA Commercial Building Characteristics, 1992, to see what130

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 their estimate was as to the total number of

occupancy sensors . Give me a few minutes, I'll have the information for you.

DR. TURIEL: We'll continue. MS. ATKINSON: Let me say that for the, again this is the survey of the OEMs: For 4- foot electronic, 47 percent of those ballasts are predicted in the year 2000 to be destined to office buildings, small and large, where this three hour start time might be more appropriate. And then the rest are interspersed between building types with 8 percent in industrial.

The same numbers for '93 were actually even higher; 58 to office buildings and 3 percent industrial. So you're in the vanguard with your factory facility.

I should talk also about the nature of the annual lighting hours, the origin of those. The EIA did a study in 1992 which took information from their previously published CBEC survey, and this was entitled: Lighting in Commercial Buildings. So they did a sort of snapshot of lighting in commercial buildings.131

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 And I believe that was from the '86 CBEC, so it was a little dated to start with.

They had already published building operating hours. What they did is they looked at their questionnaire where they asked questions on operating hours of lighting equipment; and those numbers are published by building type for that study.

We asked them if we wanted to separate fluorescent operating hours from incandescent and HID, and so they crunched some numbers from their data tapes, and so those are the numbers that we used in the study, and we did a weight averaging of those by square footage of building type from the same original source.

Now I will say that there is some -- our most recent data, we did the weight averaging by number of shipments of ballasts destined to the building types from the LRI survey, for the year 2000.

Those lighting hours are higher than the building operating hours. We have always suspected they might be somewhat high because132

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 the way the question was asked by the CBEC's

auditors is: What fraction of your square footage is lit after hours? So that doesn't indicate how many hours after hours; two hours or all night.

So they could be on the high side. What we're going to compare them to is information from a large database of energy audits that we've purchased from Z-Energy.

That is a company who does nationwide energy audits. And that will give us not only commercial sector numbers, lighting hours and building operating hours by building type, but also industrial, which is where the data are

more scarce.

MR. RUBENSTEIN: This is Francis here. I finally managed to figure out the stupid table I was looking at.

According to this Commercial Buildings Characteristics, 1992 they basically quote about 67 billion square feet of commercial space. And according to the survey, anyway, they list about 3.6 billion square feet of space that uses133

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 occupant sensors. It sounds to me like that is a very, very optimistic number, especially since it also says that 15 billion square feet is speculative -- don't believe that for a minute.

Independent of that, it looks to me as though basically the amount of square footage where occupant sensors are being used today is really relatively small, it's sort of a 5 percent kind of effect.

So it seems as though basically that probably hasn't had that much of an impact, on the overall, on the general switching patterns within the commercial sector, anyway.

MS. ATKINSON: That was 1992 data? MR. RUBENSTEIN: Exactly, that's 1992. I think the only other thing that probably would have affected theirs is that in commercial buildings, how much manual switching do you see at different times throughout the day, and I think that probably most of our experience would be that there's relatively little switching that goes on during the day, let's say during134

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 lunchtime and stuff like that. So I think that in general, I tend to agree with the earlier comment that when you're talking about 4100 hours a year, the amount of switching you're going to do in a given day is good, in the general case can by typical, pretty minimal. MR. GELLER: Let me make a comment on those numbers. I have looked into exactly what they mean by the prevalence of different efficiency measures in buildings, and my understanding of how that survey works is that if the respondent has one occupancy sensor or one specular reflector, they indicate that 'yes, they have occupancy sensors in their building.'

And it may be that it's one percent or less of the floor space actually has occupancy sensors, but that building will be listed with occupancy sensors.

So as Francis indicated, those numbers are upper bounds on the actual fraction of total floor space with the different efficiency

measures.135

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 MR. RUBENSTEIN: Yes, I agree 100

percent with you, Howard. It's pretty clear, basically, these are definitely high numbers.

MR. LOGEE: Any more comments on this aspect? It seems to me now that we've discussed the energy costs; unless NEMA has other concerns there, to address, and we've discussed the operating hours. And that leaves us with discount rate; but this seems like a good point to take a lunch break.

So we'll take a lunch break and then discuss the discount rate.

MR. GELLER: Could I just ask, how much longer do people intend to go on? If this is going to be another half an hour and then we're out of topics, maybe it makes sense to continue. I just raise that.

MR. LOGEE: We have several items to discuss from NEMA. I don't know how long it's going to take to discuss those, and then we have non-energy factors, and -- so I think Howard, that it's time for lunch break.136

2 3

5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 [Laughter] MR. LOGES: 1 o'clock; it's Friday, it's nice weather, it's St. Patrick's Day.

[Lunch recess at 12:02 p.m.]

23137

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 A F T E R N O O N S E S S I O N [1:12 p.m., [Reestablishing telephone hookup] MR. LOGEE: I'd like to remind you that there are copies of all the handouts over there at the doors, if you didn't get one when you came back in.

There will be one more handout and it will be entered into the record. That's actually the compiled survey results from Burke & Associates that was done for Lighting Research, and that will also be available. That probably won't be available until later, but it will be available.

MS. ATKINSON: Some of the numbers that I've been quoting that you didn't have yet are in that data, and we're going to give you copies. MR. LOGES: There's a typed attendance list as well, and all of this will be part of the transcript and it will also be in the Freedom of Information reading room.

Discount rates is where we were, I138

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 guess, and NEMA. had some concerns or questions

there. MR. WISBEY: It's our feeling that the discount rates that are used, of 4, 8 and 12 in the analysis that was provided is reasonable, is better than it was before in the earlier analysis when we thought the discount rates were ridiculously low and could not be defended at all. We still believe that the discount rates in the present analysis are still too low. There are two numbers that we think should be more logical, and there are two bases for using higher numbers.

First of all is the fact that ballasts that we are talking about are used in industrial and commercial-type applications.

The users are on the average relatively sophisticated companies that are interested in maximizing their profitability and maximizing their cash flow.

Companies that almost without exception have internal normal discount rates that they139

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 use in evaluating among the various choices of possible expenditures that they can make.

The typical rates that are being used internally today in most major corporations to evaluate expenditures are in the range of 20, 25, 30 percent.

We don't necessarily propose going as high as 25 or 30 percent, although we think it would really be realistic for the kinds of things that are being done. MR. LOGEE: Let me interrupt there just a moment -- and discount rates is not anything that I have much expertise with, but•the discount rates that the Department uses, they include effects and some of those other inflationary effects and so forth.

I assume these 20 to 30 percent rates are market rates.

MR. WISBEY: Those are rates not adjusted for those kinds of things, I would say.

MR. LOGEE: Not in terms of taxes, so. MR. WISBEY: That's correct. MR. STEIN: So that's part of the140

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 difference. MR. WISBEY: So that could be part of the difference.

The numbers that we propose as being the most appropriate, and again we come back to some of the guidelines from the government; EPA has had the Green Lights Program, still has the Green Lights Program, which is a very major initiative aimed at improving lighting efficiency and so on and so forth.

The Green Lights Program traditionally, as it was originally established, used for evaluation purposes a discount rate of prime plus 6 percent.

At the time that we did our written comments on the initial rule last summer, the prime rate was 7 1/4 percent, so we used 13 1/4 percent in our examples. Since then the prime rate is 9 percent, so on that basis you would come to a discount rate of 15 percent.

EPA, in the Green Lights Program, has over the past year come to realize that that concept of establishing discount rates is141

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 probably too low, and is unrealistically low for

industrial-commercial concerns, and has changed their program so that now a rate of 20 percent is being used.

So it's our suggestion, our proposal, our recommendation that the analysis be done using 20 percent as the discount rate, and then the sensitivity analysis on either side of that -- for example 15 percent, according to the old EPA Green Lights Program for example would be a good low side sensitivity analysis.

That pretty much summarizes our thoughts and feelings on the discount rate.

MR. PERLIS: One further point on that. Because as you've mentioned before the rates that Bob just mentioned are normal rates, we wanted to do an inflation adjustment, make it comparable to the real rate that LBL used in their study, I think that you could take the 20 percent and reduce it by 4 percent to make it 16 percent. I think some of the sensitivity 23 ( analyses on our chart -- do you have any142

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 

### discount rates? MR. WISBEY: We did a 16 percent on that analysis.

MR. PERLIS: We did 16 percent based on the 20 percent EPA green light less 4 percent.

MR. STEIN: Another factor is, when we're talking about the analysis done in the Camin {ph} model, which is used to determine the energy savings in this whole process, the explanation that was given to us for the Camin model in the meetings in California, I think they talked about a range of 15 to 29 percent. Do you remember that, Ike, in what they're using? DR. TURIEL: You'd have to ask Barbara. She's more familiar with it.

MS. ATKINSON: That sounds right. MR. STEIN: So if you're using it in the Camin model to determine energy savings, why not use it in this engineering and economic analysis to talk about payback and lifecycle?

MR. LOGEE: Well, I'm really not going to try to answer that here other than to say143

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 that there are some restrictions placed on the

Department by the Office of Management and Budget in regards to discount rate, so we have to defer to their wishes to some extent.

MR. WISBEY: I don't think we were expecting some negotiation of this, if you will, but we wanted to make sure that we had our viewpoint out.

MR. LOGEE: Yes, that's fine; that's good, and we appreciate that and we'll try to take that into account as much as we can.

That's all you have on discount rate, then? MR. STEIN: Yes.

MR. LOGEE: Does anybody else have any comments on discount rate?

[No response] All right. MR. STEIN: Maybe we can get into the other thing we wanted to talk about, which is really a little bit of a sensitivity analysis, little different the way Ike did it. And we provided copies of this, and there are some144

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 copies on the table, so there should be enough

copies to go around.

We don't have to go through all the data; I just want to explain what we did.

MR. LOGEE: Mike, do you have an overhead?MR. STEIN: We didn't put overheads in, because we figured it was too difficult, I think, with this. We realize if we had this overhead it could have been better, but I'm not going to spend too much time on it.

We'll go through the numbers; in fact, I like what Ike and Barbara did in terms of the sensitivity analysis to allow the payback and pullout lifecycle costs, because those are the numbers we were concerned with, and leave all the other numbers off.

So when we do that for our written comments, that's what we'll do. That was a much better approach. We have an original set of data, just as you publish.

So Table 110 and Table 410, it says original data, are exactly as you published,145

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 land then we have Table 110 (Revised) where we

make corrections on the BEF for energy-efficient magnetic and the BEF for that maximum efficiency numbers, and they're highlighted.

So line 0 and line 3 are highlighted to show the differences, and if you want you can compare it to the original data.

For each of these, then, we provided a 4.10 that was comparable to show what, when we made those changes, what the results were. So those results are highlighted also.

Then in this case you did 6500 operating hours; we didn't think that was really realistic for this type of product.

We took the 6500 hours and tried to figure out what that should be because we thought it was high, and we looked in this book you gave us last time we were out there, where you talk about for the Camin building type and the hours, and we just try to pick some categories we think this product is used, and we think it's mostly -- Barbara read off some other information; based upon what we knew last night146

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 we said it's retail and grocery, mostly. It sounds like there's actually industrial, but even for the commercial sectors, retail and grocery, it looks like your numbers turn out to be 50-50 from the survey.

Where we said it was like 25-75. Anyway, for our purposes of this analysis, we put 4500 hours. And 6000 hours for the grocery represents 25 percent of the use, 4000 hours for the retail represents 75 percent of the use, so we just said "Let's make it 4500 hours." So for the analysis here, we replaced the 6500 hours with 4500 hours.

DR. TURIEL: Is this on Table 410, Mike? MR. STEIN: 110 and 410.

DR. TURIEL: Because here it says revised BEF, I see 6500 hours, it still says.

MR. STEIN: Yes, but then go to the next sheet. If you look on top it says, first is revised BEF and then the next pair sheets are revised BEF, and annual operating hours.

DR. TURIEL: Okay.147

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 MR. STEIN: We did each one in stages

so we didn't mix them up. We did so what the effect of each change would be.

Again, and the numbers affected are shown highlighted on the 410 sheet.

DR. TURIEL: Right. MR. STEIN: And then we put down -- 110 with new base assumptions really the same as this last.One time we revised the BEF and operating hours and then made a bunch of sensitivity analyses of each of those, where we did a 10 percent reduction in electricity, a 16 percent discount rate, and you look at that title on top, it's a 410 and then define what the change was. A 16 percent discount rate and a 10 percent reduction in electricity, and then -- MR. ADAMS: And this is all using the Table 110 new base assumptions.

MR. STEIN: Right. So we corrected the BEF then we went to 4500 hours, and then we made some sensitivity analysis on that. And I148

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 actually liked the way you did it, you did a

high and a low, and we'll try to do that, and also try to define what we're giving as typical.

When we pick a high and a low, try to give what we think the application is that means that high and low. Like a school or like a 24- hour operation grocery store or whatever we think is consistent with high-low information, we'll try to give a definition to it. And we'll do a little better sensitivity analysis.

Since we did go through this, we felt we should turn over the data. We'll give you data to substantiate on the energy-saving lamp types, the new BEFs.

This was data that I had, only from my data point, it isn't from all the manufacturers. But just for an example because we knew the number was way out, and we felt we had to point out the correction; and rather than to say it's wrong, let's show you approximately what it should be.

MR. LOGEE: So that's one reason you used this example you used this example, is149

2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 because you felt the BEFs were - MR. STEIN: Right. We found a couple errors in BEFs, so those should be changed, and then we did a couple other areas in the examples. For our written comments we will provide inputs, and wherever we think are applicable.

We may not redo all the tables or analyze all tables; we will determine which ones we think you will be contributing information. Just to send a whole bunch of data to you is not really what we're trying to do.

MS. ATKINSON: You're not going to redo the tables for us?

[Laughter] MR. WISBEY: Yes, we probably will. [Laughter] MS. ATKINSON: We'll do them with our database and see if they match.

DR. TURIEL: I'd like to suggest, if you are going to submit new BF or BEF or watts numbers that you not just give us the average,150

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 but as before we want to see the whole database

from which you arrived at your average.

MR. STEIN: What we're going to do for the submittal of data is give you a package just like we gave you last time.

DR. TURIEL: Yes. MR. STEIN: We will give you all the data points.

DR. TURIEL: Okay, that's fine. MR. WISBEY: Within the group, we agreed in the last hour that between now and the 31st that we can get this information put together for the six energy-saving lamp types.

Our database is nowhere nearly as good as what it was on the ten that we already provided; but looking at the sources you have to work with now, we recognize that even though we feel our database isn't that great but it's certainly better, I think, than what was already available to work with.

And this one was an example' because the BEF number in this particular rating for the energy-efficient magnetic or the energy-saving151

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 lamp was simply wrong. I have no idea why the

source of the number was wrong, but it was simply wrong.

It points out that no matter how imperfect, I guess I'll say our database may. be, it's maybe better than some of the others.

MS. ATKINSON: So you're going to provide data for the ES product classes?

MR. WISBEY: Yes. MS. ATKINSON: Including the 4-lamp? MR. STEIN: We may not have data for 4- lamps. MR. WISBEY: There may not be any data for 4-lamp.

MR. STEIN: There's old data for 4- lamp, but I'm not sure any of us make products for 4-lamp these days.

DR. TURIEL: Well, we'll look at the data when it comes in.

MR. WISBEY: This is the format in which we will provide it to you; the same format with the standard language.



### MR. ADAMS: Did I understand you to say152

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 that this is one of the products that you think

there are the biggest differences between our original and what you're providing? You said this was just from your -

MR. STEIN: In most cases of the cases, actually, we didn't find errors in BEF, but we'll have other corrections to make, possibly, in the operating hours or whatever discount rates or whatever else we want to say should be put in there.

Actually, for BEF we had problems in three tables; they're all energy-saving lamps. Three of those were magnetic ballast operating energy-saving lamps, and on two of those tables, the max efficiency number also didn't make

sense. We had one product where the data showed up 101 percent efficiency, so something -- doing a calculation the way we calculate what the theoretical efficiency is, and this was theoretically 101 percent. We said, something's wrong.

MS. ATKINSON: That would be the max.153

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 [Laughter] MR. STEIN: Like the couple of products that are identified, you know, were you able to find them in the Seattle database are identified as Motorola products and how we're going to go back and check them --

MR. WOLFMAN: There's at least one product that we pulled off the market several years. We submitted no data on that ourselves, but many of the utility databases are never purged. MR. LOGEE: That comment, Howard, about this product was pulled off the market several years ago and wasn't purged out of the database I think would be relevant to put into the written statement as well just to help -- then it says we can -- LBL can take that out, as well. MR. WOLFMAN: Yes, but that's for a specific product that we can identify. No problem doing that.

MR. WISBEY: I think the products also, a product of Howard's that is 101 percent154

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 efficientMR. WOLFMAN: We're good. [Laughter] MS. ATKINSON: I'd like to point out that we did do, in the tables that you have, for two of them we did do sensitivities of, produce a new table, and that would be Tables 49a and 410a. So those are the two F96212 regular lamps and with ES lamps.

Basically comparing them to.the commercial sector operating hours and electricity price, and the industrial sector.

MR. STEIN: Yes; we thought that was very good. And it shows up with different applications; I mean, that was the point, those are two real things that are out there for this particular product, and in one case it looks one way on payback and lifecycle and in the other case it looks completely different.

I guess the data -- did you have data on what percentage --?

MS. ATKINSON: Right, and for that product list, there were significant --155

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 MR. STEIN: Actually there's more

industrial.

MS. ATKINSON: Actually -- now I gave those away to be copied, but it's significant in commercial, though.

MR. STEIN: It's significant in both, and I thought it was more commercial than industrial, and your numbers came out more industrial than' commercial, which surprised me.

DR. TURIEL: For the HO I think it's a little more industrial, I think.

MR. STEIN: HO is even more industrial, that we would expect. That was 8020.

DR. TURIEL: No, I don't think it was that high. But we'll look --

MR. STEIN: We'll look at the data. But those are the things that are meaningful when you really have some sources that say 'Yes, we're using this product here in good quantities'and this product here in good quantities,' and in one case you get good returns and in the other case you don't get good returns.156

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Those are the kinds of things that are

actually going to happen, and that's what happens in the marketplace. Some places you can easily sell electronic products and in some cases you can't. That's what these calculations actually reflect.

MR. LOGEE: Are there any other questions or comments on the BEF, the adjustments and assumptions that NEMA made?

[No response] MR. ADAMS: Okay. I guess I almost hate to MR. LOGEE: Say it, Carl.

MR. ADAMS: There still is, somewhat troubling to me, this issue of -- on your last table, where you have a 10 percent increase in assumed difference in ballast consumer price for baseline and design option ballasts.

We have the same price for three different levels of efficiency of ballasts, electronic ballasts, whether we're talking about the 10 percent, the 50 percent or the max.

Obviously always the max is going to157

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 look better than the 10 percent, because they

cost the same and it's more efficient, from what we have here. Is there any way for us to get any sort of a differentiation between these different --?

MR. STEIN: Well, look at Wayne's circuits and analyze them, and determine which

ones -- [Laughter]

MR. STEIN: Let me talk at it differently; I was just making jest a little bit there. The prices in the marketplace are not necessarily determined by cost; and that's true in a lot of businesses; it's true in our business. So even if it costs more, if the end user doesn't pay a different price, you wouldn't change your analysis anyway. And that's really -- and we don't, as we talked about before, necessarily control what the end user pays. It goes through several channels and 23 1 each one takes their markup, and for different158

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 reasons; it could be for features or functions,

but it may not necessarily be to be competitive to take a job and not necessarily mean it's more efficient or less efficient, or if it has high THD or low THD or a whole bunch of the other, parameters that we talked about, are not necessarily reflected in what the end user pays.

MR. ADAMS: I guess my real question is, are you comfortable, to the extent that you can be comfortable with this as the data?

MR. WISBEY: Yes, Carl. In fact, we had some very extensive discussions of this at the two workshops that we held at LBL; the one in December and the one in January, to come back to the question:

I think a very basic point, it's a conclusion I think that everybody at this point is comfortable with, which is that the difference -- the question would be, if you can make a product, say, an electronic instant start of a certain rating, of this efficiency at this cost, how much more does it cost you to make it this efficient?159

2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 How much more does it cost to make it

this efficient is the question; and the answer to that, and I think it consistently is that none of us are able to actually differentiate in cost between these different levels of efficiency, if you will, and in prindiple all electronic ballasts that are being built and sold today are being built and sold based on their efficiency; so in almost every case, given the other performance requirements that may be required by the user like things that affect lamp life, things that affect harmonic distortion, etcetera, in every case, every individual company is building a ballast of that type as efficiently as they know how.

And if somebody were to come back to us and say, "you're building this electronic ballast, but now you have to make it 2 percent more, how much does it add to your cost?" We would wind up throwing up our hands and not being able to do that.

In each case, within the technology that's available in an individual company, and160

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 within the other performance parameters that are

done, there's not really a design trade-off of design efficiency versus cost; and we explored that in some length, because I think there's some possible logical assumption that that might be the case.

But it really doesn't exist in that manner because everybody's pushing so hard for each given type of electronic ballast to make it as efficient as possible, because that's the basis on which it's being sold today.

DR. TURIEL: So I guess the short answer is you are not suggesting that we change it? We don't hear anybody suggesting that we change that relationship.

MR. WISBEY: Right. The differences in efficiency between different -- for example, once we've adjusted this thing, you'll also see the differences if you look at the Table 1.10.

The third page that we have for the electronic instant start, for 10 percent, 50 percent and maximum, you'll see the numbers --161

2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 and we believe these to be realistic -- of .78,

.79 and .81.

And those differences are almost at the level of random variation and differences in efficiency that can be attributed possibly to other performance characteristics like, and I repeat again the total harmonic distortion, for example, is a very significant performance factor that has an impact, generally inverse, on efficiency, for example.

MR. LOGEE: So in your written comments, then, are you going to say anything about the different levels we have here, the 10 percent, the 50 percent or the maximum efficiency as a recommendation from NEMA, or anything in that regard? Sort of along the lines that we just said -- would justify the cost or lack of cost?

MR. WISBEY: My personal thing would be, and I don't know whether this is the time to do it, even now in the written comments in March or not, but in the end we certainly would have a recommendation as to whether, when you review162

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 standards, whether you should use the 10

percent, the 50 percent, or the max or not.

From the standpoint of the work that LBL is doing, and doing the study, using 10 percent, 50 percent and maximum, showing the data and the performance of those and with any inputs that we think we may disagree with, like some of the BEFs for example, will suggest changes. Is it appropriate, in the March 31st comments to make comments relative to how we think DOE should analyze or review the data once it's done, or should we only be making comments on the data itself?

MR. LOGEE: I think in those written comments, it's appropriate. It was not something that I wanted to get into here, but in the written comments it would be appropriate.

MR. WISBEY: Okay, because we are already on record as saying that what's referred to as the 10 percentile points are the ones that we think should be used in the review of possible study; and that's, we're already on163

2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 record as that, and we certainly reiterated. MR. PERLIS: Terry, I'm sorry, I stepped out for a second, but maybe this has already been touched on while I stepped out, the term "maximum efficiency" that's used here is arguably a term that comes from the statutory requirement of the Department of Energy looked at the maximum-technologically feasible product.

And there's a question in my mind as to whether that statutory source asks you to look at the maximum technological feasible design, which would be instant start electronic, as a global classification, or whether you had to probe within instant start and in effect the way this table might be read by some is that there are three different product classes; there's an electronic instant start 10 percent,-there's an electronic instant start 50 percent, an electronic instant start maximum efficiency.

I think what Bob just said is that that's not the case; it's just an electronic instant start ballast; and while they do differ because of certain performance characteristics,164

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 it's not that there is a high efficiency

electronic ballast and a low efficiency, a 10 percent efficiency electronic ballast.

The 10 percent number in our submission came about because we thought that there's just an instant start category; and so that really should have been the maximum efficiency. A single instant start number should have been the maximum efficiency for purposes of the statute.

The 10 percent number was chosen because there is some variability in efficiency within the design, and that it seemed to us appropriate for the Department, if they were thinking about setting the standard, and that's why you do this analysis to begin with, the standard shouldn't be set any higher than the 10 percentile of efficiency level; that you should not set as your goal elimination of half the electronic ballasts, because they're -- well, the other half have achieved the efficiency and this half hasn't.

The goal ought to be, at most, set it at the 10 percentile level, and that the165

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 differences then that would result in efficiency

are not inherent in the efficiency of the design, but various other random factors.

It could be design on these other performance characteristics, it could be materials, it could be processed, just inherent variability. And it was not an identification of products.

One of the unfortunate presentation aspects of the way these cables are laid out is that it gives somebody the impression that these are different products, and they're not.

MR. LOGEE: Well, these identify those various levels from a cluster of points given, in this case, in electronic instant start ballast, and three different levels of efficiency that are achievable.

That's what we've laid out here, and we've done that consistently throughout. In some cases there are rapid start ballasts as well included.

I think that NEMA, it would be good to have the rationale for why you would recommend166

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 some one level over another and what these other

causes of variability might be.

MR. CAUSEY: From our standpoint I guess there is a distinction in efficiency within the instant start. And we could certainly talk about the trade-offs of the designs. Of course, efficiency is not the only issue that's being sold in the marketplace presently.Low THD plays a major role. And of course to push down to the lower THD does cost. And so there are really two factors we're dealing with; low THD and also efficiency.

There's really a third one, and that's before. As soon as you see the before going up on a particular ballast there, you can anticipate the costs going up. And when THD goes down, you can anticipate an additional cost there. We can work to quantitize those for you if you'd like to have those.

So I certainly see within the instant start there, breaking out on a cost basis. You don't get 10 percent THD for free, and you don't167

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 get the higher ballast factors for free. And there has been a -- I'm a little bit surprised that you normalize to a ballast factor of 95.

What we've been seeing in the marketplace for the T8s, of course, and everything is moving toward 87 and 88, and it has apparently been established that that's a sufficient amount of light for frame fixtures.

The 95, there's a premium cost; when you push that ballast up to a ballast factor of 95, you've got to pay for the I-squared-R. And you've got to get the additional heat out, and you've got to overrate some of the components.

So there are costs associated with all of these things, and there are trade-offs. In the designs there is a continuous optimization process that goes on between THD and-ballast factor. DR. TURIEL: I was going to make two comments; one about the normalizing to 95 percent, that we started off with 95 percent for magnetics, and this is simply to put on an even168

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 playing field to go up to 95 percent. It's not that I am suggesting that you should do that in the actual workplace.

MR. CAUSEY: I understand. DR. TURIEL: It's just strictly to make an equal comparison.

MR. CAUSEY: It would be a little bit more favorable for the magnetics when you normalize at 88 or 87.

DR. TURIEL: But I think we did talk about this morning we could do an 88, also. We could do the same process. There should be some comments on that, actually, I'd like.to suggest to people, because that's something we talked about early this morning, should we normalize at 95 or 88.MR. CAUSEY: The industry seems to be moving toward 87, 88. I guess the latest ANSI standard is a minimum of 85. So it makes sense cost-wise to push your ballast factor down as close to the minimum as you can. That will give you the lowest cost possible in the market.

DR. TURIEL: The second thing I wanted169

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 to comment on was the relationship between THD

and BEF, and we looked at that pretty carefully from a number of sources of data, and we couldn't find any correlation between BEF and THD. I know there has been a few comments made here that the cost is affected, but as far as the actual efficiency, we didn't see anything. If you have different data than that, you should present it, but our present conclusion is that there is no relationship.

MR. CAUSEY: We can demonstrate the cost difference.

DR. TURIEL: Yes. MR. CAUSEY: As you push the THD down, we can show an increasing cost, most definitely, for a constant ballast factor.

MR. PERLIS: I think showing that kind of data is only relevant if the Department were going to consider standards based on the THD. And you're not going to.

The original technical support document170

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 just talked about instant start ballast as a

single class product, and the suggestion that there are now three types of instant start ballasts, whether it's THD-related or some other factors is, in my view, unwarranted.

The reason why the 10 percent number was provided here I think stems from our comments to you all last year, is that you should use the 10 percent -- there is some variability in the efficiency within the class of instant start electronic ballast, and that you shouldn't try to set your standard based on internal differences within the class.

That being so, you're going to choose to obsolete less efficient product designs when you set the number at the 10 percentile level, not at the 50 percentile level which is where you might have one if you hadn't thought about it in any more detail.

It's not because the 10 percentile was, on a cost-benefit analysis comparing its payback period with the 50th percentile; it's the place to be.171

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 That's not where this 10 percent number

came from. It's not what it should be used for is perhaps the way I should phrase it.

DR. TURIEL: We're not saying it's a different technology; we recognize it's the same technology, but there's a distribution of values at instant start.

MR. PERLIS: Right. And there's a distribution, a value perhaps in other products. I'm not personally familiar with whether there's a distribution of values at instant start.

DR. TURIEL: There's a distribution of value, perhaps,-in other products. I'm not personally familiar with it; there's adistribution in cathode cutout or energyefficient magnetic. I assume there is some.

DR. TURIEL: Oh, yes, there is some. MR. PERLIS: And it's not identified anywhere. It doesn't need to be identified, just as the instant start doesn't need to be identified by the Department to make the basic judgment. 23 1 But if you're going to do the analysis172

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 we thought that the standard should be set at

the 10 percentile level.

Therefore, all your comparigons ought to be set at the 10 percentile level. And that that's the only line that matters; the maximum efficiency doesn't matter.

The maximum efficiency is the 10th percentile of electronic ballasts, instant start electronic ballasts.

That's how you do it for every other product. You don't take -- the lamps are the ones that I'm most familiar with -- you don't take the lamp of a particular type that's described.There are four fluorescent lamps described in the statute. You don't take each of those fluorescent types which are a completely different types of product design and say well now within each of those, there's a range of efficiency differences that might reflect process, materials, maybe even some performance characteristics analogous to THD.

You can go to that level and then try173

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 to say Well, now, how do I justify-- are the

efficiency levels going to be justified within this? Now, Congress did that, not the Department of Energy.

What I'm suggesting is that that's the proper level at which you define the classes of products. And to think of cutting the instant start product more finely than just instant start is in our view unnecessary.

It's not how you started out the TSD, and so the revisions I don't think were designed to start cutting the instant start category ever more finely.

The issue is basically about whether you're going to obsolete magnetic ballasts; everybody knows that; that's what this whole process is about. And the analysis should all be geared to that so that if you do come up with standards now, or if you don't come up with them now but you've at least put out in the public a benchmark, so five years now when you revisit it we'll see what happened in the marketplace - 23 1 it's a comparison between instant start or rapid174

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 start and magnetic, the two types of magnetic

ballasts. And that's it.

MS. ATKINSON: The reason that both levels are in the table now are to look at the -- to see how much difference it makes; whether a 10 percent or a 50 percent level is chosen. I mean, this is what DOE requested from

us. The debate was over, "where's the BEF for the instant start ballast?"

MR. PERLIS: Right, exactly. And what we're - MS. ATKINSON: And a standard would be set at a BEF level, not a type.

MR. PERLIS: Right, and what we're suggesting is that as a matter of policy, the Department should have adopted at the outset a judgment that within instant start they would set it at 10th percentile, and that there would be no analytical examination or no necessity for the examination -- you have the numbers here, fine, you have them here.175

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 But that there shouldn't be policy

judgments being made on whether or not we should set the efficiency level at 50 or 10 based upon payback analysis, the way you would do the decision between instant start and magnetic based on payback and lifecycle costs, but within instant start, there should be no judgment as to where the number is set based on payback and lifecycle cost.

Instead, it should just be based on what percentile you want to get at, and our judgment is that you shouldn't go any higher than 10 percent because in effect you'd be just disturbing the marketplace for non-efficiency

reasons. You know, whatever would account for the variability has nothing to do intrinsically with efficiency.

MR. ADAMS: Can a case be made that the applicability of instant start ballasts is a function of these percentiles of the market?

As I understand it, to get the low THD or to get the improved life or something you may176

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 have to make compromises in the design to

achieve these results, to be able to use the ballast in various circumstances, and that, I guess I'm wondering, is there a relationship -- can we make a case between more universal applicability with the lower percentile as opposed to the higher percentile, if I use percentiles instead of percents?

In other words, the most efficient ballast that there is in any given category has less usefulness or applicability -- I'm speculating there.

That you could make it a little more efficient, but then it's not as useful in as many places?

MR. PERLIS: I just prefer to say that it's different.

There are different performance characteristics, other performance characteristics that will be different between the maximum efficiency electronic ballast and the 10 percent.

Those differences are not being studied177

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 by Lawrence Berkeley Laboratories. They have

not undertaken a study of THD, they have not undertaken a study of any of the material differences within the instant start category.

DR. TURIEL: I'd like to make a correction about that., because at least that one factor; we did look at THD, and I just said it about one minute ago, that we looked at it and found no correlation. I just told you.

MR. PERLIS: Well, then, I misspoke, and you're correct. You've undertaken the analysis but have determined that there were no performance -- you couldn't slice the category based on performance criteria.

Performance criteria. It's another way of saying you can't sub-define the class based on THD. Had they found the correlation, then maybe they would think of doing that.

MR. CAUSEY: Where was the correlation looked for? Where did LBL look for a correlation?

DR. TURIEL: Where? You just looked at THD versus BEF, that particular feature, THD178

1 2 3 4 5 6 7 8 9 feature. MR. CAUSEY: Yes, but those two features are somewhat unrelated, and I'm not surprised you found the lack of a correlation.

DR. TURIEL: Well that was thrown out as one of the things that we should look at.

MR. CAUSEY: They can be treated very much independent of each other, so you would find a poor correlation. But on the other hand, 10 if you went at this thing -- and of course I 11 think THD is very important, because THD leads 12 to, there's an energy consideration there, THD 13 leads to K factor, and then K factor tells how 14 much additional energy you're dissipating in the 15 distribution transformer that's supplying that 16 particular power grid. 17 And the higher the K factor is, and 18 it's not directly related, but in general the 19 higher the THD, the higher the K factor. 20 So now. you're increasing the power 21 dissipation in the transformer down the street, 22 which can be significant. 23 It's hard for me to think of you179

2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 looking at ballast from an energy standpoint

without concerning yourselves with K factor, and what you're doing in dissipating additional energy in the transformer outside the building. But if you wanted to, you could oscillate out --if you were going for the low cost energyefficient ballast, then you'd probably want to trade off on THD.

Also, you're struggling with ballast factor. You've got about three variables here, and you're looking for correlations. It's very difficult for you to decide what you want. And so the electronic ballast area is probably complex enough that it may be necessary for you to segment it out.

When you deal with that high ballast factor, you're going to run the cost up. Anytime you kick in low THD you're going to run the cost up, and those are pretty much independent of each other; they're related but they're also independent.

MR. PERLIS: That's all to be done on the next Department of Energy review of the180

2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 products, when you just have an electronic class

and then you're trying to figure out whether you're going to raise the efficiency rating, then you can examine these other factors.

They haven't been examined to date; but to introduce it now you're almost requiring everybody to reexamine the whole approach here. This is basically an electronic versus magnetic study. MR. LOGEE: Any other comments on that?

MR. SWANSON: Yes, this is Dail Swanson. If you look in the data, there actually is, I guess, an example cited that Carl brought up about looking at the difference between a 10 and a 50 percent. If you look at Table 1.14, on a 2-lamp T8 model, the ballast factor for the 50 percent is .78 versus .88 for the 10.

DR. TURIEL: One second. 1.14, you say? MR. SWANSON: Yes, 1.14. NEMA's data.

The issue being is that the 50 percent number is a low ballast factor product. And it181

1 2 3 4 5 6 7 8 9 10 goes into an area where high lumen levels or

normal lumen levels aren't needed.

DR. TURIEL: Hold on one second. I don't even have the table yet.

MR. . It's your 114. DR. TURIEL: Our 114, not NEMA's 114. MR. : Well, you collected data, too. MR. LOGEE: That's 2 F32 T8s, is that what that's for?

MR. STEIN: This happens to be the 11 ballast that represented halfway in the middle. 12 But on either side of it could have been an 85 13 or an 88, and you look in that maximum, that was 14 a .9 present. 15 We have a lot of variables that are -- 16 I'm not sure how many different ballast 17 manufacturers are looked at in the table. If 18 you look at the Seattle data, there's probably 19 at least a dozen. If you look at NEMA, there's 20 five that we have in there. 21 There are variations for THD that have 22 been talked about, and an indication that -- and 23 actually, if you take one design and-one type of182

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 electronic circuit in your 20 percent THD and

you want to get 10 percent THD, you can probably calculate literal cost to get from one to the other and how much energy will cost.

But that's not the way to do it because once you get to that point, you'll probably want to do a different circuit to get to the 10 percent THD, and then the EMI changes, and you have to look at EMI and how do you get the EMI down to the levels you want, and there are a bunch of different parameters that a design engineer looks at, and not only the ones that Wayne talked about with several others, in trying to pick his most efficient and optimum design based upon his manufacturing process and based upon the circuits, that he doesn't want to infringe on someone else's patents because there's that issue around there, too.

There are lots of factors that play into this thing in getting into a level that excludes some of the products on the market. We may be excluding a product that there is demand for in the marketplace.183

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 If someone wants to have a very low THD

and it's less efficient, or a very low EMI and it's less efficient, whatever else, they are out there. We haven't quantified what these markets are, we know they're out there because we sell into these markets. We haven't quantified what the differential these particular things call for. The 10 percent would allow most of the products on the marketplace to be sold in that product class, and then let the marketplace determine who has the most cost efficient and energy-efficient product out there, once you pick whatever level you're going to pick.

We're getting too far in, and you've picked the 50th percentile, you're already digging into the marketplace and saying "these products are no good to go away."

MR. ADAMS: Let me say first of all; Gene and I need to leave to go to another meeting. Certainly the meeting will carry on.

As I understand it, it was not our intent to have three different design levels of184

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 ballasts here. We are looking for, or we would

be looking for a basis for selecting what the justification is for selecting 10, 50, 90.

And I guess that was the basis of my question; can we say, can a case be made that by picking here it is more applicable; you know, it covers all the ranges of THD, EMI, life and so forth, that in designing for those particular characteristics that it has an effect on efficiency; and if you want to have the most applicable representative, electronic ballast, this is the point that you pick it at, not that we're looking at three different levels.

MR. STEIN: Another fact, just to throw in, we provided this data to LEL was, what kind of variation in efficiency do we get for a large production run? And we presented that, and it varied within our runs, but it typically ran up to plus or minus 2 percent. So you're talking a 4 percent range of what we're capable of producing.If you. look at the variation of the numbers here, you could have picked one product185

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 one day and another product the other day and

have this 4 percent, and it covers part of what we're talking about, a good part of what we're talking about between 10 and 50. So actually that could be even the same product.

MR. PERLIS: The 296 is a 4 percent range between the 10 percent and the maximum efficiency is a 4 percent variance. Table 110. And that's probably no more than what manufacturing tolerances would give us.

MR. LOGEE: Yes, Wayne? MR. CAUSEY: I just want to make a statement about the 10 percent versus 50 percent. The products out there now represent kind of the start of a new technology, and it's really just a hodgepodge of designs.

A lot of the designs are just inefficient, and they're going to fall out of the marketplace in time. The point being that the 10 percent, you're talking about year 2000.

The 10 percent doesn't push the technology hard enough; that doesn't even scratch it.186

2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 The 50 percent is just a place to start talking. You're talking about year 2000, and you're looking at that on a bunch of old designs for the most part.

They had just come out, been out there for the past five, ten years. Folks are just now getting their acts together on the electronic ballast. Ten percent is way, it's not nearly high enough.

You're just not pushing the technology enough; you're accepting a bunch of older designs. MR. LOGEE: Okay, thank you, Wayne.

Are there any other comments, just to wrap this up? Otherwise, we'll move on.

MR. PERLIS: Let me just suggest one thing, Terry, that since the three year payback period is presumptively to be adopted.

MR. LOGEE: That's the rebuttable presumption, yes.

MR. PERLIS: No, it's irrebuttable, if 

### it's less than three years - 23 1 MR. LOGEE: "Irrebuttable" that's -187

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 [Laughter] MR. LOGEE: What we call rebuttable. It's a given.

MR. PERLIS: If you look at the ballast price, the low ballast price, the low delta, the $6 delta that LBL presented this morning, and that happens to be in this handout here, the maximum efficiency --

DR. TURIEL: Hold on just one second, please, so we can take a look with you?

MR. PERLIS: Right, it's the 2 F4 T12 and T12BS.

MR. CAUSEY: Is there a page number? MR. STEIN: SENS, SOS. Page 8. MR. PERLIS: If you look at the right hand column here, regardless of whether that's the right assumption to use for the analysis, but if you compare maximum efficiency to 50 percent to 10 percent, the maximum efficiency is lower than the 50 percent and it's way below three years. It's presumptively the one that should be adopted.188

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 That's clearly not where the Department

should go. It may be, as the last speaker said, that you may in some theoretical sense want to push the technology envelope closer to the 50 percent level, but this study that's been undertaken doesn't consider any of the other relevant characteristics, as presented here. Not to say that they didn't look at the THD and not present the data; but there is no analysis of all the other aspects that you would want to take into account if the issue on the table was, where within electronic instant start ballasts are we going to set the efficiency levels at?

And in order to do that we need to define the electronic products; we need to define them in some way.

We need to take account of other performance characteristics, of variabilities whether it's due to process, manufacturing, the hodgepodge or whatever it is. And none of that has been done.

The 10 and 50 percent were just looking at picking numbers off. And as I say, I think189

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 the 10 percent was suggested by us for a

particular reason, and it had nothing to do with trying to say that that' s as far as you wanted to push the envelope within the electronic class. It was'based on an assumption that you were going to make a choice between electronic or magnetic.

DR. TURIEL: Mark, I agree with you that this table doesn't look at those factors; it wasn't meant to.

MR. PERLIS: Right. DR. TURIEL: What you just said now about your 10 percent, I think what Carl was asking -- I'm trying to speak for Carl but I might be wrong -- but what I think what he was asking was, there needs to be some justification as to where you came up with your 10 percent. It can't be just saying "Well, we want to keep 90 percent of our products." It has to be something more than that.

MR. PERLIS: No, it is exactly that. It is exactly that. It is exactly that the190

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Department has hot undertaken an analysis to

make a rational judgment in the sort of sophisticated way that you're doing here as between magnetic and electronic, as to where within the electronic category you should set the standard.

If you make the judgment that electronic has a payback period and lifecycle cost that justifies it, for one of these product classes, there is no comparable analysis undertaken that would allow you to set it at 50 percent rather than 10 percent.

Therefore, the only logical place to do it is at a very low percentile. We chose 10 percent; it's an arbitrary number. It is not justified by any analysis per se.

MR. LOGEE: Part of the reason we don't have the analysis is because we don't have the cost data. And you're telling us you can't identify; I need to know the cost.

MR. PERLIS: No, it's not a cost issue, Terry, it's not a cost issue. It's that within the class there are other performance191

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 characteristics, other reasons why the

efficiency might vary and that you would need to undertake all those by considering the proper definition of the product classes within electronic instant start. And that hasn't been done from Day One in the analysis here.

If you want to do that, that's fine, but you've got to start over again and look at it from that perspective. And that hasn't been done yet. And just because you have these three lines here doesn't mean that there are three product classes.

I think what's happened, I fear, is that people are perceiving it that way, that somehow there are three distinct product classes that one could imagine defining here, as 50 percent, 10 percent, and maximum efficiency.

While there may be such classes, they're not defined by those numbers.

MR. LOGEE: These are levels within the same class, Mark; they're not three different classes. 23 1 MR. PERLIS: They're just numbers off192

2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 of 20 data points. Out of 20 data points we gave, they took the second lowest, and that was the 10th percentile.

DR. TURIEL: And we recognize that. I'm not saying anything different.

MR. PERLIS: Well, you do, but I'm not sure that we've persuaded Terry that that's all that's gone on here.

DR. TURIEL: I'm sure Terry is very aware of that.

MS. ATKINSON: He's been in on it. MR. LOGEE: That's not the main point of this particular workshop, but I thought that we had time and we needed to raise that as an issue, and to get response from the manufacturers and others in that regard.

As I looked at what we had originally put on the agenda, it seems like everything hasbeen covered at this point except for those nonenergy factors. Did you want to discuss those now, Barbara? Have we already discussed some of those. 23 1 DR. TURIEL: That's what we were193

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 discussing. MR. STEIN: That's probably what we were discussing.

MS. ATKINSON: We talked at the last meeting about the manufacturers seeing if they could work on something that would have given us more detail on these non-energy factors and how they affect, correlate or don't correlate to efficiency and possibly the cost.

DR. TURIEL: Right. You were going to get some information to us about that, but we haven't received anything, so far anyway.

MR. STEIN: Repeat that again, Barbara? I want to make sure I answer that right. What information did you ask for?

DR. TURIEL: How these other features, performance features --

MR. STEIN: I thought we discussed why we can't give you a quantifiable answer, because there's more to it and there's more compromises than just saying "THD equals this and EMI equals this, and XYZ equals that." If it was quantifiable, I think we'd try to do it. Maybe194

2 Wayne thinks he can quantify more power to

3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 him. Our engineers do this all the time, and

to look at the whole basket of what the requirements are, and in their design considerations, pick what they think is the best compromise. That's what engineering is, picking the best compromise.

I would like to throw out something, that when we got into regulating ballast efficiency, it actually happened in the early '80s; it happened when we had magnetic ballasts and we had -- we made four classes of product, I don't know how many other people made, and we decided to eliminate three of those classes. These are all magnetic. We know it as a standard magnetic, and then there were two intermediates and then the energy-efficient magnetic. Those products were on the market.

And in California, California decided to push for energy efficiency and they met with the ballast manufacturers, and they decided, "Let's pick the,energy-efficient magnetic," and195

1 2 3 4 5 then they said "Let's come up with a requirement that will encompass all the energy-efficient magnetic. Don't pick the most efficient one and have everyone else push up to it; come up with a class of all the energy-efficient magnetic" and 6 that's where the standard was set. That's where 7 we got 105 and 106. 8 We said because the 2-light 40 was the 9 most popular, we said we can do more with 10 efficiency on 120 volt than we can on 277 volt 11 in the magnetic world; so we came up with 12 actually two numbers there, and the others, we 13 decided one number because the volumes weren't 14 as great as on the 2-light 40, and we said we 15 can meet the same efficiency on both. 16 The goal was to make a standard that 17 will be an umbrella and incorporate all the 18 requirements, and you didn't have the next 19 lowest level creep up in there and people try to 20 sell into that level; everyone made the energy 21 efficient magnetic. And I think that's sort of 22 what Mark was addressing in a different way, but 23 he wasn't part of this process originally is:196

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 we have electronic rapid start, electronic

instant start, or just electronic rapid start or electronic instant start; sometimes you have both and sometimes you only have one.

And our 10 percent was saying we probably have some bad numbers and bad data and maybe some inefficient designs; and we said "Let's pick a 10 percentile. Maybe the numbers should be 15 or 20, but we want to come up with an umbrella that includes all our manufacturing variables and most of the designs are out there. Let's not exclude people, then the marketplace will be what determines if we set a different efficiency level. The marketplace will be what determinative people want to go out and be more efficient or go out and sell in the marketplace and be more efficient; that's what capitalism is. We have an opportunity to do that; if it costs more or it costs less, the guy'that has the best product and the most cost effective is going to win.

DR. TURIEL: Well, I understand perfectly what you're saying, but I think what197

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Carl is looking for is something that he could base a decision on.

MR. LOGEE: Yes, something more quantifiable.

DR. TURIEL: Exactly. That's what he was trying to ask.

MR. PERLIS: I think we've pretty much said the same thing in different ways in the last three meetings; and if we could quantify it, we would.

MR. WISBEY: We're willing to make a statement as a NEMA group, I think, but it is not quantifiable, in our opinion and.our capabilities. We've said that as many different ways, I think, already as we can.

MR. LOGEE: Well, that's fine. We'll certainly take that into account as best we can.

Barbara? MS. ATKINSON: Can I make hopefully a clarifying question to you. On final tables of design options, is it likely then that one or the other of the 10 and 50 would be selected and analyzed? And also that there would always be a198

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 maximum efficiency because by law, an option

needs to be defined.

MR. LOGEE: Right. There will always be a maximum efficiency because as Barbara said, by law we have to put that on there.

MR. PERLIS: It doesn't have to be done that way, Terry. The instant start could be the maximum efficiency.

MR. LOGEE: Well, that's not my understanding, Mark. But then I don't make the interpretation of the law here; Eugene does that. MR. PERLIS: You've defined the world into four product designs.

MR. LOGEE: I'd like to cut that off, Mark, because I think we -- you know, we've covered the ground, it's in the record, and I would appreciate written comments to expand on it if you think you need to. That would be helpful, I think, for DOE. And to answer your question, that decision hasn't been made, really. So we'll have to look at that.

I think when we've got these written199

2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 comments, then we'll make that as a final decision. DR. TURIEL: I was going to say, there has been some input that is quantitative that you've given us already that does impact this question which is about the variability in terms of manufacture of the same exact ballasts, that there is some variation. So you have provided that information. That does bear on this question. I think Carl was looking for anything beyond that. That's how I interpret his question. MR. LOGEE: Ned.

MR. BRUSH: Getting back to the point on payback analyses and why some of these things are of great importance in determining just what the payback is going to be.

Mike Stein mentioned something about operating hours a minute ago, and I think Francis Rubenstein had referred to this commercial buildings characteristics book by EIA, and there is a 1992 version of that out;200

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 and in table A20, under weekly operating hours,

if you look at their first line which is a summary for all buildings, which include some 68 billion square feet of space in the United States surveyed, you come up with about 8 billion of that has less than 40 hours a week of use. And an additional almost 15 billion comes in at between 40 and 48 hours. Or if you total that, percentage-wise, some 34.2 percent of all of the space surveyed is in use less than 48 hours a week. And with the trends towards increased controls and requirements for more controls and so on, I think that will probably come closer to what actually the lighting is in future years than perhaps it has in the past, but you've got a huge number of the total square feet surveyed, that in fact has a very short duty cycle, at least compared to the numbers of 4,000 hours a year, which is closer to 80 hours a week. DR. TURIEL: Is that lighting hours you're reading off, or are you reading supposed occupied hours, because they could be different.201

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 MR. BRUSH: That's right. That's why

I'm saying --

DR. TURIEL: The lighting hours could begreater thanMR. BRUSH: Absolutely. Because you'd have janitors and so on.

DR. TURIEL: Right. MR. BRUSH: But I think with occupancy sensors and some of the controls, perhaps that trend will grow closer by the year 2000 in terms of actual lighting in use for in fact the service hours of the facility.

But the point I was trying to make is, it's not an inconsequential percentage of that total surveyed square footage of 68 billion. In fact, it's like 34 percent that is in use 48 hours or less, which is a tremendously different number than your maybe 4000 hours a year which works out to what, 78 hours a week I guess or so number roughly like that.

MS. ATKINSON: No. Those buildings - MR. BRUSH: So there are some distinct 

### 23 1 applications that are low duty cycle, I guess is202

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 what I'm saying. That may be big volume. MS. ATKINSON: The lighting hours of those buildings were included, would have been included by EIA in their report from which we took our annual lighting hours. So they would be factored in, offset by buildings with higher operating cycles.

MR. GELLER: I was curious what the percentage of 24 hour buildings was on that same chart. MR. BRUSH: It's about 10 billion square feet out of 68, which must be about what, 14 percent, continuous?

MR. GEJiLER: So 14 percent is double the hours?

MR. BRUSH: Oh, yes. I guess the point I was trying to make is it's not an inconsequential number and I think the market forces here, there are going to be a big number of applications of low duty cycle where there's not going to be any payback anything like 80 hours a week. If you use the average of 80 23 1 hours a week or your 4000 hours, roughly, you203

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 have just about doubled that payback period for those buildings that are only on 40 hours a week or less. DR. TURIEL: Right. Well, that's an average, that's the consequence of an average. Some buildings will be higher, some will be lower than that average.

MR. BRUSH: I was trying to say there should be a sensitivity analysis here on operating hours, very definitely.

DR. TURIEL: That's what we showed this morning. MR. BRUSH: Yes, and that's a great one, and I think Mike Stein was saying there's going to be something additional because some of those hours, at least for some classes of use, might even be lower or slightly different than your 4000 and 6500; but among the marketplace for low duty cycle, there is a substantial percentage that-is actually in use for very limited hours.

MR. LOGEE: Thank you. Would you please see that Sandy gets a copy of that so we204

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 can refer to that, properly cite that in the

proceedings.

MR. BRUSH: Sure, be happy to. MR. LOGEE: So that people can look at that particular table with the transcript, and then look at the entire citation if they want to. Any other -- this is I think a good time, now, unless someone has another issue to just recap, if there is any further discussion on any of the issues that we've covered.

Have we finished everything that LBL wanted to present?

DR. TURIEL: Yes. MR. LOGEE: Is there anything else from NEMA? MR. STEIN: I thought it was a very 

### 18 good meeting, good exchange of information on 19 what we've basically been proposing in a 20 continuing dialogue and not just a little bit 21 here and go away and do your own thing; I think 22 there's dialogue back and forth. It has been 23 good because you get to a certain point and205

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 there are other things that pop out, like we

talked about today, that we didn't see to discuss the first time around.

We I think are trying to be.as forthright as we can and being open as we can and supply as much information as we can, sometimes we're restricted internally by the company or actually technically, as part of the last conversation is; but we hope the process is working, it seems to be working, and I think LBL has done a very good job up to this point.

MS. ATKINSON: Terry, we did want to clarify something about manufacturer costs.

MR. LOGEE: Yes, you could perhaps do that better justice than I could.

MS. ATKINSON: In the last meeting -- we talked about this several times today, but I wanted to just mention it again. In the meeting at LBL in January we talked about the piece of the MIM request that had to do with the manufacturing costs, and some breakdowns of those. 

### manufacturing costs. And you said that you206

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 would see whether rephrasing that questionnaire

and clarifying those breakdowns of the pieces of that cost, and asking the question in terms of the whole industry instead of your individual companies, you might be able to come up with some numbers and I want to ask where that went.

MR. STEIN: Well, some of us came up with some numbers and some didn't, based upon constraints we have with our management, and I know personally I'm going to go back to our management and see if we can give it another shot. It's difficult to release information that we consider very proprietary and confidential to someone even though the promise of confidentiality is there; our management is just uneasy in doing that.

I maybe didn't push hard enough, but I did push quite a bit, and we'll go back and make another effort.

MR. WOLFMAN: I would echo Mike's comments. Many of our corporations have very firm -- they're not just guidelines, they're rules about manufacturing information and207

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 manufacturing numbers, data costs, etcetera. I,

too, will go back and try again.

MR. LOGEE: Well, that's all we can ask. The point was that there are sort of two parts of this data request, and the one part may be a little more, a little easier, maybe, to get release of, and maybe you could release that data to LBL; not to DOE, because LBL can provide better confidentiality. In DOE, we have to deal with the Freedom of Information Act in determining whether it's confidential, and so forth, and that's pretty complex.

DR. TURIEL: Let me just clarify, because there were two parts to the request; one part had a whole bunch of questions about the company; another one was manufacturing cost tables. And I think the part that had all these different questions was rephrased, is my memory, and sent to NEMA, and I think it was distributed in a way that the questions would be about industry averages rather than the particular company. 

### 23 1 It would help if that was done also for208

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 the manufacturing costs. MR. STEIN: The way I interpreted it, the manufacturing costs were done that way.

DR. TURIEL: Was that done that way, too? I don't recall. Okay.

MR. STEIN: That's the way we would have tried to answer it.

DR. TURIEL: Okay. So that was done already that way.

I wasn't clear that both parts -- because I didn't do that part myself.

MR. WISBEY: I don't think it was ever a written questionnaire went out, that formal. We discussed that at the last meeting --

DR. TURIEL: Okay. To interpret it that way.MR. WISBEY: And agreed -- in fact that would be an unacceptable interpretation. Because I know we responded and I know that as the manner in which we responded.

DR. TURIEL: Okay. Thanks for the clarification.

MR. WISBEY: I don't think there was209

2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 ever any change in the written questionnaire. DR. TURIEL: Okay. MS. ATKINSON: And LBL is obliged to make estimates, to make our best estimates based on what we get at the cutoff time.

MR. LOGEE: Howard? MR. WOLFMAN: This may be your last question, Terry, but at this point can you share your timetable with us?

MR. LOGEE: I can share some of it; LBL is probably going to have a completed analysis by perhaps the end of May. I think we have to readjust their time schedule for some of the delay to get these written comments in. But that's -- the end of May, early June is a -

MR. STEIN: That's the complete TSD. MR. LOGEE: That's the completed analysis, yes.

After that, why hopefully within not too long a time, perhaps a month or six weeks or so, we'll begin'to circulate within DOE a draft notice of proposed rulemaking. Now that may be pretty optimistic, but that's what I think --210

2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 I'm going to be under that kind of pressure. It then takes, as you can well imagine, a fair amount of time to get through the draft to incorporate comments from a number of different sources internal to DOE, then to go back out with what we call a concurrence draft, and again go through some of the same hurdles. Concurrence is a more formal approach to it, and I don't have the schedule in front of me to really speak to it, as to just when we might be looking at publication. So I really can't speak to that. I believe there is a schedule but I just don't know what it is. It's far enough off in the future at this point -- and I'm not under the gun for it, yet.

[Laughter] MR. LOGEE: Does that answer --? MR. STEIN: That's good. We were trying to guess, and I guess what we sort of guessed, first quarter this year, first quarter next year.MR. LOGEE: Your guess is probably as good as mine if not even better. It's really211

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 crystal ball stuff. Anything else from the other end of the table? Well, I thank you again for participating in this; I agree with what you've commented, Mike; I think this has been very beneficial on behalf of DOE. A number of issues have surfaced that we are going to have to pay closer attention to and deal carefully with. We're looking forward to getting those written comments that include in as many cases as possible data and the rationale and reason for why you've approached it this way; that's very useful to us, and I'd like to repeat that we do need that by the end of this month so that we can keep this schedule moving. That's a critical cutoff point for us, that's the 31st of March. And if there are no more -- You're just resting your arm over there?

MR. : Sorry. MR. LOGEE: This is like an auction, you know, if you twitch your nose, why, it's212

2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 sold. [Laughter] Okay, thank you for coming, and this workshop is adjourned.

[Workshop adjourned at 2:31 p.m.]

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