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 

Fax 402-471-3064 

energy@nebraska.gov 

www.neo.ne.gov 

John Cymbalsky, U.S. Department of Energy, Office of Building 

Technologies 

Ginger Willson, Director, Nebraska Energy Office 

November 28,2011 

Meeting regarding DOE Energy Conservations Standards for Battery 

Chargers 

In preparation 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 of Energy (DOE) Energy Conservation 

Standards for Battery Chargers. 

The following will participate in the meeting: 

(1) Ginger Willson, Director ofthe Nebraska Energy Office 

(2) Luke Prussa, Director of Sales and Marketing for Lester Electrical, Inc. 

(3) Spencer Stock, Product Marketing Manager for Lester Electrical, Inc. 

Request: ClassifY Golf Cars as Non-Consumer Products 

• The DOE battery charger efficiency regulations cover only consumer products. 

• According to the DOE, the statutory definition of a consumer product: 

"is any article other than an automobile, as defined in section 32901 (a)(3) of title 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 of new golf cars are sold to commercial or industrial businesses, 

primarily golf courses, we disagree with the current classification of golf cars as 

consumer products. 

An Equal Opportunity/Affirmative Action Emp/oyer 

Printed with soy Ink on recycled paper 
November 28,2011 

Page 2 

Questionable Balance of Cost vs. Benefit Derived from Proposed Standard for Golf Car 

Applications 

• Lester Electrical products have enabled the conversion of commercial 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 of the DVIDT charge termination 

algorithm, which made possible chargers that automatically terminated when the battery 

is fully charged, eliminating wasted overcharge and AC energy consumption. 

• The market forces in play when supplying commercial and industrial customers have 

resulted in golf car battery chargers naturally evolving to high-efficiency designs, in 

comparison to true consumer products, for example: 

o Golf car battery charger efficiency (typical): 80-84 percent 

o Electric tooth brush battery charger efficiency (typical): less than 10 percent 

• National energy savings potential for golf car battery chargers (Class ID 7) is only 9 

Trillion BTU for Candidate Standard Level (CSL) 1, which is the lowest of all battery 

charger Class IDs and represents less than 1 percent of the total national energy savings 

potential for all battery chargers. 

• Over half of the golf car battery chargers that are sold each year in the 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 meet the CSLs beyond CSL 0 (Baseline), which will 

eliminate this important battery charging technology for golf car applications. 

Loss of u.s. Jobs 

• The primary battery charger technology that Lester Electrical designs and manufactures 

at the facility in Lincoln, Nebraska, Silicon-Controlled Rectifier (SCR), will likely be 

unable to meet the CSLs beyond CSL 0 (Baseline). 

• This will result in the loss of 50 to 100 U.S. jobs as Lester Electrical would be required to 

transition the golf car battery charger designs to Switch Mode technology that currently 

requires foreign manufacturing in Asia in order to be cost competitive. 

About Lester Electrical 

• 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 in the 

pro4ucts in-house in a 90,000 square foot facility in Lincoln. 
November 28, 2011 

Page 3 

• Lester Electrical employs over 250 Americans and have steadily added jobs this year. 

• Lester Electrical's U.S. made products compete primarily with imported products 

manufactured in Asia. 

• Lester Electrical is one of the 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://www 1.eere.energy. gov /buildings/appliance standards/residential/pdfs/bceps preanal ysis t 

sd.pdf 

Report to Congress: 

http://www1.eere.energy.gov/buildings/appliance standards/pdfs/2010 aug report to congress. 

oM 

Thank you for your time and consideration.