1

I I i

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



### SAG, CORP 4218 LENORE LANE, N.W. WASHINGTON, D.C. 200082 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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. D.C. 20008 (202) 797-2525 VIDEO ; TRANSCRIPTIONS3 P-R-O-C-E-E-D-I-N-G-S 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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. 

### SAG, CORP 4218 LENORE LANE, N.W. WASHINGTON, D.C. 20008 (202) 797-2525 VIDEO; TRANSCRIPTIONS2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 4 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 

### SAG, CORP 4218 LENORE LANE, N.W. WASHINGTON, D.C. 20008 (202) 797-2525 VIDEO; TRANSCRIPTIONS6 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 

### SAG, CORP 4218 LENORE LANE, N.W. WASHINGTON , D.C. 20008 (202) 797-2525 VIDEO; TRANSCRIPTIONS7 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 

### SAG, CORP 4218 LENORE LANE, N.W. WASHINGTON, D.C. 20008 (202) 797-2525 VIDEO; TRANSCRIPTIONS9 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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, 

### SAG, CORP 4218 LENORE LANE, N.W. WASHINGTON, D.C. 20008 (202) 797-2525 VIDEO; TRANSCRIPTIONSI 13 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. 

### SAG, CORP 4218 LENORE LANE, N.W. WASHINGTON, D.C. 20008 (202) 797-2525 VIDEO; TRANSCRIPTIONS14 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 -- 

### SAG, CORP 4218 LENORE LANE, N.W. WASHINGTON, D.C. 20008 (202) 797-2525 VIDEO; TRANSCRIPTIONS17 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 

### SAG, CORP 4218 LENORE LANE, N.W. WASHINGTON, D.C. 20008 (202) 797-2525 VIDEO; TRANSCRIPTIONS18 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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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4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 

### SAG, CORP 4218 LENORE LANE, N.W. WASHINGTON, D.C. 20008 (202) 797-2525 VIDEO ; TRANSCRIPTIONS22 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 

### SAG, CORP 4218 LENORE LANE, N.W. WASHINGTON, D.C. 20008 (202) 797-2525 VIDEO ; TRANSCRIPTIONS2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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



### SAG, CORP 4218 LENORE LANE, N.W. WASHINGTON, D.C. 20008 (202) 797-2525 VIDEO ; TRANSCRIPTIONS 24 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 clearly1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 25

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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4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26

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? 

### SAG, CORP 4218 LENORE LANE, N.W. WASHINGTON , D.C. 20008 (202) 797-2525 VIDEO; TRANSCRIPTIONS1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 27 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 

### SAG, CORP 4218 LENORE LANE, N.W. WASHINGTON, D.C. 20008 (202) 797-2525 VIDEO ; TRANSCRIPTIONS28 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 s the way --

down? That 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. 

### SAG, CORP 4218 LENORE LANE, N.W. WASHINGTON, D.C. 20008 (202) 797-2525 VIDEO; TRANSCRIPTIONS1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 32 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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2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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 neodymiumdoped 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. 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. 

### SAG, CORP 4218 LENORE LANE, N.W. WASHINGTON, D.C. 20008 (202) 797-2525 VIDEO ; TRANSCRIPTIONS41 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 ft it 13 en.

qu e o 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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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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2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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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7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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. 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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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 asplant 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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6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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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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.



### SAG, CORP 4218 LENORE LANE, N.W. WASHINGTON, D.C. 20008 (202) 797-2525 VIDEO; TRANSCRIPTIONS1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 53 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 -- 

### SAG, CORP 4218 LENORE LANE, N.W. WASHINGTON, D.C. 20008 (202) 797-2525 VIDEO ; TRANSCRIPTIONS2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 57 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, 

### SAG, CORP 4218 LENORE LANE, N.W. WASHINGTON, D.C. 20008 (202) 797-2525 VIDEO; TRANSCRIPTIONS58 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. 

### SAG, CORP 4218 LENORE LANE, N.W. WASHINGTON , D.C. 20008 (202) 797-2525 VIDEO ; TRANSCRIPTIONS59 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 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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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 

### SAG, CORP 4218 LENORE LANE, N.W. WASHINGTON, D.C. 20008 (202) 797-2525 VIDEO; TRANSCRIPTIONS63 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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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 Infact, 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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3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 74 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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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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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 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 definefilament, 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



### SAG, CORP 4218 LENORE LANE, N.W. WASHINGTON, D.C. 20008 (202) 797-2525 VIDEO; TRANSCRIPTIONS79 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 theaforementioned matter, as reported and reduced to typewriting.

S A G CORP. 202/797- 2525 4218 LENORE LANE, NW 202/797-2525 WASHINGTON , DC 20008