January 3, 2011 

Mr. Victor Petrolati 

U.S. Department of Energy 

1000 Independence Ave. 

Washington, DC 

Subject: Ex Parte Meeting with DOE and Navigant Consulting on Battery Charger Energy 

Standards, December 6, 2010 

Dear Mr. Petrolati: 

This memo memorializes the meeting between AHAM, PTI and the Department of Energy on 

December 6, 2010 for inclusion in the public docket. 

In summary, during the meeting, we were able to cover several topics that are related to DOE 

setting the standards for consumer battery chargers that apply to power tools and other 

appliances and fall under the category of Motor Operated and or Detachable Battery (MADB) 

chargers. 

1. AHAM and PTI noted that some of the Candidate Standards Levels for Product Classes 2, 3, 

and 4 appear to be set dependent upon the type of cell chemistry. It looked in the initial 

evaluation that CSL 2 was only achievable with Lithium-based cell chemistries. 

2. AHAM and PTI noted that most of the consumer products marketed are still composed of 

nickel-based battery chemistries which continue to offer great consumer value. Often, 

consumers do not perceive the value that lithium-based batteries might bring them. This restricts 

the value for consumers and makes it difficult to market them. 

3. Most of the products in Product Class 3 are computer devices and they mask the cost and 

performance of the consumer MADB battery chargers. AHAM and PTI asked DOE and 

Navigant to investigate what would happen to the LCCA of Product Classes 2, 3, and 4 if the 

information technology products (non-MADB) were not included in the equations to calculate 

unit energy consumption. 

4. AHAM and PTI noted that the preponderance of the BCS’s are under 50 Wh and asked that 

DOE and Navigant consider a minimum value on the line slopes that could be drawn horizontal 

to allow for fixed energy losses of lower power systems. 
p 2 

5. AHAM and PTI asked DOE to look again at the usage profiles, particularly for the Product 

Class 2 in-frequently charged products. In addition, there seems to be a wide split of products in 

Product Class 2, with many digital devices already at CSL 1 or 2, but most nickel-chemistry 

consumer MADB devices at CSL 0. This would mean that any increase should consider the 

impact on the MADB and not factor in the products that are already well beyond CSL 1 or 2. 

6. AHAM and PTI pointed out that there are additional costs that may not have been considered 

in the original LCC. 

 a. UL 2575 is being implemented in 2010 and 2011 and will have an effect requiring 

additional safety redundancies for lithium power cells that are used in MADB applications but 

not in computer devices. 

 b. In order to meet consumer expectations on cell life, manufacturers using Lithium 

chemistries may install discharge control devices. It seems as if the samples that DOE 

considered for the costing analysis may not have included this functionality that would provide 

constant utility compared to nickel based systems. AHAM and PTI asked DOE to look at the 

LCC again. 

The attendees at this meeting were, Mr. Larry Albert representing Power Tools Institute (PTI) 

and Wayne Morris, representing the Association of Home Appliance Manufacturers (AHAM) 

were present in addition to Victor Petrolati from DOE, Michael Vladimer, Matt Nardotti and 

Michael Rivest of Navigant, and Toby Swope of D&R International. 

We appreciate the opportunity to meet with DOE on this subject. We are enclosing a set of 

PowerPoint slides that were used in the discussion. 

Sincerely, 

Wayne Morris 

Vice President, Division Services 
DOE – BCS TSD comme

BCS TSD comme

December 6, 2010

Wayne Morris AHAM

Larry Albert PTI
CSL s’

• For Appliances, each CSL represen

l l ft h l level of technology

– CSL 0 – “bad” NiCd– CSL 1 – “good” NiCd

• Better conversion efficiency, lower standb• B i etter maintenance power management 

• Still limited by inefficiency of chemistry itse

– CSL 2 – Li-ion

• Cell has no maintenance power and bette

acceptance
CSL s’

• Appliances have both NiCd and Li-ion in 

market

– NiCd still major proportion 

• C i 75% f t l Comprises 75% of pro tools

• Over 90% of small appliances• No market driver other than retailers

– Mi i l tilit d t Minimal utility advantage 

• For non-appliances (electronics), most ar• These share the same Product Classes These share the same Product Classes• We believe that there are some negative 

conseq g uences resulting from this combin
Example - Product Class 3 – 23,116K total shi
Example – PC 3

• Roughly half the shipments are from DVD 

players and camcorders players and camcorders

– Virtually all Li-ion – low UEC

• These should only be considered in CSL 2

– But these are included in CSL 0 and CSL 1 

• Distorts CSL 1 because this mixes good NiCd App

with Li with Li

-ion consumer electronics ion consumer electronics

• No energy savings in going to CSL 1 for these prod

– But shipments of these products are included – G d NiCd li i t Li Goo

d NiCd appliances compare against Li-ion cons

electronics

– Li-ion based consumer electronics should be 

excl d d f CSL 1 lu

d

e

d

from CSL

1
Scaling

• Scaling proposed at public meeting 

i th li bilit f CSL improves the applicability of CSL ov

wide range of power levels

– Appropriate for Eb levels higher the rep

• High correlation of data to regression 

– I it f l l l Inappropriate for lower levels

• Effect of fixed losses dominate at lower lev• Evidenced by lower correlation Evidenced by lower correlation

• Propose “break” at rep. unit for lowe
Original Regression Analys

Area of 

Concern
Proposed – “break” at representative unit 
LCC – benefit overstateme

benefit overstateme

Usage and life in PC 3&4

• Usage in PC 3&4 – power tools not accur

– Pro - is: 2.70 should: 1.

• Why: 2 charges/ workday, 10 charges/7 days= 1.4

– DIY detachable - is: 0.64 should: 0.

• Why: 2 charges/week 2charges/7days = 0 29 Why: 2 charges/week, 2charges/7days = 0.29

• Life – some lifespans are overstated

– Wearout based on usage Wearout based on usage – at old usages life 

at old usages, life 

curtailed

– Market life at “normal” usage is no more than 
LCC – benefit overstateme

U fil i PC 2 Usage profiles in PC

2

• Usage of MADB appliances in PC2 is 

dramatically distorted by inclusion of con

electronics in PC electronics in PC

– Currently 0.55 charges/day

• Most MADB app y 

liances see onl

y a few c

a month (0.1 charges/day at the most)

• Many electronics in the product class are 

ch d l ti k harge

d several times a wee

k

• Consider segregating MADB’s from non-

for this PC for this PC
LCC – cost understatemen

Cost of conversion to CSL 2 – Lith

• Holding Safety and utility constant 

– Charging Safety –

• analyy y sis may not have considered uniform safety a

CSL 2 products and associated costs

• UL 2575 should correct this in time

– Drives redundant, cell-by-cell monitoring and contro

• Energy savings should not be an incentive to lowe

Energy savings should not be an incentive to lowe

– Utility

• Same performance: use of power cells rather than 

cells -

– Eb lower for power cells – more cells for same capa

• Same Cycle life – requires discharge control 

– Analysis does not consider cost impact of discharge 
Safety - Charge contro

Charge contro

• Specified in UL2575 Specified in UL2575

– While standard is not design proscriptiv

state of the art usually requires: state of the art usually requires:

• Independent, redundant control• Cell-by-cell monitoring

• Some manufacturers follow this alre

– Unclear if cost analysis was sensitive t

Unclear if cost analysis was sensitive t

differences between products
Utility - Cycle Life Cycle Life

• Pro tool users expect long cycle life Pro tool users expect long cycle life

• Typically 800 – 1000 cycles from NiC

• Li-i ith t di h t l 250 ion without discharge control: 250

• Equivalent cycle life can be achieved 

discharge control

– Requires circuitry on load side– Not included in analysis as focus was 

charging
Typical Ni-Cd System

N di h l No disc

harge control

MOT
10A Cycle Life test 18V NiCd with 6V cut-off
18V 1.5Ahr Pack 

10A life with 5V cutoff 
Li-ion System

Electronic Discharge control turns off Electronic Discharge control turns off 

cell voltage – extends life

Hi current 

solid state 

device

Control MOT

Electronics
10A Cycle Life – 18V Li-ion with tool cut-off
Multi-voltage Chargers voltage Chargers

• Common in power tools Common in power tools

• Supported in TP

• H t h dl i St d d ? How to handle in Standard ?

– Especially when voltage range crosses 

b di oun aries

• We made suggestions in supplemen

comments 

– Scaling helps