# January 3, 2011

Mr. Victor Petrolati

U.S. Department of Energy

1000 Independence Ave.

Washington, DC

Subject: Ex Parte Meeting with DOE and Na vigant 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 t opics that are related to DOE

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

appliances and fall under the ca tegory 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 contin ue to offer great consumer value. Often,

consumers do not perceive the value that lithium-ba sed 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 co mputer 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 Pr oduct 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 th e line slopes that could be drawn horizontal

to allow for fixed energy lo sses 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 alrea dy 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 produ cts that are already well beyond CSL 1 or 2.

6. AHAM and PTI pointed out that there are additio nal 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 ce lls that are used in MADB applications but

not in computer devices.

b. In order to meet consumer expectati ons on cell life, manufact urers 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 functiona lity that would provide

constant utility compared to nickel based sy stems. 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 Associati on of Home Appliance Manufacturers (AHAM)

were present in addition to Victor Petrola ti 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 ServicesDOE–BCS TSD commentsBCSTSDcommentsDecember 6, 2010Wayne Morris AHAMLarry Albert PTICSL’s• For Appliances, each CSL represents al l ft h lleveloftechnology– CSL 0 – “bad” NiCd–CSL 1–“good” NiCd• Better conversion efficiency, lower standbyB i•etter maintenance power management• Still limited by inefficiency of chemistry itselfCSL 2Liion––-• Cell has no maintenance power and better chargeacceptanceCSL’s• Appliances have both NiCd and Li-ion in themarket– NiCd still major proportionC i 75% f t l•Comprises75%ofprotools• Over 90% of small appliances• No market driver other than retailersMi i l tilit d t–Minimalutility advantage• For non-appliances (electronics), most are Li-ion•These share the same Product ClassesThesesharethesameProductClasses• We believe that there are some negativeconsequences resultingfrom this combinationgExample - Product Class 3 – 23,116K total shippedExample – PC 3• Roughly half the shipments are from DVDplayers and camcordersplayersandcamcorders– 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 Applianceswith Li-ion consumer electronicswithLiionconsumerelectronics• No energy savings in going to CSL 1 for these products– But shipments of these products are includedG d NiCd li i t Lii–GoodNiCdappliances compare againstLi-on consumerelectronics– Li-ion based consumer electronics should bel d d f CSL 1excludedfromCSL1Scaling• Scaling proposed at public meetingi th li bilit f CSLimprovesthe applicability ofCSLover awide range of power levels–Appropriate for Eb levels higher the rep. unit• High correlation of data to regressionI it f l l l–Inappropriateforlowerlevels• Effect of fixed losses dominate at lower levelsEvidenced by lower correlation•Evidencedbylowercorrelation• Propose “break” at rep. unit for lower Eb’sOriginal Regression AnalysisArea ofConcernProposed – “break” at representative unitLCC–benefit overstatementbenefitoverstatementUsage and life in PC 3&4• Usage in PC 3&4 – power tools not accurate– Pro - is: 2.70 should: 1.43• Why: 2 charges/ workday, 10 charges/7 days= 1.43– DIY detachable - is: 0.64 should: 0.29•Why: 2 charges/week 2charges/7days = 0 29Why:2charges/week,2charges/7days=0.29• Life – some lifespans are overstated–Wearout based on usage–at old usages life isWearoutbasedonusageatoldusages,lifeiscurtailed– Market life at “normal” usage is no more than 5 yearsLCC – benefit overstatementU fil i PC 2Usage profilesinPC2• Usage of MADB appliances in PC2 isdramatically distorted by inclusion of consumerelectronics in PCelectronicsinPC– Currently 0.55 charges/day• Most MADB appliances see onlya few chargesy ga month (0.1 charges/day at the most)• Many electronics in the product class areh d l ti kchargedseveraltimes a week• Consider segregating MADB’s from non-MADB’sfor this PCforthisPCLCC–cost understatementCost of conversion to CSL 2 – Lithium• Holding Safety and utility constant– Charging Safety –• analysis maynot have considered uniform safetyacross ally yCSL 2 products and associated costs• UL 2575 should correct this in time– Drives redundant, cell-by-cell monitoring and controlEnergy savings should not be an incentive to lower safety•Energysavingsshouldnotbeanincentivetolowersafety– Utility• Same performance: use of power cells rather than energycells-– Eb lower for power cells – more cells for same capacity• Same Cycle life – requires discharge control– Analysis does not consider cost impact of discharge controlSafety-Charge controlChargecontrol•Specified in UL2575SpecifiedinUL2575– While standard is not design proscriptive,state of the art usually requires:stateoftheartusuallyrequires:• Independent, redundant control• Cell-by-cell monitoring• Some manufacturers follow this already–Unclear if cost analysis was sensitive to theseUnclearifcostanalysiswassensitivetothesedifferences between productsUtility-Cycle LifeCycleLife•Pro tool users expect long cycle lifeProtoolusersexpectlongcyclelife• Typically 800 – 1000 cycles from NiCdLii ith t di h t l 250•-ion withoutdischarge control:250• Equivalent cycle life can be achieved withdischarge control– Requires circuitry on load side– Not included in analysis as focus was onchargingTypical Ni-Cd SystemN di h lNodischarge controlMOTOR10A Cycle Life test 18V NiCd with 6V cut-off18V 1.5Ahr Pack10A life with 5V cutoffLi-ion SystemElectronic Discharge control turns off at lowElectronicDischargecontrolturnsoffatlowcell voltage – extends lifeHi currentsolid statedeviceMOTORControlElectronics10A Cycle Life – 18V Li-ion with tool cut-offMulti-voltage ChargersvoltageChargers•Common in power toolsCommoninpowertools• Supported in TPH t h dl i St d d ?•HowtohandleinStandard?– Especially when voltage range crosses PCb diounaries• We made suggestions in supplementalcomments– Scaling helps