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.

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TRANSCRIPTION SERVICES

1831 Ivy Oak Square

Reston , Virginia 22090

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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 Laboratory

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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

NEMA

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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 Lighting

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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 items

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P R O C E E D I N G S

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(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. All

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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 interested

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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 to

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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.

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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.

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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.

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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 to

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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.

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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.

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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 problem

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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.

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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 in

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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 on

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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 few

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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.

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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 essentially

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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 maximum

efficiency. 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 life

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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 when

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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.

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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 to

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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 higher

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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 the

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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 affect

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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]

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[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. As

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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, as

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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 out

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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 looking

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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.

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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 to

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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 identify

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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're

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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, the

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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.

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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.

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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 have

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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, the

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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 is

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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 fixture

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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 that

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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,

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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 get

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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 for

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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 analyzing

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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 for

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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 bring

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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 with

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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.

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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 provided

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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 looking

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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 way

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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.

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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, it

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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 two

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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 the

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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 the

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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.

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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?

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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.

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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 the

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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 for

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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 done

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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 least

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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 taken

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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 the

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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 and

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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.

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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,

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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.

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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. What

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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 was

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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 --

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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 fact

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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 project

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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 life

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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, the

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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 the

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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 of

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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 change

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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; so

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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 the

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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, and

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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.

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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 have

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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,

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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?

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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 more

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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 we

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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 used

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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 cents

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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 50

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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 of

Lamp Ballasts Workshop March 17, 1995 Comment 09
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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.

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DR. TURIEL: Do you have stuff to hand

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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 were

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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'd

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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 data

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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 market

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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, your

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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 embargo

environment 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]

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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,

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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 that

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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 of

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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 took

here 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 very

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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 user

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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 delta

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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.

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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 on

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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 4

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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 that

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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 we

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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;

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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 up

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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?

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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 --

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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 do

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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're

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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 labor

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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 for

the 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.

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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 is

primarily based-on the number of starts, the oncycle.

23 1 MR. WISBEY: No. That's the rating

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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 annual

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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 space

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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 be

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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.

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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 what

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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.

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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 because

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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 uses

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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 during

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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.

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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.

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[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.]

23

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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, I

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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 they

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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 the

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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 is

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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 any

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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 say

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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 some

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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,

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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 night

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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.

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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 I

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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, is

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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,

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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-saving

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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 say

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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.

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[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 percent

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efficient

MR. 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 --

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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.

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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 to

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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 different

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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?

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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, and

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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 --

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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 review

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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 on

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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,

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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 the

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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 recommend

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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't

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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 even

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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 wanted

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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 document

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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.

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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 a

distribution 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 analysis

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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 try

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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 rapid

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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.

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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 may

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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 studied

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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, THD

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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 you

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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 the

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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 it

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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 of

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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.

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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 of

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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 product

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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.

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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 -

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[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.

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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 think

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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 the

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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 performance

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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 off

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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 has

been 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 were

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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. Maybe

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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," and

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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:

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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 what

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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 a

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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 written

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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;

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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.

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MR. BRUSH: That's right. That's why

I'm saying --

DR. TURIEL: The lighting hours could be

greater 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 is

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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, you

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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 we

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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 and

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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 you

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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 and

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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 for

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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 was

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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 --

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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 really

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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's

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sold. [Laughter]

Okay, thank you for coming, and this

workshop is adjourned.

[Workshop adjourned at 2:31 p.m.]

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