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 DEPARTMENT OF ENERGY

 PUBLIC MEETING ON

 ENERGY CONSERVATION STANDARDS FRAMEWORK-

 GENERAL SERVICE LAMPS

 Department of Energy

 1000 Independence Avenue, S.W.

 Washington, D.C.

 Tuesday, January 14, 2014

 9:04 a.m.

 Reported by: Christine Allen,

 Capital Reporting Company
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1 A P P E A R A N C E S

 FACILITATOR

2 Doug Brookman, Public Solutions, Inc.

3 DOE AND ASRAC REPRESENTATIVES

4 John Cymbalsky, U.S. Department of Energy

Lucy deButts, U.S. Department of Energy

5 Celia Sher, U.S. Department of Energy

6 INDUSTRY PARTICIPANTS

7 Alex Boesenberg, National Electronic

Manufacturers Association

8 Susan Callahan, Osram Sylvania

Keith Cook, Philips Electronics North America

9 David Gatto, Westinghouse

John Green, Easton's Cooper Lighting Business

10 Noah Horowitz, National Resources Defense

 Council

11 Joe Howley, General Electric

Taylor Jantz-Sell, U.S. Environmental Protection

12 Agency

Andrew deLaski, Appliance Standards Awareness

13 Project

Michael McGaraghan, California Investor Owned

14 Utilities

Terry McGowan, American Lighting Association

15 Robert Nachtrieb, Lutron Electronics

Kyle Pistor, National Electronic Manufacturers

16 Association

Rebecca Ranier, Easton's Cooper Lighting

17 Business

Ken Rider, California Energy Commission (via

18 phone)

Charlie Stephens, Northwest Energy Efficiency

19 Alliance

Jennifer Thorne Amann, American Council for an

20 Energy Efficient Economy

21

22
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1 A P P E A R A N C E S Cont'd

 CONSULTANTS

2

Lawrence Berkeley National Laboratory:

3 Colleen Kantner

Brian Gerke

4

Navigant Consulting, Inc.:

5 Robert Cholnoky

Aisha Husain

6 Maureen Kienle

Ali McDonald

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

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1 C O N T E N T S

 PAGE

2 Welcome

 John Cymbalsky, Department of Energy 5

3 Introductions 6

 Agenda Review 8

4 Opening Statements

 Alex Boesenberg 13

5 Andrew deLaski 15

 Noah Horowitz 25

6 Overview

 Lucy deButts, DOE Lighting Project Manager 27

7 Scope of Coverage

 Maureen Kienle, Navigant Consulting, Inc. 38

8 Test Procedure

 Maureen Kienle, Navigant Consulting, Inc. 73

9 Market and Technology Assessment

 Maureen Kienle, Navigant Consulting, Inc. 80

10 Screening Analysis

 Maureen Kienle, Navigant Consulting, Inc. 80

11 Break 102

 Engineering Analysis

12 Aisha Husain, Navigant Consulting, Inc. 102

 Product Price Determination

13 Aisha Husain, Navigant Consulting, Inc. 125

 Energy Use Analysis

14 Colleen Kantner, Lawrence Berkeley Laboratory 144

 Life-Cycle Cost Analysis

15 Colleen Kantner, Lawrence Berkeley Laboratory 148

 Shipments Analysis

16 Brian Gerke, Lawrence Berkeley Laboratory 156

 National Impacts Analysis

17 Brian Gerke, Lawrence Berkeley Laboratory 173

 NOPR Analysis

18 Aisha Husain, Navigant Consulting, Inc. 173

 Closing Remarks

19 Lucy deButts, DOE Lighting Project Manager 181

20

21

22
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1 P R O C E E D I N G S

2 (9:04 a.m.)

3 MR. BROOKMAN: Can I get started here?

4 Good morning, everyone, welcome. This is the U.S.

5 Department of Energy's Public Meeting on Energy

6 Conservation Standards and Framework, General

7 Service Lamps.

8 Today is Tuesday, January 14, 2014, here

9 in the Forrestal Building in Washington, D.C.

10 Welcome, everyone. I'm glad to see you here this

11 morning. We're going to start with welcoming

12 remarks from John Cymbalsky.

13 MR. CYMBALSKY: Thank you, Doug. I'm

14 John Cymbalsky. I'm the program manager for

15 Appliance Standards here at the Department of

16 Energy. I'd like to welcome everyone to today's

17 meeting on general service lamps.

18 I wish everyone a happy New Year. I

19 think this rule--just thinking of the scope and

20 the potential energy savings here, we think, is

21 obviously very significant. We understand that

22 the backstop could kick in on this rule, too, for
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1 45 lumens per watt in 2020. So I can't stick

2 around too long here, but I want to wish everybody

3 a good meeting and a very productive meeting.

4 And I know there were some discussions

5 along the way between efficiency advocates and the

6 manufacturers regarding potential negotiated

7 rulemaking on this product class, so if that

8 opportunity still exists I'd just like to say the

9 Department welcomes that opportunity. And, of

10 course, we could use the ASRAC Federal Advisory

11 Committee to serve as the vehicle to do a

12 negotiated rulemaking. Thank you.

13 MR. BROOKMAN: Thank you. And it is our

14 tradition to start with introductions.

15 REPORTER: Mr. Bookman, could you use

16 your other microphone?

17 MR. BOOKMAN: Okay, this thing is not

18 working well. It's our tradition to start with

19 introductions, so let's start to my immediate left

20 here. Name and organizational affiliation,

21 please?

22 MR. BOESENBERG: Alex Boesenberg,
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1 manager of Regulatory Affairs for the National

2 Electrical Manufacturers Association.

3 MS. CALLAHAN: Sue Callahan, Osram

4 Sylvania.

5 MR. COOK: Keith Cook, Philips Lighting.

6 MR. GATTO: David Gatto, Westinghouse

7 Lighting.

8 MS. RANIER: Rebecca Ranier, Eaton's

9 Cooper Lighting.

10 MR. GREEN: John Green, Eaton's Cooper

11 Lighting.

12 MR. HOROWITZ: Noah Horowitz, National

13 Resources Defense Council, NRDC.

14 MS. JANTZ-SELL: Taylor Jantz-Sell, U.S.

15 Environmental Protection Agency, Energy Star

16 program.

17 MR. McGARAGHAN: Mike McGaraghan, on

18 behalf of the California Investor Owned Utilities.

19 MR. HOWLEY: Joe Howley, manager of

20 Industry Relations at GE Lighting.

21 MR. McGOWAN: Terry McGowan, I'm a

22 director of engineering for the American Lighting
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1 Association.

2 MS. SHER: Celia Sher, DoE general

3 counsel.

4 MS. KANTNER: Colleen Kantner, Lawrence

5 Berkeley National Laboratory.

6 MR. GERKE: Brian Gerke, Lawrence

7 Berkeley National Laboratory.

8 MS. McDONALD: Ali McDonald, Navigant

9 Consulting.

10 MS. KIENLE: Maureen Kienle, Navigant

11 Consulting.

12 MS. HUSAIN: Aisha Husain, Navigant

13 Consulting.

14 MS. DEBUTTS: Lucy deButts, Department

15 of Energy.

16 MR. BROOKMAN: Okay, thank you. Did

17 everyone get a chance to introduce themselves?

18 Okay, that's fine. Lucy, do you wish to--well,

19 let me do a brief agenda review here.

20 As you can see from the packet of

21 information, as you received walking in the door

22 today, we have both an agenda and a colorful
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1 packet of PowerPoint slides. Immediately

2 following this agenda review there will be some

3 overview slides and then following the overview

4 slides, an opportunity for anybody that wishes to

5 make opening remarks, brief summary comments about

6 issues that matter to you.

7 Following that, we will return to the

8 content in the presentation materials, scope of

9 coverage, and test procedures and then directly

10 moving on, market technology assessment screening

11 analysis. We'll take a break mid- morning, around

12 about 10:30. From there are returning to

13 engineering analysis and then directly to product

14 price determination and then energy use analysis,

15 life-cycle cost analysis.

16 We'll take lunch midday, around about

17 noon or so. And then, as we return from lunch,

18 shipments analysis, national impact analysis, then

19 NOPR analyses, and then closing remarks at the end

20 of the day, another opportunity for anybody that

21 wants to raise any additional issues that haven't

22 been covered sufficiently.
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1 Questions or comments about the agenda?

2 (No response.)

3 MR. BROOKMAN: Seeing none, if you would

4 please, on the first page of your packet, ground

5 rules. Please, if you would speak one at a time

6 and say your name for the record each time you

7 speak. There will be a complete transcript of

8 this meeting made available on the DoE website.

9 Be concise, please share the airtime. If

10 you could keep the focus here, turn your cell

11 phones on Silent mode, limit sidebar

12 conversations. You've already got used to turning

13 these microphones on and off, please turn them on

14 and off.

15 And then, webinar participants, welcome.

16 The Department of Energy's trying very hard to

17 make these meeting totally accessible to folks,

18 via the web. If you would turn your phones on

19 mute, raise your hand to be recognized to speak.

20 We've been mostly successful making that work and

21 we can typically hear you in the room, if you wish

22 to comment or ask a question.
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1 And I think that's most of what I had at

2 this point. Lucy? Lucy deButts, for a few

3 overview slides.

4 MS. DEBUTTS: Okay, so just to follow up

5 on what Doug said regarding the webinar. We

6 encourage comments from participants in the

7 meeting and, of course, over the webinar. Any

8 questions or comments made over the webinar would

9 be made part of the transcript for today's

10 meeting. However, we also encourage everyone to

11 submit written comments after the meeting.

12 All right, to the purpose of this public

13 meeting. So the purpose of today's meeting, of

14 course, is to present the procedural analytical

15 approaches to evaluate standards for general

16 service lamps. We are hoping to get comments from

17 everyone who has stated and we also would like to

18 discuss the next steps for this rulemaking.

19 So, if participants have their summary

20 of comments that they would like provide to us,

21 that's great. Any addition information you can

22 provide to us, any data, the department always
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1 welcomes. The more information we have, the

2 easier it is for us to actually analyze the

3 rulemaking.

4 When we discuss the issues, you will see

5 throughout the presentation the comment boxes.

6 These comment boxes actually correspond with the

7 issues in the framework document. So if you see--

8 I just want to mention again, if you see a comment

9 box that is numbered 3, that goes after 4, it's

10 not because we can't count. It's because it's

11 just easier to present that way.

12 They actually are numbered normally in

13 the framework document. If you'd like to access

14 the framework document itself, as you all know,

15 it's on regulations.gov. In the docket it's also

16 accessible via DoE website and if anyone has any

17 issues accessing any of those electronically, they

18 can also call me and we will try to see if we can

19 assist you in any way. But, hopefully, everybody

20 has access to the Internet by this point.

21 One thing I want to bring up is that the

22 deadline for submitting comments is on January
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1 23rd of 2014, so, hopefully, everyone will have

2 time to review and will be mindful of the

3 deadline.

4 So at this point I want to give it back

5 to Doug.

6 MR. BROOKMAN: Thank you. As we stated

7 at the outset, an opportunity for opening remarks,

8 issues that matter to you here at the outset? Alex

9 Boesenberg?

10 MR. BOESENBERG: I meant to print this

11 out, so I'll have to do it off my phone. Well,

12 I'm Alex Boesenberg of NEMA and speaking on behalf

13 of NEMA and my lamp manufacturer members, first,

14 of course, we thank the Department for hosting

15 today's meeting. As an administrative item, we've

16 had some discussions with the energy advocates and

17 we would like to request a two- week extension to

18 the comment period.

19 Comments are coming together, but the

20 gap in the holidays has put us a little behind and

21 to give the Department as thorough comments as

22 possible, two weeks would be a great help. I can
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1 definitely pull it together in that time. I won't

2 request any more. I'll let Andrew speak to that

3 when it gets back around to him. I think they

4 feel the same way.

5 We wanted to comment with respect to the

6 scope of the rulemaking. John already alluded to

7 the legislative backstop and some other things

8 that are concerns for all of us and so I have a

9 little statement that our counsel gave me and I'll

10 read it and then I'll translate it.

11 (Laughter.)

12 MR. BOESENBERG: So with respect to the

13 scope of the rulemaking and DoE's apparent

14 position that the Consolidated Appropriations Act

15 of 2012 appears to restrict the use of

16 appropriated funds in connection with several

17 aspects of the Department's incandescent lamps

18 program. To us this is not the most obvious

19 reading of the Burgess Amendment that resulted in

20 that restriction. Because the scope of this

21 rulemaking is important to all stakeholders, NEMA

22 believes DoE owes stakeholders a more detailed
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1 explanation of the conclusion that's provided on

2 page 11 of the framework document for general

3 service lamps.

4 So the translation is, we don't

5 necessarily read it the same way you do and rather

6 than offer our own interpretation, since we are

7 not the Department, it would be of great

8 assistance if the Department could provide some

9 more background information as to the mental steps

10 to where you arrived at that conclusion on page

11 11, and we would appreciate that. Obviously, the

12 sooner the better. If it could be delivered

13 within a week, then we could definitely turn that

14 around and provide, I think, more finely tuned

15 comments regarding that subject. Thank you.

16 MR. BROOKMAN: Okay, thank you, Alex.

17 Other comments here at the outset? Andrew

18 deLaski? Here's the microphone.

19 MR. DELASKI: I'll just start just by

20 concurring with Alex on both of those points. A

21 two-week extension for the comment period would be

22 very helpful, given that the 23rd is just a week
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1 from today and we want to have our comments based

2 not just on the framework document, but on what we

3 hear today in these discussions, so a little bit

4 more time would give us time to do that

5 effectively.

6 And keep in mind, please, as you

7 consider that, that both NEMA and those of us who

8 are in the energy advocacy community have

9 processes where we need to get approval for our

10 comments before they can go into you, so if the

11 deadline is the 23rd, they have to be done today

12 for us to be able to get them through our

13 processes.

14 MR. BROOKMAN: Right. Okay.

15 MR. DELASKI: So we'd just ask for some

16 consideration for that. And I also want to concur

17 with Alex's comments with respect to your

18 interpretation of the Burgess Amendment. We think

19 we would like to understand better where you're

20 coming from on this. I guess I can-- maybe a line

21 or two in the framework document. So we need a

22 better understanding of the DoE's interpretation
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1 so that--you know, we think again that you've

2 taken an awfully restrictive reading of it.

3 I want to make a couple of other

4 comments here at the outset on other issues that I

5 hope we'll get to today, but before I do that, I

6 want to just recognize that January 1st just

7 passed and we've just completed the phase-in

8 period for the initial standards that were enacted

9 as part of EISA. And I want to recognize and

10 congratulate the manufacturers, in particular, but

11 really the entire market for what's been a really

12 very successful implementation of Phase 1 of the

13 EISA standards.

14 Those of us who had been working on this

15 for many years now recognize that it was a big

16 effort by the part of the NEMA companies and other

17 companies as well as the entire distribution

18 chain. You walk into a Home Depot today or any

19 company that sells lighting and you see an

20 entirely different tableau than you saw a few

21 years ago. You know, the education that's gone to

22 help consumers understand the options that they
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1 now have, the choices they now face, which have

2 increased, relative to a few years ago, is really

3 amazing. And a lot of that credit is due to the

4 efforts of the companies in this room.

5 And I think the thing that we've seen in

6 the market, and those of us who, you know, been

7 following this right closely, is that the light

8 bulbs have gotten better. The consumers are

9 saving a lot of money. They're more energy

10 efficient. We have--the halogen incandescents

11 look the same. They light up the same as the

12 light bulb that they've replaced, and the

13 consumers also have the options of the more

14 efficient CFLs and LEDs that save even more. So

15 it's been a really good news story, despite what

16 you see some of the press--but I think that's

17 turned. The storm has turned, I would say, and

18 we're seeing a lot more positive recognition of

19 this.

20 And I think the news story out the end

21 of last year from my colleague John's old shop of

22 the EIA put out a very fascinating result, which
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1 is that U.S. energy consumption in the residential

2 sector is now down for the third year in a row.

3 And that result is, in a large measure, connected

4 back to the transition to more energy efficient

5 lighting.

6 The huge portion of residential energy

7 consumption was residential lighting, so we really

8 have to look at the EISA lighting standards as

9 having been a huge success so far and the work in

10 this docket will build on that success.

11 Now, if we think about this particular

12 docket--and I want to join Alex in thanking DoE

13 for starting this rulemaking. The idea behind

14 this docket was, when Congress enacted EISA, was

15 to give DoE the charge of designing an intelligent

16 approach to how light bulbs will evolve over time.

17 And, unfortunately, the rider now gets in the way

18 of doing that, in DoE's interpretation. So we're

19 disappointed, obviously, that Congress has

20 continued the rider. And, again, it's in the bill

21 that was released last night, the appropriations

22 bill, so to all apparent appearances it will
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1 continue again for another year.

2 But it's harmful in the sense that it

3 puts consumer savings at risk that have been

4 accomplished by the standards and by the industry

5 and it threatens the investments of your

6 companies, of the manufacturers that have invested

7 to comply with the standards, and the U.S. jobs

8 that are entailed in making compliant products.

9 And the framework, as Alex noted, the

10 DoE interprets the rider as preventing it from

11 considering incandescent technology in this

12 rulemaking. Now, that's going to reduce DoE's

13 flexibility a lot if that interpretation stands.

14 Flexibility combined with solution that will be

15 best for consumers and solutions that will be best

16 for manufacturers, and solutions that will be best

17 for the environment. In this interpretation, the

18 rider--and to use the current interpretation of

19 it--are a real hindrance to the best outcomes.

20 So we hope to learn today more about how

21 DoE interprets the rider and what it will mean for

22 the rulemaking process.
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1 So I want to highlight here as I close a

2 few other concerns I hope will come up today, and

3 if they don't come up, then we'll bring them up

4 during the rest of the meeting.

5 First, DoE has proposed in the framework

6 to use an approach for this standard that will be

7 based on equations, smooth curves, for the

8 standards. I think that's a good idea. Equation9 based standards generally result in less

10 discontinuities, less gaming potential, and we

11 think it's a good idea to move towards standards

12 that are based on continuous functions.

13 Secondly, we're concerned about DoE's--

14 what we think is a premature determination not to

15 thoroughly examine exempted lamps. We think

16 there's both legal error in DoE's decision, and

17 technical error. Technical error, we'll get into

18 the legal error probably in our written comments

19 or perhaps later today, if it comes up, but from a

20 technical perspective, there are several lamp

21 types out there that sell for an incremental cost

22 without delivering incremental energy savings.
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1 And although those lamp types meet a

2 particular market niche and a particular need,

3 which is why they're exempted, but three-way

4 lamps, rough service lamps, high-output lamps,

5 these all play an important role in the market,

6 but they also don't deliver energy efficiency

7 savings like the EISA standards do.

8 So there's a potential risk there both

9 for a loophole and, also, a potential opportunity

10 to improve efficiency with those lamps that we

11 think DoE should be evaluating in the rulemaking.

12 Indeed, we've determined in the framework that

13 based on current sales, that their sales have not

14 increased, therefore, they won't be considered. So

15 we think that's a premature determination. DoE

16 should be evaluating these lamp types.

17 Product classes, DoE's approach to

18 product classes seems to be based on CFLs for some

19 reason. And we're interested in how DoE envisions

20 other lamp types would fit into that lamp product

21 class structure.

22 The framework document does not address
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1 modified spectrum lamps, which have a lower

2 standard than conventional lamps, so we're curious

3 how DoE intends to include these lamps as part of

4 the stock and what DoE's plans are for modified

5 spectrum lamps. We didn't see that addressed in

6 the framework.

7 The backstop, in the framework DoE has

8 not described how it will analyze the backstop.

9 We'd like to hear more about that today. And

10 we're sure that since the backstop is an important

11 element to this rulemaking, how are you going to

12 analyze that, since the standard has to deliver at

13 least saving equal to the backstop.

14 We're concerned and have questions about

15 DoE's approach for product price determination,

16 what we think is similar to other dockets, but in

17 this docket there may be some lamp types that are

18 not on the market today, such as improved lamps

19 for which that methodology might not work. So

20 we're curious as to how DoE will address product

21 price determination for technologies that aren't

22 currently available in the marketplace.
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1 And the last point I want to make, to

2 make sure it gets on the agenda for today, is the

3 standard for compact fluorescent lamps. We

4 believe the DoE intends to treat this as the six5 year review for the EPACT compact fluorescent lamp

6 standards. And that provision in EPACT 2005

7 authorizes DoE to consider revision to existing

8 quality components of the standard, such as the

9 rapid cycle test and also authorized DoE to

10 consider new quality elements, such as power

11 factor. So our question is, does DoE intend to

12 evaluate these other elements of the CFL standard

13 and, if so, why? And if so, how? And if not, why

14 is that not a part of the discussion?

15 So we hope we can discuss each of these

16 issues and others, I'm sure, that will come up

17 today as well, to start off. Thank you.

18 MR. BROOKMAN: Okay, thank you, Andrew.

19 Other comments here at the outset?

20 MR. BROOKMAN: Noah?

21 MR. HOROWITZ: Noah Horowitz, with NRDC.

22 I concur with my colleague Andrew deLaski that the
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1 Phase 1 transition has gone very well. And I want

2 to point out that there is some lag time- -January

3 1, the 60s and 40s just went into effect. That's

4 roughly half of the market, so we haven't seen

5 what impact that will have on the market.

6 So, given that, we still can buy most

7 likely legal bulbs that are 75 watt equivalents

8 and some even 100s because there's been some

9 warehousing. There might be even additional

10 stockpiling by manufacturers or retailers, so the

11 60 watts will stay on the shelf for many months to

12 come and we need to be aware of that. And as such,

13 we need to be careful not to prematurely or

14 incorrectly lock down a baseline because we

15 haven't really seen the full impact of the Phase 1

16 part of the standards.

17 And we also need to be careful not to

18 make assumptions about the specialty or accepted

19 bulbs, again, because you can still buy the 60

20 watt inexpensive incandescent bulb, so there is

21 less motivation for manufacturers and/or consumers

22 to move to some of these other niche bulbs that
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1 currently have low sales, but that could escalate.

2 Thank you.

3 MR. BROOKMAN: Thank you. Additional

4 comments before we launch into the content? Okay,

5 I see--yes, Terry?

6 MR. McGOWAN: Yeah, Terry McGowan, with

7 the American Lighting Association. I'd like to

8 call attention to the fact that our friends up in

9 Canada have moved very strongly to harmonize these

10 standards with theirs and they are, this year,

11 going to handle the whole thing. On behalf of our

12 Canadian members, we would like to thank them for

13 doing that, which was no small feat, and so that

14 we avoid cross-border problems, which can be very

15 important to manufacturers as well as retailers.

16 So I just call attention to that. We're not alone

17 in this and that we have implications in another

18 country and this industry crosses those borders

19 very freely, thankfully, but we welcome that

20 cooperation.

21 MR. BROOKMAN: Thank you, that's a nice

22 note as well. Okay, final comments here? Then
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1 back to Lucy.

2 MS. DEBUTTS: Okay. All right, so now

3 we're going into the overview and we'll start with

4 the regulatory history here. As already

5 mentioned, the amendments to EPCA that were

6 initiated by EISA directed DoE to conduct two

7 cycles of the rulemaking to evaluate GSLs was the

8 framework that was published on December the 9th.

9 DoE actually initiated the first cycle of review

10 and we are directed to publish the final rule for

11 this rulemaking by January 1st of 2017.

12 This also directs DoE to have a

13 compliance date of at least three years later, if

14 standards are to be established. So we are

15 evaluating existing exemptions for certain

16 incandescent lamps. We're not limited in scope to

17 incandescent lamp technologies. And also

18 considering a phase-in compliance date based on

19 the impact of amendment standards on

20 manufacturers.

21 Finally, as was stated earlier, DoE is

22 directed to consider a minimum standard of 45
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1 lumens per watt and if we do not issue that

2 standard, EISA requires that if the final rule

3 does not provide savings greater than or equal to

4 the savings of a 45 lumens per watt standard. GSLs

5 that do not need 45 lumens per watt standard

6 cannot be sold, beginning January 1st of 2020. So,

7 with this rule, we are satisfying the requirements

8 to review existing standards for medium-based

9 compact fluorescent lamps as well.

10 This slide talks about the rulemaking

11 schedule as we're proposing it right now. So if

12 you look at it as we've stated, we published the

13 framework document on December 9th of 2013. That

14 implies that we're going to collect the comments

15 and review all of your comments, then do the

16 analyses, and we're hoping to publish the pre17 analysis with technical support documents by

18 November of 2014. After that, of course, there's

19 going to be another time to submit comments for

20 the manufacturers and the rest of the

21 stakeholders.

22 We will review those, an offer is
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1 proposed to come up in December of 2015, with the

2 final rule in December of 2016. And again, as I

3 said, three-year compliance date, so that means

4 the compliance date is projected to be in December

5 of 2019.

6 When DoE is evaluating any standards, as

7 we are all well aware, we need to consider several

8 factors that EPCA directed and these are listed on

9 this slide. I'm not going to go through them, but

10 we will consider each and every one in order to

11 establish a standard.

12 So that, actually, concludes the

13 overview of the rulemaking and the history. So

14 now it's to the scope and now, Maureen, you will

15 be presenting them.

16 MR. BROOKMAN: Yes, please, Mike?

17 MR. McGARAGHAN: Mike McGaraghan from

18 the California IOUs. This might be the best time

19 to reiterate one of the questions that Andrew

20 brought up, and that is, this rulemaking is

21 charged with delivering the equivalent savings to

22 the backstop, so the question is, does DoE intend
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1 to do an analysis to establish what that savings

2 would be, what that baseline is? And if so, is

3 that going to be part of this rulemaking or is

4 somebody working on that concurrently? Is that

5 something that somebody can speak to today?

6 MR. GERKE: This is Brian Gerke from

7 LBNL. I suspect that that analysis will be part

8 of this rulemaking process. We'd consider that as

9 one of the possibilities, although we are still in

10 the framework stage, so no decisions have been

11 made on that.

12 MR. BROOKMAN: Alex.

13 MR. BOESENBERG: Alex Boesenberg, NEMA.

14 Since it's been brought up, I am curious, I would

15 ask the Department to confirm my interpretation of

16 the last point on Slide 9, Item 2, 'Consider a

17 minimum standard of 45 lumens per watt.? It's our

18 understanding, as the people who helped to craft

19 that legislative language, that it was a fleet

20 average. That is, all the product covered in

21 scope when you add their efficiencies together

22 across the market share, 45 lumens per watt or
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1 better, is that the same interpretation that the

2 Department has or is it a minimum 45 for any

3 product as an individual entity? We don't think

4 that's it, but I want to just make sure everyone's

5 on the same page?

6 MS. McDONALD: This is Ali McDonald.

7 Just to clarify, you mean when you look at the

8 products that are available after the standard, on

9 average, their efficiency is 45 lumens per watt?

10 MR. BOESENBERG: Well, there's two ways

11 to interpret your question.

12 MS. McDONALD: I'm trying to understand

13 what your point of view was.

14 MR. BOESENBERG: You guys jump in if I

15 get this wrong. Our understanding of the minimum

16 standard in relation to the backstop is that it

17 means that for the scope of products, after the

18 rule takes effect, with the anticipated market

19 share, et cetera, that the average across all of

20 that is 45, and not each individual product, 45 or

21 better.

22 MR. BROOKMAN: Keith, follow on?
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1 MR. COOK: Yeah, I think what Alex is

2 asking is, if you took the total wattage of all

3 lamps sold and divide it by the total number; you

4 end up with a fleet average. Is that the 45? Or

5 is it an average of 45 for CFLs and an average of

6 45 for LEDs and an average of 45 for halogen

7 incandescent, et cetera? That's what he's asking.

8 MR. BROOKMAN: Celia?

9 MS. SHER: Yeah, excuse me, I think that

10 it would be useful to submit those comments in

11 writing and then we can provide some clarity on

12 those provisions and, you know, hopefully, answer

13 that question to your satisfaction in the next

14 rulemaking document.

15 MR. HOWLEY: This is Joe Howley. As

16 someone who is involved with that original

17 language, I can share with everyone that our

18 intent at the time was to achieve an average 45

19 lumens per watt. In other words, theoretically,

20 if every lamp that went into a medium-based socket

21 was at 45 lumens per watt, there'd be a certain

22 energy use to that and that would be fairly easy
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1 to calculate: 45 lumens per watt times the number

2 of available sockets.

3 So this standard was supposed to achieve

4 a savings as if every lamp in every socket was at

5 45 lumens per watt, which would be considerable

6 given back when we were negotiating this,

7 incandescent probably averaged about 15 lumens per

8 watt, which was the dominant source. So the

9 concept was to get that average up to 45 lumens

10 per watt or get a standard that had the equivalent

11 of that type of energy use or savings, depending

12 on how you're looking at this.

13 MR. BROOKMAN: Joe? Joe, you were

14 involved in those negotiations on that language?

15 MR. HOWLEY: Yes.

16 MR. BROOKMAN: Thank you. Noah.

17 MR. HOROWITZ: Noah Horowitz, NRDC. My

18 group and other advocates were also involved in

19 the negotiation. There was no consensus. It was

20 done through legislation--

21 MR. BROOKMAN: Yeah.

22 MR. HOROWITZ: --so I think it's
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1 incorrect to suggest that there was unanimous

2 positions on, is it 45 lumens per watt--a hard

3 number for every bulb--and/or a weighted average?

4 We believe there are two different

5 things going on here. The requirement that the

6 agency consider a minimum standard of 45 lumens

7 per watt, we interpret that as what if every bulb

8 that could be sold after the standard achieve 45

9 lumens per watt or better?. So we agree with the

10 way it's written there and that's a slightly

11 different interpretation than the industry is

12 taking.

13 A second thing that we might be

14 confounding together is the requirement that this

15 standard save as much energy, on average, as what

16 a 45 lumen per watt standard would deliver. And

17 that's where I think the ability to have some sort

18 of weighting could occur. But these are different

19 things and we don't agree that one should rule out

20 the option for a hard 45 lumen per watt that every

21 bulb must achieve.

22 MR. BROOKMAN: Okay, thank you. Joe.
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1 MR. HOWLEY: Just a counter to that is

2 that the position that every lamp would have a 45

3 lumens per watt ended up being the backstop. So

4 there would be no reason to do an analysis that

5 said the fleet average would be 45 lumens per watt

6 if indeed--the backstop, if there is no

7 rulemaking, would be 45 lumens per watt. What

8 would be the point of doing the analysis if

9 everything was at 45?

10 The reason that was put in there and the

11 only reason industry agreed to it, from our point

12 of view, was that we did not want a hard 45 lumens

13 per watt standard. That's why, basically, saying

14 to us that we better come to the table and

15 participate in a rulemaking process during this

16 time or the alternative would simply be a flat 45

17 lumens per watt across all products.

18 To avoid that, we said we will agree to

19 a rulemaking process and actively engaged in it

20 and get savings equivalent to--as if there would

21 be a 45 lumens per watt standard across all types.

22 The only interpretation that makes sense was that
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1 that analysis was designed to be a fleet average.

2 That is industry's view on this.

3 MR. BROOKMAN: Okay, thank you.

4 MR. DELASKI: So, I'm misunderstanding,

5 Joe--

6 MR. BROOKMAN: Andrew, closer, please.

7 MR. DELASKI: So, Joe, I'm not sure if

8 you guys are agreeing or disagreeing? So, the

9 backstop says--the language isn't up there, I was

10 just looking for it and I didn't find it, but I

11 think you're agreeing that the backstop says

12 savings equivalent to 45--

13 MR. HOWLEY: No, the backstop is a hard

14 45 lumens per watt number across all types. That's

15 what the backstop is. That's the alternative to

16 no rulemaking. The rulemaking is supposed to

17 produce savings equivalent to a--

18 MR. DELASKI: Yeah, and one of the ways19 -and there are many ways one could get there,

20 right?

21 MR. HOWLEY: Right.

22 MR. DELASKI: And one of them would be
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1 the backstop, right? And it would be right for

2 DoE to evaluate that, just so we know what it

3 means, right? I mean, that was probably my

4 question at the outset is that we want to know

5 what the impact of the backstop is, right? So I

6 think it makes sense for DoE to evaluate that as

7 an option because it is, indeed, one of the

8 options, right?

9 It may not be the best option, but it's

10 one of the options because Congress put it in the

11 statute.

12 MR. HOWLEY: Right, but it was put there

13 to assure a rulemaking process and not just a

14 blind 45 lumens per watt standard with no thought

15 to it whatsoever.

16 MR. DELASKI: And I guess what I would

17 suggest is that DoE also has to--it's like a

18 statutory requirement to evaluate Max Tech, so Max

19 Tech is going to be above 45 lumens per watt.

20 MR. HOWLEY: But it doesn't prevent

21 that, of course.

22 MR. DELASKI: Right.
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1 MR. HOWLEY: It's just a minimum of 45--

2 MR. DELASKI: You're going have a spread

3 of options, like in every rulemaking, from the

4 baseline up to Max Tech. And since Max Tech is

5 above 45 LPW, I think we would all agree then, you

6 know, it seems to me it makes sense that you're

7 going to have to fill that space and 45 LPW is

8 certainly part of that space between that, it

9 seems to me, you want to fill.

10 MR. BROOKMAN: So I hope that exchange

11 was clear on the record. There's a lot of back

12 and forth between Andrew and Joe and we'll just

13 deal with the ambiguity, I guess.

14 Okay, so additional comments here? I'm

15 wanting to return to the content here, the

16 presentation content.

17 (No response.)

18 MR. BROOKMAN: Okay, we're going to

19 return.

20 MS. KIENLE: Good morning. My name is

21 Maureen Kienle and I'm with Navigant. We will now

22 be discussing the scope of coverage for this
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1 rulemaking.

2 General service lamp includes several

3 lamp types, by definition, including general

4 service incandescent lamps, or GSILs; compact

5 fluorescent lamps, or CFLs; general service light6 emitting diode, or LED lamps; organic light7 emitting diode, or OLED lamps; or any other lamps

8 that the Secretary determines are used to satisfy

9 lighting applications traditionally served by

10 general service incandescent lamps.

11 The definition also specifies lamp types

12 that are not covered, including any lighting

13 application or bulb shape that's exempt from the

14 general service incandescent lamp definition or

15 any general service fluorescent lamp or

16 incandescent reflector lamp.

17 As discussed, general service

18 incandescent lamps are included in the definition

19 of GSL. GSILs are standard incandescent or

20 halogen-type lamps that are used in general

21 service applications, have a medium screw base, a

22 lumen output within a specific range, and operate
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1 at a common voltage.

2 Several incandescent lamps are also

3 excluded from the definition, including lamp types

4 as reflector, rough service, colored, three-way

5 incandescent lamps and lamps of certain shapes and

6 wattages.

7 As mentioned previously, the EISA

8 amendments direct DoE to determine whether

9 exemptions for certain incandescent lamps should

10 be maintained or discontinued based in part on

11 exempted lamp sales. In March 2013, DoE reviewed

12 the 2012 sales of the five exempt lamp types. DoE

13 published a notice of data availability,

14 concluding that the five exempt lamp types have

15 not experienced significant growth since their

16 exemption from standards. Because this assessment

17 indicated no further action was necessary, DoE is

18 not planning on including these lamps in the GSL

19 rulemaking.

20 Additionally, the Consolidated

21 Appropriations Act restricts the use of

22 appropriated funds in connection with several
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1 aspects of DoE's incandescent lamps program,

2 specifically Section 315 curtails any further

3 activity to implement or enforce standards for

4 GSILs, therefore, DoE will not be including GSILs

5 in the general service lamp rulemaking at this

6 time.

7 Compact fluorescent lamps are also

8 included in the definition of GSL. However,

9 because this term is not currently defined, DoE

10 will propose a definition for compact fluorescent

11 lamps. CFLs can be self-ballasted, for example,

12 medium screw-base CFLs, or externally ballasted,

13 such as pin-base CFLs. DoE's existing standards

14 apply only to self-ballasted medium-based compact

15 fluorescent lamps. Pin-base CFLs are not

16 currently subject to standards.

17 All medium-base CFLs that meet the

18 definition of medium-base compact fluorescent lamp

19 are proposed to be included in the scope of this

20 rulemaking. However, certain lamps are exempted

21 from the definition of medium-base CFL, including

22 medium-base CFLs designed for a special
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1 applications, medium-base CFLs unlikely to be used

2 in general purpose applications. The definition

3 of medium-base CFL specifically references the

4 GSIL definition for a list of several lamp types

5 that are not considered for use in general service

6 applications.

7 Thus, DoE is interpreting the same

8 exemptions to also apply to medium-base CFLs. The

9 term pin-based is currently defined, however,

10 there is not a definition for a pin-base CFL

11 unless a definition will also be proposed. For

12 this rulemaking, DoE is considering including all

13 pin-base CFLs that serve general lighting

14 applications, are not GSFLs, and are not the lamps

15 excluded from the GSIL definition.

16 In Issue 2, DoE welcomes comment on

17 definitions for compact fluorescent lamp and pin18 based compact fluorescent lamp.

19 MR. BROOKMAN: Definitions? Noah.

20 MR. HOROWITZ: If it's appropriate,

21 there was an Item 1 in the document that spoke to

22 scope. If I could talk about the exempted bulbs
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1 very quickly? Thank you.

2 As my colleague Andrew deLaski stated,

3 and I did as well, we think it's premature that

4 there will be no growth of the exempted bulbs and

5 we disagree with DoE's position to not include

6 them in the rulemaking. And, again, the 60 watt

7 bulb is still available. Once it is no longer

8 available, then one could easily imagine sales of

9 the other bulbs could really take off. And I have

10 an example for you.

11 This is a product I bought at Walgreen's

12 in San Francisco. When we had the original

13 rulemaking vibration service required additional

14 filaments. The expectation was that bulb will

15 cost a lot of money, it's going to be a niche

16 product. Even before the standard went into

17 effect--this is for a dozen bulbs--vibration

18 service lamps, 12 for $3.00. That's a quarter a

19 bulb. So this will be the lowest-cost bulb that

20 looks and is marketed exactly as the old 60 watt

21 bulb. And even worse, due to the additional

22 supports, this bulb is less efficient than the old
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1 60 watt bulb, so we'd be going backwards as if

2 we'd never even had Tier 1.

3 MR. BROOKMAN: I'm confused. Is that an

4 incandescent bulb?

5 MR. HOROWITZ: Yes, it is.

6 MR. BROOKMAN: Okay.

7 MR. HOROWITZ: With the only difference

8 being it has some additional support so it could

9 withstand vibrations. This lamp only gives off

10 600 lumens, where the incumbent bulb gives off

11 roughly 800. So this is exactly why we need to be

12 very careful not to prematurely rule out these

13 sort of products. Thank you, and I'll be sending

14 images of this in our written comment.

15 MR. BROOKMAN: Okay, thank you. Joe.

16 MR. HOWLEY: Noah, I'll just make a

17 mention that there is a requirement now that

18 restricts the packaging sale size to, I believe,

19 two lamps per package. Perhaps it's--I don't know

20 if it's really clear when that went into effect

21 and I think there's different interpretations.

22 However, clearly it's into effect starting in
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1 2014, regardless of previous interpretations. So

2 I think that pack size would be restricted to two

3 lamps going forward.

4 MR. BROOKMAN: Noah.

5 MR. HOROWITZ: The only point here is,

6 this product is being sold for a quarter a bulb,

7 so even though the pack size might differ, there

8 was clearly profit being made. So even if it's 35

9 cents a bulb in a two-pack, this would be by far

10 and away the lowest cost option on the market.

11 MR. BROOKMAN: Okay, thank you.

12 Additional comments here' Yes, Mike?

13 MR. McGARAGHAN: Mike McGaraghan from

14 California IOUs. I just want to reiterate what

15 Noah said and state that from our perspective

16 we've seen a huge amount of shelf space start to

17 open up for all of these exempted lamp types, so

18 we really encourage DoE to consider standards for

19 these. And the conclusion that DoE came to that

20 there was not a sufficient sales spike as of the

21 last time DoE looked at this, that should not be

22 the only trigger. DoE should consider whether
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1 these are appropriate standards, as I said, or

2 appropriate products to set standards for. And

3 for all the reasons that Noah stated, we believe

4 they are.

5 We've started to see a lot of products

6 just over 2600 lumens available for sale right

7 next to the EISA compliant lamps and the shatter

8 resistant, the three-way lamps, they're all

9 marketed right next to the other lamps. So,

10 particularly, as EISA Phase 1 really kicks in, the

11 pressure on that market is going to increase and

12 we're going to start to see more and more of those

13 lamps.

14 And it's just an anecdote, but in my

15 hotel room last night the table lamps had

16 vibration service incandescent lamps in them. So

17 they're starting to pick up.

18 MR. DELASKI: It's when you bump table,

19 Mike.

20 MR. BROOKMAN: Alex.

21 MR. BOESENBERG: Alex Boesenberg, NEMA.

22 NEMA will continue to honor our responsibility to
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1 the federal government, tracking and reporting on

2 the sales figures of those lamps and if sales

3 change then, obviously, how much it has changed

4 and that trend will be of interest to everyone.

5 MR. BROOKMAN: Alex, does--

6 MS. DEBUTTS: Lucy deButts--sorry.

7 MR. BROOKMAN: Go ahead, Lucy.

8 MS. DEBUTTS: Lucy deButts, DoE. As I

9 said, as was mentioned earlier, DoE tracks those

10 results; NEMA helps us with that. And it's

11 another cycle that is going to be due in March, so

12 we will definitely take that into consideration.

13 MR. BROOKMAN: Alex, does NEMA have any

14 idea about inventories? Do you know how much is

15 on the shelves everywhere?

16 MR. BOESENBERG: This is Alex

17 Boesenberg. Typically, we're not able to answer

18 that question because my manufacturers tend to

19 sell to distributors and then, after that, we're

20 not sure where it goes. I mean, I have that

21 question in so many different flavors--

22 MR. BROOKMAN: Yeah.
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1 MR. BOESENBERG: --so I can tell you the

2 answer is we don't know. Just like I can't tell

3 you how many were sold in Massachusetts or in

4 Vermont or in any other state with mercury

5 concerns and things like that.

6 MR. BROOKMAN: Okay.

7 MR. BOESENBERG: Just a--no, they're not

8 selling them anymore.

9 MR. BROOKMAN: Andrew, please get the

10 microphone close.

11 MR. DELASKI: Andrew deLaski, Appliance

12 Standards Awareness Project. Alex, is the NEMA

13 data--or do all NEMA manufacturers participate and

14 give you answers or respond to your surveys for

15 the lighting products? I'm trying to get a grasp

16 on how complete the NEMA data is that you submit

17 to the Department, so I guess there's two parts to

18 my question. I'll ask them both and you can

19 figure out what you can answer.

20 Do all NEMA manufacturers participate

21 and then do any non-NEMA manufacturers participate

22 in the NEMA data submittals?
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1 MR. BOESENBERG: This is Alex

2 Boesenberg. I need to defer to one of my members

3 who participates in that survey because I don't

4 manage it. Joe is the chair of our lamp section

5 and probably knows the answer better than me.

6 MR. HOWLEY: Yes, the immediate past

7 chair of lamp section.

8 (Laughter.)

9 MR. BROOKMAN: Thank heavens, right?

10 MR. HOWLEY: All NEMA manufacturers do

11 participate in that survey. I do not believe that

12 non-NEMA manufacturers are participating in that

13 survey. I would have to double check with the

14 NEMA statistical department, but I believe that to

15 be the answer right now.

16 MR. BROOKMAN: Hey, Joe, could you

17 speculate NEMA manufacturers represent what

18 portion of the market?

19 MR. HOWLEY: Well, certainly the

20 majority. The exact percentage is difficult to

21 provide.

22 MR. BROOKMAN: Okay, thank you. Noah.
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1 MR. HOROWITZ: Yeah, what I--

2 MR. BROOKMAN: Pardon me, back to

3 Andrew.

4 MR. DELASKI: Andrew deLaski, Appliance

5 Standards Awareness Project. The concern is not

6 so much with NEMA manufacturers because we have

7 the data for that, but the concern is the low8 cost products being sold at the dollar store from

9 off-market brands that few of us have heard of

10 before. You know, it's the way that portion of

11 the market where we think there's the greatest

12 risk where you will see the exploitation of

13 potential loopholes.

14 You know, I don't think you're going to

15 see it, at least initially, at sort of the brand

16 name retailers. It tends to happen more on the

17 corners of the market and then the potential is

18 there for expansion where you see this kind of

19 exploitation of loopholes. And once one

20 manufacturer does it and starts getting a cost

21 advantage and getting market share, that creates a

22 lot of pressure for others to follow suit, so this
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1 is the kind of thing that we have to be paying

2 attention to.

3 In addition, I want to just expand on

4 the point that standards for these products may

5 make sense on their own right. You know, lighting

6 is a huge portion, as I said at the outset, of

7 residential energy consumption. I would venture a

8 guess that standards for some of these classes,

9 some of these categories of exempted lamps, would

10 generate potentially savings on the order of other

11 dockets DoE pursues. So they make sense not just

12 from the send of loophole prevention, but because

13 of potentially--on their own merits, even if you

14 weren't concerned about the loophole, but because

15 a lot are sold and they're a significant portion

16 of residential energy consumption.

17 MR. BROOKMAN: Okay, Noah?

18 MR. HOROWITZ: Noah Horowitz, NRDC. A

19 quick point on collection of sales data.

20 Hopefully, as the docket proceeds, we'd like some

21 clarity if the NEMA survey includes sales of

22 private label bulbs. If you go to Home Depot or
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1 Wal-Mart a lot of the bulbs being sold there are

2 not Philips or GE, but it might be bulbs made by

3 those manufacturers, marketed, for example, under

4 Home Depot or a private label at Wal-Mart, so

5 we're hoping that that data is included. If it's

6 not, let's find a way to get that because that's a

7 significant part of the market share.

8 And the second part is, there are many

9 new manufacturers who were previously very small

10 and their sales are increasing, companies like

11 Cree that make LEDs. If they're not part of the

12 NEMA dataset, we need to find a way to include

13 them.

14 MR. BROOKMAN: Alex.

15 MR. BOESENBERG: Alex Boesenberg, NEMA.

16 If my manufacturers make it, regardless of who's

17 name is on it, it's in the survey. And Cree is a

18 NEMA member.

19 MR. BROOKMAN: Thank you. Yes, I didn't

20 get your name, please?

21 MR. NACHTRIEB: Good morning, Robert

22 Nachtrieb from Lutron Electronics. I'm lucky to
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1 be sitting next to Noah, so I can see the

2 packaging of the example that he provided us from

3 Feit and Feit is also a NEMA manufacturer. Thank

4 you.

5 MR. BROOKMAN: Yeah, thank you. Yes,

6 Mike?

7 MR. McGARAGHAN: Mike McGaraghan,

8 California IOUs. Before referenced the EISA Phase

9 1 standards and their impact on exempted lamps,

10 and it probably goes without saying, but obviously

11 this rulemaking that we're talking about now is

12 going to take effect in 2020 and in that time

13 we're going to see a completely different scenario

14 out there and we're talking about EISA Phase 2.

15 And whether it's through this rulemaking

16 or through the backstop, there is going to be

17 twice as much pressure on all of these exempted

18 lamp types, or all of the covered lamp types, by

19 2020. So our comment would just be that the DoE

20 should model what the impacts are, what the future

21 lamp market is going to look like in this 45

22 lumens per watt or equivalent world and consider
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1 what is likely to happen to sales of all of these

2 exempted lamp types, not just looking

3 retrospectively at lamp sales patterns.

4 MR. BROOKMAN: Joe Howley.

5 MR. HOWLEY: Just a note that we are

6 required to continue to monitor five exempted lamp

7 types that are probably the most likely to be used

8 as potential alternatives. And I would just note

9 that if in this monitoring, if one of those types

10 crosses the threshold, that probably might be the

11 appropriate time for DoE to consider it, but it

12 would be after it crossed that threshold. But

13 we'll know that data within this rulemaking

14 process. Certainly there will be two or three

15 more surveys within the rulemaking process. So

16 it's probably the appropriate time to look at if

17 any of these exempted types are presenting a

18 problem. I think it will become clear with these

19 surveys if it is an issue or not.

20 MS. DEBUTTS: Lucy deButts. As stated

21 before, we will consider the survey. DoE has the

22 authority to initiate a rulemaking if one of those
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1 exempted lamps go over the threshold, so we will

2 consider all comments and proceed with the

3 rulemaking accordingly.

4 MR. BROOKMAN: Andrew.

5 MR. DELASKI: So I wanted to bring it to

6 a different topic, if that's okay?

7 MR. BROOKMAN: Yeah, that sounds good.

8 And, in fact, typically we try and stay fairly

9 close to the--

10 MR. DELASKI: Well, I guess--

11 MR. BROOKMAN: Yes, go ahead, Andrew.

12 MR. DELASKI: --the slides before this

13 skidded through a few different issues and I don't

14 know whether it will come up later or whether--

15 REPORTER: Can you come closer to the

16 microphone?

17 MR. DELASKI: The slides before this

18 went through a few different issues that did not

19 get comment boxes and I don't know whether it is

20 appropriate now to ask questions now about those

21 slides--

22 MR. BROOKMAN: Let's do it now. Yeah,
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1 since we're on this divergent tangent here.

2 MR. DELASKI: And so, let me start with

3 CFLs since that's the slide up there.

4 MR. BROOKMAN: Yes.

5 MR. DELASKI: In my opening comment I

6 mentioned some questions about DoE's plans with

7 respect to the quality specifications for CFLs.

8 Will that come up later or is this an appropriate

9 time to talk about that?

10 MR. BROOKMAN: Let's talk about it now.

11 MR. DELASKI: So the question I asked

12 for the Department is, the Department has

13 described this as the review required under the

14 Look Back Provision that says that DoE must issue

15 a proposed rule or a determination of no revision

16 within six years of the last final rule for CFLs.

17 And the CFL standard is an unusual one because it

18 does include quality specifications, I think 3 or

19 4 and I'm forgetting precisely which they are, but

20 they are from--and they were copied from Energy

21 Star 2001 and they were enacted into law.

22 I think most CFLs on the market now are
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1 Energy Star. It's gone through a couple

2 iterations since then, so it would make sense, in

3 our view, to update the quality specifications to

4 reflect the current Energy Start specification

5 since this will go into effect several years from

6 now in terms of those quality parameters instead

7 of what's now clearly outdated.

8 So question 1 is, is the Department

9 looking at updating the quality specifications as

10 authorized by EPACT?

11 MS. McDONALD: This is Ali McDonald.

12 We're looking at whether there's quality--

13 REPORTER: Can you sit back? You're in

14 a dead zone with the wireless.

15 MS. McDONALD: We're looking at those

16 quality specifications that you mentioned and if

17 you have specific comments about updating them or

18 how they should be updated or, I think, earlier

19 you mentioned additional specifications, I think

20 in your--

21 MR. DELASKI: Yeah, so the statute has

22 two parts. You know, one part says you have these
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1 existing specifications and the DoE's authorized

2 to update the existing specifications for rapid

3 stress tests and a couple of different items. And

4 in addition, DoE is authorized to set new

5 specifications for additional parameters and those

6 parameters are spelled out, additional features,

7 and power factor is one of them.

8 So, the question is, is the DoE also

9 considering adding additional factors? And they

10 also are ones that are in Energy Star and have

11 been in Energy Star for a long time, so.

12 MS. McDONALD: It's something we're

13 considering, so we welcome any comments on it.

14 MR. BROOKMAN: I thought you had two

15 issues.

16 MR. DELASKI: Yeah, so the two issues

17 are updating existing quality specifications and

18 the second issue is adding new quality

19 specifications.

20 MR. BROOKMAN: Okay.

21 MR. DELASKI: If you consider power

22 factor as a quality specification?
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1 MR. BROOKMAN: Let me bring everyone

2 back to Slide 16. And I'm not sure we've had

3 adequate comment yet on Issue Box 2, the CFL

4 definitions. Alex?

5 MR. BOESENBERG: This is Alex Boesenberg

6 from NEMA. I'll comment to 2, 3, and 4. I'll say

7 that NEMA is developing our written comments, our

8 proposals, and/or recommendations for definitions

9 for the various types of lamps.

10 MR. BROOKMAN: Okay, thank you. Andrew.

11 MR. DELASKI: So then if we could step

12 back to the slide in which DoE mentions the rider?

13 I suspect this is the one time the rider's going

14 to come up in the presentation, is that right?

15 MS. SHER: Yeah, I can--this is Celia.

16 Sure, I can talk about that now.

17 MR. DELASKI: Okay.

18 MS. SHER: So we've interpreted this

19 rider to mean that DoE is precluded from engaging

20 in a rulemaking involving the covered lamps, which

21 include GSILs. This is obviously an important

22 issue to stakeholders, so we would encourage you
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1 to submit your comments and we'll take those into

2 consideration and do our best to respond to them.

3 MR. DELASKI: This is Andrew deLaski

4 with ASAP. I'm not going to ask this as a

5 question, I'll pick it as a statement. I don't

6 think the Department can evaluate standards for

7 general service lamps without evaluating

8 incandescent lamps. So, in other words, if you're

9 going to set standards, even if you're not going

10 to modify the standard as they relate to general

11 service incandescent lamps, if you're going to set

12 standards for other lamps that are general service

13 lamps, that's going to affect general service

14 incandescent lamps because they are substitutes

15 one for the other.

16 So, for example, when DoE does a

17 rulemaking for incandescent reflector lamps, which

18 is a whole separate docket, DoE evaluates the

19 market share of LED reflector lamps, which are not

20 related products. You have to look at LEDs

21 because it's a growing market share. You know,

22 you walk into any major lighting retailer right
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1 now and they're right there at eye level, right?

2 That's what they want to be selling because it's

3 an attractive new product that's got, I suspect, a

4 lot of appeal.

5 So DoE evaluates LED technology even

6 though it's not part of the rulemaking.

7 MS. SHER: Okay, so--

8 MR. DELASKI: So DoE, in this instance,

9 I think has to evaluate it, even if it isn't part

10 of the rulemaking.

11 MS. SHER: So this is Celia again. So

12 you're saying that you would like us--even though

13 you're not saying that you want us to make it part

14 of the standard, but even that we should include

15 it in our evaluation.

16 MR. DELASKI: I do think you should make

17 it part of the standard. Don't get me wrong.

18 MS. SHER: Right.

19 MR. DELASKI: But at the very least--

20 MS. SHER: Is it prohibited by the

21 right?

22
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1

2

3 MR. DELASKI: --from an analytical point

4 of view.

5 MS. SHER: Okay.

6 MR. DELASKI: You can't do a true and

7 accurate analysis on the question that you have to

8 answer statutorily.

9 MS. SHER: Okay.

10 MR. DELASKI: That Congress has said you

11 have to answer without, you know, considering the

12 entire marketplace, like you do in every docket.

13 DoE always looks at substitutes, whether they're

14 regulated or not, and that's true, I think, of

15 every single docket that I've seen. So not having

16 it subject to the standard doesn't mean you can't

17 evaluate it, although my going-in position is that

18 you should.

19 MS. SHER: Right.

20 MR. DELASKI: That you need to go and

21 look at the rider.

22 MS. SHER: Okay, this is Celia. That's
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1 a useful comment and we'll certainly take that

2 into consideration.

3 MR. BROOKMAN: Okay, Joe?

4 MR. HOWLEY: Just to add on to the

5 conversation, which, again, goes back to the

6 original concept that industry envisioned after

7 2020, certainly part of the market would be

8 products that were under 45 lumens per watt. And

9 so the analysis that if this new standard,

10 combined with what the existing market was for

11 products under 45 lumens per watt, averaged 45

12 lumens per watt, you could declare that the

13 rulemaking achieved its objective of hitting 45

14 lumens per watt, on average the savings equivalent

15 to a standard, as if every product had 45 lumens

16 per watt. So that analysis that Andrew is

17 suggesting, actually, makes some sense under that

18 context as well.

19 MR. BROOKMAN: Mike.

20 MR. McGARAGHAN: Sure. Mike McGaraghan.

21 I just wanted to add a perspective on the

22 equivalent savings. I don't think it's a trivial
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1 or easy number to calculate, multiplying sockets

2 by 45 lumens per watt. I think that's actually a

3 pretty challenging effort to model that scenario

4 because if you set a standard that was a flat 45

5 lumens per watt, you'd actually see a larger

6 market share for LEDs and CFLs as a result. So

7 you'd have to model that whole market.

8 So the comment earlier was that LBNL

9 suspects that DoE will do that during this

10 rulemaking. We think it's a really important part

11 of this rulemaking and part of the whole thing. So

12 whether it's DoE doing as in this docket or

13 separate, we'd like to track it and we encourage

14 you to make that a public process because it's

15 actually a fairly complicated question, I think.

16 Thanks.

17 MR. BROOKMAN: Thank you. Additional

18 comments on Issue Box Number 2 definitions before

19 we move on? Noah?

20 MR. HOROWITZ: I'm going to stay in the

21 present here, if I can, and address Issue 2. We

22 agree that both CFLs, whether they're screw- based
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1 or pin-based, should be included. And one of the

2 challenges we'll get to when we discuss pin-bases

3 in more detail is what do you connect that pin4 based lamp to? What is the ballast? Is there an

5 assumed ballast because it's really a system?

6 Thank you.

7 MR. BROOKMAN: Thank you. Other

8 comments on CFL definitions?

9 (No response.)

10 MR. BROOKMAN: Okay, we're going to move

11 on.

12 MS. KIENLE: Okay. General service LED

13 lamps are also included in the definition of GSL.

14 The term general service LED lamp is not currently

15 defined and thus DoE will also propose a

16 definition for this term in the rulemaking. DoE is

17 considering including all LED lamps that serve

18 general lighting applications and are not the

19 lamps excluded in the GSIL definition.

20 In Issue 3, DoE welcomes comment on a

21 definition for a general service LED lamp.

22 MR. BROOKMAN: And I would repeat for
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1 the record what Alex Boesenberg already said. NEMA

2 is developing their definitions for Issues 2, 3,

3 and 4.

4 Other additional comments on Issue 3,

5 LED definitions? Nothing additional here?

6 (No response.)

7 MR. BROOKMAN: Okay.

8 MS. KIENLE: Okay. OLED lamps are also

9 included in the definition of GSL. However, DoE

10 is considering excluding OLED lamps from this

11 rulemaking for two main reasons. First, OLEDs are

12 diffuse light sources that are made of thin layers

13 of carbon-based semiconductor material. This

14 layer-based construction supports the development

15 of large flat surfaces, rather than the typical

16 lamp shapes. Because of this they are not

17 generally used in general lighting applications.

18 Second, OLEDs are an emerging technology

19 with limited commercial availability. Therefore,

20 it's also unclear whether the efficacy of existing

21 OLED lamps can be improved.

22 In Issue 4, DoE welcomes comment on the
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1 commercial availability of OLED lamps that can

2 serve in general lighting applications and DoEs

3 consideration to exclude these lamps from the

4 rulemaking.

5 MR. BROOKMAN: Celia.

6 MS. SHER: This is Celia Sher. So, to

7 respond to the comments that we received earlier,

8 I think "exclusion" was not the appropriate word

9 to use here. We are considering not setting

10 standards for OLEDs, not excluding OLEDs. So,

11 under EPCA we can decline to set standards if we

12 find it is not economically justified. You can

13 certainly disagree with us and send us any

14 comments and data you have and we'll take that

15 into consideration.

16 MR. BROOKMAN: Thank you. Joe Howley.

17 MR. HOWLEY: NEMA generally agrees that

18 it is inappropriate to set OLED standards at this

19 time for this particular rulemaking.

20 MR. BROOKMAN: Do you want to say a

21 little more about that, Joe?

22 MR. HOWLEY: No, I think that's--
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1 MR. BROOKMAN: Okay, I just thought I'd

2 give you a chance. DoE welcomes comment on the

3 commercial availability of OLED lamps that can

4 serve as general lighting applications. Other

5 comments related to Issue Box 4? Noah?

6 MR. HOROWITZ: This is a question--and

7 pardon my ignorance if it's already there--is

8 there an existing definition by DoE and/or the

9 statute for OLEDs. If not, then we need to have a

10 clear one to distinguish between LEDs and OLEDs,

11 especially if no standard will be set for OLEDs.

12 MS. KIENLE: There is a definition for

13 OLED already.

14 MR. HOROWITZ: In the statute?

15 MS. KIENLE: Yes, in 10 CFR 430.2.

16 MR. HOROWITZ: Okay.

17 MR. BROOKMAN: Thank you.

18 MS. KIENLE: Not a definition for OLED

19 lamp, but an organic light-emitting diode.

20 MR. HOROWITZ: Right, so we might need

21 to extend that to an OLED lamp.

22 MS. KIENLE: Okay. I see.
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1 MR. BROOKMAN: Additional thoughts or

2 comments here?

3 (No response.)

4 MR. BROOKMAN: Okay.

5 MS. KIENLE: Pursuant to the definition

6 of GSL, DoE also has the authority to consider

7 additional lamps that satisfy the lighting

8 applications traditionally served by GSILs. The

9 definition of GSIL states that these lamps are

10 typically intended for general service

11 applications, have a medium screw-base, a lumen

12 output within a certain range, and operate at a

13 common voltage. DoE is, therefore, proposing that

14 any lamps that meet these 4 GSIL criteria are

15 included in the scope of this rulemaking,

16 regardless of the technology used to produce the

17 light.

18 DoE surveyed the market and found

19 additional lamp types that it believes are

20 intended to serve general lighting applications.

21 The first type is a hybrid lamp. Hybrid lamps use

22 one lighting technology as the primary application
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1 and another technology to provide supplemental

2 lighting. For example, DoE found CFLs with a

3 halogen capsule that provides instant illumination

4 during the CFL warm up period. After the CFL

5 warms up, the halogen capsule is turned off.

6 Another example is a CFL lamp that also

7 contains an LED mounted inside the CFL spiral to

8 provide night light functionality. The second

9 type, identified as a self-ballasted mercury vapor

10 lamp that's intended for general service

11 applications. DoE identified self-ballasted

12 mercury vapor lamps that meet the GSIL

13 specifications and are also marketed as GSIL

14 replacements.

15 In Issue 5, DoE welcomes comment on a

16 definition for a hybrid lamp. In Issue 6, DoE

17 welcomes comment on additional lamp types that

18 should be considered. And in Issue 7, DoE

19 welcomes comment on any lamps discussed that

20 should not be considered within the scope of this

21 rulemaking.

22 MR. BROOKMAN: Alex.
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1 MR. BOESENBERG: Alex Boesenberg, NEMA.

2 I will reiterate my previous comment that we are

3 developing comments for the definition of a hybrid

4 lamp and there are some suggestions that I am

5 reviewing with my members regarding additional

6 lamp types.

7 Issue 7, we will also comment on my

8 manufacturers? knowledge of the market for those

9 lamps listed. I would back up and question the

10 sensibility of thinking that people are going to

11 race out to buy mercury vapor lamps with all of

12 the excitement regarding the 2 milligrams of

13 mercury in a CFL. But we're seeing if we even

14 make them and can comment on their market share,

15 since there are some lamps excluded due to market

16 share. We're pretty sure mercury vapor is even

17 less, but we're actually having trouble finding

18 those numbers, they are so small.

19 MR. BROOKMAN: Thank you. Noah.

20 MR. HOROWITZ: Noah Horowitz, NRDC,

21 regards Issue Number 7, reiterating comments made

22 earlier. We think there may well be a lot of
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1 lamps that are sold that are just over 2600

2 lumens. We've seen some 2650 lumen lamps, for

3 example, that are marketed as 150 watt

4 incandescent, so we would hope that DoE could

5 consider extending the maximum lumen output range

6 beyond 2600, to cover those 150 and 200 watt

7 incandescents which could increase in sales, in

8 particular, as Tier 2 goes into effect.

9 Similarly, three-way lamps could be

10 another way and we'd like to see those included in

11 the scope. Thank you.

12 MR. BROOKMAN: Thank you. Final

13 comments on Issue 5, 6, and 7? Yes, Andrew

14 deLaski?

15 MR. DELASKI: I just want to concur

16 Noah's comment and I think make a general point

17 that it strikes me that in all likelihood we would

18 find that the sales of some of these lamps that

19 are "exempted" from the initial standards are

20 significantly larger than these additional

21 categories that are listed here. And these hybrid

22 products are mercury products, so I think, yeah,
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1 the DoE should be focused on where the opportunity

2 lies in terms of evaluating standards. And the

3 opportunity is likely going to lie in some other

4 directions than the ones enumerated here.

5 MR. BROOKMAN: Okay. Mike? No? Okay.

6 Yes, Joe.

7 MR. HOWLEY: Joe Howley. Just to not--

8 again that three-way and the higher lumen lamps,

9 the 150 watt lamps, are included in our annual

10 surveys. And, therefore, DoE has the ability to

11 evaluate those to see if indeed it's an exempted

12 lamp type of concern or not.

13 MR. BROOKMAN: Okay, we're moving on.

14 MS. KIENLE: Okay. EPCA sets forth to

15 an early applicable criteria and procedures for

16 DoE's adoption and amendment for test procedures.

17 Manufacturers of covered products must use these

18 test procedures to certify compliance with

19 standards and to quantify the efficiency of their

20 products.

21 DoE is considering developing and

22 amending test procedures for products included in
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1 the definition of GSL. Test procedures for GSILs

2 and medium-base CFL are existing and the LED lamps

3 test procedure rulemaking is currently underway as

4 well.

5 Test procedures for pin-base CFLs and

6 the additional lamp types identified would need to

7 be developed. And, as discussed, DoE did not

8 identify any OLED lamps that fall within the scope

9 of this rulemaking and, therefore, a test

10 procedure is not necessary at this time.

11 In Issue 1, DoE welcomes comment on the

12 adoption of test procedures for additional lamp

13 types covered in this rulemaking.

14 MR. BROOKMAN: Alex Boesenberg.

15 MR. BOESENBERG: This is Alex with NEMA.

16 As always, we will provide more detail in our

17 written comments on this, but I wanted to, for the

18 record, state a couple of topics. One is just a

19 general comment. The more lamp types you add that

20 don't have a test procedure right now, the longer

21 it takes to accomplish the rulemaking, so a

22 concern for timing.
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1 And as Noah Horowitz already pointed out

2 and might elucidate further, given the topic right

3 now, pin-based CFLs, because they are externally

4 ballasted, can appear to have an efficiency

5 advantage over their self-ballasted peers because

6 the losses in the ballast are part of a standard

7 self-ballasted CFL efficiency calculation, whereas

8 the pin-based CFL is just a fluorescent tube

9 driven externally from something outside the pins.

10 And it would be important that both the test

11 procedure recognize how to best accommodate that.

12 We do not have a reference ballast at this time.

13 And furthermore, just on the subject of

14 pin-based CFLs, in general, my manufacturers

15 assure me that that technology has been maxed out

16 for its efficiency. Whether or not some savings

17 are possible or if you look at the average of the

18 fleet, there are some that perform better, so we

19 can identify those in this. It may end up being a

20 very minor increment. I understand that when the

21 DoE does it all nationally sometimes minor is

22 significant, but we will be very interested in
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1 seeing what the technical support document reveals

2 regarding that.

3 It's a niche market. And it's really

4 not test procedures, but since I'm talking about

5 pin-based CFLs, we point out that they are not a

6 direct replacement for the 5 million incandescent

7 screw-based products, even though they are used in

8 some cases for general service lighting because to

9 retrofit my mother's table lamp with a pin-based

10 CFL, I have to trash it to put a pin-based socket

11 on it. Or may likely, the scenario is that you

12 have to buy new luminaries to take advantage of

13 pin-based products.

14 If there's a screw-based product already

15 out there that fits your existing fixture, well,

16 you are not going to buy a pin-based. So that

17 market is noticeable, but minor and its chance to

18 grow is only if people buy new fixtures.

19 Regarding the test procedures, one last

20 point. There are at least two rulemakings or I

21 would say pairs or, you know, related rulemakings

22 that the DoE is pursuing. One is in lighting, one
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1 is not. Where the rulemaking for test procedures

2 have been run concurrently with the standards rule

3 and we've been on record, we've gone ex parte

4 about both of those, and the concerns of how do I

5 comment on what I'm being judged on in the

6 standard when I don't know exactly yet what the

7 test procedure is? We will continue to voice

8 those concerns.

9 And I would illustrate, it's no one's

10 fault here in this room, but we are now commenting

11 this next month to the electric motors standard,

12 NOPR, for the Energy Conservation Standard. And

13 part of my comment is a detailed correction or

14 suggestions for improvement to the definitions of

15 the product classes that came out in the test

16 standard procedure that was only released a month

17 before the standards NOPR and the Department--I

18 understand why they try to do what they do and I'm

19 glad that they tried--they did their best, but now

20 I've got to use the standards rule to fix the test

21 procedure definitions. And if we'd just done the

22 test procedure first, we wouldn't know how to do
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1 that.

2 And, you know, we certainly don't want

3 to end up there in HID. So, choosing a list of

4 products for the advantage it provides in getting

5 the test procedures done quickly, there is a lot

6 of timing and complexity issues that that

7 provides. I'm not saying that's how you have to

8 do it, that's not necessarily our consensus

9 position yet regarding which types we suggest be

10 included. Just that the more you add, the more

11 temptation is to run them concurrently.

12 We've got some displayed challenges in

13 the other rules that have attempted that and we're

14 on record, we don't want it to be the habit. So I

15 am obliged to point that out again. Thank you.

16 MS. DEBUTTS: Lucy deButts. I will

17 respond--oh, sorry.

18 MR. BROOKMAN: Lucy, please.

19 MS. DEBUTTS: I just want to respond to

20 the last point about the test procedures running

21 concurrently or after the standards have been

22 issued. If John Cymbalsky was here he would have
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1 definitely told you that we've learned a lesson

2 and we're trying to make sure that the test

3 procedures are coming before the standard. That's

4 why when you look at the slide, we're trying to

5 issue the test procedures for those products prior

6 to the standards, so the industry will have the

7 ability to comment and look at a test procedure

8 before a standard gets into effect.

9 MR. BROOKMAN: Thank you, Lucy. Noah.

10 MR. HOROWITZ: Noah Horowitz, NRDC.

11 Comments on the test procedure in Issue 1. Two

12 points.

13 Hybrid lamps, we think those are

14 increasing in sale on the CFL side, in particular

15 products being marketed by GE. Those products are

16 brighter and use more power when the consumer

17 initially turns on the bulb, and then after a

18 certain amount of time--call it one or two

19 minutes, whatever that time is--it then goes down

20 to a lower light output level and consumes a lot

21 less power. So if hybrids are included, which we

22 think they should be, the question is how do you
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1 set up the test and when do you make the

2 measurement? Is it after 10 seconds or after 2

3 minutes? I don't know what the right answer is,

4 but I think it's longer rather than shorter, when

5 the lamp is at a steady state.

6 Secondly, in terms of sample size, the

7 performance requirements for CFLs that were cut

8 and pasted from Energy Star 2 way back when. Many

9 of the tests are based on a sample size of five.

10 Right now Energy Star and the test method that's

11 in there, assume 10 samples. So it would be good

12 if we can update the sample size to be consistent

13 with current testing methods, so we can use that

14 data for future enforcement. Thank you.

15 MR. BROOKMAN: Thank you. Additional

16 comments here?

17 (No response.)

18 MR. BROOKMAN: Okay.

19 MS. KIENLE: Okay? Next we will discuss

20 the market and technology assessment and the

21 screening analysis.

22 The purpose of the market and technology
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1 assessment is to determine product classes and to

2 identify technology options to improve lamp

3 efficacy. To do this DoE will characterize the

4 GSL market. For the screening analysis, DoE will

5 screen out technology options based on four

6 criteria.

7 DoE will look at technological

8 feasibility, that is whether the technology is

9 commercially available or in a working prototype;

10 practicability to manufacture, install, and

11 service, meaning it should be possible to achieve

12 mass production and reliable installation and

13 servicing of a technology in commercial products

14 on the scale necessary to serve the market, but it

15 does not have adverse impacts on utility to

16 consumers or availability and that it does not

17 have adverse impacts on health or safety.

18 In Issue 8, DoE welcomes information on

19 shipments, product future and efficiency trends,

20 distribution channels, and the estimates of market

21 shares for the lamps considered in this

22 rulemaking.
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1 MR. BROOKMAN: Alex Boesenberg.

2 MR. BOESENBERG: Alex Boesenberg with

3 NEMA. As always, I am working with the NEMA

4 business office and my members to provide as much

5 information as possible regarding market share and

6 trends. I recognize, of course, that we don't

7 represent 100 percent of the market, but we'll do

8 everything that we can. I'm always interested in

9 helping the DoE get as much data as soon as

10 possible.

11 And I think I'll put in my written

12 comments. I would have been better if I'd waited

13 until Item 8 to talk about the pin-based CFL

14 thing. The practicability to install, there's

15 where the pin-base runs into these 5 million

16 sockets we're trying to hit, if that's how many

17 there still is.

18 Pin-based are not a ready install, and

19 while that doesn't mean they should be excluded,

20 the fair way to perform the feasibility analysis

21 is if it's expected to retrofit a screw-based

22 socket, the cost of the new luminaire that accepts
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1 those pin-based products is reasonable to include.

2 And so we'll be interested in seeing what that

3 analysis shows regarding feasibility of financial,

4 et cetera.

5 MR. BROOKMAN: Noah.

6 MR. HOROWITZ: Noah Horowitz with NRDC.

7 At the risk of stating the obvious, the lighting

8 market is not static, with or without the

9 standards. We're seeing LED sales escalate

10 dramatically and their price is coming down, so we

11 hope that DoE doesn't take a static approach,

12 taking a snapshot of the market today and using

13 that modeling to assume that's where we're going

14 to be in 2020.

15 So, LED sales, I think there is a

16 consensus that sales will increase dramatically.

17 The question is, will they be taking sales away

18 from CFLs and/or from the current filament-based

19 products? Nobody knows the answer, so we hope you

20 explore a various range of options for

21 stakeholders to comment on. Thank you.

22 MR. BROOKMAN: Okay, Alex?
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1 MR. BOESENBERG: Alex Boesenberg, NEMA.

2 I would amplify what Mr. Horowitz said. One

3 realization we had in discussions was for some of

4 the incandescent or even CFL technologies-- you

5 know, we're still gathering data making sure LEDs

6 last as long as everybody says they do. Assuming

7 they do--and I believe they will, at least for the

8 reasonable estimations. The people guaranteeing

9 50 years, they hope they're around when that thing

10 fails and they can give you a new one, but

11 probably they won't be.

12 But for the trend we're seeing with the

13 longer lifetimes of LEDs and the ever-increasing

14 popularity and reduction in price for the types

15 that, you know, the first timers will buy, one

16 interesting point is, if the other technologies at

17 play, particularly incandescent, are shorter

18 lived, when that socket then has to be filled

19 again, it's worth analyzing and estimating what

20 product is going to go in it.

21 The fact that incandescent will hold on

22 while people stay with what they know, I think
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1 over time that will reduce. And so, the next time

2 that bulb burns out, they'll put an LED in. That's

3 certainly, as I see it, working in my own personal

4 life. So if that's an interesting dynamic to try

5 to figure that algorithm out.

6 Once a socket is an incandescent doesn't

7 mean it stays that way. And even so, after the

8 first or second lifetime--which is pretty short- -

9 then a long-life, high-efficiency product goes in

10 there. So I don't know how we're going to capture

11 that, but we look forward to attempting that in

12 the TSD.

13 MR. HOWLEY: Just to follow on to that,

14 the alternative is--

15 MR. BROOKMAN: Joe Howley.

16 MR. HOWLEY: Yes, Joe Howley. Once an

17 LED bulb goes in, even LED bulbs going in today

18 most likely will still be there in 2020, and so

19 it's a cumulative building of LED products. As

20 they're going into sockets they're removing the

21 availability for that socket to get a halogen or a

22 CFL. Even if a CFL goes in today, now with the
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1 new Energy Star spec--I believe it's 10,000 hours2 - those will also most likely still be here by

3 2020. So as these technologies continue to be

4 bought and sold, they're reducing the market for

5 potential, say, halogen lamps or incandescent

6 lamps to be sold as well. So they have to be

7 analyzed sort of in a cumulative socket. LEDs are

8 a little different, and CFLs, because they're in

9 the sockets for so long once they're put in.

10 MR. BROOKMAN: Let's hear from Brian.

11 MR. GERKE: This is Brian Gerke from

12 LBNL. I'm going to suggest that we delay further

13 discussion of this topic until we're talking about

14 the shipments analysis, which is where that will

15 be considered.

16 MR. BROOKMAN: Okay. Robert.

17 MR. NACHTRIEB: I'll delay this topic

18 until we talk about shipments analysis. Thank

19 you.

20 (Laughter.)

21 MR. BROOKMAN: Okay. Final comments on

22 market assessment?
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1 (No response.)

2 MR. BROOKMAN: Okay.

3 MS. KIENLE: Okay. One of the main

4 results of the market and technology assessment is

5 the establishment of product classes, which are

6 fed into the engineering analysis. DoE divides

7 covered products into classes by the type of

8 energy used, capacity of the product, or any other

9 performance related features that require

10 different standard levels, such as features

11 affecting consumer utility. DoE then establishes

12 separate energy conservation standards for each

13 product class. DoE is considering establishing

14 separate product classes for GSLs based on three

15 factors.

16 The first is ballast location or if a

17 lamp is self-ballasted or externally ballasted.

18 The second factor being considered is cover or if

19 a lamp has a cover or if it's bare. And a cover

20 is typically an extra glass enclosure around the

21 light source, such as an A-line bulb shape that

22 you sometimes see that are used to cover a spiral
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1 CFL. The final factor under consideration at this

2 point is its immobility. Because these three

3 factors are thought to affect both efficacy and

4 utility, DoE is considering eight separate product

5 classes based on these divisions.

6 In Issue 9, DoE welcomes comment on the

7 product class divisions under consideration, in

8 particular DoE welcomes comment on the impact that

9 ballast location and dimmability have on the

10 efficacy of CFLs and LEDs. DoE also welcomes

11 comment on the utility offered by self- ballasted,

12 covered, and dimmable lamps.

13 In Issue 10, DoE welcomes comment on any

14 other class setting factors that should be

15 considered. And in Issue 11, DoE welcomes comment

16 on a definition for the term "covered" which is

17 applicable across all technologies.

18 MR. BROOKMAN: Mike.

19 MR. McGARAGHAN: Mike McGaraghan.

20 Reading through the product classes, it's hard to

21 understand where certain types of lamps would fit

22 into each class and I'm wondering if DoE can
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1 provide that information before we issue--before

2 we submit our comments?

3 Specifically, questions like if

4 incandescent lamps were being evaluated here,

5 would they be self-ballasted? They don't have a

6 ballast, would they be covered or bare? And then

7 the same question for LED lamps. Most LED lamps

8 have some sort of covering, but it's actually in

9 some cases there's a remote phosphor, so it's not

10 just a cover, it's actually part of the emitter.

11 So it's hard to comment on these product classes

12 without understanding where different types of

13 lamps would fit.

14 And then the last comment is on the term

15 "dimmable" and wondering if DoE is going to define

16 that a little better. Dimmability isn't just a

17 yes or no type of situation. It's sort of a scale

18 of how dimmable something might be. Is it down to

19 2 percent? Is it 20 percent? If there's a step

20 dimming, does that count? So specificity on what

21 dimmable means would help in this, too.

22 MS. KIENLE: Sure, yeah. They can
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1 comment just on the first part. We're looking at

2 the market right now and analyzing that. Kind of

3 what you've said is what we've seen as well. So

4 we've seen LED lamps that probably qualify as

5 having an external covering, but we'd welcome

6 comments on any suggestions on how you think the

7 products would align. And we'll, obviously, be

8 putting more information out there in the next

9 round on where they would fit in.

10 MR. BROOKMAN: Joe.

11 MR. HOWLEY: So, just initial

12 observations on the product classes is, especially

13 the externally ballasted, dimmable/non-dimmable,

14 did not make a lot of sense to us. The pin-based

15 lamps themselves that have no ballast are not

16 necessarily designed to be dimmed or not dimmed.

17 There are manufacturers that make dimmable

18 ballasts that will dim these lamps, but the lamps

19 themselves are not necessarily made to be dimmed

20 or not dimmed. So that particular classification

21 split for externally ballasted is probably not a

22 very good one.
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1 In addition, most of those are bare

2 lamps. The pin-based lamps would be bare lamps.

3 So there are certain categories--well, I don't how

4 you would define dimmable versus non- dimmable,

5 what you'd put where.

6 And then bare versus covered, the

7 majority of those would go into bare. So, again,

8 I'm not sure that those product classes make sense

9 for the externally ballasted. They do seem to

10 make a lot more sense for the self- ballasted CFL

11 or LED, but not so much for the externally

12 ballasted.

13 MR. BROOKMAN: Charlie Stephens.

14 MR. STEPHENS: I'm Charlie Stephens,

15 Northwest Energy Efficiency Alliance. This is

16 sort of a general comment and I'm not sure how

17 many questions DoE will be able to answer with

18 this, but sometime in the next six months there

19 will be a database, downloadable from our website,

20 that will have all of our metering data from

21 socket by socket for 2200 sockets, by room, by

22 fixture type, by lamp type. And we'll have hours
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1 of use by fixture type, by room, by lamp type, and

2 energy use, annual energy use. And we'll have

3 that statistically applied to the entire Northwest

4 based on 1400 houses that were surveyed for

5 fixture type, lamp type, lamp wattage, and all

6 those sorts of things.

7 So you'll be able to spread that over

8 the entire population and we'll have all the

9 demographics that go along with all of those

10 households, so you'll be able, hopefully, to parse

11 that out for where our demographics don't match

12 other places. But that will be downloadable from

13 the website, we think, in the next six months and

14 there will be a report that will come out here in

15 the next six months that will explain how all of

16 that was done and you can download that, too.

17 Anybody can.

18 MR. BROOKMAN: Thank you. Noah.

19 MR. HOROWITZ: A question for DoE and

20 their consultants. An LED bulb by itself doesn't

21 have a ballast. It is a driver. So are LEDs

22 self-ballasted? Externally ballasted? We think
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1 neither, in which case, how would you intend to

2 handle them?

3 MS. KIENLE: Just as a comment as well,

4 we noted in the framework document that we're

5 using "ballast" and "drivers" somewhat

6 interchangeably in this rule, but that's something

7 that we'll have to consider, that an LED generally

8 has the driver.

9 MR. BROOKMAN: Joe Howley.

10 MR. HOWLEY: Just on the other question

11 that you had about additional product classes, we

12 think there's other factors affecting lamp types

13 that would also affect efficiency, particularly in

14 the color area. And we'll comment more on, maybe,

15 classifications, more involving color than

16 involving whether they're externally ballasted or

17 have an external driver. As Noah points out, it's

18 more correct to say driver when you're referring

19 to LED technology. Thank you.

20 MR. BROOKMAN: Additional comments here?

21 Did we cover all three of these, 9, 10, and 11?

22 Did you have anything that you want to queue?
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1 MS. KIENLE: I think if we?'ll just

2 expect to see some, hopefully, some written

3 comments addressing any of the definitions, as

4 Alex mentioned before.

5 MR. BROOKMAN: Okay.

6 MR. DELASKI: This is Andrew deLaski

7 with ASAP. I think if I just make a general point

8 and close on this one. I think that as you think

9 about your product classes, you've got to design

10 them in a way that they're robust, that they can

11 accept new technologies as they come along, right?

12 I know the DoE has a method to give

13 guidance to manufacturers when questions come up.

14 Where does this thing fall into the structure may

15 come up a lot. Although, unfortunately, I guess

16 you guys can't get those questions answered these

17 days due to the rider. But it strikes me that one

18 of the things you want to do is, you know, to have

19 a product class structure where it's clear, as

20 clear as possible, you know, that it can

21 accommodate lots of different kind of products

22 that may not even be on the market today or
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1 included in DoE's scope today.

2 And that when you use a term like

3 "ballast," which has a particular meaning in the

4 industry and in the world, to mean something other

5 than ballast, that creates a lot of tension. You

6 know, when ballast means driver, you know, that's

7 not a particularly robust structure and creates

8 ambiguities that I would hope that you would look

9 to address as you go through the next phase of the

10 rulemaking.

11 MR. BROOKMAN: Lucy.

12 MS. DEBUTTS: As Maureen said, we

13 welcome all comments on that and any suggestions

14 you may have.

15 MR. BROOKMAN: Ken Rider, who is joining

16 us via the web, has raised his hand. He wishes to

17 speak. Ken, unmute your phone and join us.

18 MR. RIDER: Hi. Yes, as you mentioned,

19 this is Ken Rider from the California Energy

20 Commission. I have a question and it may lead to

21 a comment here. So in earlier slides you

22 mentioned that you're really focused in this
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1 rulemaking on medium screw-base lamps. And if I'm

2 incorrect on that, I think that if you do include

3 other base types, smaller base types, for example,

4 candelabras, maybe a type of product class that

5 you would want to differentiate because of space

6 constraints in certain products?

7 MR. BROOKMAN: Okay, thank you. So I

8 guess we're ready to move on then?

9 MR. McGARAGHAN: Doug.

10 MR. BROOKMAN: Oh, one more. Mike.

11 MR. McGARAGHAN: Can the DoE confirm

12 that you are--well, I guess that's not the right

13 way to put it. You're obviously not looking at

14 technology based standards or product classes at

15 this point. Is that something that you would

16 consider?

17 And one of the reasons I ask is--

18 MR. BROOKMAN: Can you give an example,

19 Mike?

20 MR. McGARAGHAN: For example, an LED

21 product class or a CFL product class.

22 MR. BROOKMAN: Okay. Yeah.
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1 MR. McGARAGHAN: CFLs already have

2 standards set for them and because of the

3 backsliding clause, DoE cannot end up with any

4 standard that's weaker for CFLs, so if there are

5 no technology distinctions in the product classes

6 that would suggest that the end result here for

7 all GSLs would have to be stronger than the

8 current medium-base CFL standards in EPCA. And

9 that may be DoE's intent, but I'm not sure that's

10 where you are aiming to go here, so I wanted to

11 flag that and see if DoE has a comment on it or if

12 anybody else in the room has a comment on that at

13 this time?

14 MR. BROOKMAN: Lucy?

15 MS. DEBUTTS: Maureen.

16 MR. BROOKMAN: No, Maureen?

17 MS. KIENLE: I would just say that,

18 right, so the way that the product classes are

19 structured right now, this is just, again, the

20 framework stage, so--or even before the

21 preliminary analysis here. They wouldn't be

22 technology specific, but we, of course, would have
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1 to consider existing standards that are in place

2 already. If you have any other comments, though,

3 and you want to provide a written comment, that

4 would be great, too.

5 Yes, we are aware.

6 MR. BROOKMAN: Okay, anything additional

7 here?

8 (No response.)

9 MR. BROOKMAN: Okay, we're moving on.

10 MS. KIENLE: Okay, so now we'll move on

11 to discussing the technology options that improve

12 efficacy of GSLs. Technology options are measures

13 that improve the energy efficiency of products.

14 This slide shows the options that DoE is planning

15 to examine currently.

16 The technology options listed here are

17 organized by lamp type as these are technology

18 specific. Also listed as a technology option is

19 the transition to higher efficiency technologies.

20 For GSILs this list includes technology options

21 that increase operating temperature and improve

22 the filament. For CFLs this list includes options
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1 such as higher efficiency phosphors and fill gases

2 as well as improved ballast for self-ballasted

3 CFLs. For LEDs this list includes options

4 centered around improvements to package efficacy,

5 increased thermal management, improved optics,

6 improved driver design and other options, such as

7 reducing the current density.

8 Technology options that pass the

9 screening criteria are considered design options

10 and will be considered as ways to improve the

11 efficacy of products in the engineering analysis.

12 They will also help DoE to determine the Max Tech

13 design.

14 In Issue 12, DoE welcomes comments on

15 the preliminary technology options identified and

16 whether there are additional technology options

17 that should be considered. In Issue 13, DoE

18 welcomes comments on the applicability of the four

19 screening criteria to the technology options

20 listed. And in Issue 14, DoE welcomes comments on

21 how the four screening criteria would apply to any

22 additional technology options that are considered.
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1 MR. BROOKMAN: Alex Boesenberg.

2 MR. BOESENBERG: This is Alex

3 Boesenberg, NEMA. NEMA has commented in previous

4 rulemakings to general service incandescent lamp

5 and CFL technology options and so we are

6 revisiting our responses to those to ensure that

7 they are still current and I'll submit those with

8 our written comments. And we are developing

9 technical comments to the LED since we've not

10 necessarily had to comment on that before and so

11 that will be included in our written comments.

12 MR. BROOKMAN: Okay, thank you. Mike.

13 MR. McGARAGHAN: Mike McGaraghan.

14 Halogen infrared is one of the best technology

15 options to improve incandescent filament

16 technology and I don't see it here and maybe it's

17 just here by a different name?

18 MS. KIENLE: That is something that we

19 could consider, too. I'm not sure if it's

20 explicitly listed. This is just a preliminary

21 list, but we'll definitely consider that. And if

22 you want to submit that in written comments as
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1 well, that would be great.

2 MR. BROOKMAN: Issue 12, 13, and 14,

3 additional comments?

4 (No response.)

5 MR. BROOKMAN: Okay. So I think we're

6 due for a break.

7 MS. KIENLE: Yes.

8 MR. BROOKMAN: It's now 10:35. Let me

9 note that we're about halfway through these

10 slides, so if we get to 12:30 and we're almost

11 done, we're going to press on and finish and not

12 break for lunch. Okay, as a plan. 10:35, which

13 means we'll resume at 10:50 here in this room.

14 Please make sure you wear your badge. I would

15 note that my little plastic clip is not working

16 very well. It keeps falling off. Keep track of

17 it. They want you to wear this badge when you're

18 inside the Forrestal Building.

19 Most of you, I think, are aware there's

20 a coffee shop down on the ground floor and you

21 hang a left and just about right underneath us.

22 And go quickly if you're going for coffee. And
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1 there's also a Coke machine as you turn that

2 corner there, if you want to get that.

3 So we'll resume at 10:50. Thanks, we've

4 made a good start on the day and we'll resume at

5 10:50.

6 (Break.)

7 MR. BROOKMAN: Okay, let's resume.

8 Please take your seats.

9 Okay, we're going to pick up where we

10 left off, then we're going to hear from Aisha.

11 MS. HUSAIN: Hi, I'm Aisha Husain and

12 I'm with Navigant. We'll be moving on to

13 discussing the engineering analysis now.

14 So the engineering analysis and the

15 product price determination, which we'll discuss a

16 little bit later, together are used to determine

17 the relationship between efficacy and the end-user

18 price. The results of these analyses are also

19 used downstream in the life- cycle cost analysis,

20 the national impact, and the manufacturer impact

21 analysis.

22 So this slide shows step-by-step the
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1 general methodology DoE plans to use for

2 engineering analysis. The first step is choose

3 representative product classes. DoE then selects

4 baseline lamps for each representative product

5 class to use as reference points. And then for

6 each baseline lamp, DoE identifies more

7 efficacious substitutes based on design options

8 determined in the screening analysis. DoE then

9 develops efficacy levels that range from the

10 baseline to the maximum technologically feasible

11 efficacies. And finally, DoE scales these results

12 to the non-representative product classes, which

13 are product classes that are not directly

14 analyzed.

15 I will now go over each of these steps

16 in a bit more detail.

17 So for representative product classes,

18 as was mentioned, DoE will not analyze every

19 product class. Instead, it will choose a

20 representative product class on which to focus its

21 analytical efforts. And these are typically

22 chosen based on high shipment volume.
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1 Based on preliminary research, DoE has

2 found that self-ballasted products are more common

3 than externally ballasted. Dimmable products are

4 more common than non-dimmable and bare lamps are

5 more common than covered lamps.

6 So in Issue 16 we're welcoming comments

7 on what DoE should consider as representative

8 products and in particular request shipment

9 information for lamps included in this scope of

10 this rulemaking. It would be most helpful if this

11 information could be provided broken down by

12 ballast location, whether the lamp has a cover or

13 is bare, and dimmability. And I know we had

14 questions on the definition of dimmability.

15 And for Issue 17 DoE is looking for how

16 characteristics of lamps with high shipment volume

17 change depending on the lamp technology.

18 MR. BROOKMAN: Alex Boesenberg.

19 MR. BOESENBERG: Alex Boesenberg, NEMA.

20 Can the Department elucidate on the item 2 under

21 the third bullet, dimmable products are more

22 common than non-dimmable?
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1 Obviously, we haven't done the detailed

2 market analysis yet, but if CFLs--of the products

3 listed, if CFLs are the bulk of the market since

4 LED is emerging and the standard CFL is non5 dimmable, whether there's a dimmer there or not--I

6 hear this every day, believe me- -so how--it's my

7 own personal--I don't have a NEMA survey on that,

8 but my own personal observation is that CFLs

9 probably are--of the products listed, is covered

10 by this rule or the majority, and the standard CFL

11 is not dimmable. So was there any analysis to that

12 or is that just an assumption?

13 MS. HUSAIN: So when we did this we were

14 looking at basically what the product offerings

15 were for CFLs and LEDs and based this analysis on

16 that, not necessarily market share. But we'd be

17 open to any information you can provide because

18 that would definitely be helpful.

19 MR. HOWLEY: This is Joe Howley from GE.

20 I can state that certainly the non-dimmable type

21 of CFL is much more common than dimmable by a huge

22 factor. When I looked at this I thought perhaps
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1 you were talking about just lamps and sockets are

2 generally more dimmable because in a medium screw

3 base world a lot of those are still incandescent

4 or halogen and, of course, those are always 100

5 percent dimmable. But in CFL or LED today, most

6 of them are not dimmable.

7 MR. BROOKMAN: Let's hear from Ali.

8 MS. McDONALD: This is Ali McDonald. We

9 realize that some of these characteristics vary

10 based on the technology that's use. So it's

11 helpful, you know, for comments to elaborate on

12 that or point out differences in popularity within

13 technology as well. We put dimmable products are

14 more common than non-dimmable for most products

15 thinking, as you are, acknowledging that non16 dimmable CFLs are probably more popular for that

17 technology type.

18 MR. BROOKMAN: Charlie.

19 MR. STEPHENS: Charlie Stephens, NEEA. I

20 just wanted to make a note here that based on the

21 data that we got in the field, there were some

22 pretty not surprising observations we were able to
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1 make here. I'm not sure shipment volume by itself

2 is enough of a criterion to be looking at

3 representative product classes because unlike so

4 many other products, like air-conditioners or

5 refrigerators or such, these different

6 technologies have different lifetimes, they have

7 different numbers of hours.

8 You know, for instance, we found that

9 about 25 percent of the sockets, literally

10 sockets, in our houses in the single-family

11 sector--we also do multi-family and manufactured

12 homes--but in the single-family sector were CFLs,

13 but they were way more than 25 percent of the

14 operating hours. And so the savings, the energy

15 savings, derived not from how many sockets there

16 were and, therefore, how many sales, but it

17 depended on the lifetime of the product, which

18 interacts with the number of hours that the

19 product is in it and, in some cases, how many

20 times it's switched on and off.

21 So there's a lot of factors here that

22 will impact the economics of all of this that
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1 don't have to do with just shipment volume here.

2 And I also would point out that because

3 lifetimes are shifting and because they're so

4 different for the different products, the future,

5 as has been pointed out by others here today, what

6 will happen because of the standard and in the

7 future could be radically different from the way

8 it is today. So what I know today is pretty

9 perishable compared to what we will need to know

10 and forecast going forward. So I would just urge

11 DoE to look at more than shipment volume here as

12 you select what to analyze.

13 MR. BROOKMAN: Okay, thank you. Andrew?

14 MR. DELASKI: Another issue with

15 shipments that's a little different for this

16 product compared to other consumer durables,

17 although I think an LED of becoming a consumer

18 durable, is inventory in people's homes. You

19 know, no one buys an air-conditioner and puts it

20 in a box in the basement, but you do buy light

21 bulbs and put them in a box in the basement.

22 So I think Tom Eckman from Power Council
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1 sent me the data from the Northwest, and maybe

2 Charlie can corroborate this, but that in the

3 Northwest, in the data that they have, is that a

4 typical home has 25--well, about two-thirds of the

5 lamps in a typical home are covered by EISA

6 standards. And of those, about half are CFLs,

7 according to the data that Tom sent, but another

8 five CFLs are in storage. So if you look at the

9 data and the sales you would think that everybody

10 has--every socket should be CFLs by now based on

11 the data, but the fact is that's not true, in part

12 because there's an inventory that happens with

13 light bulbs in people's homes and that needs to be

14 reflected in the analysis.

15 MR. BROOKMAN: Okay. Thank you. So,

16 we're still looking for the additional comment on

17 product classes here, I think. By ballast

18 location, covered or bare, other thoughts on

19 Comment Box 16. Mike.

20 MR. McGARAGHAN: Mike McGaraghan. I'm

21 going to try to rephrase a question that I didn't

22 quite get an answer to earlier. You say here that
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1 bare lamps are more common than covered lamps, so

2 that means DoE has done some assessment of what

3 types of--you know, which category each products

4 falls into. So, for example, incandescent lamps,

5 are they bare or covered lamps?

6 MS. HUSAIN: So I think the way we

7 approach this for the framework was a covered lamp

8 would be something that's maybe where you would

9 consider like a frosted coating, so some

10 incandescents would fall under that and others

11 would fall under a bare.

12 MR. McGARAGHAN: Okay.

13 MS. HUSAIN: But we're open--I mean, as

14 we said earlier, like for those definitions and

15 how those are classified, we're open to any

16 comments and where you think technologies would

17 fall and the utility of that product class as

18 well.

19 MR. BROOKMAN: Keith.

20 MR. COOK: Keith Cook with Philips. I

21 guess I'm still confused. What about LED lamps?

22 Most of those, are they covered or bare?
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1 MS. HUSAIN: So I think we consider most

2 of those covered.

3 MR. BROOKMAN: Because they're in a

4 capsule?

5 MS. HUSAIN: Because they have an outer6 -yeah, the A-shapes, if you look at those we would

7 consider those as covered.

8 MR. COOK: Even though the lamp it's

9 replacing looks identical to it is bare?

10 MS. HUSAIN: Right, I mean, you would

11 have--that's why we're considering different

12 product classes for bare versus covered.

13 MR. McGARAGHAN: Keith, this is Mike.

14 And I think what I heard is that on incandescents

15 they would call a frosted incandescent, you're

16 basic--

17 MR. COOK: Yeah--but--

18 MR. McGARAGHAN: As a covered--

19 MR. HOWLEY: This is Joe Howley. I

20 think really for incandescent and perhaps even LED

21 it's probably more logical to look at clear versus

22 diffuse coatings. For CFL it makes sense to look
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1 at bare, which meaning the bare spiral versus a

2 covered spiral. But for the LED and incandescent

3 you're really looking at a clear glass or you're

4 looking at a diffuse glass. And I think there

5 does need to be further work on these

6 classifications and how you're looking at these

7 technologies.

8 MS. HUSAIN: Sure, and that's a good

9 point there.

10 MS. McDONALD: This is Ali McDonald. I

11 also wanted to mention, you know, we keep saying

12 we'll welcome comments on the definition of

13 covered, also welcome comments on whether a

14 covering should be a product class factor or not.

15 MR. BROOKMAN: Okay, Noah.

16 MR. HOROWITZ: Something I had assumed

17 differently. Did I understand it right that if

18 the bulb has a "cover" or "enclosure," but if

19 that's not frosted, if it's clear, that's

20 considered a bare bulb?

21 MS. HUSAIN: Right. In the framework

22 that's how we looked at it.
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1 MR. HOROWITZ: Okay. Thanks.

2 MR. BROOKMAN: Okay, so we're moving on.

3 MS. HUSAIN: Okay. So the next step is

4 selecting a baseline lamp for each representative

5 product class. A baseline lamp is what DoE

6 believes to be the most common, least efficacious

7 lamp within each representative product class. For

8 products that do not have existing standards, DoE

9 plans to select the most common, least efficacious

10 lamp. For products that do have standards, DoE

11 plans to select the most common, least efficacious

12 lamp that just meets those standards.

13 In Issue 18 DoE is requesting comments

14 on its approach to baseline lamps.

15 MR. BROOKMAN: No comments here. Yes,

16 Noah.

17 MR. HOROWITZ: Noah Horowitz with NRDC.

18 I think we need to be careful here what's a

19 baseline lamp. It could be brighter lamps versus

20 less bright. So, for example, a 40 watt lamp and

21 its alternatives might be very different than the

22 100 watt ones in terms of pricing and
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1 availability. So I don't know if light output is

2 one of the criteria or you could have multiple

3 baseline lamps is probably what might be needed.

4 MR. BROOKMAN: Okay. Thank you.

5 MR. HOROWITZ: Thank you.

6 MR. BROOKMAN: Additional on baselines?

7 MS. HUSAIN: So DoE will select a higher

8 efficacy replacement for each baseline lamp by

9 considering technologies not eliminated in the

10 screening analysis. When considering more

11 efficacious designs DoE plans to consider lamps

12 that emit lumens equal to the lumen output of the

13 baseline lamp or are greater than or below the

14 baseline lamp by no more than 10 percent. DoE also

15 plans to select commercially available lamps for

16 this analysis.

17 In Issue 19 DoE requests comments on

18 this methodology.

19 MR. BROOKMAN: Joe.

20 MR. HOWLEY: Joe Howley. Just to bring

21 up one issue that occurred in another rulemaking

22 is that sometimes the highest volume lamp is the
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1 least efficacious, but sometimes it is not. And I

2 think in the terms of establishing an energy

3 efficiency regulation you probably want to look at

4 the least efficient technology as your baseline.

5 If it happens to be the highest volume, then that

6 certainly is the correct lamp to pick for your

7 baseline, but if it's not the highest volume I

8 think still the least efficacious lamp should be

9 your baseline.

10 I don't know if that occurs here or not.

11 I mean, we've had a lot of discussions on what the

12 classes should be and perhaps there'll be changes

13 to these classifications, but it's really hard for

14 us to determine right now in some cases what lamps

15 fit into what classes, given how the classes have

16 been proposed. I think we need to relook at what

17 the classifications are and then that might make

18 it clearer what the baseline lamps should be in

19 those classifications. Thank you.

20 MS. HUSAIN: Okay.

21 MR. BROOKMAN: Okay. Final comments

22 here. Yes, Mike.
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1 MR. McGARAGHAN: Mike McGaraghan. We

2 agree with Joe's comment that the efficacy is the

3 more important metric to look at for establishing

4 the baseline.

5 MR. BROOKMAN: Okay, that's helpful.

6 Thank you. Okay.

7 MS. HUSAIN: All right. After

8 identifying the more efficacious substitutes for

9 each baseline lamp DoE develop efficacy levels

10 based on three factors. These are: the design

11 options associated with a specific lamp, the

12 ability of the lamp to comply with the efficacy

13 level of a given product across wattages, and the

14 Max Tech efficacy level. DoE's considering

15 developing continuous equations that represent

16 levels of efficacy issue across all wattages. And

17 for this analysis DoE will consider compliance

18 data submitted by manufacturers as well as data

19 from verification testing, such as what is

20 provided in the DoE Lighting Facts database.

21 In Issue 20 we're welcoming comments on

22 the methodology for developing efficacy levels,
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1 particularly on the equation-based approach, and

2 in Issue 21 requesting comment on the use of

3 compliance and verification test data to establish

4 these levels.

5 MR. BROOKMAN: Keith.

6 MR. COOK: Keith Cook from Philips. I

7 think one thing we need to start thinking about,

8 though, is instead of trying to group these things

9 by wattages, we need to do it by lumens, simply

10 because that's how they will essentially be bought

11 for the applications. But more importantly is

12 there's such large variations in the wattages for

13 the same application anymore that it no longer

14 makes any sense to do it that way.

15 MR. BROOKMAN: Okay, thank you. Joe.

16 MR. HOWLEY: Joe Howley with GE. The

17 equation-based approach we've seen used in some

18 rulemakings in a tiered or stepped approach we've

19 seen used in other rulemakings. I think both

20 potentially could be considered. It depends on

21 what you're trying to achieve, but I think it was

22 very successful to use the step approach in the
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1 previous incandescent rulemaking and I don't think

2 we should immediately toss out that as a potential

3 approach to use here. The equation-based

4 sometimes is not the best approach. Certainly

5 it's something that can be analyzed, but I think

6 we could assume it's always the best approach for

7 each rulemaking.

8 MR. BROOKMAN: Mike.

9 MR. McGARAGHAN: Mike McGaraghan. First,

10 just to echo Keith's comment, I wholeheartedly

11 agree that lumens is the driver there and that's

12 what identifies the product utility, so standards

13 and equations should be based on lumens, not

14 wattage.

15 And then on the curve versus a stepped

16 function, I felt like in EISA Phase 1 what ended

17 up happening is we ended up seeing a bunch of

18 products introduced right at the least efficacious

19 part of that step and ended up with products that

20 maybe weren't as bright as what the consumer

21 thought they might get. So it creates a--it's a

22 mis-incentive there in the design process if you
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1 have a step. You no longer have--you give an

2 advantage to lesser products than the products

3 that the consumer may have been seeking out at a

4 certain lumen light output.

5 MR. BROOKMAN: Joe.

6 MR. HOWLEY: I would just counter that

7 by saying, though, it did have an effect of having

8 all manufacturers end up at the same wattage

9 points and to avoid consumer confusion versus, for

10 instance, the 72 watt is now the replacement for

11 the 100 watt across all manufacturers. With a

12 linear function we could have been at seven

13 different wattage points and just produced massive

14 consumer confusion. So there's some marketing

15 benefits and other industry benefits and consumer

16 education benefits to perhaps focusing on a step

17 point, if you will. I thought that's the part

18 that worked well with the incandescent standard in

19 terms of educating the consumer to the new wattage

20 point levels.

21 MR. BROOKMAN: Noah? Oh, Jen, please.

22 MS. AMANN: Jennifer Amann, ACEEE. Just
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1 adding to that point, I think, you know, the

2 manufacturers and the advocacy community and

3 others have spent a lot of time and effort in the

4 recent years educating the consumer about the

5 importance of shopping based on lumens. Getting to

6 Keith's point, as we're seeing more and more

7 products enter the market with very different

8 wattages for delivering the same lumen package, I

9 think we'll be getting away from that. And so

10 while the step function may have served that

11 purpose in the past, I think, you know, hopefully,

12 we'll have made great strides toward getting the

13 shift to lumen-based purchases before the standard

14 takes effect.

15 MR. BROOKMAN: Okay, thank you. Ken

16 Rider has raised his hand. Ken, you're next in

17 the queue. Please speak.

18 MR. RIDER: Yeah, hi. This is Ken Rider

19 from the California Energy Commission. I have a

20 question on Issue 20. When you talk about

21 considering different levels for all covered lamp

22 technologies, does that mean that in the baseline
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1 and all the different levels you'll only be

2 looking at CFL and LED levels or will baseline

3 potentially include some incandescent technologies

4 even though they're not what you're looking to

5 (phone drop) in the scope of this (phone drop)?

6 MS. SHER: Hi, this is Celia Sher. Can

7 you rephrase your question again?

8 MR. RIDER: Yeah, so I'm wondering

9 you're going to develop a baseline and then a--

10 (phone connection drops) market Max Tech level and

11 you say here for all covered lamp technologies

12 (phone drop). I'm wondering if (phone drop) you

13 will develop the baseline only for CFLs and LEDs

14 and look at CFL and LED replacement and one

15 another up from levels or if you'll also consider

16 that some baseline products will be incandescent

17 even though that is not covered, but is a covered

18 lamp technology and it's (phone drop).

19 MS. SHER: Okay, and this did come up

20 earlier and we--you know, that falls under our

21 constraints, under the rider, and we will consider

22 your comment. I can't answer that right now, but
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1 we will--if you provide that as a written comment

2 we'll take into consideration.

3 MR. RIDER: Okay, thank you.

4 MS. SHER: Yeah.

5 MR. BROOKMAN: Noah.

6 MR. HOROWITZ: Noah Horowitz with NRDC.

7 I want to reiterate support for what Keith Cook

8 from Philips said that future standards should be

9 focused on the light output, the amount of lumens

10 the bulb gives out. And the way to do that is

11 setting minimum efficiency standards as a function

12 of light output. And we support the notion of a

13 smooth, continuous curve and we encourage DoE and

14 its consultants to look at what Europe has done.

15 Their standards are smooth, continuous curve since

16 it's a very large market. The levels probably

17 might be different than Europe because you have to

18 take into account the different voltages involved.

19 Thank you.

20 MR. BROOKMAN: Thank you. Final

21 comments here? Yes, Dave.

22 MR. GATTO: Dave Gatto, Westinghouse.
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1 Just a comment on the intention to use compliance

2 data. We agree with that. However, we would like

3 to point out that when we've had some ex parte

4 conversations with DoE and with industry and

5 otherwise, there's noise in the compliance

6 database due to confusion about how to enter

7 certain things, simple human error. Even in the

8 case of the GSIL, the template doesn't allow

9 certain products to be entered at this time. So

10 we would simply like DoE or Navigant, whoever's

11 doing that analysis, to keep in mind that there

12 are going to be outliers and we would recommend

13 that you ignore those in any baseline

14 establishment or you're going to potentially

15 create a disruption in the market because we've

16 used a number that's not real.

17 MR. BROOKMAN: As is always the case,

18 the Department would especially appreciate

19 detailed comments on this kind of stuff. Yeah,

20 okay. And we're moving on.

21 MS. HUSAIN: Okay, so finally DoE will

22 develop efficacy levels for their product classes
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1 that are not analyzed by scaling from the levels

2 determined for the representative product classes.

3 To do so, DoE plans to determine scaling factors

4 by comparing efficacies of representative products

5 to non- representative products.

6 And in Issue 22 DoE requests comments on

7 its scaling methodology.

8 MR. BROOKMAN: Comments on scaling?

9 (No response.)

10 MR. BROOKMAN: No comments here.

11 MS. HUSAIN: Okay. So the next slide is

12 a bunch of requests for comments. Issue 15 is a

13 general request on the--on comment on engineering

14 methodology that has been presented. Issue 23 is

15 comments on proprietary designs that are relevant

16 to this rulemaking. Issue 24 requests comments on

17 regulatory burdens that we should be considering

18 in the engineering analysis. And 25 welcomes just

19 any other issues regarding engineering analysis.

20 MR. BROOKMAN: Mike.

21 MR. McGARAGHAN: Mike McGaraghan,

22 California IOUs. My understanding is that the
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1 engineering methodology is--or the engineering

2 assessment has generally developed a cost

3 efficiency relationship. And then later in the

4 price section you convert that into end-user

5 prices. And my read is that you're not doing that

6 here and that all price analysis is happening in

7 the price--in the product price determination

8 section. Is that accurate?

9 MS. HUSAIN: Right. So we're developing

10 the levels and the engineering analysis and then

11 I'll be discussing after this the product price

12 determination where we'd be determining end-user

13 prices associated with those levels.

14 MS. McDONALD: This is Ali McDonald.

15 This is consistent with the approach in general

16 service fluorescent lamps and incandescent

17 reflector lamps.

18 MR. McGARAGHAN: Okay.

19 MR. BROOKMAN: Ali, would you repeat

20 that? I'm sorry.

21 MS. McDONALD: Oh, boy, here we go. It's

22 consistent with an approach that has been taken in
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1 previous rulemakings, so the rulemaking for

2 general service fluorescent lamps and incandescent

3 reflector lamps took a similar approach where end4 user prices were determined directly.

5 MR. McGARAGHAN: Thank you.

6 MR. BROOKMAN: Andrew.

7 MR. DELASKI: Can we--I just infer from

8 your comments, so can we infer that you'll do what

9 we've done in that docket as the approach in this

10 one or there'll be some variation from what we've

11 done with the GSFL/IRL docket. I mean, are you

12 seeing a variation on that or you said "consistent

13 with," how consistent with? Is it the same thing

14 or is it--

15 MS. McDONALD: Sure, well, I guess the

16 point that, you know, oftentimes DoE develops like

17 an MSP, a manufacturer's selling price, and then

18 applies mark-ups. And though that cost efficiency

19 is used in later analyses, here we're kind of

20 instead of going right to an MSP and applying

21 mark-ups, we're going right to an end- user retail

22 price. So that approach is what we're describing
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1 here and that's consistent with previous

2 rulemakings, previous rulemakings for some other

3 lighting products, like the GFLs and IRLs.

4 MR. McGARAGHAN: So if we have

5 additional comments on your pricing approach at

6 this point, we should hold them until we get to

7 the pricing section.

8 MS. McDONALD: The next slide, yeah. I

9 was just going to talk about it.

10 MR. BROOKMAN: Okay, yes. Well, so what

11 about proprietary designs, regulatory burdens, and

12 other engineering issues?

13 (No response.)

14 MR. BROOKMAN: No additional comments

15 here? Okay.

16 MS. HUSAIN: Okay, so now we'll move on

17 to the product price determination. As mentioned,

18 the engineering analysis and product price

19 determination provide a relationship between the

20 efficacy level and the end-user price. The

21 product price determination will establish end22 user prices for representative lamp units
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1 identified in the engineering.

2 DoE plans to apply discounts to Blue

3 Book values based on the relevant distribution

4 channels for these products. Specifically, DoE's

5 pulling together prices from state procurement

6 contracts, electrical supply distributors, home

7 improvement/hardware stores, and Internet

8 retailers. DoE then plans to develop a range of

9 discounts based on these various distribution

10 channels and come up with high, medium, and low

11 prices for each lamp. Where a Blue Book value is

12 not available for a lamp, the price will be

13 extrapolated from available lamp prices.

14 So on Issue 27 your comments are welcome

15 on the pricing methodology.

16 MR. BROOKMAN: Robert.

17 MR. NACHTRIEB: Robert Nachtrieb, Lutron

18 Electronics. DoE has already published

19 exponentially decreasing prices, dollars per

20 kilolumen for LEDs. The methodology that you're

21 describing here seems to take a snapshot and hold

22 that constant. How do you intend to project the
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1 declining prices of LEDs with this methodology and

2 the increasing market adoption of LEDs that

3 result?

4 MR. GERKE: This is Brian Gerke from

5 LBNL. It is probably best for me to answer that

6 question. We will be looking at DoE's previous

7 analyses and currently we're considering taking a

8 similar approach to what was done there for LEDs.

9 For other technologies we will use

10 similar methods to what DoE's used in the past for

11 rulemakings: looking at historical shipments,

12 historical prices, and putting together a

13 projection of future prices from that.

14 MR. BROOKMAN: Noah.

15 MR. HOROWITZ: Noah with NRDC. I think

16 as people are aware, the price for the exact same

17 bulb might vary very much depending which retail

18 outlet you went to purchase it and whether you

19 bought it as a onesie or in a multipack. Some of

20 the CFLs and the new halogen incandescents, if you

21 buy it in a multipack it could be $1.50 each or

22 you could buy a single bulb for $5 for the exact
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1 same bulb. So we need to be careful to

2 distinguish between the retail cost of the bulb

3 and what it costs to make. There could be a very

4 big difference there.

5 Also, as you just mentioned LED,

6 tomorrow's LED might not only be more efficient,

7 but also cost less. The assumption in these

8 dockets often is the more efficient bulb costs

9 more than today's less efficient bulb, and I think

10 we have to be careful not to make that same

11 assumption. Thanks.

12 MR. BROOKMAN: Yes, Mike.

13 MR. McGARAGHAN: Mike McGaraghan. Will

14 you be developing price efficiency curves then

15 based on all the data you collect? If you collect

16 product prices for a wide array of products, will

17 you then generate some sort of relationship

18 between efficacy and user price?

19 MS. McDONALD: Sure. This is Ali.

20 That's ultimately what's created here. You

21 combine the outputs of the engineering and product

22 price determination and you have a cost efficiency
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1 curve. Sorry--

2 MR. McGARAGHAN: Okay. You have a price

3 efficiency curve, yeah.

4 MS. McDONALD: Yes.

5 MR. McGARAGHAN: And then, the Blue

6 Books, can you expand on those? Are those

7 publicly available? Are you going to publish

8 what's in them?

9 MS. HUSAIN: So we usually obtain Blue

10 Books from manufacturers and they're usually not

11 publicly available. We request for them. And

12 that was one of the--Issue 29 was one of the

13 Requests for Comment we had on what--maybe the

14 manufacturers can speak on the availability of the

15 Blue Books or price schedules for the lamp

16 technologies that are covered in this rulemaking,

17 in particular LEDs. But, yeah, they're usually

18 something that we request from manufacturers.

19 MR. McGARAGHAN: And then would they

20 become part of the docket? Would they be public

21 in the rulemaking?

22 MS. HUSAIN: We request those under
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1 NDAs. We don't publish the Blue Book prices. We

2 use them in our analysis.

3 MR. BROOKMAN: Have we skipped

4 distribution channel?

5 MS. HUSAIN: Yeah, if there's any

6 comments on distribution channels.

7 MR. BROOKMAN: Let's see if we can get

8 some comment on distribution channels.

9 MS. HUSAIN: So we mentioned a few that

10 we were considering--the state procurement, the

11 large electrical supply distributors, the home

12 improvement stores, and Internet retailers--if you

13 have any comments on those or additional ones.

14 MR. BROOKMAN: Joe.

15 MR. HOWLEY: The distribution channels

16 you're mentioning are often also distribution

17 channels for more of the commercial products. The

18 consumer products we're talking about here,

19 though, often go into additional retail channels,

20 such as mass merchants and/or drugstores, grocery

21 stores. So I think that the distribution of these

22 general service lamps is a little bit broader than
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1 the distribution that you might find in more of

2 the commercial products, which is electrical

3 distributors and direct state contracts and things

4 of that nature. This list looks like it was

5 developed for one of the other rulemakings for the

6 commercial products, so you may want to expand it

7 to a few more consumer channels for this

8 particular analysis.

9 MR. BROOKMAN: Noah. Oh, pardon me,

10 Terry.

11 MR. McGOWAN: I would also like to add

12 for the more efficient products, such as CFLs and

13 particularly LEDs, there are now new retailers

14 that are hoping to enlarge their share of the

15 market, and these would include retailers such as

16 battery stores. One just recently changed its

17 name from Batteries to Batteries and Bulbs. There

18 are also lighting showrooms, many of which are ALA

19 members, who because of the higher cost of LED

20 products now find these profitable to sell via

21 lighting showrooms. And by "lighting showrooms" I

22 do mean retail showrooms for consumers, generally
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1 consumer- oriented, that do sell lighting

2 products-- lighting fixtures, controls, and bulbs3 -to the consumer as part of their product line.

4 MR. BROOKMAN: Noah.

5 MR. HOROWITZ: Noah Horowitz with NRDC.

6 As part of this pricing methodology we think it

7 would be good for DoE to not only collect

8 individual price per product data, but also

9 relative waiting of sales. So, for example, for

10 the mass merchants and the large retailers,

11 whether it's Home Depot or lighting which is more

12 in the hardware do-it-yourself category or

13 somebody like Wal-Mart like Target, if 80 percent

14 of the bulbs are being sold there at lower price

15 points, you want to weight that versus the bulb

16 that might be sold as a onesie at the Safeway

17 grocery store where volume might be much lower. So

18 it'd be good to get some data on volume

19 distribution.

20 MR. BROOKMAN: Okay.

21 MS. HUSAIN: And we would definitely

22 welcome comments on that. Specifics would be
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1 great.

2 MR. BROOKMAN: Final comments on these

3 three: pricing methodology, distribution

4 channels, and Blue Books. Yes.

5 MR. McGARAGHAN: Mike McGaraghan. A

6 comment, too, about experience curves, which you

7 mentioned you were going to utilize. We think

8 that's the right approach to use. One comment on

9 that is there's a number of different ways you

10 could implement experience curves for any product.

11 But specifically for this one experience curves

12 generally take a certain rate of industry

13 experience and apply that every time, total

14 shipments double. So if you look at total

15 shipments of general service lamps they're

16 doubling very, very slowly because they've been

17 around a long time. So we would recommend that

18 you look specifically at LEDs and specifically at

19 CFLs and specifically at incandescent because

20 they're entirely different technologies on totally

21 different parts of their experience curve.

22 And then lastly, I've got to come back
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1 to the Blue Books thing. I am still not totally

2 clear on what DoE's proposing to do. You're going

3 to gather these Blue Book values and do your own

4 research into actual prices that you find in the

5 market and then throw those all together as equal

6 contributors to the analysis? Am I understanding

7 it? So you'll have some manufacturer Blue Book

8 prices and some that you gathered yourself and

9 then analyze them altogether?

10 MS. HUSAIN: So the Blue Book prices

11 would be used as sort of the starting point of the

12 price analysis and then we would look up, based on

13 distribution channels, retail prices and compare

14 those to the Blue Book prices that are provided

15 and come up with a discount analysis as was

16 indicated in the previous slide. And so in this

17 discount analysis we would basically, based on a

18 high, low, medium discount, come up with, you

19 know, low, medium, high prices. The discounts

20 would then be applied to, you know, Blue Book

21 values to get to an end-user price.

22 MR. McGARAGHAN: I see.
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1 MS. McDONALD: Yeah, so this is Ali

2 McDonald. One of the reasons we use the Blue

3 Books is to try and develop a consistent starting

4 point for prices and work off of those to get to

5 the retail prices.

6 MR. McGARAGHAN: So you'll just collect

7 enough retail prices to be able to make these

8 conversions, the discounts.

9 MS. McDONALD: Right, to feel confident

10 in developing a relationship between those Blue

11 Books and the retail prices.

12 MR. McGARAGHAN: Got it. Okay.

13 MR. BROOKMAN: Yes, Robert.

14 MR. NACHTRIEB: Robert Nachtrieb, Lutron

15 Electronics. I'd like to support the point that

16 Mike just make. If the experience curves are

17 going to be part of the methodology for

18 determining the decline in prices of LEDs, then I

19 would ask that the methodology of those experience

20 curves also be made available so that they can be

21 scrutinized. Is it because of learning in the

22 manufacturing process? Is it because of
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1 competitive pressures? What are the reasons why

2 the price is declining? At least let's have that

3 methodology be available for scrutiny. Thank you.

4 MR. BROOKMAN: Okay. Mike. Andrew.

5 MR. DELASKI: Just a question for

6 clarification. This is Andrew deLaski. As we've

7 been talking this through it occurs to me that I

8 don't really understand what a Blue Book price is.

9 Can someone describe for me what a Blue Book--what

10 goes into a manufacturer's Blue Book price?

11 MR. HOWLEY: Suggested retail.

12 MR. DELASKI: Suggested retail.

13 MR. BROOKMAN: Is that Ali?

14 MS. DEBUTTS: It's for manufacturers.

15 MR. BROOKMAN: Okay, please.

16 MR. DELASKI: And is that a common--just

17 to follow up on my question. So, Joe, I thought I

18 was trying to interpret what you said, that that's

19 more commonly a tool for the commercial market.

20 Were you saying it's more commonly a tool for the

21 commercial market than for the consumer market?

22 MR. HOWLEY: No, I didn't comment at all
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1 with regard to Blue Books, and that includes

2 everything.

3 MR. DELASKI: It includes everything,

4 okay. Okay, thank you.

5 MR. BROOKMAN: Okay. Now Mike.

6 MR. McGARAGHAN: Mike McGaraghan. One

7 other comment on this methodology. If you don't

8 first develop a cost efficiency curve, then do you

9 have a method to estimate the price of future

10 products that aren't necessarily around yet, new

11 technologies that are in development now or, you

12 know, that are on a certain trend in terms of

13 their improvement? Will you be able to use this

14 methodology to forecast prices for those types of

15 products?

16 MS. HUSAIN: So are these products that

17 are commercially available? If we've considered

18 them--if we're able to consider them in the

19 engineering analysis and identify them as

20 representative lamp units, we would figure out the

21 prices for them as well. Is that your question or

22 are you talking about products that are not
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1 considered in the engineering analysis?

2 MR. McGARAGHAN: Products that are not

3 necessarily commercially available yet, which

4 shouldn't be screened out of your analysis.

5 MS. HUSAIN: So--

6 MR. McGARAGHAN: Your analysis doesn't

7 necessarily have to only look at products that are

8 on the shelves. So I'm wondering how you come up

9 with prices for those types of products.

10 MS. HUSAIN: I mean, we can look at

11 working prototypes that, as was mentioned in the

12 screening analysis, we can look at working

13 prototypes that meet all the screening criteria.

14 And if they don't have a price plan, I think we

15 would try to gather as much information as we can

16 as feedback we can get from the manufacturers or

17 any other resources.

18 Ali, did you want to--

19 MS. McDONALD: Sure. Yeah, this is Ali.

20 We'd welcome any kind of information, not only

21 expected retail price, but also differences in

22 manufacturing costs associated to make those and
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1 whatever especially incremental cost would be

2 expected to produce those products on a commercial

3 scale.

4 MR. McGARAGHAN: Okay.

5 MR. BROOKMAN: Noah.

6 MR. HOROWITZ: I think I'm with Andrew

7 on this. I'm still struggling with the concept of

8 a Blue Book. A suggested manufacturer retail

9 price often is just a number and retailers could

10 sell something for a quarter of that price or more

11 than that. And isn't what's more relevant what

12 we're seeing in the market versus a manufacture

13 number that might not necessarily be used?

14 MR. BROOKMAN: Lucy.

15 MS. DEBUTTS: I think what we're trying

16 to say is that we're going to use the Blue Books

17 as a base, but then it's not going to be the only

18 consideration the DoE is making. We're going to

19 get the bigger set of data and welcome anything we

20 can get from the stakeholders to evaluate the

21 pricing.

22 MR. BROOKMAN: Noah.
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1 MR. HOROWITZ: So to clarify then, will

2 part of DoE and consultants? task to go into

3 retail and do an actual survey of what the real

4 prices are?

5 MS. HUSAIN: Yes.

6 MR. HOROWITZ: Great. Thank you.

7 MR. BROOKMAN: Okay, 27, 28, 29, taking

8 one more peek. We're about to move on.

9 MR. DELASKI: Just one observation I

10 had.

11 MR. BROOKMAN: Andrew.

12 MR. DELASKI: I think in terms of

13 pricing on this one, it's tricky because, I mean,

14 just look at the historical pattern. You know, I

15 think the light bulbs that are being marketed

16 today, Joe or Keith can correct me if I'm wrong,

17 that are just compliant with the existing

18 standards were not on the market in 2007, so

19 they're not in their head. So there are places in

20 this market where we have to be able to look at

21 the potential for standards that would be at

22 levels that are not represented by products
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1 currently being sold. A little different from a

2 lot of dockets and I think it's one--

3 MS. DEBUTTS: And we welcome the data

4 that you can provide to us.

5 MR. DELASKI: Well, I'm not a

6 manufacturer, so.

7 MS. DEBUTTS: Or manufacturers for that

8 matter.

9 MR. DELASKI: But it's a challenge that

10 I think the Department has to wrestle with and

11 come up with methodologies for being able to

12 address. And I think some of the constraints that

13 have been applied in other dockets where you say,

14 well, if I can't put my hands on it, I can't model

15 it, need to be thought through in this docket and

16 consider modeling things that you can't

17 necessarily put your hands on physical products

18 today.

19 MR. BROOKMAN: Anybody else? Then we're

20 moving on to energy use life-cycle cost analysis.

21 MS. HUSAIN: I'll pass it on to my

22 colleague, Colleen Kantner.
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1 MR. BROOKMAN: Oh, pardon me, Ken Rider.

2 I almost dropped you out of the queue. Ken,

3 please speak.

4 MR. RIDER: Oh, thank you very much.

5 This is Ken Rider from the California Energy

6 Commission. I just wanted to point out that when

7 you're doing this price analysis, you really need

8 to be careful (phone drop) for things, such as CRI

9 and other features outside of the product classes

10 that you're proposing that may have an impact on

11 price and then maybe compounding impacts on price

12 when you're trying to develop these price

13 efficiency curves; that you've really got to take

14 more into account than just the efficiency when

15 you're looking at these product prices.

16 MR. BROOKMAN: Ken, I think I know what

17 you're talking about, but I didn't get what you

18 were suggesting. Are you suggesting that--

19 MR. RIDER: All right. So--

20 MR. BROOKMAN: Keep going.

21 MR. RIDER: Go ahead.

22 Yeah, if you're looking at there's
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1 multiple characteristics of these lamps, not just

2 efficiency, and so when you're trying to develop

3 the price of the (phone drop) market technology,

4 you need to try to keep things like lamp life and

5 color quality in mind so you're not comparing

6 something that provides not just (phone drop)

7 efficiency, but also improved other aspects that

8 are being included in your incremental (phone

9 drop). If you do do that you need to somehow go

10 backwards and figure out what proportion of the

11 incremental cost (phone drop) rather than other

12 improved qualities of the lamp.

13 MR. BROOKMAN: Okay. Okay, thank you.

14 Now we're going to hear from Colleen.

15 MS. KANTNER: Thanks for the

16 introduction, Doug. Again, my name is Colleen

17 Kantner and I'm from Lawrence Berkeley National

18 Laboratory.

19 As Aisha just mentioned, up next is the

20 energy use analysis. The purpose of the energy

21 use analysis is to identify how GSLs are operated

22 and to determine the energy savings potential of
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1 more efficient designs. This analysis will be

2 used as an input to both the life-cycle cost and

3 payback period analyses as well as the national

4 impact analysis.

5 The proposed methodology involves taking

6 the input power developed in the engineering

7 analysis and then multiplying that by the annual

8 operating hours to determine energy use. DoE pans

9 to develop a distribution of operating hours for

10 general service lamps. Data sources for this may

11 include DoE's Residential Lighting End-Use

12 Consumption Study, DoE's 2010 U.S.

13 Lighting Market Characterization as well

14 as the Energy Information Administration's

15 Commercial Building and Residential Energy

16 Consumption Surveys and any other source that may

17 come up as well.

18 So we just have one sort of broader item

19 for comment. DoE welcomes comments on the

20 methodology it is considering to determine energy

21 use. In particular, DoE requests comments on its

22 approach to calculating operating hours for the
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1 covered lamps.

2 MR. BROOKMAN: Robert.

3 MR. NACHTRIEB: Do you plan to

4 accommodate in your methodology the likelihood

5 that people will use their lamps more as they

6 become more efficacious and, therefore, the

7 pressure of their utility bill is reduced?

8 MS. KANTNER: I think DoE typically

9 takes into consideration whether or not there will

10 be any--I think this is usually referred to as

11 rebound.

12 MR. BROOKMAN: Charlie Stephens.

13 MR. STEPHENS: Charlie Stephens. We

14 probably will also in our analysis have some

15 estimate of whether we think there is any based on

16 our own field data, so you may have other people's

17 opinions on the table as well, if you want to read

18 them.

19 MS. KANTNER: That would be great.

20 Thanks.

21 MR. BROOKMAN: Brian, you wish to

22 comment?
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1 MR. GERKE: This is Brian Gerke from

2 LBNL. I was just going to agree. The rebound

3 analysis is a typical part of the national impacts

4 analysis.

5 MR. BROOKMAN: In this case we might

6 even have actual data. Keith.

7 MR. COOK: Keith Cook from Philips. One

8 question I've got, though, is since you're saying

9 that a fair percentage of these things are in

10 dimming circuits, are you going to compensate for

11 the amount of time that the light is actually

12 dimmed?

13 MS. KANTNER: Yes, we plan to do that.

14 MR. HOWLEY: Joe Howley. Another factor

15 to consider, and it sounds like it perhaps is

16 located within some of Charlie's data, is the fact

17 that people do tend to seek out these longer life

18 products, not so much for efficiency, but just for

19 the fact that they don't have to replace them so

20 often in sockets that are on for long periods of

21 time and this just has to be--it's a convenience

22 factor where if you have a lot of operating hours,
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1 they get tired of replacing a halogen or

2 incandescent over and over again and they'll go to

3 a CFL or an LED. And I think you'll find, and it

4 sounds like some of these data is confirming this,

5 that a lot of these more efficient products are

6 put into sockets and in applications that have

7 much longer operating hours. So you should also

8 perhaps factor operating lifetime differently with

9 the three different technologies because of this

10 convenience element I'll call it.

11 MS. KANTNER: And DoE, again, would

12 welcome any data that gets to that point.

13 MR. BROOKMAN: Keith.

14 MR. COOK: Yeah, following up on Joe's

15 comment, the other thing, though, that's also kind

16 of interesting is the fact that, as we said

17 earlier, CFLs do not dim, so you're going to have

18 to have a different amount of time allowing for

19 dimming on certain technologies versus others. And

20 so, again, it won't be a uniform factor.

21 MR. BROOKMAN: Okay. Noah.

22 MR. HOROWITZ: In terms of dimming there
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1 seems to be--Noah Horowitz with NRDC--there seems

2 to be a lot of interest in dimming bulbs and

3 treating those sockets differently. It'd be good

4 for DoE to collect data on what percent of general

5 service lamp sockets are dimmable. I think the

6 number's quite low, and Energy Star might have

7 some of that data as well. Recessed cans are

8 typically on dimmers, but those are reflector

9 lamps that aren't part of this docket. So whatever

10 we decide on dimmers, let's make sure not to apply

11 it to the whole market because we think it's

12 pretty small. Thanks.

13 MR. BROOKMAN: Yes, Robert.

14 MR. NACHTRIEB: Robert Nachtrieb Lutron

15 Electronics. I feel obliged to comment on the

16 topic of dimming.

17 (Laughter.)

18 MR. NACHTRIEB: I think NEMA has

19 provided DoE in the past with an estimate of the

20 total number of dimmers shipped, incandescent

21 lamps. And as some of you might be aware, NEMA

22 has worked recently on a standard for dimming LED
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1 lamps. So that might be helpful to constrain some

2 of the analysis that we're talking about on

3 dimming. Thank you.

4 MR. BROOKMAN: Okay, thank you. Final

5 comments here?

6 (No response.)

7 MS. KANTNER: So next is the life-cycle

8 cost and payback period analysis. The LCC

9 analysis determines the impact of energy

10 conservation standards on consumers under

11 different efficiency levels. It is from the

12 consumer's perspective and it reflects the total

13 cost of an appliance over its lifetime.

14 Specifically, the LCC is equal to the consumer

15 price plus the discounted sum of annual operating

16 costs.

17 As part of this analysis we also

18 calculate the payback period, which is the amount

19 of time required for energy cost savings to pay

20 back any increased costs of a higher efficiency

21 product. It's also worth noting that in the case

22 of GSLs, DoE is considering utilizing an
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1 annualized LCC analysis to account for the very

2 significant differences in lamp lifetimes.

3 The LCC analysis takes a look at the

4 selection process for GSLs. It's based on the

5 distribution of product efficiencies expected for

6 the compliance year. So some customers may not be

7 affected by a standard and the LCC accounts for

8 that. It aggregates the annual energy consumption

9 over the product's lifetime and it uses

10 probability distributions to characterize a number

11 of parameters. Then a computational simulation is

12 run to determine the percent of customers

13 benefiting from, being burdened by, or not being

14 affected by the standard.

15 So we use the energy use analysis we

16 just discussed a moment ago to get the annual

17 energy consumption and then combine that with

18 other parameters, including lifetime, discount

19 rate, energy price, installation costs, among

20 others, to arrive at a final life-cycle cost. And

21 I'm going to briefly discuss a few of these

22 points.
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1 So first up is installation cost. For

2 GSLs, DoE expects that installation cost will be

3 zero for the residential setting and is

4 considering calculating commercial installation

5 costs based on the labor rate and the time to

6 install the lamp. As far as energy prices, DoE is

7 planning to use the latest version of EIA's Annual

8 Energy Outlook to estimate future energy prices.

9 At this point, DoE is assuming that

10 maintenance and repair costs for GSLs will be

11 zero, but many consider the different maintenance

12 costs associated with lighting systems with

13 certain lamp types--basically taking external

14 ballasts into consideration.

15 Another important component is the

16 product lifetime. Lifetime here is defined as the

17 age in hours of operation when a lamp? is retired

18 from service. DoE plans to determine lifetime

19 using published literature. DoE will take into

20 account any disposal costs associated with GSLs.

21 So when a GSL fails, some consumers may recycle

22 the lamp and the cost of recycling is the disposal
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1 cost. DoE will estimate disposal cost based on

2 public sources.

3 Regarding the analysis period, as I

4 mentioned on the previous slide, DoE is

5 considering determining life-cycle cost over the

6 lifetime of the product and then annualizing

7 because of the very different lifetimes of the

8 lamps covered in this rulemaking.

9 DoE will also determine a discount rate

10 to calculate the present value of any cash flows

11 over the analysis period. DoE will derive a

12 discount rate for GSL users, which will be an

13 estimate of the financial cost to the consumer.

14 And this could include both the cost of any debt

15 incurred to purchase the product as well as the

16 opportunity cost, if any equity was used.

17 So now we have an issue for comment

18 slide. Issue 31, DoE welcomes comments on the

19 approach it is considering to conduct the LCC and

20 payback period analyses.

21 MR. BROOKMAN: So lots of inputs listed

22 there. Keith.
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1 MR. COOK: Keith Cook from Philips. One

2 quick comment, though, is I'm not sure that you

3 should allow for zero installation cost even

4 though it's not obvious. Personally, I've had two

5 installations where I put in LED lamps and it was

6 not compatible with the dimmer that was already in

7 there and I had to replace the dimmer and that's

8 not cheap.

9 MR. BROOKMAN: Okay.

10 MR. COOK: Sorry, Rob.

11 MR. BROOKMAN: Yeah. Dave.

12 MR. GATTO: A little bit similar. Dave

13 Gatto, Westinghouse. A little similar to Keith. I

14 think that using zero for the install cost on--if

15 pin-based CFLs are determined to be included in

16 the rulemaking, they're not a direct replacement,

17 as Alex said earlier, to incandescents. So it

18 would require the purchase of a fixture. Now, I

19 don't know if that would go in installation cost.

20 The consumer, you know, they might just plug it in

21 if it's a table lamp or have it hard--if it's a

22 hardwire fixture it would be the same install as a
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1 standard incandescent fixture. However, I think

2 that using zero there would lead to some

3 miscalculation later on about what the lifetime

4 cost to the consumer would be for a pin-based

5 socketed fixture.

6 MR. BROOKMAN: Robert.

7 MR. NACHTRIEB: In general I'm in favor

8 of the approach that's taken here to consider the

9 life-cycle costs. The approach that you're taking

10 strikes me as being particularly appropriate for

11 facilities managers who do have to worry about

12 capital, budgets, and taking out a loan for

13 equipment. With the exception of the cost of some

14 LED bulbs, Keith, I don't think that residential

15 consumers have to take out a loan to buy a light

16 bulb.

17 (Laughter.)

18 MR. NACHTRIEB: But I think that it

19 might be useful to determine the relative weight

20 of the purchase price versus the remainder of the

21 life-cycle cost when characterizing the behavior

22 of consumers in this case. Thank you.
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1 MR. BROOKMAN: Noah.

2 MR. HOROWITZ: Noah Horowitz, NRDC. In

3 terms of product lifetime, there are new flavors

4 of incandescents that have longer life. Some of

5 them are generically referred to as a 2X lamp,

6 which could have 1500 to 25 hours of life, and the

7 next generation is possible as well. I would

8 encourage you to include those in consideration of

9 lifetime and potential paybacks.

10 MR. BROOKMAN: Andrew.

11 MR. DELASKI: Go back to the previous

12 slide. I appreciate it. How do you--in assessing

13 disposal costs for a GSL that fails, some could

14 maybe start with the lamp, which I presume you

15 mean you're talking about CFL options. How would

16 you assess that cost for a residential consumer?

17 MS. KANTNER: Well, first you try to

18 determine what percentage of residential consumers

19 actually recycled the lamp and then you would try

20 to find some sort of public source of a typical

21 recycle cost to the consumer.

22 MR. DELASKI: So, I mean, right now Home
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1 Depot, Ikea, other retailers just take them back.

2 You drop them in the bin and they're gone and they

3 recycle them. So is there a cost?

4 MS. KANTNER: So there would not be a

5 cost in that case to the consumer.

6 MR. DELASKI: Okay. And then if you

7 would go back to the prior slide, I think its

8 right what you describe here for installation

9 costs and I agree with the general point made by

10 others that it's appropriate to consider

11 installation costs. Joe commented earlier that,

12 you know, many consumers value the benefit of a

13 long-lived lamp. Noah made the point as well. You

14 know, there is a benefit to a consumer in a long15 lived lamp. It means fewer trips to the store to

16 buy additional lamps. It means, you know, fewer

17 household--particularly if it's hard to reach or

18 hard to replace, fewer replacements, and there's a

19 benefit there.

20 For the commercial sector--with the

21 actual price because you've got to pay someone to

22 do it. I'm not quite sure--I don't have a firm
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1 recommendation right now, but there is a benefit

2 that should be captured somehow, at least

3 qualitatively, I mean, in the analysis. Keith's

4 pointing that in some instances there's a cost.

5 There's benefits and costs to long- lived--to

6 these new products and it needs to be captured

7 somehow or another, and I'm not sure what the--how

8 you would do it in terms of a financial number,

9 but it is a benefit.

10 MS. KANTNER: Right, your point is

11 definitely taken.

12 MR. BROOKMAN: Additional comments here?

13 (No response.)

14 MR. BROOKMAN: Okay.

15 MS. KANTNER: Okay. Next I'd like to

16 introduce my colleague Brain Gerke, who's going to

17 be talking about shipments and the national impact

18 analysis for GSLs.

19 MR. GERKE: Thanks, Colleen. I'm Brian

20 Gerke from Lawrence Berkeley National Lab. I'll

21 be going over the details of the approach that

22 DoE's considering for the shipments and national
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1 impact analyses.

2 So, the purpose of the shipments

3 analysis is to project future shipments of the

4 covered products by product class and also by

5 efficiency level as a prelude to computing the

6 national impacts of a potential energy efficiency

7 standard. We are proposing to use the typical

8 general methodology for this shipments analysis

9 that is used in other rulemakings. That is,

10 projecting shipments over a 30-year period,

11 beginning on the expected compliance date of the

12 standard, and to consider various price trend

13 analyses and investigate various methods for

14 forecasting the future price of the products based

15 on guidance that's been given for all DoE

16 rulemakings.

17 The more detailed approach for this

18 particular rulemaking is that we'll be using an

19 economic model to project the shipments in the

20 standards case compared to the base case. In

21 particular, for those who are familiar with the

22 approach we took in the preliminary analysis of
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1 the GSFL/IRL rulemaking, it will be--what we are

2 considering at the moment is something similar to

3 that in which we look at the decisions that are

4 made by consumers who are choosing new and

5 replacement lamps. This is based on observed and

6 projected technology price trends and adoption

7 rates and will account for the shift to LED

8 technology that is expected to occur even in the

9 absence of standards as consumers naturally move

10 to that technology over time.

11 The inputs that go into the shipments

12 analysis are, as for the LCC, the energy price

13 forecasts from the Annual Energy Outlook. Also

14 the forecast of the growth of the building stock

15 from AEO. The lamp lifetimes coming from the

16 analyses upstream of this one, mainly the

17 engineering analysis. The lamp prices and

18 operating and maintenance costs also coming from

19 the LCC and upstream analyses from that. The

20 hours of use distribution coming from the LCC;

21 actually from the energy use analysis.

22 Historical shipments data and price
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1 trends, those that are available from the Census

2 Bureau and anything that we get from stakeholder

3 input or published literature.

4 And, of course, we are very, very open

5 to whatever data is available from stakeholders on

6 that front. And will also include forecasts of

7 lighting controls adoption over the period of the

8 standard, in particular, to understand, for

9 example, what fraction of dimmers are going to be

10 out on the market.

11 So we have general issues for comment on

12 the various approaches being taken to the

13 shipments analysis. We welcome comment on the

14 approach we take to price forecasting. We've

15 already had some of those, but we'd be happy to

16 hear more.

17 We, of course, seek information on

18 historical shipments of GSLs for each of the

19 product classes and technology types covered under

20 this rulemaking as well as any industry trend data

21 on the relative growth in each of the different

22 areas.
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1 And we request general comments on the

2 impact of energy conservation standards on the

3 shipments of GSLs and any input on other federal

4 programs that currently exist in this area.

5 MR. BROOKMAN: Robert.

6 MR. NACHTRIEB: Robert Nachtrieb, Lutron

7 Electronics. Your model forecasts shipments based

8 on forecast prices and characteristics of the

9 lamps. Do you calibrate your model against

10 historical data and do you plan to show the

11 agreement between historical data of shipments and

12 your model?

13 MR. GERKE: Yes, in answer to both

14 questions.

15 MR. NACHTRIEB: For the record, you plan

16 to show the agreement between your model and

17 historical shipment data.

18 MR. GERKE: Yes.

19 MR. NACHTRIEB: Excellent. And will you

20 share the calibration coefficients as well?

21 MR. GERKE: That is typically done in

22 the spreadsheet analysis that's made available
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1 with this.

2 MR. NACHTRIEB: Excellent, thank you.

3 MR. BROOKMAN: Yes, Joe?

4 MR. HOWLEY: Just a comment that it kind

5 of illustrates that Issue 33 illustrates the

6 difficulty with starting a rulemaking so soon

7 after the previous rule goes into effect. It

8 finally just went into effect January 1, 2014, and

9 here we're discussing a new rulemaking and we

10 really don't have good, accurate data on exactly

11 what the effects are of this past rulemaking and

12 probably won't for another year, so we're still in

13 the transitional phase.

14 And we have some information, but

15 clearly not what the full effects of this

16 rulemaking, and it's difficult to have two

17 rulemakings so close together. Separation of

18 rulemaking perhaps, in the future years, would

19 make this type of analysis a lot easier. Right

20 now all we can do is sort of estimate/guess and

21 it's difficult to do with rulemaking based on

22 estimates and guesses. Thank you.
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1 MR. BROOKMAN: Andrew.

2 MR. DELASKI: Well, in DoE's defense, as

3 Joe well knows--

4 MR. BROOKMAN: Are you turned on?

5 MR. DELASKI: --DoE is doing this

6 rulemaking because the law says they have to right

7 now. And it's what was included in EISA and it

8 said they have to start it now, so the timing of

9 this rulemaking is not a discretionary decision

10 for DoE.

11 I also would point out that although the

12 60 watt, as Joe knows, the 60 watt standard took

13 effect as of January 1st, it's been phased in over

14 three years. And in California, which I think is,

15 I think, the sixth biggest economy in the world,

16 it took effect one year earlier, so we do have--

17 it's incomplete, I will contend with that. I will

18 give you that, but we still do have a pretty good

19 sense --we have some sense of how the market's

20 reacting.

21 And, fortunately, California, they go a

22 year in advance and that was a good thing in terms
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1 of helping us to do a transition. And the staging

2 is a good thing to do a transition that has

3 actually worked.

4 MR. BROOKMAN: Keith.

5 MR. COOK: Keith Cook with Philips. The

6 other complicating factor, though, in this

7 particular rulemaking is the fact that the prices

8 are dropping so dramatically on the LEDs that the

9 market adoption is ramping up much faster than

10 what history would show it right now, too. And so

11 to be able to project that is going to be also

12 very difficult.

13 MR. BROOKMAN: Charlie.

14 MR. STEPHENS: Yeah, I would concur with

15 what Keith just said. I think what we really may

16 be looking at here, more than in other

17 rulemakings, perhaps, is a scenario analysis where

18 were really just looking at alternative scenarios

19 and see how closely they align when it comes to

20 the ultimate impact of life-cycle costs and

21 rationality of the different ways this might play

22 out.
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1 One of the things we're going to try to

2 do to help, though it will be of limited help

3 because of what we just agreed on, that things are

4 shifting quickly, is that we are going to try to

5 develop a way to provide DoE quarterly data on

6 sales at SKU by SKU for all of the retail channels

7 where most of the lighting volume will likely go.

8 And if we can do it, well also provide pricing

9 for all of that in an aggregated way to DoE.

10 And we'll do that quarter by quarter

11 until DoE makes its decisions. I don't know

12 whether we'll see the trends there or not, but we

13 need the data anyway, so we'll provide it in

14 aggregated fashion, quarter by quarter, until DoE

15 tells us they don't need it anymore.

16 MR. GERKE: Thanks, that will be

17 helpful. We also, in following up to that

18 comment, we'd welcome any input on what issues we

19 should consider in the scenarios we look at in the

20 shipments analysis.

21 MR. BROOKMAN: Additional comments on

22 these three? Yes, Taylor?
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1 MS. JANTZ-SELL: Taylor Jantz-Sell at

2 EPA. Just in terms of other federal programs for

3 efficiency, we've had three years of Energy Star

4 levels for LED lamps and--

5 REPORTER: Can you pull closer to the

6 microphone, please?

7 MS. JANTZ-SELL: And--sorry--we've had

8 three years of voluntary standards for LED lamps

9 and many more years, over a decade of CFL

10 standards, and we've released a new specification

11 for those lamps that goes into effect September

12 30th of this year, which have raised the bar in

13 terms of efficiency for medium screw base CFLs.

14 MR. BROOKMAN: Okay, take a quick peek

15 at 54 again. Price forecasting, historical

16 shipments, and shipments, additional comments on

17 those three?

18 (No response.)

19 MR. BROOKMAN: Nothing additional. Okay.

20 MR. GERKE: Okay. Moving on to the

21 National Impacts Analysis. The purpose of the

22 National Impacts Analysis is to determine the
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1 projected national energy savings and consumer

2 national net present value associated with

3 potential energy conservation standards over the

4 same 30-year period as considered in the shipments

5 analysis. The general methodology is to develop

6 an annual time series of national energy and

7 economic impacts. We do that by utilizing the

8 shipments models to estimate both the shipments

9 and the stock in each year of the analysis period,

10 use the outputs of the LCC to develop the total

11 installing cost and energies per unit in any year,

12 and then aggregate that across the shipments to

13 determine the total energy use in all years and

14 cost in all years of the analysis period, and then

15 report the national energy savings.

16 So you do that analysis for both the

17 base case and each of the proposed standard cases

18 and then report the national energy savings from

19 each of the candidate standards in terms of the

20 site energy savings, the primary energy savings,

21 and the full-fuel-cycle energy savings, where the

22 full-fuel-cycle energy savings include savings
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1 from, for example, not extracting new fossil fuels

2 from the ground to produce the power that is

3 saved. We also report the change in the national

4 consumer net present value in constant year

5 dollars, using standardized 3 percent and 7

6 percent discount rates over the 30-year analysis

7 period.

8 The inputs in the National Impacts

9 Analysis are, of course, the lamp shipments from

10 the shipments analysis; again, the energy price

11 forecast from AEO; and, again, the outputs of the

12 life-cycle cost analysis and energy use analysis

13 for the lamp price and the O&M costs and for the

14 annual lamp energy use; the current rate of

15 lighting control adoptions and forecasts from

16 published literature and conversion factors for

17 site to source and site to full-fuel-cycle energy

18 consumption from NEMS.

19 So we welcome comments generally on the

20 analysis, the spreadsheet model we plan to use to

21 estimate the energy savings and on the inputs, and

22 also we generally welcome comments on this overall
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1 methodology.

2 MR. BROOKMAN: Robert.

3 MR. NACHTRIEB: Robert Nachtrieb from

4 Lutron. Brian, I'm sorry. I think I missed it

5 earlier, but I wanted to confirm. You said that

6 one of the inputs that you're going to consider is

7 construction, which will increase the number of

8 sockets. Do you also intend to consider

9 demolition, which will decrease the number of

10 sockets, question number one.

11 Question number two, is your model

12 focused on the total number of sockets and,

13 therefore, shipments have to fill existing sockets

14 and, therefore, total shipments are constrained by

15 the rate which sockets become empty because of the

16 failure of existing lamps? Or is this a simple

17 projection of sales for each lamp type?

18 MR. GERKE: The approach we're

19 considering at the moment would involve filling

20 sockets, although based on some of the comments

21 today, looking at in-house inventory seems to be

22 worth considering as well within that analysis.
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1 Although if inventories in homes remain constant,

2 it's the same thing.

3 MR. BROOKMAN: Go ahead, Robert, follow

4 on.

5 MR. NACHTRIEB: As a follow-up, I would

6 encourage you not to agonize over inventory in

7 homes if it's an inventory of incandescents

8 because consumers are concerned about them not

9 becoming available. Once they go into service,

10 they don't last that long, so they'll practically

11 be gone in a very short time. And I would be

12 surprised if consumers stockpile an inventory of

13 very expensive new technology lamps.

14 So my suggestion is, first of all,

15 you're doing it the right way focusing on the

16 sockets. And second of all, don't agonize over

17 the inventory. Okay?

18 MR. GERKE: Thank you.

19 MR. BROOKMAN: Thank you. Additional

20 comments on the NIA model? And any NES and NPV

21 calculations?

22 (No response.)
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1 MR. BROOKMAN: Okay.

2 MR. GERKE: All right, I'm now handing

3 this over, moving on to the NOPR analyses, which--

4 Aisha, are you reading that? Handing it back to

5 Aisha Husain.

6 MS. HUSAIN: Okay, this is Aisha from

7 Navigant. Now, I'll just briefly discuss--so the

8 other analyses that DoE plans to conduct in the

9 NOPR stage of the rulemaking. And we'll begin

10 with the Manufacturer Impact Analysis.

11 The purpose of the Manufacturer Impact

12 Analysis, or MIA, is to assess the impacts of

13 standards on manufacturers,; to identify and

14 estimate impacts on manufacturer subgroups that

15 may be more severely affected than the industry as

16 a whole,; and to examine the direct employment

17 impacts, manufacturing capacity, and regulatory

18 impact on the industry.

19 DoE plans to use the Government

20 Regulatory Impact Model, or GRIM, to analyze

21 industry cash flow and industry net present value.

22 DoE also plans to obtain feedback from
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1 manufacturers through interviews.

2 So, just to lay it out a bit, DoE plans

3 to conduct the MIA in three phases. In Phase 1

4 DoE will create an industry profile to conduct

5 this first phase in the preliminary analysis and

6 it will be based on publicly available financial

7 information and preliminary manufacturer

8 interviews. In Phase 2, DoE plans to prepare an

9 industry cash flow model and an interview

10 questionnaire. In Phase 3, DoE plans to interview

11 manufacturers and assess the impacts of standards,

12 both quantitatively and qualitatively.

13 The second two phases of the MIA will be

14 conducted in the NOPR phase. So, Issue 37, DoE is

15 requesting comments on manufacturer sub-groups,

16 any that should be considered by DoE. And Issue 38

17 to request feedback on small businesses that could

18 be impacted by potential standards.

19 MR. BROOKMAN: No comment here.

20 MS. HUSAIN: All right. So I'll briefly

21 go through some of the other NOPR analyses that

22 will be conducted. In the Life-Cycle Subgroup
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1 Analysis DoE analyzes life-cycle cost impacts on

2 various national consumer subgroups that might be

3 adversely impacted due to potential standards.

4 In the Utility Impact Analysis DoE

5 determines the impact on the general capacity of

6 utilities as a result of potential standards.

7 The Employment Impact Analysis covers

8 indirect employment impacts resulting from, say,

9 shifts in expenditures or changes in income due to

10 potential standards. So I'd note this is

11 different from the Employment Impact Analysis

12 conducted in the MIA, which assesses direct

13 employment.

14 In the Emissions Analysis DoE will

15 estimate reduction in power sector emissions for

16 carbon dioxide, nitrogen oxide, sulfur dioxide,

17 and mercury due to potential standards. DoE also

18 assesses the monetary benefits of reduction of

19 carbon dioxide and nitrogen oxide due to potential

20 standards.

21 And in the Regulatory Impact Analysis

22 DoE looks at impacts of non-regulatory
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1 alternatives that could improve the energy

2 efficiency or reduce energy consumption of

3 products covered in this rulemaking.

4 So the next few slides are basically

5 issues for comment on each of these analyses. I

6 can go one by one.

7 MR. BROOKMAN: I think just leaving them

8 up there will be sufficient.

9 MS. HUSAIN: Okay.

10 MR. BROOKMAN: Charlie.

11 MR. STEPHENS: Charlie Stephens, NEEA. I

12 know I'm going to get this question from some of

13 my funders, but in the Utility Impact Analysis are

14 you able to take into account the impact on

15 generation capacity from moving from products that

16 have power factor of 1 to products that have a

17 power factor of something on the order of half

18 that?

19 MS. HUSAIN: I'm going to leave it to my

20 colleagues over there.

21 MR. GERKE: We can certainly look into

22 that possibility. This product certainly has that
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1 strong impact, but I'm not sure I can answer your

2 question directly right now.

3 MR. STEPHENS: Okay, but--

4 MR. BROOKMAN: Thank you.

5 MR. STEPHENS: Yeah, my funders are

6 going to be concerned about that to some extent if

7 there's really a massive shift toward, you know,

8 low power factor.

9 MR. GERKE: Yeah. We'll take that under

10 consideration certainly.

11 MR. BROOKMAN: Keith.

12 MR. COOK: Keith Cook, Philips. When

13 you do that analysis, though, you can't look at it

14 as just a power factor change because you have to

15 look at the effect of the actual usage of the

16 energy itself. And so if you're going, let's say,

17 from 100 watt lamp down to a 20 watt lamp, even

18 though the power factor may also go from 1 down to

19 .5, the imaginary power is still half of what the

20 original was, so.

21 MR. BROOKMAN: Charlie.

22 MR. STEPHENS: Yeah, Charlie. We agree
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1 with that, but my folks are interested in

2 calculating the actual generation capacity saved,

3 not just the energy saved.

4 MR. BROOKMAN: Terry.

5 MR. STEPHENS: So we don't care what it

6 is exactly, but we want to be able to understand

7 what the real generation capacity impacts are, not

8 just, you know, generation.

9 MR. BROOKMAN: Terry.

10 MR. McGOWAN: Terry McGowan, ALA. This

11 is a confusing issue for luminaire manufacturers

12 who are concerned about meeting requirements for

13 power factor, but we don't understand in the

14 industry just what impact that has on residential

15 products. What effect does residential products

16 have upon system power factor and generation power

17 factor is very unclear to us and we would

18 appreciate some information on this, whether it be

19 reports or studies or whatever it is. Because it

20 isn't clear that that low power factor device

21 drawing 25 watts is really having much of an

22 impact at the generating plant.
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1 MR. BROOKMAN: Noah.

2 MR. HOROWITZ: This is a more broad

3 question. Noah with NRDC. The CFL standards that

4 exist via prior statute not only deal with the

5 efficiency of the product, but also some of the

6 performance characteristics. My question to DoE,

7 is there an openness to include other metrics

8 besides efficiency for the non-CFL bulbs or lamps

9 that might be covered? So consideration of power

10 factor or some stress test or other things where

11 there might be interest by a broad set of

12 stakeholders.

13 MS. DEBUTTS: Well, we definitely can

14 consider it. We're going to have to consult with

15 the legal counsel on the constraints that we have

16 in analyzing this. But we hear your comments and

17 we'll look into it.

18 MR. BROOKMAN: Thank you, Lucy. So

19 additional comments here? You can see all of

20 these issues. Any additional comments on all of

21 these different analyses, which are considerably

22 downstream?
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1 (No response.)

2 MR. BROOKMAN: Okay.

3 MS. HUSAIN: The second slide is just on

4 the monetizing and the regulatory impact analyses.

5 MR. BROOKMAN: Okay. So then, as we

6 promised you this morning, first thing, now is

7 another opportunity for any additional comments,

8 any other issues that you wish to raise at this

9 point, things that have not been covered

10 sufficiently, anything you wish to bring to the

11 fore as we move towards closer. Yes, Noah.

12 MR. HOROWITZ: Noah with NRDC. I want

13 to go back to Alex's initial comment requesting a

14 potential extension of a couple of weeks from the

15 current deadline of January 23rd. I'm wondering

16 if DoE can provide that today or when might we be

17 expecting it? Thanks.

18 MS. DEBUTTS: We hear the request. I

19 will have to talk to my superiors to see what they

20 would like to do, but we definitely respond to

21 that. If we issue it, you're going to see the

22 notice soon.
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181

1 MR. BROOKMAN: Thank you, Lucy. Other

2 comments here at the end of the day? Nothing to--

3 yes, Andrew.

4 MR. DELASKI: If you could--the

5 Department, I know, has the mechanisms for just

6 using it's e-mail distribution list, if you could

7 use that instead of waiting for a Federal Register

8 publication, that would help us.

9 MS. DEBUTTS: Definitely. We'll send

10 out the notice if it's signed--as it's signed into

11 effect.

12 MR. BROOKMAN: Thank you, Lucy. Okay.

13 Well, then for my part, I'll say thank you. A

14 very, very productive meeting, very efficient.

15 Lots of good content came forward in the framework

16 stage. And I'll turn it back to Lucy deButts for

17 closing remarks.

18 MS. DEBUTTS: So I'll address everyone

19 from here. Hopefully, it's okay. Thank you all

20 for coming. We appreciate the input. Thus far

21 it's been a pretty interesting conversation and,

22 hopefully, we can get the comments, written
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182

1 comments, from the stakeholders, too, discussing

2 the issues that were raised.

3 And any additional information, any

4 additional data is welcome. We will assess the

5 data as it becomes available. If the six months

6 from now the date is going to be available, it's

7 going to be assessed again or evaluated again.

8 So thanks, everyone. And I'm glad to

9 see everyone here and, hopefully, hear from all of

10 you soon.

11 MR. BROOKMAN: Safe travels.

12 (Whereupon, at 12:22 p.m., the Public

13 Meeting on Energy Conservation

14 Standards Framework - General Service

15 Lamps was adjourned.)

16

17

18

19

20

21

22

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$1.50 129:21

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1 17:12 25:1,3,15

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200 72:6

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2005 24:6

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2010 146:12

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2014 1:11 5:8 13:1

28:18 45:1

164:8

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2016 29:2

2017 27:11

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21 117:2

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3 12:9 56:18 59:6

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30-year 160:10

169:4 170:6

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33 164:5

35 45:8

37 174:14

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4 12:9 56:19 59:6

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5 4:2 70:15 72:13

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6 4:3 70:16 72:13

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7
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72 119:10

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8 4:3 81:18 82:13

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9 30:16 88:6 93:21

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40:20

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146:14

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13:15

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ago 17:21 18:2
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152:16

agonize 172:6,16

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101:6,12 102:6

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brief 8:19 9:5

briefly 152:21

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bright 113:20

118:20

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30:12 31:22

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44:3,6,15

45:4,11 46:20

47:5,7,13,22

48:6,9

49:9,16,22 50:2

51:17 52:14,19

53:5 54:4

55:4,7,11,22

56:4,10

58:14,20

59:1,10 63:3,19

64:17

65:7,10,22 66:7

67:5,16,20

68:1,17 69:1,4

70:22 71:19

72:12 73:5,13

74:14 78:18

79:9 80:15,18

82:1 83:5,22

85:15

86:10,16,21

87:2 88:18

90:10 91:13

92:18 93:9,20

94:5 95:11,15

96:7,10,18,22

97:14,16 98:6,9

100:1,12

101:2,5,8 102:7

104:18 106:7,18

108:13 109:15

110:19 111:3

112:15 113:2,15

114:4,6,19

115:21 116:5

117:5,15 118:8

119:5,21 120:15

122:5,20 123:17

124:8,10,20

125:19 126:6

127:10,14

128:16 129:14

130:12

132:3,7,14

133:9 134:4,20

135:2 137:13

138:4,13,15

139:5

141:5,14,22

142:7,11 143:19

144:1,16,20

145:13

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148:5 149:13,21

150:13 151:4

154:21 155:9,11

156:6 157:1,10

159:12,14 163:5

164:3 165:1,4

166:4,13 167:21

168:14,19 171:2

172:3,19 173:1

174:19 176:7,10

177:4,11,21

178:4,9

179:1,18

180:2,5

181:1,12 182:11

brought 29:20

30:14

budgets 156:12

build 19:10

building 5:9 85:19

101:18 146:15

161:14

bulb 18:12 25:20

34:7,21 39:13

43:7,14,19,21,2

2 44:1,4,10

45:6,9 79:17

85:2,17 87:21

92:20 112:18,20

122:10

129:17,22

130:1,2,8,9

134:15 156:16

bulb--and/or 34:3

bulbs 18:8 19:16

25:7,19,22

42:22 43:4,9

51:22 52:1,2

85:17 108:21

109:13 133:17

134:2,14 142:15
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150:2 156:14

179:8

bulbs--vibration

43:17

bulk 105:3

bullet 104:21

bump 46:18

bunch 118:17

124:12

burdened 152:13

burdens 124:17

127:11

Bureau 162:2

Burgess 14:19

16:18

burns 85:2

business 2:9,17

82:4

businesses 174:17

buy 25:6,19 71:11

76:12,16,18

84:15 108:20

129:21,22

156:15 158:16

buys 108:19

C

calculate 33:1

64:1 151:18

154:10

calculating

146:22 153:4

178:2

calculation 75:7

calculations

172:21

calibrate 163:9

calibration

163:20

California 2:13,17

7:18 29:18

45:14 53:8

95:19 120:19

124:22 144:5

165:14,21

Callahan 2:8 7:3

Canada 26:9

Canadian 26:12

candelabras 96:4

candidate 169:19

cans 150:7

can--this 59:15

capacity 87:8

173:17 175:5

176:15 178:2,7

capital 1:15

156:12

capsule 70:3,5

111:4

capture 85:10

captured 159:2,6

carbon 175:16,19

carbon-based

66:13

care 178:5

careful 25:13,17

44:12 113:18

130:1,10 144:8

case 93:1 123:8,17

148:5 151:21

156:22 158:5

160:20 169:17

cases 76:8 89:9

107:19 115:14

169:17

cash 154:10

173:21 174:9

categories 51:9

72:21

categories--well

91:3

category 110:3

134:12

Celia 2:5 8:2 32:8

59:15 61:11

62:22 67:5,6

121:6

cell 10:10

Census 162:1

centered 99:4

cents 45:9

certain 27:15

32:21 40:5,9

41:20 69:12

79:18 88:21

91:3 96:6 119:4

123:7,9 135:12

139:12 149:19

153:13

certainly 38:8

49:19 54:14

63:1,7 67:13

78:2 85:3

105:20 115:6

118:4 176:21,22

177:10

CERTIFICATE

183:1

certify 73:18

183:4

cetera 31:19 32:7

83:4

CFL 24:12 41:21

42:3,10 56:17

59:3 65:8

70:4,6,7 71:13

74:2 75:7,8

76:10 79:14

82:13 84:4

85:22 88:1

91:10 96:21

97:8 100:5

105:4,10,21

106:5 111:22

121:2,14 149:3

157:15 168:9

179:3

CFLs 18:14 22:18

32:5 39:5

41:11,12,13,15,

17,22 42:1,8,13

56:3,7,16,22

64:6,22 70:2

74:5 75:3,14

76:5 80:7 83:18

86:8 88:10

97:1,4 98:22

99:3 105:3,8,15

106:16 107:12

109:6,8,10

121:13 129:20

133:12 135:19

149:17 155:15

168:13

CFLs--of 105:2

CFR 68:15

chain 17:18

chair 49:4,7

challenge 143:9

challenges 65:2

78:12

challenging 64:3

chance 8:17 68:2

76:17

change 47:3

104:17 170:3

177:14
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changed 47:3

133:16

changes 115:12

175:9

channel 132:4

channels 81:20

128:4,10

132:6,8,15,17,1

9 133:7 135:4

136:13 167:6

characteristics

104:16 106:9

145:1 163:8

179:6

Characterization

146:13

characterize 81:3

152:10

characterizing

156:21

charge 19:15

charged 29:21

Charlie 2:18

91:13,14

106:18,19 109:2

147:12,13

166:13

176:10,11

177:21,22

Charlie's 148:16

cheap 155:8

check 49:13

choices 18:1

Cholnoky 3:5

choose 103:2,19

choosing 78:3

161:4

chosen 103:22

Christine 1:14

183:2,15

circuits 148:10

clarification

138:6

clarify 31:7 142:1

clarity 32:11

51:21

class 6:7 22:21

87:13

88:7,14,22

94:19 96:4,21

103:5,19,20

110:17 112:14

113:5,7 160:4

classes 22:17,18

51:8 77:15 81:1

87:5,7,14

88:5,20 89:11

90:12 91:8

93:11 94:9

96:14 97:5,18

103:3,12,13,17

107:3 109:17

111:12

115:12,15

123:22 124:2

144:9 162:19

classification

90:20

classifications

93:15 112:6

115:13,17,19

classified 110:15

clause 97:3

clear 38:11 44:20

54:18 68:10

94:19,20 111:21

112:3,19 136:2

178:20

clearer 115:18

clearly 44:22 45:8

57:7 164:15

clip 101:15

close 21:1 48:10

55:9 94:8

164:17

closely 18:7

166:19

closer 36:6 55:15

168:5 180:11

closing 4:18 9:19

181:17

coating 110:9

coatings 111:22

coefficients

163:20

coffee 101:20,22

Coke 102:1

colleague 18:21

24:22 43:2

143:22 159:16

colleagues 176:20

collect 28:14

130:15 134:7

137:6 150:4

collection 51:19

Colleen 3:3

4:14,15 8:4

143:22

145:14,16

159:19

color 93:14,15

145:5

colored 40:4

colorful 8:22

combine 130:21

152:17

combined 20:14

63:10

comes 21:19

166:19

coming 13:19

16:20 79:3

83:10

161:15,18,20

181:20

comment 10:22

12:5,6,8 13:18

14:5 15:21

42:16 44:14

53:19 55:19

56:5 59:3,6 63:1

64:8 65:20

66:22 68:2

70:15,17,19

71:2,7,14 72:16

74:11,19

77:5,13 79:7

83:21

88:6,8,11,13,15

89:11,14 90:1

91:16 93:3,14

95:21 97:11,12

98:3 100:10

109:16,19 116:2

117:2 118:10

121:22 122:1

123:1 124:13

131:13 132:8

135:6,8 138:22

139:7 146:19

147:22 149:15

150:15 154:17

155:2 162:11,13

164:4 167:18

174:19 176:5

180:13

commented 100:3

158:11

commenting

77:10

comments 9:5
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10:1

11:6,8,11,16,20

12:22 13:19,21

15:15,17

16:1,10,17 17:4

21:18 24:19

26:4,22

28:14,15,19

32:10 38:14

45:12 55:2

57:17 58:13

59:7 60:1 64:18

65:8 66:4

67:7,14 68:5

69:2 71:3,21

72:13 74:17

79:11 80:16

82:12 86:21

89:2 90:6 93:20

94:3 95:13 98:2

99:14,18,20

100:8,9,11,22

101:3 104:6

106:11 110:16

112:12,13

113:13,15

114:17 115:21

116:21 122:21

123:19

124:6,8,10,12,1

5,16 126:8

127:5,14 128:14

132:6,13 134:22

135:2 146:19,21

151:5 154:18

159:12 163:1

167:21 168:16

170:19,22

171:20 172:20

174:15

179:16,19,20

180:7 181:2,22

182:1

commercial 66:19

67:1 68:3 81:13

132:17 133:2,6

138:19,21 141:2

146:15 153:4

158:20

commercially

81:9 114:15

139:17 140:3

Commission 2:17

95:20 120:19

144:6

Committee 6:11

common 40:1

69:13

104:2,4,5,22

105:21 106:14

110:1

113:6,9,11

common--just

138:16

commonly

138:19,20

community 16:8

120:2

compact 24:3,5

28:9 39:4

41:7,10,14,18

42:17,18

companies

17:16,17 18:4

20:6 52:10

company 1:15

17:19

compare 136:13

compared

108:9,16 160:20

comparing 124:4

145:5

compatible 155:6

compensate

148:10

competitive 138:1

complete 10:7

48:16

completed 17:7

completely 53:13

complexity 78:6

compliance

27:13,18 29:3,4

73:18 116:17

117:3 123:1,5

152:6 160:11

compliant 20:8

46:7 142:17

complicated

64:15

complicating

166:6

comply 20:7

116:12

component

153:15

components 24:8

compounding

144:11

computational

152:11

computing 160:5

concept 33:9 63:6

141:7

concern 50:5,7

73:12 74:22

concerned 21:13

23:14 51:14

172:8 177:6

178:12

concerns 14:8

21:2 48:5 77:4,8

concise 10:9

concludes 29:12

concluding 40:14

conclusion

15:1,10 45:19

concur 16:16

24:22 72:15

166:14

concurrently 30:4

77:2 78:11,21

concurring 15:20

conduct 27:6

154:19 173:8

174:3,4

conducted

174:14,22

175:12

confident 137:9

confirm 30:15

96:11 171:5

confirming 149:4

confounding

34:14

confused 44:3

110:21

confusing 178:11

confusion

119:9,14 123:6

congratulate

17:10

Congress

19:14,19 37:10

62:10

connect 65:3

connected 19:3

connection 14:16

40:22 121:10

consensus 33:19

78:8 83:16
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conservation 1:5

5:6 77:12 87:12

151:10 163:2

169:3 182:13

consider 16:7

24:7,10 27:22

29:7,10 30:8,16

34:6 45:18,22

53:22 54:11,21

55:2 58:21 69:6

72:5 93:7 96:16

98:1 100:19,21

104:7 110:9

111:1,7 114:11

116:17

121:15,21

139:18 143:16

148:15 153:11

156:8 158:10

160:12 167:19

171:6,8 179:14

considerable 33:5

considerably

179:21

consideration

16:16 47:12

60:2 63:2

67:3,15 88:1,7

122:2 141:18

147:9 153:14

157:8 177:10

179:9

considered 22:14

42:5 70:18,20

81:21 86:15

87:18 88:15

99:9,10,17,22

112:20 117:20

139:17 140:1

169:4 174:16

considering 20:11

27:18 42:12

58:9,13 62:11

65:17 66:10

67:9 73:21

87:13 88:4

111:11 114:9,10

116:14 120:21

124:17 129:7

146:20 151:22

153:4 154:5,19

159:22 161:2

171:19,22

considering--the

132:10

consistent 80:12

125:15,22

126:12,13 127:1

137:3

Consolidated

14:14 40:20

constant 128:22

170:4 172:1

constrain 151:1

constrained

171:14

constraints 96:6

121:21 143:12

179:15

construction

66:14 171:7

consult 179:14

consultants 3:1

92:20 122:14

142:2

Consulting 3:4

4:7,8,9,10,12,13

,18 8:9,11,13

consumer 20:3

79:16 87:11

108:16,17

118:20

119:3,9,14,15,1

9 120:4 132:18

133:7 134:1,3

138:21 151:14

154:13 155:20

156:4 157:16,21

158:5,14 169:1

170:4 175:2

consumers 17:22

18:8,13 20:15

25:21 81:16

133:22 151:10

153:21

156:15,22

157:18 158:12

161:4,9

172:8,12

consumer's

151:12

consumes 79:20

consumption

19:1,7 51:7,16

146:12,16

152:8,17 170:18

176:2

contains 70:7

Cont'd 3:1

contend 165:17

content 9:8 26:4

38:15,16 181:15

context 63:18

continue 20:1

46:22 54:6 77:7

86:3

continued 19:20

continuous 21:12

116:15

122:13,15

contracts 128:6

133:3

contributors

136:6

control 170:15

controls 134:2

162:7

convenience

148:21 149:10

conventional 23:2

conversation 63:5

181:21

conversations

10:12 123:4

conversion 170:16

conversions 137:8

convert 125:4

Cook 2:8 7:5 32:1

110:20 111:8,17

117:6 122:7

148:7 149:14

155:1,10 166:5

177:12

Cooper 2:9,16

7:9,10

cooperation 26:20

copied 56:20

corner 102:2

corners 50:17

correct 93:18

115:6 142:16

correction 77:13

correspond 12:6

corroborate 109:2

cost 4:14 9:15

21:21 43:15

45:10 50:8,20

82:22 102:19

125:2 126:18

130:2,7,22

133:19 139:8

141:1 143:20

145:11 146:2
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151:8,13,19

152:20

153:1,2,22

154:1,5,13,14,1

6 155:3,14,19

156:4,13,21

157:16,21

158:3,5 159:4

169:11,14

170:12 175:1

costs 130:3,8

140:22

151:16,20

152:19

153:5,10,12,20

156:9 157:13

158:9,11 159:5

161:18 166:20

170:13

could--the 181:4

Council 2:10,19

7:13 108:22

counsel 8:3 14:9

179:15

count 12:10 89:20

counter 35:1

119:6

country 26:18

couple 17:3 57:1

58:3 74:18

180:14

course 6:10

11:7,14 13:14

28:18 37:21

82:6 97:22

106:4 162:4,17

170:9

Court 183:1,2,16

cover 72:6

87:18,19,22

89:10 93:21

104:12 112:18

coverage 4:7 9:9

38:22

covered 9:22

30:20 39:12

53:18 59:20

73:17 74:13

87:7 88:12,16

89:6 91:6 104:5

105:9 109:5,18

110:1,5,7,22

111:2,7,12,18

112:2,13 120:21

121:11,17

131:16 147:1

154:8 160:4

162:19 176:3

179:9 180:9

covering 89:8

90:5 112:14

covers 175:7

craft 30:18

create 123:15

174:4

created 130:20

creates 50:21

95:5,7 118:21

credit 18:3

Cree 52:11,17

CRI 144:8

criteria 69:14

73:15 81:6

99:9,19,21

114:2 140:13

criterion 107:2

cross-border

26:14

crossed 54:12

crosses 26:18

54:10

cumulative 85:19

86:7

curious 23:2,20

30:14

current 20:18

22:13 57:4

80:13 83:18

97:8 99:7 100:7

170:14 180:15

currently 23:22

26:1 41:9,16

42:9 65:14 74:3

98:15 129:7

143:1 163:4

curtails 41:2

curve 118:15

122:13,15

131:1,3 135:21

139:8

curves 21:7

130:14

135:6,10,11

137:16,20

144:13

customers

152:6,12

cut 80:7

cycle 24:9 27:9

47:11 102:19

cycles 27:7

Cymbalsky 2:4

4:2 5:12,13,14

78:22

D

D.C 1:10 5:9

data 11:22 40:13

48:16,22 50:7

51:19 52:5

54:13 67:14

80:14 82:9 84:5

91:20 106:21

109:1,3,7,9,11

116:18 117:3

123:2 130:15

134:8,18 141:19

143:3 146:10

147:16 148:6,16

149:4,12

150:4,7 161:22

162:5,20

163:10,11,17

164:10 167:5,13

182:4,5

database 91:19

116:20 123:6

data--or 48:13

dataset 52:12

date 27:13,18

29:3,4 160:11

182:6

Dave 122:21,22

155:11,12

David 2:9 7:6

day 9:20 102:4

105:6 181:2

days 94:17

dead 57:14

deadline 12:22

13:3 16:11

180:15

deal 38:13 179:4

debt 154:14

deButts 2:4 4:6,19

8:14 11:2,4 27:2

47:6,8 54:20

78:16,19 95:12

97:15 138:14

141:15 143:3,7

179:13 180:18
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181:9,16,18

deButts--sorry

47:6

decade 168:9

December 27:8

28:13 29:1,2,4

decide 150:10

decision 21:16

165:9

decisions 30:10

161:3 167:11

declare 63:12

decline 67:11

137:18

declining 129:1

138:2

decrease 171:9

decreasing 128:19

defense 2:10 7:13

165:2

defer 49:2

define 89:15 91:4

defined 41:9 42:9

65:15 153:16

definitely 14:1

15:13 47:12

79:1 100:21

105:18 134:21

159:11 179:13

180:20 181:9

definition

39:3,11,14,18

40:3

41:8,10,18,21

42:2,4,10,11,15

65:13,16,19,21

66:9 68:8,12,18

69:5,9 70:16

71:3 74:1 88:16

104:14 112:12

definitions

42:17,19 59:4,8

64:18 65:8

66:2,5 77:14,21

94:3 110:14

deLaski 2:12 4:5

15:18,19 16:15

24:22

36:4,7,18,22

37:16,22 38:2

43:2 46:18

48:11 50:4

55:5,10,12,17

56:2,5,11 57:21

58:16,21

59:11,17 60:3

61:8,16,19

62:3,6,10,20

72:14,15 94:6

108:14 126:7

138:5,6,12,16

139:3 142:9,12

143:5,9

157:11,22 158:6

165:2,5 181:4

delay 86:12,17

deliver 22:6 23:12

34:16

delivered 15:12

delivering 21:22

29:21 120:8

demographics

92:9,11

demolition 171:9

density 99:7

department 1:3,8

2:4,5 4:2 5:5,15

6:9 8:14 10:16

11:22 13:14,21

15:7,8 30:15

31:2 48:17

49:14 56:12

57:8 60:6

104:20 123:18

143:10 181:5

Department--I

77:17

Department's

14:17

depended 107:17

depending 33:11

104:17 129:17

depends 117:20

Depot 17:18 51:22

52:4 134:11

158:1

derive 154:11

derived 107:15

describe 138:9

158:8

described 23:8

56:13

describing 126:22

128:21

design 94:9

99:6,9,13 103:7

116:10 118:22

designed 36:1

41:22 90:16

designing 19:15

designs 114:11

124:15 127:11

146:1

despite 18:15

detail 65:3 74:16

103:16

detailed 14:22

77:13 105:1

123:19 160:17

details 159:21

determination

4:12 9:14 21:14

22:15 23:15,21

56:15 102:15

125:7,12

127:17,19,21

130:22

determine 40:8

81:1 99:12

102:16 115:14

124:3 145:22

146:8,20 152:12

153:18 154:9

156:19 157:18

168:22 169:13

determined 22:12

103:8 124:2

126:4 155:15

determines 39:8

151:9 175:5

determining

125:12 137:18

154:5

develop 116:9

121:9,13 123:22

128:8 137:3

139:8 144:12

145:2 146:9

167:5 169:5,10

developed 74:7

125:2 133:5

146:6

developing 59:7

66:2 71:3 73:21

100:8 116:15,22

125:9 130:14

137:10

development

66:14 139:11

develops 103:9
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126:16

device 178:20

differ 45:7

difference 44:7

130:4

differences

106:12 140:21

152:2

different 17:20

34:4,11,18

44:21 47:21

53:13

55:6,13,18 58:3

86:8 87:10

89:12 94:21

100:17

107:5,6,7

108:4,7,15

111:11 113:21

119:13 120:7,21

121:1 122:17,18

135:9,20,21

143:1 149:9,18

151:11 153:11

154:7 162:21

166:21 175:11

179:21

differentiate 96:5

differently 112:17

149:8 150:3

difficult 49:20

164:16,21

166:12

difficulty 164:6

diffuse 66:12

111:22 112:4

dim 90:18 149:17

dimmability 88:9

89:16 104:13,14

dimmable 88:12

89:15,18,21

90:17 91:4

104:3,21

105:5,11,21

106:2,5,6,13,16

150:5

dimmable/nondimmable

90:13

dimmed

90:16,19,20

148:12

dimmer 105:5

155:6,7

dimmers

150:8,10,20

162:9

dimming 89:20

148:10

149:19,22

150:2,16,22

151:3

diode 39:6,7 68:19

dioxide 175:16,19

direct 40:8 76:6

133:3 155:16

173:16 175:12

directed

27:6,10,22 29:8

direction 183:6

directions 73:4

directly 9:9,13

103:13 126:4

177:2

director 7:22

directs 27:12

disagree 43:5

67:13

disagreeing 36:8

disappointed

19:19

discontinued

40:10

discontinuities

21:10

discount

136:15,17,18

152:18 154:9,12

170:6

discounted 151:15

discounts 128:2,9

136:19 137:8

discretionary

165:9

discuss 11:18 12:4

24:15 65:2

80:19 102:15

152:21

discussed 39:17

70:19 74:7

152:16

discussing 38:22

98:11 102:13

125:11 164:9

182:1

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86:13

discussions 6:4

13:16 16:3 84:3

115:11

discuss--so 173:7

displayed 78:12

disposal

153:20,22 154:1

157:13

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distinctions 97:5

distinguish 68:10

130:2

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81:20 128:3,9

132:4,6,8,15,16,

21 133:1 134:19

135:3 136:13

146:9 152:5

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152:10

distributors 47:19

128:6 132:11

133:3

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divide 32:3

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divisions 88:5,7

do--and 84:7

docket 12:15

19:10,14 23:17

51:20 60:18

62:12,15 64:12

126:9,11 131:20

143:15 150:9

docket--and 19:12

dockets 23:16

51:11 130:8

143:2,13

document

12:7,13,14 15:2

16:2,21 22:22

28:13 32:14

42:21 76:1 93:4

documents 28:17

DoE 2:3 4:6,19

8:2 10:8 12:16

14:22 19:12,15

20:10,21 21:5

22:11,15,19

23:3,7,20

24:4,7,9,11

27:6,9,12,21
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37:2,6,17

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41:4,9

42:7,12,16

45:18,19,21,22

47:8,9 51:11

53:19 54:11,21

56:14 58:4,8

59:12,19

60:16,18 61:5,8

62:13 64:9,12

65:15,16,20

66:9,22 68:2,8

69:6,13,18

70:2,11,15,16,1

8 72:4

73:1,10,21

74:7,11 75:21

76:22

81:3,4,7,18 82:9

83:11

87:6,11,13

88:4,6,8,10,13,1

5,22 89:15

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94:12 96:11

97:3,11 98:14

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103:1,3,6,8,11,1

8 104:1,7,15

108:11 110:2

113:5,8,10,13

114:7,11,14,17

116:9,17,20

122:13

123:4,10,21

124:3,6 126:16

128:2,8,18

134:7 141:18

142:2

146:8,19,21

147:8 149:11

150:4,19 151:22

153:2,6,9,18,19

154:1,4,9,11,18

160:15 165:5,10

167:5,9,11,14

173:8,19,22

174:2,4,8,10,14,

16

175:1,4,14,17,2

2 179:6 180:16

DoE's 14:13 16:22

19:18 20:12

21:13,16 22:17

23:4,15 41:1,13

43:5 56:6 58:1

73:16 95:1 97:9

116:14 128:4

129:6,10 136:2

146:11,12

159:22 165:2

do-it-yourself

134:12

dollar 50:8

dollars 128:19

170:5

dominant 33:8

done 16:11 33:20

77:21 78:5

92:16 101:11

105:1 110:2

122:14 126:9,11

129:8 163:21

door 8:21

double 49:13

135:14

doubling 135:16

Doug 2:2 5:13

11:5 13:5 96:9

145:16

download 92:16

downloadable

91:19 92:12

downstream

102:19 179:22

dozen 43:17

dramatically

83:10,16 166:8

drawing 178:21

driven 75:9

driver 92:21

93:8,17,18 95:6

99:6 118:11

drivers 93:5

drop 121:5,12,18

144:8

145:3,6,9,11

158:2

dropped 144:2

dropping 166:8

drops 121:10

drugstores 132:20

due 18:3 43:21

47:11 71:15

94:17 101:6

123:6

175:3,9,17,19

durable 108:18

durables 108:16

during 21:4 35:15

64:9 70:4

dynamic 85:4

E

earlier 27:21 47:9

57:18 64:8 67:7

71:22 95:21

109:22 110:14

121:20 149:17

155:17 158:11

165:16 171:5

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easier 12:2,11

164:19

easily 43:8

Easton's 2:9,16

easy 32:22 64:1

Eaton's 7:8,10

echo 118:10

Eckman 108:22

economic 160:19

169:7

economically

67:12

economics 107:22

economy 2:20

165:15

educating 119:19

120:4

education 17:21

119:16

effect 25:3 31:18

44:20,22 53:12

57:5 72:8 79:8

119:7 120:14

164:7,8

165:13,16

168:11 177:15

178:15 181:11

effectively 16:5

effects 164:11,15

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efficacies 103:11

124:4

efficacious 103:7

113:6,9,11

114:11 115:1,8

116:8 118:18

147:6

efficacy 66:20

81:3 88:3,10

98:12 99:4,11
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127:20 130:18

efficiencies 30:21

152:5

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22:6,10 31:9

73:19 75:4,7,16

81:19 91:15

93:13 98:13,19

99:1 115:3

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126:18

130:14,22 131:3

139:8 144:13,14

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160:5,6

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179:5,8

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43:22 115:4

130:6,8,9

133:12 146:1

149:5 181:14

effort 17:16 64:3

120:3

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103:21

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EIA's 153:7

eight 88:4

EISA 17:9,13

19:8,14 22:7

27:6 28:2 40:7

46:7,10 53:8,14

109:5 118:16

165:7

elaborate 106:11

electric 2:11

77:11

electrical 7:2

128:6 132:11

133:2

Electronic 2:7,15

electronically

12:17

Electronics 2:8,15

52:22 128:18

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149:10

elements 24:10,12

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else 97:12 143:19

elucidate 75:2

104:20

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emerging 66:18

105:4

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175:14,15

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emitting 39:6,7

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employment

173:16

175:7,8,11,13

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enclosure 87:20

112:18

encourage 11:6,10

45:18 59:22

64:13 122:13

157:8 172:6

End-Use 146:11

end-user 102:17

125:4,12 127:20

136:21

energies 169:11

energy 1:3,5,8

2:4,5,17,18,20

4:2,13 5:5,16,20

7:15 8:15 9:14

13:16 16:8 18:9

19:1,4,6 21:22

22:6 32:22

33:11 34:15

51:7,16 56:20

57:1,4 58:10,11

77:12 80:8,10

86:1 87:8,12

91:15 92:2

95:19 98:13

107:14 115:2

120:19 143:20

144:5 145:20,22

146:8,14,15,20

150:6 151:9,19

152:8,15,17,19

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161:12,13,21

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169:1,3,6,13,15,

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170:10,12,14,17

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177:16 178:3

182:13

Energy's 5:5

10:16

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enforcement

80:14

engaged 35:19

engaging 59:19

engineering 4:11

7:22 9:13 87:6

99:11 102:13,14

103:2

124:13,18,19

125:1,10

127:12,18 128:1

130:21 139:19

140:1 146:6

161:17

enlarge 133:14

ensure 100:6

entailed 20:8

enter 120:7 123:6

entered 123:9

entire 17:11,17

62:12 92:3,8

entirely 17:20

135:20

entity 31:3

enumerated 73:4

environment

20:17

Environmental

2:11 7:15

envisioned 63:6

envisions 22:19

EPA 168:2

EPACT 24:5,6

57:10

EPCA 27:5 29:8

67:11 73:14

97:8

equal 23:13 28:3

114:12 136:5
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Equation 21:8

equation-based

117:1,17 118:3

equations 21:7

116:15 118:13

equipment 156:13

equity 154:16

equivalent 29:21

33:10 35:20

36:12,17 53:22

63:14,22

equivalents 25:7

error 21:16,17,18

123:7

escalate 26:1 83:9

especially 68:11

90:12 123:18

141:1

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establish 29:11

30:1 117:3

127:21

established 27:14

establishes 87:11

establishing 87:13

115:2 116:3

establishment

87:5 123:14

estimate 139:9

147:15 150:19

153:8 154:1,13

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173:14 175:15

estimate/guess

164:20

estimates 81:20

164:22

estimating 84:19

estimations 84:8

et 31:19 32:7 83:4

Europe 122:14,17

evaluate 11:15

24:12 27:7

37:2,6,18 60:6

61:9 62:17

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evaluated 89:4

182:7

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61:5

evaluating

22:11,16 27:15

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evaluation 61:15

ever-increasing

84:13

everybody 6:2

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109:9

everyone

5:4,10,16,18

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everything 35:9

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exact 49:20

129:16,22

exactly 43:20

44:11 77:6

164:10 178:6

examine 21:15

98:15 173:16

example 41:11

43:10 52:3 53:2

60:16 70:2,6

72:3 96:3,18,20

110:4 113:20

134:9 162:9

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Excellent 163:19

164:2

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exchange 38:10

excitement 71:12

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excluding 66:10

67:10

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excuse 32:9

exempt 39:13

40:12,14

exempted 21:15

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41:20 42:22

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53:9,17

54:2,6,17 55:1

72:19 73:11

exemption 40:16

exemptions 27:15

40:9 42:8

exist 163:4 179:4

existing 24:7

27:15 28:8

41:13 58:1,2,17

63:10 66:20

68:8 74:2 76:15

98:1 113:8

142:17

171:13,16

exists 6:8

expand 51:3 131:6

133:6

expansion 50:18

expect 94:2

expectation 43:14

expected 82:21

140:21 141:2

152:5 160:11

161:8

expecting 180:17

expects 153:2

expenditures

175:9

expensive 172:13

experience

135:6,10,11,13,

21 137:16,19

experienced 40:15

explain 92:15

explanation 15:1

explicitly 100:20

exploitation

50:12,19

explore 83:20

exponentially

128:19

extend 68:21

extending 72:5

extension 13:17

15:21 180:14

extent 177:6

external 90:5

93:17 153:13
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externally 41:12

75:3,9 87:17

90:13,21

91:9,11 92:22

93:16 104:3

extra 87:20

extracting 170:1

extrapolated

128:13

eye 61:1

F

face 18:1

FACILITATOR

2:1

facilities 156:11

fact 26:8 55:8

84:21 109:11

148:16,19

149:16 166:7

factor 24:11

58:7,22 87:18

88:1 105:22

112:14

148:14,22

149:8,20 166:6

176:16,17

177:8,14,18

178:13,16,17,20

179:10

factors 29:8 58:9

87:15 88:3,14

93:12 107:21

116:10 124:3

170:16

Facts 116:20

fails 84:10 153:21

157:13

failure 171:16

fair 82:20 148:9

fairly 32:22 55:8

64:15

fall 74:8 94:14

110:10,11,17

falling 101:16

falls 110:4 121:20

familiar 160:21

fascinating 18:22

fashion 167:14

faster 166:9

fault 77:10

favor 156:7

feasibility 81:8

82:20 83:3

feasible 103:10

feat 26:13

features 58:6

87:9,10 144:9

fed 87:6

federal 6:10 47:1

163:3 168:2

181:7

feedback 140:16

173:22 174:17

feel 14:4 137:9

150:15

Feit 53:3

felt 118:16

fewer

158:15,16,18

field 106:21

147:16

figure 48:19 85:5

139:20 145:10

figures 47:2

filament 98:22

100:15

filament-based

83:18

filaments 43:14

fill 38:7,9 99:1

171:13

filled 84:18

filling 171:19

final 26:22 27:10

28:2 29:2 56:16

72:12 86:21

88:1 115:21

122:20 135:2

151:4 152:20

finally 27:21

103:11 123:21

164:8

financial 83:3

154:13 159:8

174:6 183:10

finding 71:17

fine 8:18

finely 15:14

finish 101:11

firm 158:22

first 10:4 13:13

21:5 27:9 66:11

69:21 77:22

84:15 85:8

87:16 90:1

103:2 118:9

139:8 153:1

157:17 172:14

174:5 180:6

fit 22:20 88:21

89:13 90:9

115:15

fits 76:15

five 40:12,14 54:6

80:9 109:8

fix 77:20

fixture 76:15

91:22 92:1,5

155:18,22

156:1,5

fixtures 76:18

134:2

flag 97:11

flat 35:16 64:4

66:15

flavors 47:21

157:3

fleet 30:19 32:4

35:5 36:1 75:18

flexibility

20:13,14

floor 101:20

flow 173:21 174:9

flows 154:10

fluorescent 24:3,5

28:9 39:5,15

41:7,10,15,18

42:17,18 75:8

125:16 126:2

focus 10:10

103:20

focused 73:1

95:22 122:9

171:12

focusing 119:16

172:15

folks 10:17 178:1

follow-up 172:5

fore 180:11

forecast 108:10

139:14 161:14

163:8 170:11
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forecasting

160:14 162:14

168:15

forecasts 161:13

162:6 163:7

170:15

foregoing 183:3

forgetting 56:19

Forrestal 5:9

101:18

forth 38:12 73:14

fortunately

165:21

forward 45:3

85:11 108:10

181:15

fossil 170:1

fraction 162:9

framework 1:5

5:6 12:7,13,14

15:2 16:2,21

20:9 21:5

22:12,22 23:6,7

27:8 28:13

30:10 93:4

97:20 110:7

112:21 181:15

182:14

Francisco 43:12

freely 26:19

friends 26:8

from--and 56:20

front 162:6

frosted 110:9

111:15 112:19

fuels 170:1

full 25:15 164:15

full-fuel-cycle

169:21,22

170:17

function 118:16

119:12 120:10

122:11

functionality 70:8

functions 21:12

funders 176:13

177:5

funds 14:16 40:22

furthermore

75:13

future 53:20

80:14 81:19

108:4,7 122:8

129:13 139:9

153:8 160:3,14

164:18

G

gaming 21:10

gap 13:20

gases 99:1

gather 136:3

140:15

gathered 136:8

gathering 84:5

Gatto 2:9 7:6

122:22

155:12,13

GE 7:20 52:2

79:15 105:19

117:16

general 1:6 2:11

5:6,17 8:2 11:15

15:2

39:2,3,5,10,14,1

5,17,20 41:5

42:2,5,13

60:7,10,12,13

65:12,14,18,21

66:17 67:2 68:4

69:10,20 70:10

72:16 74:19

75:14 76:8

91:16 94:7

100:4 103:1

124:13 125:15

126:2 132:22

135:15 146:10

150:4 156:7

158:9 160:8

162:11 163:1

169:5 175:5

182:14

generally 21:9

66:17 67:17

93:7 106:2

125:2 133:22

135:12

170:19,22

generate 51:10

130:17

generating 178:22

generation 157:7

176:15

178:2,7,8,16

generically 157:5

Gerke 3:3 4:16,17

8:6 30:6 86:11

129:4 148:1

159:16,19,20

163:13,18,21

167:16 168:20

171:18 172:18

173:2 176:21

177:9

gets 14:3 19:17

24:2 79:8

149:12

getting 50:20,21

78:4 120:5,9,12

GFLs 127:3

given 15:22 25:6

33:6 75:2

115:15 116:13

160:15

gives 44:9,10

122:10

glad 5:10 77:19

182:8

glass 87:20

112:3,4

going-in 62:17

gone 17:21 25:1

57:1 77:3 158:2

172:11

gotten 18:8

government 47:1

173:19

grasp 48:15

great 11:21 13:22

15:7 98:4 101:1

120:12 135:1

142:6 147:19

greater 28:3

114:13

greatest 50:11

Green 2:9 7:10

GRIM 173:20

grocery 132:20

134:17

ground 10:4

101:20 170:2

group 33:18 117:8

grow 76:18

growing 60:21

growth 40:15 43:4

161:14 162:21

GSFL/IRL

126:11 161:1
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GSFLs 42:14

GSIL 42:4,15

65:19 69:9,14

70:12,13 123:8

GSILs 39:4,19

41:4 59:21 69:8

74:1 98:20

GSL 39:19 40:18

41:8 65:13 66:9

69:6 74:1 81:4

153:21 154:12

157:13

GSLs 27:7 28:4

87:14 97:7

98:12 145:21

151:22 152:4

153:2,10,20

159:18 162:18

163:3

guaranteeing 84:8

guess 16:20 37:16

38:13 48:17

51:8 55:10

94:15 96:8,12

110:21 126:15

guesses 164:22

guidance 94:13

160:15

guys 31:14 36:8

94:16

H

habit 78:14

half 25:4 109:6

176:17 177:19

halfway 101:9

halogen 18:10

32:6 70:3,5

85:21 86:5

100:14 106:4

129:20 149:1

halogen-type

39:20

hand 10:19 95:16

120:16

handing 173:2,4

handle 26:11 93:2

hands 143:14,17

hang 101:21

happen 50:16

54:1 108:6

happens 109:12

115:5

happy 5:18

162:15

hard 10:16

34:2,20 35:12

36:13 88:20

89:11 115:13

158:17,18

hard--if 155:21

hardware 134:12

hardwire 155:22

harmful 20:2

harmonize 26:9

has--every 109:10

haven't 9:21

25:4,15 105:1

have--that's

111:11

have--the 18:10

have--you 119:1

having 19:9 62:15

71:17 90:5

119:7 178:21

head 142:19

health 81:17

hear 10:21 16:3

23:9 86:10

102:10 105:6

106:7 145:14

162:16 179:16

180:18 182:9

heard 50:9 111:14

heavens 49:9

help 13:22 17:22

89:21 99:12

167:2 181:8

helped 30:18

helpful 15:22

104:10 105:18

106:11 116:5

151:1 167:17

helping 82:9

166:1

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hereby 183:3

Here's 15:18

he's 32:7

Hey 49:16

hi 95:18 102:11

120:18 121:6

HID 78:3

high 103:22

104:16 128:10

136:18,19

high-efficiency

85:9

higher 73:8 98:19

99:1 114:7

133:19 151:20

highest 114:22

115:5,7

highlight 21:1

high-output 22:4

hindrance 20:19

historical

129:11,12

142:14 161:22

162:18

163:10,11,17

168:15

history 27:4 29:13

166:10

hit 82:16

hitting 63:13

hold 84:21 127:6

128:21

holidays 13:20

home 17:18 51:22

52:4 109:4,5

128:6 132:11

134:11 157:22

homes 108:18

109:13 172:1,7

homes--but

107:12

honor 46:22

hope 17:5 20:20

21:2 24:15

38:10 72:4

83:11,19 84:9

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13:1 32:12

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44:5,7 45:5 50:1
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68:6,14,16,20

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hours 86:1 91:22

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household--

particularly

158:17

households 92:10

houses 92:4

107:10

how--it's 105:6

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32:15 33:15

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4:12,13,18 8:12

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importantly

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hardware 128:7

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incandescent

14:17 20:11

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included 39:18

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21:21,22 141:1

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intention 123:1

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interchangeably

93:6

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44:21 45:1

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jobs 20:7
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32:15 33:13

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larger 64:5 72:20

last 18:21 19:21

24:1 30:16

45:21 46:15

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lifetime 107:17

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lifetimes 84:13

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85:8

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68:19

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66:19 167:2
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linear 119:12

list 42:4 78:3

98:20,22 99:3

100:21 133:4

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50:13,19

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lowest 45:10

lowest-cost 43:19

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8:14,18 11:2

27:1 47:6,7,8

54:20 78:16,18

79:9 95:11

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179:18

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lumen 34:16,20

39:22 69:11

72:2,5 73:8

114:12 119:4

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120:13

lumens 6:1

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30:17,22 31:9

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1 36:14

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machine 102:1

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mainly 161:16

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153:10,11

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manager 4:6,19

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manufactured

107:11

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13:13 50:20

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manufacturers

6:6 17:10

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25:10,21 26:15

27:20 28:20

47:18

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market 4:9 9:10

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okay 6:17 8:16,18

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procedural 11:14

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93:11 94:9,19

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97:5,18 102:15

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108:16 109:17

110:17 111:12

112:14 113:5,7

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123:22 124:2

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140:7,9 141:2

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132:1
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28:12 40:13

128:18 153:19

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pull 14:1 168:5

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satisfying 28:7

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21:20 29:7 39:2

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severely 173:15

shape 39:13 87:21

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