# STATE 

# OF NEBRASKA

Dave Heineman Governor

TO:
FROM: DATE: 

### R,E: MEMORANDUM NEBRASKA ENERGY OFFICE Ginger Willson Director 1111 "0" Street, Suite 223 P,O. Box 95085 Lincoln, Nebraska 68509-5085 Phone 402-471-2867

Fax402-471-3064 energy@nebraska.gov www.neo.ne.gov

John Cymbalsky, U.S. Department ofEnergy, Office ofBuilding Technologies Ginger Willson, Director, Nebraska Energy Office November 28,2011 Meeting regarding DOE Energy Conservations Standards for Battery Chargers
Inpreparation for the Friday, December 2, 2011, meeting scheduled for 1:30 pm, please find below additional information related to the meeting request. Specifically, the listed participations would like to discuss the U.S. Department ofEnergy (DOE) Energy Conservation Standards for Battery Chargers.

The following will participate inthe meeting: (1) Ginger Willson, Director oftheNebraska Energy Office (2) Luke Prussa, Director ofSales and Marketing for Lester Electrical, Inc. (3) Spencer Stock, Product Marketing Manager for Lester Electrical, Inc.



### Request: ClassifY GolfCars asNon-ConsumerProducts • The DOEbattery charger efficiency regulations cover only consumerproducts. • According to the DOE, the statutory definition ofa consumer product: "is any article other than an automobile, as defined in section 32901 (a)(3) oftitle 49, that consumes energy or water and which, to any significant extent, is distributed in commerce for personal use or consumption by individuals." • Since over 90 percent ofnew golfcars are sold to commercial or industrial businesses, primarily golfcourses, we disagree with the current classification ofgolfcars as consumerproducts.

AnEqual Opportunity/AffirmativeActionEmp/oyer Printed with soy Ink on recycled paperNovember 28,2011 Page 2 Questionable Balance of Cost vs. BenefitDerived from ProposedStandard for GolfCar Applications • Lester Electrical products have enabled the conversion ofcommercial and industrial vehicles to "green" electric power from internal combustion engines for almost 50 years. • Lester Electrical has invented and pioneered many battery charging innovations that have improved energy efficiency, including the invention ofthe DVIDT charge termination algorithm, which made possible chargers that automatically terminated whenthe battery is fully charged, eliminating wasted overcharge and AC energy consumption. • The market forces inplay when supplying commercial and industrial customers have resulted in golfcarbattery chargers naturally evolving to high-efficiency designs, in comparison to true consumer products, for example: o Golfcarbattery charger efficiency (typical): 80-84 percent o Electric tooth brush battery charger efficiency (typical): less than 10 percent • National energy savings potential for golfcar battery chargers (Class ID 7) is only 9 Trillion BTU for Candidate Standard Level (CSL) 1, which is the lowest ofall battery charger Class IDs and represents less than 1percent ofthe total national energy savings potential for all battery chargers. • Over halfofthe golfcarbattery chargers that are sold each year inthe United States use Silicon-Controlled Rectifier (SCR) technology. This is a technology that is often selected for commercial and industrial applications because it offers excellent reliability, longevity, durability, and ruggedness, as well as very good efficiency. However, SCR technology will likely be unable to meetthe CSLs beyond CSL 0 (Baseline), which will eliminate this important battery charging technology for golfcar applications. Lossof

## u.s. Jobs • The primary battery chargertechnology that Lester Electrical designs and manufactures atthe facility in Lincoln, Nebraska, Silicon-Controlled Rectifier (SCR), will likely be unable to meet the CSLs beyond CSL 0 (Baseline). • This will result inthe loss of50 to 100 U.S. jobs as Lester Electrical would be required to transition the golfcarbattery charger designs to Switch Mode technology that currently requires foreign manufacturing in Asia in order to be cost competitive. AboutLesterElectrical • Lester Electrical is a leading industrial and commercial battery charger manufacturer. • Since 1963, Lester Electrical has been designing and manufacturing battery chargers and other electrical power conversion and storage products in Lincoln, Nebraska. • Lester Electrical is a vertically-integrated company. o Lester Electrical designs and manufacturers nearly every component inthe pro4ucts in-house in a 90,000 square foot facility inLincoln.November 28, 2011 Page 3

• Lester Electrical employs over 250 Americans and have steadily addedjobsthis year. • Lester Electrical's U.S. made products compete primarily with imported products manufactured in Asia. • Lester Electrical is one ofthe industry's highest volume manufacturers. • Lester Electrical Quality Management System is registered to ISO 9001 standards and they assemble printed circuit boards per IPC guidelines.



### References Battery Charger and External Power Supply Rulemaking Docket Number EERE-2008-BT-STD-0005 Regulatory Information Number (RIN) 1904-AB57 Webpage: http://www1.eere.energy.gov/buildings/appliance standards/residential/battery external std 200 8.html Preliminary Technical Support Document: http://www1.eere.energy.gov /buildings/appliance standards/residential/pdfs/bceps preanalysis t sd.pdf Reportto Congress: http://www1.eere.energy.gov/buildings/appliance standards/pdfs/2010 aug report to congress. 

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Thank you for your time and consideration.