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Tuesday,

November 15$,_1994

The Public Hearing was held at the Department of

Energy, 1000 Independence Avenue, S.W., Room 1E245,

Washington , D.C®, at 9:30 a ® m., Terry Logee, DOE,

presiding.

PRESENT:

TERRY LOGGEE, DOE

STEVE TREADO, NIST

EUGENE MARGOLIS, Esq., DOE

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EE-RM-94-220-NOPR COMMENT 0D
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A G E N D A

Page

Opening Remarks, Terry Logee 3

Hytron Electric Products, Irving Stine 8

Philips Lighting Company, A.C. Rousseau 18

Duro-Test, Steven L. Martel 30

GE Lighting Institute and Worldwide Technology 43

Standards , Russell C . Churchill

Angelo Brothers Company, Barton Pasternak 63

Rebuttal Statement 78

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9:33 a®m®

MR. LOGEE: By my watch it's time to start.

Good morning, gentlemen. I'm -- Like to go

ahead and get started. I'm Terry Logee. On behalf of

the Department of Energy, I'd like to thank you for

taking the time to participate in this public hearing

concerning the Department's energy conservation

program for consumer products.

The purpose of this hearing is to receive

oral testimony from the public on DOE's notice of

proposed rule making to define colored incandescent

and fluorescent lamps and to define the exemption from

energy conservation standards for rough or vibration

service incandescent reflector lamp as published in

the Federal Register on September 28th, 1994® The

comments received here today and those submitted

during the written comment period will assist the

Department in developing the final rule. The written

comment period for this rule making ends December

12th, 1994. All comments submitted on this notice

will be considered before DOE establishes the final

rule. Comments received after the comment period

closes will be considered to the fullest extent

possible.

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As the presiding official for this hearing,

I will set for the the guidelines for conducting the

hearing and provide other pertinent information. In

approximately one week a complete transcript of this

hearing will be available for inspection and copying

at the Department of Energy's Freedom of Information

reading room located in Room 1E190® Anyone wishing to

purchase a copy of the transcript may make

arrangements with the court reporter.

This will not be an evidentiary or judicial

type of hearing. It will be conducted in accordance

with Section 553 of the Administrative Procedures Act,

5 U.S.C. Section 553, and Section 501 of the DOE

Organization Act, 42 U.S.C. Section 7191. To provide

the Department with as much pertinent information and

as many views as can be reasonably obtained, and to

enable interested persons to express their views, the

hearing will be conducted in accordance with the

following procedures.

Speakers will be called to testify based on

a schedule of those people who responded to the notice

of this hearing. The speakers have been allotted 15

minutes for their oral statements as stated in the

Federal Register notice of September 28, 1994®

Speakers are requested to summarize their written

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statements when possible. I would ask that you

especially do that if you are supporting comments

already given by another speaker. Since there are

only five scheduled speakers, anyone may make an

unscheduled oral statement after all scheduled

speakers have delivered their statements. Persons

interested in making such an unscheduled statement

should submit their request to the registration desk

before the conclusion of the scheduled speakers.

At the conclusion of all presentations,

scheduled and unscheduled, speakers will be given the

opportunity to make a rebuttal statement subject to

time limitations, and will be called in the order in

which the initial statements were made . Persons

interested in making such a rebuttal statement should

submit their request to the registration desk before

the conclusion of the speakers.

Question swill be asked only by members of

the panel conducting the hearing. However, I will

allow any interested person an opportunity to question

speakers who have made oral presentations. These

questions will be taken after any rebuttal statements

subject to my determination that the question is

likely to result in a more timely and effective

resolution of the issues. There are cards at the

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registration desk for this purpose.

Persons interested in this opportunity must

submit their request to the registration desk shortly

after the completion of any rebuttal statements. The

questions submitted should be -- should identify the

author and to whom the question is directed. I will

determine whether the question is relevant. If the

question is allowed, I will ask it. Furthermore, I

will allow any interested person an opportunity to

question employees of the United States who have made

written or oral presentations with respect to disputed

issues of material facto Questions will also be

allowed after any rebuttal statements to the extent

that I determine that such a question is a disputed

issue of material fact and is likely to result in a

more timely and effective resolution of such issues.

Persons interested in this opportunity must

submit their request to the registration desk before

the completion of any rebuttal statements. They

should state specific justification, including why the

issue is one of disputed fact, and how the proposed

question would expedite its resolution. The question

submitted should identify the author and to whom the

question is directed. I will determine whether the

question is relevant. If the question is allowed, I

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will ask it.

As mentioned earlier, the close of the

comment period is December 12th, 1994. All written

comments received will be available for public

inspection at the DOE Freedom of Information reading

room, phone number (202) 586-6020. Written comments

should be addressed to the Department of Energy as

noted within the Federal Register notice for today's

hearing. Eight copies of the comments are requested.

In addition, the Department would appreciate an

electronic copy of the comments. The Department is

currently 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.

We appreciate the time and effort you have

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taken in preparing your statements and are pleased to

receive your comments and opinions. I would like to

reiterate that this hearing is for comments on the

definitions of colored incandescent and fluorescent

lamps and the definitions of a rough or vibration

incandescent reflector lamp.

Today on the panel is Eugene Margolis from

the General Counsel and Doctor Steve Treado from the

National Institute of Standards and Technology.

At this time, I would like to call the

first speaker. For the record, please state your name

and whom you represent.

And I call Mr. Irving Stine.

MR. STINE: My name 's Irving Stine. I'm

with DIC Tool/Hytron Electric Products, Meadville,

Pennsylvania.

Good morning, gentlemen. I really am not

much at public speaking. However, I did take -- Well,

I did have some comments regarding the Department's

rules and their definitions of vibration service

lamps.

Their findings on incandescent reflector

lamps and also the Berkeley Laboratories findings, I

take that -- I do believe that there was a definition

of incandescent vibration C-9 filament lamps if you

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delve into the situation.

There's a number of people in our industry,

the long life, if you will, lamp industry, that have

been -- I have notified them of my comments that I was

going to make today and to list those -- well, Terry

knows. Bruce Seagul from Supreme. Carl James from

Marvel. Al Rousseau from Philips. Gene Sepko and Bob

Soreson from Litronicsm Bart Pasternak from Angelo

Brothers/ADCO Lyle Devore from Penn Illuminating.

And Steve Martel from Duro-Test,

Now, I have -- I have, whether it was

right, wrong, or indifferent, my comments I have sent

to these gentlemen ahead of time. And those, for

those of you that were -- didn't receive my comments,

I'm going to continue on with theme

It was their request, the Department's

request, to the final and proposed rules that we would

submit comments. And the long life lamp industry,

it's a foregone conclusion that any lamp that's going

to be marketed with a life rating of 5,000 hours or

more should be designed and engineered, and

constructed, in a manner that is going to provide this

service in as many adverse conditions under any

extreme vibration conditions or anything -- any

possible installation. I believe when, perhaps this

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consideration in the manufacture of a long life lamp

is understood that you will find C-9 multiple support

filament designs that will withstand vibration and

will withstand above normal shock.

The Department was under -- Well, they said

they couldn't -- and even the Berkeley and the

Department, they could not identify a vibration

service incandescent lighting product. Well, just

about any long life true, real, long life lighting

product that's manufactured has taken the -- into

consideration that that lamp has to perform under any

installation. We -- You don't know where your lamps

are going to be put in or, I don't know where our

lamps are going to be installed.

However, there is a measure or a benchmark

in the incandescent lamp light bulb industry for C-9

multiple support filaments and that would be in the

traffic signal lamp business. Now, the Institute of

Transportation Engineers have for a number of years,

well, hey, that light bulbs been -- I mean, traffic

signal lamps have been around about 100 years, haven't

they?

Anyhow, they say that the lamp has to

withstand all the things that are -- that -- well, all

the things that a traffic signal lamp has to

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withstand. And I could read some of that if I had the

right glasses on, perhaps. But nevertheless, the

filament configuration identified by the prefix

letters and suffix letters, for instance, C-9, the

prefix letter C means filament wires, coiled. We all

know that. And the suffix number, 9, means that it's

a horseshoe shape.

Well, they also state because traffic

control devices impose a greater service requirement

than most applications of incandescent lamps, the

construction features of traffic signal lamps require

that the filament shall be adequately supported to

withstand the vibration that may be induced in the

lamp by signal system design , suspension , vehicular

traffic and high winds. Like most long life lamps

with a C-9 configuration, the multiple filament

supports, traffic signal lamps are not labeled for

rough or vibration services even though they are used

in a rough or vibration service application.

And the Department, in their reviewing the

industry, they said since reflector lamps with C-9

filaments are marketed for long life, and since there

is no industry consensus for the C-9 filament as a

vibration design, I find that -- I've researched just

a little further than they have perhaps, or maybe they

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are -- maybe they overlooked the traffic signal part

of our lighting business even though it was traffic

signals are exempt in the -- in the law.

In support of my comments, everybody here

probably knows that traffic signals lamps and the

standard of the Institute of Transportation Engineers

where everything that they say lamps have to be. I

also put in with my letter of comments a comparison

test of Hytron products by the New Jersey highway

department in a high level vibration, high wind

application on Par. 38 incandescent products. And I

guess to indicate that indeed a long life lamp is

constructed to withstand high winds or vibration

service, there was a -- 13 lamps of the kind that we

want to get rid of, I guess, and four lamps of the

kind that I say are manufactured for vibration

applications, or they were a long life, 8,000 to

10,000 hour Par. 38 lamp. I've put a copy of that

comparison in with my letters.

Also -- see, traffic signal lamps ® I don't

want to get mixed up here. Also, I put in with my

comments a report dated most recently, October 31st,

from ETL Testing Laboratory covering the vibration

testing of three Hytron long life reflector lamps

having a C-9 multiple support, meaning four or more,

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of filament design. All of these lamps, there were

2 four wattages on three different reflector lamps.

3 What were those wattages? Well, nevertheless, there

4 was an R30 lamp, a Par. 38 lamp, and an R40 lamp. And

5 the four different wattages of those three reflector

6 lamps were a 69 watt, a 75 watt, a 91 watt, and a 100

7 watt lamp.

8 And our report back from using the

9 vibration test that is proposed, which we find

10 acceptable, along with a C-17 or C-22 filament design

11 and a C-9 design that would pass the vibration test,

12 they all passed, frequency results, the vibration,

13 endurance results. And there's copies of this

14 available to anybody that might want to see it. This

15 was passed along to the gentlemen that I -- all the

16 gentlemen that I mentioned before.

17 And so, in conclusion, I guess, we feel

18 that our sincere belief and deep conviction in our

19 comments and the enclosed support of information

20 authorizes complete justification to request that all

21 long life lamps, reflector lamps included, with a

22 service rating of 5 , 000 or more hours, and having a C23 9 multiple support, that means four or more, filament

24 design be considered designed for rough or vibration

25 service.

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Thank you

MR. LOGEE: Thank you, Mr. Stine.

Dean, do you have any questions?

MR. MARGOLIS: No questions.

MR, LOGEE: Oh, Irv, would you hold --

MR. STINE: Oh, I have to stay here.

MR. LOGEE: Yes, hold here please for

questions if the panel has any.

You said no questions.

Steve, do you have any?

DOCTOR TREADO: I have a couple of

questions, just points of clarification.

On the ETL tests that were preformed, and

I have a copy of the results, it appears that the

amplitudes that were tested were only half of what was

listed in the actual test procedure, unless that

wasn't written up quite the way it was. Because our

own test procedure called for half the amplitude to be

.01 and maybe that's a confusing point. Peak to peak

was .02® So, I wasn't quite sure what -- maybe you

can project on that.

MR. STINE: I can perhaps get a hold of the

ETL testing laboratory and find out why they were

either negligent or didn't read that right. When it

comes to the amplitudes and the things like that, I

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don't know but I know when you drop one and it still

keeps on lighting -- I mean, but the vibration, this

was -- Well,

DOCTOR TREADO: Yes, if you could just --

MR. STINE: I can verify -- I mean, I can

maybe explain that but then they read what you had

proposed as far as the test is concerned ® And whether

maybe there's a misunderstanding in --

DOCTOR TREADO: I think it might easy to

misunderstand because the table says ®01 but it's --

that's the one-half the total excursion. And they've

reported it as being .01 but they don't say one-half

total excursions.

MR. STINE: Oh, okay. Well --

DOCTOR TREADO: Peak to peak is .02.

MR. STINE: I can probably request that

information, have them clarify that. I would be glad

to do that.

DOCTOR TREADO: Because we are interested

in how the various lamps fall out relative to that

test.

MR. STINE: Sure.

DOCTOR TREADO: On the -- As far as the

traffic signal lamps, that particular test there, to

make sure I understand it, that's some of the lamps

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failed. They were all installed on that one date

there?

MR. STINE: Oh, these were not traffic

signal lamps. These were a reflector lamp. And these

-- the lamps were installed at the Garden State

Parkway, Ii think it was the Garden State Parkway or

the New Jersey Turnpike at one of their -- Garden

State Parkway, their Raritan toll plaza. I don't

know. You guys probably are familiar with that.

DOCTOR TREADO: So, on March 5th, 1979 all

the lamps were installed?

MR. STINE: The lamps were installed, yes.

DOCTOR TREADO: And then some of them

failed at various times and those are the times that

it was --

MR. STINE: Exactly. That's what we were

trying to prove, that we could save them money if they

used our lamps. And I think we did.

DOCTOR TREADO: So, for example --

MR. STINE: And energy, too.

DOCTOR TREADO: -- the first one failed

after about a month and a half.

MR. STINE: 4/27, yes.

DOCTOR TREADO: And the first Hytron lamp

failed in August --

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MR. STINE: On 8/8, yes.

DOCTOR TREADO: I guess those are all my

questions.

MR. STINE: I also -- I guess maybe I

skipped over pretty much on that. The -- Let's see,

commercial item description for lamp incandescent and

what I was wanting to bring out there that yes, a C-9

multiple support filament design was acceptable as a

rough service incandescent lamp. And that is that the

commercial item description that was put out by the

General Services Administration.

MR. LOGEE: Do you have any more questions,

Steve?

DOCTOR TREADO: No, no more questions.

MR. LOGEE: I just wanted to clarify, Irv,

that indeed traffic signal lamps are exempted from

this regulation and perhaps that's why we didn't look

into the traffic signal engineering standard.

However, as I read the standard, I skimmed through it,

I guess, I don't see any requirement for vibration.

And the Department feels quite strongly that we are

looking for some form of performance standard that we

could measure that we could have the lighting

manufacturers to perform and measure their lamps

against. So that we would know with some degree of

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certainty whether a lamp passed or failed.

MR. STINE: Right. Well, yes, I think that

perhaps the vibration test that you did come up with,

which was the old Navy test, certainly was a good

measure. But, what I wanted to bring out is, yes,

there is a C-9 multiple support filament configuration

that is considered adequate for severe vibration

application. And that would b in the traffic signal

lamps.

And that -- See, it doesn't matter the

wattage. It doesn't matter the bulb size. It doesn't

matter anything else. What matters is the C-9

multiple support filament configuration. I mean, that

protects the filament. The filament is the life of a

lamp, I mean, as we've known it for years. And you

protect that filament is just like protecting the

quarterback. You're going -- you just have to protect

it and it will last.

MR. LOGEE: Thank you, Irv.

MR. STINE: Thanks.

MR. LOGEE: I'd like to call now Mr. Al

Rousseau with Philips Lighting Company.

MR. ROUSSEAU: Good morning, all. I wold

like to thank the DOE for allowing us to make some

comments here this morning on the proposed rule

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making.

I'm Al Rousseau from Philips Lighting and

we just had a couple of comments. one on the colored

lamps. We manufacture a gold fluorescent lamp which

has a CRI slightly greater than 30® And we feel that

this lamp is certainly not a lamp that people are

going to put in a normal application and that we would

like to see if we could have a slight relaxation on

that CRI limit, possibly up to 40. I think if we got

up there still it's going to rule out the lamps that

you want to rule out but it would allow us to still

manufacture this gold lamp unless we were able to

somehow exempt the certain color.

Also, just a general comment on the method

of defining the colored lamps. There are many

possible colored coordinates which you could get on

the XY diagram but there are places where the CCT is

undefined, particularly because the black body locus

has gone to infinity. Also, for color points that are

very distant from the black body locus, the CCT really

doesn't have any meaning. In some cases you can

calculate a number for it with a computer program and

in other cases a computer program will break down and

it won't calculate anything.

So, I think this point is rather confusing

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or could be confusing to people, probably not the

general public because not too many people do this

kind of thing. But possibly some reference could be

put into either the preamble or into the rule that

would just make note of this so that if these kind of

problems came upon someone, that they would understand

what the problem was. So that could maybe be either

put in the definitions or in the preamble.

As far as the rough and vibration service

lamps, the definition of -- in the last paragraph of

Part 2 defines rough and vibration service reflector

lamps as having either six support wires with a C-17

or a C-22 filament configuration. This I find

inconsistent with the definition proposed to be

included in Part 430® That says that there should be

no less than six filament support wires, excluding the

lead in wires. We find that the definition proposed

for Part 430 is more correct and we feel that the

Department should allow the manufacturer some design

and manufacturing freedom, and allow him to make his

product to a minimum standard but certainly if he

wants to make it to a standard greater than the

minimum, he should be allowed to do that. So that his

design freedom should not be restricted by the ruling.

Also, I find the definition for Part 430 is

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rather awkward to understand. We would suggest some

changes as follows. Rough or vibration service

incandescent reflector lamp means an incandescent

reflector lamp in which the filament is mounted in

either a C-17 or C-22 configuration with a minimum of

six filament supports, not including the lead in

wires, or an incandescent reflector lamp which meets

the requirements of the vibration test in Appendix

R4m34 to subpart B of Part 4300 To my mind, that, at

least, is a little more understandable and puts things

in the right order and perspective.

one comment on the vibration test of

Section 4.3.4.3, Appendix R, we feel there needs to be

further clarification of the test procedure. One

plane of the test is defined as being in the direction

of the vibration along the stem. The definition

should state that the lamp is tested in either a base

up or a base down position but there shouldn't be any

choice. I think you should decide on either base up

or base down.

Also, one of the two positions -- one of

the two positions should be stated to avoid confusion

in the testing. In addition, I would recommend that

the two directions perpendicular to the stem be

further defined, possibly so that the lead in wires

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1 are always kept in the same position. Say in a plane

2 with the lead in wires vertical and another plane with

3 the lead in wires horizontal. This puts a test on a

4 more even perspective for everyone so that whenever

5 you run any lamps on the test, they're always going to

6 be running the same way. I've had a lot of experience

7 with these tests, particular in miniature lamps, and

8 we found that that was always rather critical. At

9 least to make the test the same for all the products

10 so that if you specify the plane of the lead wires,

11 that's an easy way to do it a And it seems to make

12 things come out better.

13 Also, I think the word failure needs some

14 kind of a definition. It says that the lamps should

15 all pass the test but we don't know what the criteria

16 is. Certainly the lamps could still be all lighted at

17 the end of the test but perhaps the filaments are all

18 tangled and all knotted up. And instead of 100 watts,

19 the thing is really 125 watts. So possibly some way

20 you need to look at that and give some allowance at

21 the end of the test for possibly wattage may be a good

22 way to do it. And so that just because the lamp is

23 lighted, it still may not really be anything that's

24 very useable and its life may be rather short.

25 Also at this point, and we certainly

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applaud the use of the NAVLAP criteria here, but

NAVLAP has not established any test method and there

are no accredited NAVLAP labs using the vibration

test. So that's going to have -- something that's

going to have to be addressed by NAVLAP I think.

That's all.

MR. LOGEE: All right. Thank you, Al.

Gene, do you have any questions?

MR. MARGOLIS: Sir, if the gold fluorescent

lamp that your company manufactures, would that be

able to be produced if the CRI stays at 30?

MR. ROUSSEAU: No. At least as far as we

know at this point we couldn't do that.

MR. LOGEE: Any more questions, Gene?

MR. MARGOLIS: Yes.

In your comment with regard to Section

4.3.4.4, how would you define or what would be your

recommendation as to the definition of failures?

MR. ROUSSEAU: I think I would probably put

some wattage criteria on the lamp so that you could

give some tolerance so that the watts should be no

more than X percentage greater than what they were

before. And then that would allow that if the

filaments got twisted and knotted up, generally that

would cause the wattage to go up which in turn will

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MR, MARGOLIS: Then you -- then the

MR. ROUSSEAU: Oh, yes, the whole lot

MR. MARGOLIS: You don't --

MR. ROUSSEAU: No.

MR. MARGOLIS: In other words, you

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make the life go down rather rapidly. So I think

that's probably a good way to do it.

MR. MARGOLIS: I would wish to call your

attention to the Section 4.3.4.4 which says, "A sample

of five lamps shall be randomly chosen from a

production lot; no failures are permitted." How do

you interpret that section with -- when it says no

failures are permitted?

MR. ROUSSEAU: That's my problem. I don't

know how to interpret that section, that no failures

are permitted.

MR. MARGOLIS: Well, what I'm saying is, if

you have a sample of five lamps.

MR. ROUSSEAU: Right.

MR. MARGOLIS: And let's assume under your

definition or whatever definition, there is a failure.

MR. ROUSSEAU: Then the lamps clearly

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interpret this as not to allow if a failure occurs --

MR. ROUSSEAU: That's right. There is no

failures -- No failures are allowed. No

substitutions. But the problem is what constitutes

the failure? That's the whole thing. The word

failure is used but I don't know what it means.

MR. MARGOLIS: In the -- I just want to get

this to my own thinking clarified. If you have five

lamps, you're doing a test of five lamps. If one of

the five lamps fails, and assuming we know what

failure means, then --

MR. ROUSSEAU: The lot fails.

MR. MARGOLIS: The lot -- the entire lot

fails?

MR. ROUSSEAU: That's right.

MR. MARGOLIS: No substitution is allowed.

MR. ROUSSEAU: No.

MR. MARGOLIS: Thank you.

MR. ROUSSEAU: No, that's clear.

MR. MARGOLIS: I have no further questions.

MR. LOGEE: Steve, do you have any

questions for Al?

DOCTOR TREADO: Yes, a couple things, Al.

On the case of the gold fluorescent, is

there a way that a slight modification in the lamp

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could be implemented so that the CRI would be below 30

without --

MR. ROUSSEAU: I -- At this point I don't

know. We haven't had enough time to spend on it to

see if there's something that we could do to fix that.

DOCTOR TREADO: CRI is --

MR. ROUSSEAU: -- blush, it doesn't look

like it,

DOCTOR TREADO: Is, of course, dependent on

the interaction of the spectral output of the lamp and

the spectral reflectance of the samples. It seems

like it might be possible to really get a nice notch

somewhere that might degrade its color rending index.

But it's not as easy with the fluorescent lamps

perhaps. So that was one question.

As far as the correlated color temperature

either being infinite or not meaningful, would it help

if we turned the definition around because right now

we're saying that a lamp would be colored if the

correlated color temperature is either too high or too

low. What if we said a lamp would not be colored if

it fell within that range? That would mean, then, if

you had an infinite or undefined correlated color

temperature, then it would be considered to be

colored. If you get my drift there?

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MR. ROUSSEAU: Yes. I think I see where

you're coming from. I'm not the --

DOCTOR TREADO: I mean, what we're trying

to deal with --

MR. ROUSSEAU: I'm not the company expert

on color so --

DOCTOR TREADO: We're trying to define this

area on the chromaticity diagram that's bounded by

things which would be read and things which would be--

MR, ROUSSEAU: Which wouldn't be.

DOCTOR TREADO: -- saturated in the blues.

And that's where you run into the trouble within --

MR. ROUSSEAU: That's right, with the

saturated colors.

DOCTOR TREADO: So, maybe you can take a

look at that.

MR. ROUSSEAU: We can take a look at that.

DOCTOR TREADO: That would be one way of

handling that.

MR. ROUSSEAU: Sure. Sure.

DOCTOR TREADO: As far as the orientation,

is there -- and I agree, we probably should define

certainly when you have the axis of the lamp

horizontal, we should probably define those two planes

of vibration with reference to the lead in wires as

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being vertical and horizontal.

2 As far as the vertical orientation, is

3 there any reason why we wouldn't want to choose base

4 down? That ' s the way --

5 MR. ROUSSEAU: None that I can think of.

6 It's certainly going to make it a lot easier to

7 perform the test if you do it base down.

8 DOCTOR TREADO: So, it's not going to cause

9 anybody that you know of any problem performing the

10 test, the fact that the base is going to be down?

11 MR. ROUSSEAU: Noe

12 DOCTOR TREADO: And your comments on

13 failure are, I think those are very useful m What sort

14 of range of change -- would you like to make a

15 suggestion as to what would constitute?

16 MR. ROUSSEAU: I think at this point I

17 would rather not. I would like to think about that

18 a little.

19 MR. LOGES: Those all?

20 DOCTOR TREADO: That's it.

21 MR. LOGEE: Thank you, Al.

22 MR. MARGOLIS: I want to go back --

23 MR. LOGEE: Oh, you'd like to readdress?

24 MR. MARGOLIS: Sir, I want to go back to

25 the gold fluorescent lamp. Could you tell us how big

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a product that is in the company? I mean, is there --

is that -- Does the company produce many of these

lamps or is it only a small --

MR. ROUSSEAU: I honestly don't know

because I don't have anything to do with sales and

don't want to have anything to do with sales. But I'm

sure that it's not -- We don't sell as many gold

fluorescent as we do 40 watt cool lights. I can tell

you that for sure ® It's a small niche market, I'm

sure. Not really a --

MR. MARGOLIS: You've just added another

word, the niche. Is there a market?

MR. ROUSSEAU: There is -- Yes, there is a

market for it but it's certainly not a huge market.

MR. MARGOLIS: What -- Who would use that

lamp, do you know?

MR. ROUSSEAU: I don't know.

MR. MARGOLIS: In your written comments,

can you find out?

MR. ROUSSEAU: Sure.

MR. MARGOLIS: And let us know about this

market and how -- I realize there can be

confidentiality. But what you can give us or give it

to us in confidential form of how big this market is

to the company. Is it -- You said it's a small, but

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it could be small yet it still could be in dollar

volume quite large.

MR. ROUSSEAU: Sure.

MR. MARGOLIS: So, we would just like to

know the extent of the gold fluorescent lamp and the

niche market.

And, are you the only company that produces

this lamp for the niche market or are there other

competitors out there?

MR. ROUSSEAU: Okay.

MR. MARGOLIS: Thank you very much.

MR. ROUSSEAU: Yes, you're welcome. Thank

you, gentlemen.

MR. LOGES: Thank you, Al.

Next, I'd like to call Mr. Steven Martel

from Duro-Test, please.

MR. MARTEL: Thank you.

My name is Steve Martel. I'm with the

Duro-Test Corporation and we'll have some visuals

today also.

Duro-Test is a manufacturer of premium

incandescent, fluorescent, and high intensity

discharge lamps. These lamps are designed and

marketed towards a commercial industrial market and

include rough service vibration incandescent lamps,

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high color rendering fluorescent lamps, as well as

many specialized lamps for specific application.

Duro-Test has been manufacturing lamps since 19290

And we will discuss the three different areas that the

DOE has requested comments on in the three different

sections.

First on the definition for a colored

fluorescent and incandescent reflector lamps. The

proposed definition offered by the Department of

Energy for fluorescent is a CRI less than 30 or a CCT

below 2,500 K or above 7,000 K. The definitions of

CRI and CCT refer to a light falling within a certain

range of the black body curve. The lines in Figure 1

show this defined range. Since true color lamp

sources fall outside this range, the definition is

inaccurate. However, since no other alternative is

available, Duro-Test has no serious objections but

agrees that the CRI should be raised to 40.

The gold fluorescent lamp market does

constitute many different areas, one being insect

repellant. The second being the printing industry for

printing plates where the blue and UV ranges of the

spectrum deteriorate the plates. And another would be

clean rooms where electronic components are made.

That is a small niche market.

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The proposed definition offered by the

Department of Energy for incandescent reflector lamps

has a CRI less than 50 or a CCT either below 2,500 K

or above 7,000 K. Due to the same problems stated

above, certain color lamps, even heavily coated lamps,

might not comply to color standards. For example,

green. However, with no other alternatives to this

definition at the present time, Duro-Test has no

serious objections.

Duro-Test strongly believes that the

neodymium lamps should be exempt under the definition

of colored incandescent lamps. This lamp does not

meet the CRI or the CCT requirements proposed by the

Department. Duro-Test recommends that the neodymium

type lamps be exempt as a prescribed color. A

neodymium bulb is made with a neodymium oxide doped

directly into the glass. This can be seen by the

spectra distribution chart on the screen now. This

glass blocks some of the yellow, orange, and red, and

infrared created by the incandescent filament. These

lamps are used in specialized applications such as

reptile basking lights, plant lights, and display

lighting. Due to the expense of this glass, these

lamps will not be classified as a commodity item. It

should also be noted that at a recent DOE NEMA meeting

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no one had any objections to the neodymium lamp being

exempt as a colored lamp.

Going on to the vibration test to exempt

the incandescent reflector lamps onto the rough

service vibration exemption, it is Duro-Test's

position that the current test is not sufficient based

on the results that a single support CC-6 filament

passed the test. Duro-Test strongly agrees that an

incandescent reflector lamp rough service vibration

test must be available to accommodate existing

technology as well a new technology. And Duro-Test is

willing to cooperate with the Department of Energy and

National Institute of Standards and Technology in the

development of an acceptable test.

As far as the prescribed filaments types

for the rough service vibration exemption, Duro-Test

takes strong exception to the Department's following

statement. "Since reflector lamps with C-9 filaments

are marketed for long life, and since there is no

industry consensus for the C-9 filament as a vibration

design," etcetera. However, a consensus does exist.

Two professional engineering societies recognize the

C-9 as a vibration filament. The Illumination

Engineering Society verifies the C-9 filament as a

vibration filament in Figure 6-86 on page 255 of the

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8th Edition Lighting Handbook. The chart is titled

incandescent vibration service lamps for 120 and 130

volt service. The filament type listed on the chart

is a C-9® Figure 3 is a copy of that page.

Figure 6-83 from the IES Handbook shows a

C-9 filament along with a C-17 and C-22 filament under

the heading, rough service incandescent lamps for 120

and 125/130 volt circuits. Also, Figure 6-85 titled

industry service incandescent lamps, 3,000 to 4,000

hours, for 120, 125, and 130 volt service list a C-9

filament type. It should also be noted that footnote

B states, "Catalogued by Philips as industrial rough

service."

It is important to note that the C-9 and C11 is of the same family. Essentially the C-11

filament is a modified C-9® The figure on the screen

shows its modification. The center of the C-9

horseshoe shape is brought into a V-shape to place

more of the incandescent filament into the focal point

of the reflector, thus increasing the efficiency of

the system.

The Institute of Transportation Engineers

also recognizes C-9 and C-11 as a vibration design.

As Hytron quoted the ITE specifications, I look down

to that same quote from there -- from their manual and

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attached is a copy of that ITE spec.

Duro-Test has been manufacturing high

quality traffic lamps with a five support C-11

filament for decades. A large number of

municipalities and states are now presently using

Duro-Test traffic lamps. These lamps are used in the

United States, Canada, as well as many countries

around the world. These lamps are highly recommended

by traffic engineers due to their life in such adverse

conditions.

The Department of Energy has prescribed the

six support C-17 and C-22 filament construction for

the rough service vibration incandescent reflector

lamp exemption. These filament types are satisfactory

to Duro-Test, However, Duro-Test strongly believes

that a five support C-11 filament should also be

included as a viable alternative. Duro-Test has

manufactured this filament for several decades for

rough service vibration application.

As stated before, Duro-Test is a commercial

industrial lamp manufacturer. Our customers need this

type of lamp so that they have the light, even in the

most hostile situations.

Duro-Test lists a C-11 filament as a rough

service vibration filament in its technical

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specifications. Several customers have already stated

that if these lamps are not available they will

circumvent them law by replacing their incandescent

reflector lamps with higher wattage rough service

vibration A-type lamps. It is therefore essential to

exempt the five support C-11 filament so that the

intent of the law to reduce the energy consumption in

the United States may be accomplished.

Thank you for your time.

MR. LOGEE: Gene, do you have any

questions?

MR. MARGOLIS: The request I made of

Rousseau about comforting information regarding the

gold lamp and the niche market, you also mentioned

that you are in that market. Could we get the similar

information from your company in your filed comments.

MR. MARTEL: That's possible. It is a

small market out there but it's ever increasing,

especially with the electronic industry and the clean

rooms that's being developed, they need the yellow

type of lamp to -- so that their chips aren't damaged.

MR. MARGOLIS: That's what I want to see

that there is a niche market. So if we do anything,

then we would have support for what we're doing.

DOCTOR TREADO : You mentioned about

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printing plates. Is that just a storage area for

printing plates that this is used?

MR. MARTEL: That's when they take out the

plates when they're going to ink them or whatever they

might do to them. They take them out. If they're

exposed to light for even more than a few seconds, a

lot of times they'll get a hazy background when they

finally do run the plates. So any -- essentially the

single or the yellow type light is the safest light to

use.

DOCTOR TREADO: Because there is an

exemption also for reproductive equipment and I'm

wondering whether that might fall into that category.

Maybe that would be a stretch. We can look at that.

I had a couple other questions, though, on

the neodymium type lamps. Is there a fairly narrow

range of, say, percentage of doping that would -- that

these type of lamps would typically have? Or would it

be -- What I'm thinking of is if we say neodymium

doped lamps are exempt and somebody puts in onehundredth of one percent of neodymium and says we have

a neodymium lamp --

MR. MARTEL: I could find out percentages.

I do know that only one -- you can only get these

types of lamps at the present time, or the bulbs

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itself, the glass, from one country in the world a So

I could find out what they -- percentages is. As far

as I know, no other company can make that type of

glass.

DOCTOR TREADO: Do other manufacturers

produce this type of lamp?

MR. MARTEL: I believe there's one other

one that is made for specialized application,

especially the reptile industry.

DOCTOR TREADO: So this is not strictly

speaking a jewelry lamp?

MR. MARTEL: It's used for reptiles, for

plants, and for showcase type lighting, especially

where you want the heat away from the objects that

you're trying to light.

DOCTOR TREADO: On the vibration test you

mentioned newly obtained result of a CC-6 passing

testa Is there any way that we could see the test

report on that? Get a copy of the test report?

MR. MARTEL: We're in the process of

getting that from the test lab now. We do suggest

other lamp manufacturers do try the test, though, in

different labs.

DOCTOR TREADO: On the traffic lamp

standard, it's been brought up again a second time.

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Although the standard seems to -- well, definitely

mentions that the lamps need to be able to withstand

extreme conditions. Am I mistaken or does it really

not specify the filament type in there? It just says

the lamp must be able to handle the --

MR. MARTEL: As far as I know, it does not

actually say the filament type but that the filament

does have to meet a vibration criteria, has to survive

under those type of -- types of conditions that they

list. And this lamp, again, has been used for --

DOCTOR TREADO: But there's no specific

test that it needs -- that it has to undergo?

MR. MARTEL: No.

DOCTOR TREADO: It's basically saying

provide a lamp that can meet these conditions and the

manufacturers have done whatever they can --

MR. MARTEL: Yes®

DOCTOR TREADO: -- to do that?

MR. MARTEL: Yes.

MR. LOGEE: Steve, I have a question. Is

this neodymium doping used in other kinds of lamps

where the Department, if we specifically exempted that

type of lamp, we would also exempt some other future

lamps? Is it only specifically used for this

reflector lamp?

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MR. MARTEL: It's used in reflector and

certain A lamps for the same -- types of applications.

MR. LOGEE: For the record, do you know

which -- you mentioned the lighting handbook, the

eighth edition, could at least do you know which year

that is?

MR. MARTEL: That's the current one. I

think it was 1994. 1994. That is in the most current

one. It also goes back to many previous years. I'm

not sure exactly how far back. They went back as far

as our books went back.

MR. LOGEE: No, are those -- the chart just

says incandescent vibration service lamps. Is it

implied that these are reflector lamps or does it

state that these are also reflector lamps, or also

include reflector lamps?

MR. MARTEL: No, these are essentially Atype lamps. The way the law's written is that the

filament type is referred to the filament type and the

filament type in these lamps are the C-9.

MR, LOGEE: So, then by the filament, if

the filament is considered a vibration filament for an

A-line lamp, the same should be true with a reflector

lamp?

25 II MR. MARTEL: Yes.

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MR. LOGEE: The difference in the shape of

2 the lamp or the difference in the thickness of the

3 glass, and all of those things, wouldn ' t have any

4 bearing on the fact that it would be either more or

5 less vibration resistance?

6 MR. MARTEL: The way the -- that the

7 filament type being a rough service , that's basically

8 how you protect the filament , as we stated before ® Of

9 course, the weight of the glass is going to have some

10 effect on that. But as far as I know there were no

11 tables showing rough service or vibration reflector

12 type lamps . But they do refer to the filament type

13 quite often.

14 For instance, the CC- 6 would not be

15 considered a rough service vibration filament type.

16 A C-17 would no matter what the application is or what

17 you put around it. And --

18 MR. LOGEE: You see, the Department was

19 having difficulty distinguishing between the C-9

20 filament used for a long life lamp and the C-9

21 filament used for rough vibration service. And I

22 think we -- that seems to be still unclear to me and

23 certainly is something that we're trying to sort out

24 with our proposed performance vibration requirement.

25 And I 'm not that comfortable that this chart does that

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sorting out for us.

The -- you mentioned the traffic lamps

through tests of manufacturers high quality traffic

lamps with the five support C-11 filament, correct me

if I'm wrong. These are not reflector lamps, I

assume.

MR. MARTEL: No, Those are A-type lamps.

MR. LOGEE: Those are A-type lamps. But

again, your contention is that the filament design is

what makes it a vibration resistant?

MR. MARTEL: We put the same filament

design in our reflector lamps and we do sell to the

commercial and industrial market. So we do know for

a fact that they are rough service vibration type

filaments. And we've been making that filament type

for decades. I can't really place a year on it.

MR, LOGEE: Have you ever subjected these

C-11 five support filaments to a vibration test such

as proposed?

MR, MARTEL: We put -- We did put them

through the proposed test and they did pass.

MR. LOGEE: Is that information something

you would be willing to share with the Department to

enclose in your comments?

MR. MARTEL: We could put that with the

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other information.

MR. LOGEE: Thank you, Steve. I have no

further questions.

At this time, I'd like to call Russell

Churchill to the podium, please.

MR. CHURCHILL: Good morning. My name is

Russell Churchill. I'm manager of the GE Lighting

Institute and Worldwide Technology Standard for GE

Lighting in Cleveland, Ohio. We welcome this

opportunity to participate in this hearing on the

proposed definitions for colored reflector,

incandescent, and fluorescent lamps and for rough and

vibration service incandescent lamps.

We have a number of issues with -- in all--

in these areas. However, this morning, I want to

confine my comments purely to those related to the

definition of colored incandescent reflector lamps.

We will address the other issues in our written

comments to be submitted prior to the December 12th

deadline.

Colored lamps are provided in the market

place to meet defined specific customer and

application requirements. They are not used to

provide general illumination. We understand the

Department's objective in this proposed rule making to

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eliminate the possibility of lightly tinted reflector

lamps being used to circumvent the reflector

efficiency standards in EPACT® However, the

definition of colored incandescent lamps as proposed

will eliminate certain colored lamps for which there

is a defined market need for which there will not be

acceptable substitutes.

Colored lamps are designed to do one of two

things. Either to provide colored light for basically

decorative purposes or to meet more specific

application needs. One such specific lamp for a

specific application are lamps designed for plant

growth and display. I think if you look at the

unlighted lamp, it is -- it certainly is colored and

only look at it in the -- as a lighted lamp. It is --

be it lightly, it is a colored lamp. It is not a

white -- so-called white lamp. This lamp will not

meet the definition of a colored lamp as proposed in

the rule making.

MR. MARGOLIS: Sir, could you show us what

a white lamp is?

MR. CHURCHILL: Unfortunately, I didn't

bring -- Well, no --

MR. MARGOLIS: That lamp, to me, when lit

looks like a white lamp. I don't see any color in

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there whatsoever.

MR. CHURCHILL: It is tinted. Believe me,

if you saw a white lamp of that same physical

configuration next to it, there is no question this

lamp has a tint albeit a light tint. It is not a

saturated color. It is a light tint. That particular

lamp has its spectral characteristics defined, or

established, to meet the reflection and absorption

characteristics of green leaf foliage. That's what

that lamp is used for, to aid plants in growing, and

(b) to display their attractiveness. To do that,

you've got to design certain spectral characteristics

into the light output of the lamp. And that lamp is--

has that characteristic.

To modify that lamp to meet the

characteristic or the proposed characteristics in the

rule making, would totally destroy its ability to

create that. So that we would no longer have a lamp

to meet that defined market application need. The

function of the lamp disappears if we modify that

color to meet the color temperature and color

rendering index requirements.

Another lamp that may not meet the

specification, it's right on the border line and so at

this point we don't know whether it will fall in or

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out, but there's a good probability, or good

possibility, it would fall out, is a lamp -- is a

yellow lamp used -- People talk about these as bug

repellents. These are not -- lamps do not repel

insects. They have spectral characteristics which

don't attract insects. They don't repel them, they

just don't attract them. And again, the

characteristics of this lamp have been specifically

designed. Basically you take out blue energy.

Insects see blue. And so this is basically a minus

blue lamp. You take the blue out of it in order not

to attract the insects.

Should we -- If we have to modify this lamp

to meet, to pass the criteria proposed in the rule

making, this lamp will no longer be as effective in

not attracting insects. So again, the functional

characteristics which were designed to the lamp can no

longer be achieved in meeting the proposed definition.

In the proposed rule, the Department

acknowledged that one lamp might be on the border

line. The so-called jewelry white or transparent blue

is referred to, incandescent lamp. It looks

definitely colored when it's unlighted. But, Gene, to

your point, when you light without a direct

comparison, you --

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MR. MARGOLIS: No, this one you can see.

You can see that it's --

MR. CHURCHILL: But this one -- this one

doesn't pass either. Why this lamp? Well, you all

have been in jewelry stores and for obvious reasons,

fine gems are kept under lock and key under display in

a shop. But when you take your wife or significant

other in to pick out a stone, you'd like to see it on

top of the counter, not in the display counter. So,

when the stones are removed from the display counter,

or from the display case where they're under showcase

lamps, which are exempt under the energy act. So

showcase lamps are totally exempt. Now those stones

are placed on the surface of the display counter

subject to illumination over the counter. And this is

where these lamps, then, are used to maintain that

same kind of appearance that you see in the case when

you move it up on top of the case.

Again, to modify this lamp, to deepen the

lamp as was suggested in the rule making, to deepen

the coating on this lamp to meet the standard would in

effect destroy that characteristic. You would not

achieve that same appearance of the stone on top of

the case as they are within the display case. Again,

a case of a specific application product which could

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not be achieved, or a specific application need which

could not be achieved given the proposed rule making

in the regulation.

MR. MARGOLIS: In the jewelry -- Mr.

Churchill?

MR. CHURCHILL: Yes?

MR. MARGOLIS: In the jewelry showcase, is

the lamp the same as the one that you have shown us or

is it a different type?

MR. CHURCHILL: It's a -- It's not a

reflector lamp. It's a incandescent showcase lamp.

Basically a long narrow diameter lamp.

MR. MARGOLIS: But does it -- would it have

the same characteristics as --

MR. CHURCHILL: Yes, with the coating on

the lamp, it has the same characteristics. Yes.

I trust there is no question that that is

a colored lamp, either unlighted or lighted. Yet, by

the proposed rule making, this is now a white lamp.

This does not pass the definition of a colored lamp.

Now, there's nothing unique in this green lamp in

terms of its saturation. Here's the blue lamp from

the same family. That lamp passes. That is a colored

lamp. That's a colored lamp. This is a white lamp by

the rule making.

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MR. MARGOLIS: Why?

MRa CHURCHILL: Because of the numbers.

Because of the numbers that have been proposed.

So, here is a lamp that's obviously used

for decorative lighting applications, not general

lighting. In fact, none of these lamps are used for

general lighting applications. First of all, they

don't provide the light output. But secondly, their

pricing is such that no one would consider these lamps

for real wide scale general lighting applications.

They are -- All of these samples that I've shown you

are priced significantly above the price levels for

general lighting incandescent lamps.

So that taking this all into account, we

would recommend that the Department reconsider the

definition of colored lamps, recognizing that the

application needs in the market place for these lamps

which do not pass the proposed criteria. Albeit we

recognize the intent of the criteria but there are

specific application opportunities and requirements

that can't be achieve with those proposed requirements

and also existing technology.

Also let's take into account that colored

lamps by definition are "low volume" in terms of their

relative sales versus the more popularly used general

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lighting reflector type lamps. Low volume, limited

sales, there's only so much engineering effort that

can be justified in being put into those kinds of

products to in effect meet certain criteria. The

volume just isn't there. So the proposed requirements

are taking products out of the market place that have

been there and serve well recognized needs, and yet at

the same time the size of the market does not justify

substantial engineering expense to find other coatings

and materials that might meet the requirements.

one suggestion we have is that taking a

page from the cold temperature fluorescent exemption,

Gene, and which you and Terry are very familiar with.

There the requirements that the Department have

established state that lamps that are designed and

marketed for cold temperature fluorescent applications

are exempt from the regulation. We would suggest that

you look at that approach possibly to some of these

specialized application areas for incandescent

reflector lamps such as jewelry displays, such as

plant growth and display, such as insect nonattraction, and there are probably better words to

describe that. But use the approach of that if lamps

are designed for and --designed and marketed for these

specific applications, that they then would be exempt

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from any proposed regulation.

Thank you for your time. I'd be happy to

answer any questions.

MRa LOGEE: Thank you, Russ.

Gene, do you have any further questions for

Russ?

MR. MARGOLIS: Under your suggestion of

designed and marketed for, would that mean that the

company in their brochures would state that these

lamps are designed and marketed for (a), and then they

go on and say these lamps are designed and marketed

for (b)? I mean --

MR. CHURCHILL: Not only in the literature

but on a lamp itself e In other words, this one is

marked grow and show. And similarly, the bug.

MR. MARGOLIS: Can I see that, please?

MR. CHURCHILL: The packaging has it very,

very --

MRa MARGOLIS: Yes, plant grow.

MR. CHURCHILL: So yes, the intent would be

that in catalogues, product marking, and packaging

that it would -- that the lamps would be very

specifically identified for a niche type

application. Absolutely.

MR. MARGOLIS: And then it would be also on

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the lamp itself?

MR. CHURCHILL: Now, I say that only with

a reservation. I say yes with a reservation saying on

the insect repellent, I don't know how you get all

those words on a lamp.

MR. MARGOLIS: But something.

MR. CHURCHILL: Something that -- it is not

a lamp for general lighting. You create that

impression by the appropriate words on the product and

the packaging.

MR. MARGOLIS: Thank you.

No further questions.

DOCTOR TREADO: Following a little bit

along that, there are some specific exemptions

mentioned in the bill and this is one of them,

obviously. But there's also sort of a general

statement that lamps not intended to satisfy the

majority of lighting needs or something like that, I'm

just wondering at what point could you sort of claim

that general exemption as opposed to -- Which can be

used -- It said that -- what are included are those

lamps which can be used to satisfy the majority of

lighting applications. And then it goes on to say,

"But does not include" a number of exemptions.

MR. CHURCHILL: Right.

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DOCTOR TREADO: So, if it's clear that this

lamp is not intended to satisfy the majority of

lighting applications, maybe that in itself is a more

general exemption for a lamp like that?

MR. CHURCHILL: I think we'd agree this

doesn't satisfy the majority.

DOCTOR TREADO: No, I don't know how that

works with DOE's proposed rule making. But, I'm

just--

MR. CHURCHILL: Well, there's another side

to that very same issue, Steve. And that is, is that

a decorative lamp? Decorative and showcase lamps are

one of the exempted categories.

DOCTOR TREADO: That's why I was hoping no

one would ask that question because we haven't had to

try to define decorative. That's a good one.

But let me --

MR. CHURCHILL: I mean, decorative is

satisfied through a number of attributes. Color is

one attribute. The shape of the lamp is another

attribute. The finish of the lamp is another

attribute. All of which meet the market application,

various market application needs in decorative, in socalled decorative applications.

DOCTOR TREADO: And of course you're

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sensitive to the issue here which is trying to prevent

inappropriately exempted lamps from displacing the

preferred energy conserving lamps.

MR. CHURCHILL: In the case of my company,

all of these lamps are identified in our catalogue as

having a unique characteristic for a particular

application. So we have always, and others do the

same thing, made the point that these specialty lamps

are provided for a particular niche market

opportunity.

DOCTOR TREADO: But that's -- you can't

necessarily prevent someone else from making the same

claim for a lamp which is not on an equal --

MR ® CHURCHILL: But the other part of it is

the cost, cost and thus pricing attribute, as I said

earlier.

DOCTOR TREADO: Again, cost and pricing and

everything hold for this lamp but that wouldn't

necessarily universally hold for all lamps which might

claim the same status.

But let me make just a few -- get a few

specific comments.

I would really like to get hold of the

written test data on these, the X and Y chromaticity

coordinates, the correlated color temperature and CRI®

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So, this is exactly the information we want to see

where these lamps fall in the chromaticity diagram

versus the ERI which is defined as being colored

versus white. So, if you can submit that with your

written comments.

MR. CHURCHILL: We were meeting on this at

3:00 o'clock yesterday afternoon pulling this

together.

DOCTOR TREADO: There's always a

possibility of measurement uncertainty and it could be

that we remeasure -- We'll get a hold of these lamps,

too. If you could include on there specific

designations so we can make sure we're testing the

same lamps, seeing how they fall.

As far -- getting back to your -- the first

lamp you had, the plant light. There is no exemption

for incandescent plant light. There is one for

fluorescent.

MR, CHURCHILL: Right.

DOCTOR TREADO: As I'm sure you're aware.

I suppose one opportunity would be for people just to

switch to fluorescent. They would be more energy

efficient just on that basis.

MR. CHURCHILL: Yes and nom It depends on

the specific application that -- We've all seen you've

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got area where plants are applied both in residential

and non-residential applications where you do want to

put a highlighted appearance on it versus justa

general diffusing appearance that you could achieve

with a linear fluorescent lamp. So there are

application requirements where simply fluorescent

lamps won't accomplish the task because they are a

broad diffusing light source versus a concentrating

light source.

And it's either -- There are A-line

versions of these same lamps which, if you put a

reflector on it, you in effect then create the

reflector lamp that way. So it isn't that there

aren't uses, recognized uses for this kind of color

characteristic in an incandescent lamp.

DOCTOR TREADO: And as far as the bug

lights, there are two approaches there. One is to --

you're saying well, you don't want to put the

frequencies back in, the wave lengths back in that

will attract the insects. On the other hand, you

could filter them even more to take more wave lengths

out to make them then be colored. Again, you

mentioned limited engineering resources for the

smaller market products but I'm just wondering how

close that might be to --

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MR. CHURCHILL: Well, unfortunately the

in the case of the bug light, it -- it's exempt under

-- If it -- Okay. It will fail under color

temperature. And to modify the color temperature, it

can't get there without disrupting the -- or, putting

blue energy in which would then defeat its purpose.

DOCTOR TREADO: The amber yellow colors are

the, probably, most difficult other than the jewelry

lamp which I still don't know how to handle that ® Are

there any substitutes for that lamp that are

acceptable?

MR. CHURCHILL: No.

DOCTOR TREADO: Tungsten halogen? Can you

make a lamp that will meet the minimum efficacy even

if it has a shorter life?

MR. CHURCHILL: No. Or is a 90 power

halogen, if you put this filter on it, you're going to

fail the energy efficiency test.

DOCTOR TREADO: Even though it's a very

fairly white light essentially. It's just has a --

MR. CHURCHILL: Right. But the

everybody's 90 power halogen is close enough to the

efficiency standard that any filter such as this on

the lamp will -- or the transparent loop, will cause

it to fail,

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1 DOCTOR TREADO: That's all I had.

2 MR. LOGES: Russ, I still am bothered a bit

3 by this doing a -- by a company doing a end run around

4 the rule. If we allow marketing and designating for

5 specific applications such as plant growth with a very

6 light blue tint on it, what's to prevent a company

7 from just putting a light blue tint on it, claiming

8 that it's for plant growth but really has very few of

9 the characteristics that your lamp has?

10 MR. CHURCHILL: I guess the force of the

11 market place. In other words, if you put a lamp out

12 there and call it a show or plant light, or whatever

13 name you want to put on it relative to the plant --

14 applying it to plants, people aren't going to -- are

15 just not going to use it in a widespread -- You know,

16 there's always an exception. But on a widespread

17 basis, people just don't go buy lamps for plant light

18 and stick them in general lighting sockets.

19 So there is the power of advertising,

20 communication, to guide people into which lamps will

21 be used.

22 MR. LOGEE: Is that lamp or any of those

23 lamps quite a bit a more expensive to produce than the

24 standard lamp without --

25 MR. CHURCHILL: Absolutely. Absolutely.

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These coatings are not inexpensive.

MR. LOGEE: Those are specialized coatings

on those?

MR. CHURCHILL: Yes. They are not just a

hint of blue on this lamp. This is a tailored, a

tailored coating to, as I indicated earlier, tailored

to both a reflective and the absorption

characteristics of foliage. Because you want to absorb

the energy from a plant growth stimulation standpoint.

You want to reflect energy from a plant appearance

standpoint. And so, these are very -- these are

highly tailored coatings. In the case of the plant

light for foliage characteristics, in the case of the

yellow lamp for the eye sensitivity characteristic of

insects.

MR. LOGEE: But the green lamp is not so

tailored? That's more like --

MR. CHURCHILL: That's tailored to get a

good saturated green.

MR. LOGEE: But if we wanted to -- didn't

want to exempt that, then you would have to change the

green to some extent?

MR. CHURCHILL: Right. The green would be

far weaker, so to speak, in a broad sense, than, say,

its blue, red, and yellow counterparts that are used

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for saturated, decorative applications. You would

then have a kind of a sallow green, so to speak,

versus a saturated green which you have today.

MR. LOGEE : So we might be -- someone

suggested language might be the saturated green color

would be -- I'm trying to search for, if we are going

to have to provide exemptions for these lamps, we have

quite a list of them here. Although the insect lamp

and the jeweler ' s lamp, and the plant growth lamp,

seem to be quite defined niched markets that are

specific applications that would fit with your

suggestion , GE's suggestion for the cold temperature

type of exemption. But I have more trouble with that

green lamp , I think.

MR. CHURCHILL: Well, it may be possible,

we haven't looked at it, Steve. But it may be

possible that you have a segmented definition.

DOCTOR TREADO: Well, that's what I'm just

thinking of. If we were using the general color

rendering index, if we went and looked at some of the

special color rendering indexes which refer to effects

on different wave length ranges, it may be that the

green is -- has real low CRIs, 3, 4 , and 8, or

whatever they may happen to be. And I think there are

eight special indexes and we could see how these match

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up with those. And maybe if you have a saturated

color that you can prove that by having a very low

special color rendering index in one of those ranges.

It's a little awkward that we're using CRI

but color appearances is a difficult thing to really

get a handle on.

MR. LOGEE: I have no further questions.

MR. MARGOLIS: Could we go back to the

first lamp that you showed, the one that you had a --

that was a tint that when you lit it, it was mostly

white.

MR. CHURCHILL: It looks more colored when

it's unlit than when it's lit.

MR. MARGOLIS: Or when you put it on an

angle, you could see a tint. But if it's shining --

Now, what is the purpose for that -- for this lamp?

MR. CHURCHILL: This lamp has two purposes.

To aid plants in their growth and, (b), to enhance

their appearance in either a residential or commercial

application where you've got plants in a -- either in

a home or in an atrium in a commercial establishment.

MR. MARGOLIS: Now, if you would install

this lamp for general purpose use, use in a recess --

in a living room, say, the -- would the consumer see

any difference in the lamp output than if he would

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have a normal reflector bulb?

MR. CHURCHILL: Yes, if you put this next

to a 75 watt so-called white reflector lamp, he will

see a difference in light output. Absolutely.

MR. MARGOLIS: Now what is the cost of this

bulb in relation to that 75?

MR. CHURCHILL: I don't have those numbers

at my fingertips. We can include them in our written

submission. But it is substantially higher than the

white version.

MR. MARGOLIS: So the consumer would not

use this bulb as a substitute for the normal bulb

because the cost would be more?

MR. CHURCHILL: Right. The packaging is

all geared to the use of this lamp in a plant lighting

application. The cost is substantially higher so that

there -- it would be no basis on which a consumer

would make that association.

MR. MARGOLIS: The light bulb, that would

be more efficient than this bulb?

MR. CHURCHILL: Absolutely. Absolutely.

MR. MARGOLIS: So, but the cost for this

bulb would be much higher. So on both grounds then,

you're saying that cost and efficiency, he would want

to stick to a white bulb and would not substitute this

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1 type bulb for the white bulb?

2 MR. CHURCHILL: Yes sir. Yes.

3 MR. MARGOLIS: And you said you will submit

4 the cost, right.

5 MR. CHURCHILL: We will.

6 MR. MARGOLIS: I have no other questions.

7 MR. LOGEE: Do you have any further

8 questions, Steve?

9 DOCTOR TREADO: No.

10 MR. LOGEE: Okay , Russ. Thank you very

11 much. Certainly appreciated your bringing the lamps.

12 At this time, I'd like to call unscheduled

13 speaker Mr. Bart Pasternak, please.

14 MR. PASTERNAK: Good morning, gentlemen.

15 Thank you for the opportunity to address the group and

16 your panel even though I was not a listed speaker.

17 My position in connection with the --

18 MR. LOGEE: Excuse me, Bart, would you

19 indicate your affiliation?

20 MR. PASTERNAK: Yes® I'm sorry. My name

21 is Barton Pasternak. I'm a vice president with Angelo

22 Brothers Company in Philadelphia, Pennsylvania.

23 I am here basically to -- against end runs.

24 The regulations with respect to vibration resistent in

25 a rough service incandescent reflector lamps as

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written with respect to the C-17 or C-22 filament

characteristics, we certainly have no objection to.

There is no question in anyone's mind, nor could

anyone reasonable infer that there is no legitimate

industrial commercial use for vibration resistent

lamps. It's clear that they do exist albeit in a

limited environment and in limited numbers.

Our concern is that the C-9 lamp, the C-9

reflector lamp, has a history and a life which has

very little to do with vibration resistent use. It

is, in fact, the football commodity low end reflector

lamp presently being sold in the United States. To

attempt to fulfill a small industrial market place by

enabling an inefficient, poorly made, and primarily

offshore made lamp to continue to infiltrate the

consumer market seems to be like trying to go after

one of Russ' bulbs with a sledge hammer.

And the point is, quite simply, that if in

fact there is a legitimate need and there is a

legitimate solution, it is not necessary to extend the

definition to include lamps which are going to be

obviously used not for that need but for, in fact, to

continue to make a mockery of this portion of the act.

If in fact there is a substantiated need in industry

for vibration resistant R-lamps, those lamps presently

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being made with other than C-9 filaments meet them.

If the C-9 filament is continued to be used in

vibration resistant A-lamps, we certainly have no

objection. It's lack of efficiency makes it not very

valuable in terms of consumer use.

The overwhelming majority of reflector

lamps that are sold in the United States and

specifically I'm not talking about the -- some of the

heavy duty lamps, are used by consumers. They go in

living rooms. They go in kitchens. I think that

probably all of us have them in our homes. The

halogen Par lamp has been a good substitute in terms

of increasing the efficiency of that lamp.

If in fact we are able to devise lamps

which meet the energy requirements without the

necessity of using halogen, so much the better. If in

fact there is no other way to do it, then Congress has

spoken on what the intent of the rule is. To

frustrate Congress' intent, to continue to let a C-9

"long life" lamp flood the market place at the low end

and -- is true, I think, in lamp sales as it is in

economics, the cheap lamps will drive out good lamps

from the market place. And that's exactly what's

going to happen.

No one -- It is no one's intent to damage

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the business of people who legitimately make vibration

resistant high impact lamps for the industrial market

place. If in fact specialized lamps are needed for

toll plazas, then certainly the C-17 and C-22 lamps

will meet that need. The question is, if there is a

need and if there is a solution, why create a solution

that not only fulfills that need, but permits not only

an end run but in essence a destruction of the intent

of the act.

Gentlemen, you're really the last bastion

from the consumer's point of view. If the Department

of Energy does not so construct its definitions so as

to eliminate the standard C-9 from standard consumer

use, merely by putting a VS or a VR, or some other

designation on the corner of a box, then all of the

works that's been done by so many people including

many of the respected lamp manufactures in the United

States will have been for not. If you don't stand up

on behalf of the consumer and stop this potential

foolishness, then no one will. And all of the work

that has been done, all of the meetings which have

been held, all of the roundtables, all the

Congressional meetings, all the staff, all the rest of

it, mean nothing.

So one last time I invade on behalf of

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balance and say yes, there is a legitimate commercial

need. There is a legitimate commercial solution.

There is not a legitimate consumer need and therefore

there should not be an illegitimate consumer solution.

Thank you.

MR. LOGEE: Bart, will you stay up.

MR. PASTERNAK: Yes. I didn't think

anybody would ask me any questions.

MR. LOGEE: Do you have questions, Gene?

MR. MARGOLIS: What is the -- what in your

opinion is the solution that DOE should come up with?

MR. PASTERNAK: It's very simple. They

have already aid that a C-17 or a C-22 -- I'm candidly

not a lighting engineer so I can't speak to the C-11

that the people from Duro-Test talked about earlier.

Our needs are of the small but albeit important

industrial commercial use for vibration resistant

lamps. So, we have a need and we have a solution. I

don't know why any more than that is required.

MR. MARGOLIS: Well, what's -- Are you

saying that our definition is sufficient?

MR. PASTERNAK: Yes, without the necessity

of getting to the Naval test.

MR. MARGOLIS: Without getting --

MR. PASTERNAK: Without the necessity of

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reaching any further tests, that a simple definition

of a vibration resistant lamp as a C-17 or C-22

filament with the requisite number of supports meets

both -- meets the need of the industry without opening

the flood gates to broad consumer invasion.

After all, I think we're all concerned with

not only meeting the niche needs of the industrial

commercial market place, but the legitimate needs of

the consumers as reflected by the will of Congress.

MR, MARGOLIS: I'm not a lighting engineer,

period. I wish to give you this definition of rough

or vibration service incandescent reflector lamps that

is use -- that we have proposed. Could you look at

that and tell me if there is any changes to that or

that's what you mean by that we should keep the

definition that we proposed?

MR. PASTERNAK: This may be the blind

leading the lame but I'd be happy to reread them.

I would say that if we put a period after

the word lead -- or after the word lead wires that it

would be sufficient.

MR. MARGOLIS: Thank you.

DOCTOR TREADO: Bart, let me propose a

hypothetical situation. Suppose there existed a C-17

lamp and a C-9 lamp of some particular construction

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and they both were installed under exactly the same

set of conditions which consisted of high vibration,

et cetera. And there was basically not difference in

their performance over their life. Would you still

maintain that there would be something about the C-9

which would justify its exclusion from the vibration

exemption?

MR. PASTERNAK: Yes, because I think we're

approaching the issue from two opposite points of

view. The question is not, in my opinion, whether a

C-9 can be manufactured to be vibration resistant in

an incandescent reflector lamp. I believe that given

the requisite number of supports or whatever the case

may be, it probably will meet that standard. The

question is, is it necessary for the department of

Energy to include it when there are other lamps which

will meet the standard and which will not give rise to

the potential end run of flooding the consumer market

with C-9 lamps under the guise that they are vibration

resistant lamps.

In a prior submission that I made, we did

an exhaustive analysis of all of the lighting

catalogues issued by the major sellers of lamps in the

United States. And prior to the passage of the act,

vibration resistant appeared very few places when it

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came to reflector lamps. And those places where it

did come up did not come up with respect to C-9so In

fact, the C-9 was the basic inexpensive consumer Rlamp that was sold and it was -- it's a highly

inefficient lamp. Not nearly as efficient as the

standards would dictate that the vast majority of

these lamp should be.

So, I think you and I are really

approaching the same question from two different

points of view. I don't approach the question as to

whether the C-9 is vibration resistant. I approach

the question by saying if in fact there is a need for

vibration resistant lamps and Congress recognized that

need, and everyone realizes that its a small part of

the overall role of the reflector lamps, and there's

a way to meet that need which is already

conventionally used, no one has to reinvent the wheel

in connection with C-17s and C-22sm Why should we

open the door to the "end run," as Terry talked about

before, by allowing the C-9 when nothing is added to

the process and the potential for detraction from the

process and for abuse of the process is enormous?

So, I don't know any other way to answer

your question, Steve.

DOCTOR TREADO: If the Department of Energy

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were to limit the vibration exemption to basically a

prescriptive standard which requires C-17, C-22 for

example, and someone were to come up with a totally

different filament design which had similar vibration

resistant characteristics , they would then be

prevented from using that under that set

circumstances?

MR. PASTERNAK: If it was superior, meaning

that it met both the resistance, the vibration

resistance, and the energy requirements because the

only thing that would be superior would be a vibration

resistant lamp that was also efficient. Then it

wouldn't be a problem because it would come in under

the efficiency standard.

To make a more vibration resistant lamp

when, and I recognize that that's a possibility. When

the need is this big and the potential for abuse is

this big, requires the type of judicious balancing

that the requires of everything.

Yes, there is a need. Yes, there is a

solution. Yes, there's a potential for harm. And I

think it is always incumbent upon the government to

balance that potential for harm against that potential

solution. I think if the -- My general understanding

of the rules of law deal specifically with that

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process, that policy is that balancing of good and

potential harm. And I simply ask once again that the

Department of Energy take that into consideration in

the final rule making.

MR. LOGEE: Bart, I'm concerned if the

Department uses this prescriptive standard that you

suggest of a C-17 or C-22, what would prevent those

types of lamps from being widely distributed after

that rule would become effective and therefore also do

an end run around the standards?

MR. PASTERNAK: It is my understanding that

these are much more expensive lamps to manufacture

because of the increased number of supports and the

way in which these lamps themselves are manufactured.

The reason C-9 becomes a potential for abuse is its

low cost. The higher the cost, the more likely it is

that some other feature will be implemented, hopefully

complying with the energy requirements in order to

bring it about.

It is not that there is anything inherently good

or bad about a C-9 filament. It's that an inexpensive

filament to make m It is make around the world and

these inefficient lamps will flood the market as long

as the C-9 is allowed to come in. And simply putting

a VS on the box doesn't change that. And I think one

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time I made a presentation showing that I could take

a C-9 lamp and from a marketing point of view say,

wow, not only is it a good lamp. It's also vibration

resistant. And there attempt to create a greater

potential for market value by virtue of trying to

obscure -- get around the law.

MR. LOGEE: Other?

MR. MARGOLIS: Why is a C-9 vibration

service lamp?

MR. PASTERNAK: I'm sorry?

MR., MARGOLIS: You said that you would take

the C-9 lamp, put it in a box and put VS on the box,

the vibration service.

MR. PASTERNAK: If you permitted the C-9

exemption, in other words, if C-9 passed the naval

test, all right, and therefore was permitted to be

sold as an exempt product, any marketer who wanted to

continue to import and sell inexpensive C-9 lamps

would simply put a VS on the box and in their

advertising say, not only is this our same wonderful

lamp but now it's vibration resistant also, as though

it was giving to consumer an added benefit when I

think it's reasonably clear that there's a minuscule,

if any, market for vibration resistant lamps in the

standard consumer market place.

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MR. MARGOLIS: But is the lamp -- would it

be a vibration -- rough or vibration service lamp?

The C-9? Whether or not the consumer needs it as

such, would -- in the commercial application, would

that lamp, the C-9, would that be a vibration service

lamp?

MR. PASTERNAK: Well, if it passes the test

as the regulations suggest, then it could be

classified as a vibration resistant lamp and therefore

be exempted from the minimum energy requirement. The

point is that there are other lamps which are

apparently available which will meet that need without

the potential for opening up the flood gates for

abuse.

MR. MARGOLIS: And you feel that it

wouldn't -- would pass the test?

MR. PASTERNAK: Well, this gentleman from--

the first gentleman who spoke, Mr. Stine, said that

their test -- their lamps passed the test. I think

Steve picked up the fact that maybe the lamp -- maybe

the test was run in accordance with the standard,

maybe it wasn't. I don't know the answer to the

question. However, if in fact it's going to be

cheaper for certain manufacturers or importers to find

the lamp that meets that lamps with the use of the C-9

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than to attempt to comply with the rule of Congress,

I can assure that the market place will demand that

result. And I don't think anyone here, and certainly

all of the important lamp manufacturers and sellers in

the United States are in this room, would disagree

with what I'm saying.

MR. MARGOLIS: Thank you, sir.

MR. PASTERNAK: Thank you.

MR. LOGEE: Has Angelo Brothers tested any

of their lamps per our definition for vibration of

service --

MR. PASTERNAK: Funny you should ask. I

have already sent samples of those lamps to Steve,

MR. LOGEE: But you haven't -- Steve hasn't

run those?

MR ® PASTERNAK: He has not run those tests.

I don't know -- And basically this comes back to what

I said before. If in fact they pass the test and

everybody's passed the test, what you're going to do

is force us to sell the lamp.

MR. LOGEE: Well, that's would

unfortunately --

MR. PASTERNAK: You're going force us to

sell the lamp.

MR. LOGEE: Right.

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MR. PASTERNAK: And we don't want to sell

the lamp.

MR. LOGEE: Okay. Is there -- You're quite

certain that only the C-17 and C-22 type of lamp would

be an effective definition from your point of view and

you're quite certain that there is nothing else we

could do to this vibration test in terms of maybe

expand the frequency range or increase the timing, or

things like that, that would get -- delete some of the

low cost C-9 type of lamps?

MR. PASTERNAK: I don't know the answer to

the question. Certainly Steve has at his facility the

opportunity to broaden the test, narrow the test, try

and bring about the optimum mix. we have neither the

testing facilities nor, candidly, the technical

knowledge to be able to answer your question.

MR. LOGEE: Do you have any further

questions?

Okay. Thank you, Bart.

MR. PASTERNAK: Thanks for the opportunity.

MR. LOGEE: Thank you, Sandy.

Sandy, I'm assuming that there are no

further unscheduled speakers? Okay. Thank you.

We have three questions that Steve Martel

would like us to ask. I'm going to take a moment to

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look at them. These are question to --

DOCTOR TREADO: To whom?

MR. LOGEE: Steve, who are you directing

these questions to?

MR. MARTEL: For Bart,

MRa LOGEE: To Bart Pasternak?

Oh, sorry, you said that Bart has already

answered --

MRe MARTEL: I think he already hit on the

first one.

MR. LOGEE: Then we'll disregard that one.

MR. MARTEL: The other two are just follow

ups on the first question.

MR. LOGEE: Yes, they're not really

questions, Steve. They're more or less comments.

I would ask you to just add these comments

to your written comments.

MR. MARGOLIS: Or he can come back. He

could add them now.

MR. LOGEE: He could add them now?

MR. MARGOLIS: Yes, because you have

rebuttal.

MR. LOGEE: You would like to allow these

questions?

25 11 MR. MARGOLIS: No, I mean, you said he

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should -- not as questions but he could state these.

He could give these comments in his rebuttal

statement.

MR. LOGEE: Steve, if you'd like to make a

short rebuttal statement, then you. could --

MR. MARGOLIS: Call on him. You go into

rebuttal statements.

MR. LOGEE: At this time, then, we'll allow

rebuttal statements and Steve Martel will present

these comments in rebuttal. And this is to Bart

Pasternak's statements from Angelo Brothers.

Thank you, Steve.

MR. MARTEL: Thank you. Again, Steve

Martel with Duro-Test.

Just a couple comments. Again, Steve hit

on the first comment that if you have a define

filament, prescriptive filament type of a C-17 and C22 only, you limit the amount of engineering that can

go into producing better filament types that might not

meet the energy act, that might be more efficient than

what's out there now, and might be better for the

rough service application. So you don't have that

incentive to increase your engineering or increase

your technology whatsoever.

We do agree that there might be a problem

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1 with some of the low quality C-9 filaments. Duro-Test

2 as a commercial industrial manufacturer, we do know

3 there is a need for a C-11 type five support filament,

4 high quality type filament out there. And again,

mostly for the commercial industrial manufacturer and

6 the halogen lamps just won't suffice under those types

7 of applications.

8 And that was about it.

9 Thank you.

10 MR. LOGEE: Thank you, Steve.

11 DOCTOR TREADO: Can we ask any questions?

12 MR. LOGEE: Oh, sure.

13 Steve, there is a question.

14 DOCTOR TREADO: Maybe I should have asked

15 this earlier of some of the other people also. But

16 can you explain why you can't make a rough service

17 tungsten halogen incandescent reflector lamp?

18 MR. MARTEL: With the halogen technology

19 you have a capsule with the filament inside. You

20 can'[t put any type of filament supports on that

21 filament without decreasing the efficacy of the lamp

22 considerably, putting it far below the standards of

23 EPACT. And I don't even think there's room to put the

24 supports in there as far as I understand it.

25 DOCTOR TREADO: So you don't think there

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would be any way of configuring a filament inside the

halogen capsule to withstand the -- a vibration

environment?

MR. MARTEL: No, And we've also worked for

a number of years and spent a lot of money on a

certain project that was called a MI-T-Watt to do

something similar to that with -- it was an

incandescent but not a halogen type but to redirect

the heat back to the filament m It just does not work

Doesn't work at all.

MR. LOGEE: Any other questions?

Thank you, Steve.

Are there other rebuttal statements or

questions?

Thank you very much, gentlemen, for

attending this hearing. At this point, the hearing is

adjourned.

(Whereupon , at 11: 22 a.m . the public

hearing was concluded.)

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I

C E R T I F I CAT E

This is to certify that the foregoing transcript

in the matter of:

Before:

i Date:

U.S. DEPARTMENT OF ENERGY

PUBLIC HEARING: PROPOSED DEFINITIONS

FOR CERTAIN FLOURESCENT LAMPS AND

INCANDESCENT LAMPS

TERRY LOGUE

NOVEMBER 15, 1994

Place: WASHINGTON, D.C.

represents the full and complete proceedings.of the

aforementioned matter, as reported and reduced to typewriting.

S A G CORP.

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