MEMORANDUM

TO: John Cymbalsky, U.S. Department of Energy, Office of Building Technologies

FROM: Ginger Willson, Director, Nebraska Energy Office

DATE: December 12, 2011

RE: Meeting regarding DOE Energy C onservations Standards for Battery Chargers

Following the Friday, December 2, 2011 meeting, pleas e find below participants and discussion points presented relating to the U.S. Depa rtment of Energy (DOE) Energy Conservation Standards for Battery Chargers.

The following participated in the meeting:

(1) Ginger Willson, Director of the Nebraska Energy Office (2) Luke Prussa, Director of Sales and Ma rketing for Lester Electrical, Inc. (3) Spencer Stock, Product Marketing Manage r for Lester Electrical, Inc.

Request: Classify Golf Ca rs as Non-Consumer Products

 The DOE battery charger efficiency regul ations 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 c onsumption by individuals.”

 Since over 90 percent of new golf cars are so ld to commercial or industrial businesses, primarily golf courses, we disagree with the current classification of golf cars as consumer products.December 12, 2011 Page 2

Questionable Balance of Cost vs. Benefit De rived from Proposed Standard for Golf Car Applications

 Lester Electrical products have enabled th e conversion of commercial and industrial vehicles to “green” electric power from intern al combustion engines fo r almost 50 years.

 Lester Electrical has invented and pioneered many battery charging i nnovations that have improved energy efficiency, including the i nvention of the DV/DT 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 supplyi ng commercial and industrial customers have resulted in golf car battery chargers natu rally evolving to high-efficiency designs, in comparison to true consumer products, for example:

o Golf car battery charger effici ency (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 (C SL) 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. Th is is a technology that is often selected for commercial and industrial applications because it offers excellent reliability, longevity, durability, and ruggedness, as we ll as very good efficiency. However, SCR technology will likely be unable to meet th e CSLs beyond CSL 0 (Baseline), which will eliminate this important battery chargi ng technology for golf car applications.

Loss of U.S. Jobs

 The primary battery charger technology that Le ster Electrical desi gns and manufactures at the facility in Lincoln, Nebraska, Silic on-Controlled Rectifie r (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. j obs as Lester Electrical would be required to transition the golf car battery charger designs to Switch Mode tec hnology that currently requires foreign manufacturing in Asia in order to be cost competitive.

About Lester Electrical

 Lester Electrical is a leading industrial a nd commercial battery charger manufacturer.

 Since 1963, Lester Electrical has been designi ng and manufacturing ba ttery chargers and other electrical power co nversion and storage products in Lincoln, Nebraska.

 Lester Electrical is a ver tically-integra ted company.

o Lester Electrical designs and manufact urers nearly every component in the products in-house in a 90,000 square foot facility in Lincoln.December 12, 2011 Page 3

 Lester Electrical employs over 250 Americans a nd 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.

Request for grant information rela ted to Research and Development

 If possible Lester Electrical, would request information on research and development grants DOE has available.

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/build ings/appliance_standards/resi dential/battery_external_std_200 8.html

Preliminary Technical Support Document: http://www1.eere.energy .gov/buildings/appliance_standards/resi dential/pdfs/bceps_preanalysis_t sd.pdf

Report to Congress: http://www1.eere.energy.gov/bu ildings/appliance_standards/ pdfs/2010_aug_report_to_congress. pdf

Thank you for your time and consideration.