Date: November 21, 2014

Case: External Power Supply Test Procedure NOPR Meeting

11-HIN

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External Power Supply Test Procedure NOPR Meeting

November 21, 2014

External Power Supply Test Procedure NOPR Meeting

U.S. Department of Energy

1000 Independence Avenue, SW

GC-61 Room 6E-066

Washington, DC 20585

Friday, November 21, 2014

The above-entitled matter convened at 9:02

a.m., Doug Brookman, moderator.

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1 APPEARANCES

2 DOUG BROOKMAN — MODERATOR

3 DEPARTMENT OF ENERGY STAFF:

4 MICHAEL KIDO, DOE

5 STEVEN GOERING, DOE

6 ASHLEY ARMSTRONG, DOE

7 JEREMY DOMMU, DOE

8 CHRIS SKAHAN, NAVIGANT CONSULTING

9 SRIRAM GOPAL, AHAM

10 DON MOYER, CONSUMER ELECTRONICS ASSOCIATION

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11 BLAKE RINGEISEN, LBL

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13 LARRY ALBERT, BLACK & DECKER

14 ALEX BOESENBERG, NATIONAL ELECTRICAL

15 MANUFACTURERS ASSOCIATION

16

17 SUSAN L. CALLAHAN, OSRAM SYLVANIA

18 KEITH COOK, PHILIPS

19 S. PEKKA HAKKARAINEN, LUTRON ELECTRONICS

20 JOHN A. HODGES, WILEY REIN, LLP

21 CHRIS HOLSTEIN, PANASONIC

22 ERICA LOGAN, INFORMATION TECHNOLOGY INDUSTRY COUNCIL

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November 21, 2014

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1 PROCEEDINGS

2 MR. BROOKMAN: Good morning. Welcome.

3 This is the Test Procedure Notice of Proposed

4 Rulemaking for External Power Supplies. Today is

5 November 21, 2014 here in the Forrestal Building in

6 Washington, D.C.

7

My name is Doug Brookman, Public

8 Solutions, Baltimore. Nice to see you here this

9 morning. We're going to start with welcoming remarks

10 from Jeremy Dommu.

11 MR. DOMMU: Hi everyone. Thank you for

12 being here. I am Jeremy Dommu. I am the project

13 manager that oversees DOE's rulemaking activities as

14 it relates to external power supplies. I appreciate

15 all of you being here in attendance, and I know there

16 are many folks logged in on the Webinar as well.

17 So, today we going to discuss some of the

18 proposed clarifications that DOE has made in the

19 recent Notice of Proposed Rulemaking on the test

20 procedure for testing external power supplies. So, I

21 look forward to receiving your comments throughout

22 today's proceeding and then in the follow-up written

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Home Appliance

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HAKKARAINEN: Pekka Hakkarainen,

nics.

COOK: Keith Cook, Philips Lighting.

GOPAL: Sriram Gopal, Association of

Manufacturers.

ALBERT: Larry Albert, Stanley Black &

External Power Supply Test Procedure NOPR Meeting

November 21, 2014

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comments. And I'll be presenting throughout most of

the day on what clarifications we are making. So,

thank you all so much.

MR. BROOKMAN: Thank you. We'll start

with introductions, as we typically do, and you can

get used to turning these microphones both on and

off. Your name and organizational affiliation,

please.

MS. CALLAHAN: Susan Callahan, OSRAM

Sylvania.

MR. MENDOZA: Ernesto Mendoza, Philips

Electronics.

MR. FRYER: Anthony Fryer of the Advanced

Standards Awareness Project.

MR. HOLSTEIN: Chris Holstein, Universal

Lighting.

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1 Decker, representing the Power Tool Institute.

2 MR. HODGES: John Hodge, Riley Wein.

3 MR. BROOKMAN: Please turn on the

4 microphone. Yes.

5 MR. SHEIKH: Shahid Sheikh, Intel

6 Corporation.

7 MR. KIDO: Michael Kido, DOE.

8 MS. ARMSTRONG: Ashley Armstrong, DOE.

9 MR. BROOKMAN: You want to just stand and

10 introduce yourself?

11 MR. PROTOPAPPAS: Peter Protopappas,

12 Navigant Consulting.

13 MR. SKAHAN: Chris Skahan, Navigant

14 Consulting.

15 MR. RINGENSEN: Blake Ringensen, Lawrence

16 Berkeley National Lab.

17 MR. BROOKMAN: Okay, thanks to all of you.

18 All of you received a packet of information as you

19 came in this morning. The agenda is listed on page 2

20 of this packet. Immediately following this agenda

21 overview and a few preliminary slides, there's an

22 opportunity for anybody that wishes to, to make an

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I opening statement, summary comments about things that

2 matter to you here at the outset.

3 Following that, moving directly into a

4 discussion on proposed amendments. We'll take a

5 break midmorning around about 10:30 or so, and then

6 returning from break continuing the discussion on the

7 proposed amendments. This agenda reflects that we're

8 probably going to conclude the day at lunchtime or

9 before lunch. So, well just be as efficient as we

10 can, but not diminish anyone's capacity to comment.

II All of you also are, or many of you are, I

Pd

12 think, used to these proceedings. I'd ask for your

13 consideration. Please speak one at a time. Please

14 say your name for the record each time you speak.

15 There will be a complete transcript of this meeting

16 available to all. Be concise, share the airtime. If

17 you could keep the focus here, turn your cell phone

18 on silent mode, if you haven't done so already.

19 Limit sidebar conversations.

20 And Webinar participants, we welcome you.

21 If you would turn your phone on mute, and you can

22 raise your hand in the software provided to be

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I recognized to speak. And we have some preliminary

2 slides from Jeremy Dommu.

3 MR. DOMM[1: Okay, everyone, so I'm just

4 going to go through a couple of preliminary slides

5 here to set the scene and then we'll open up the

6 floor for anyone in attendance or via Webinar to make

7 some of their own introductory opening remarks.

8 So, for those that are listening via the

9 Webinar, I know there's a lot of folks who are on

10 there, and I thank you guys for participating that

II way. The Webinar allows stakeholders to listen in

12 and view the slides as a way to communicate. Also,

13 you could type in a text note in the corner to get

14 the Webinar moderator's attention and we could turn

15 it over to you if you have something to say, or if

16 you have just a brief question, you could type it out

17 and we could address that, or a brief comment.

18 So, after the meeting, all stakeholders

19 are encouraged to submit written comments. That's

20 all stakeholders; any folk at all who are interested

21 in participating and submitting comments are most

22 welcomed to do so.

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November 21, 2014

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1 So, today's purpose of the public meeting

2 is to present DOE's proposed amendments to the test

3 procedure for external power supplies, provide an

4 opportunity for those who wish to comment orally on

5 the Notice of Proposed Rulemaking document. We'll

6 discuss some of the next steps in the rulemaking and

7 invite participants to provide summary comments or

8 statements or raise any other additional issues for

9 discussion.

10 So, just a brief summary of the proposed

11 amendments, I would characterize the proposed changes

12 as mostly clarifications with what we're proposing to

13 do. We believe that the fundamental testing

14 methodology is going to remain the same so that the

15 measured efficiency of EPSs that have been tested

16 should not be altered with the proposed changes in

17 this document. Rather, the changes are really to

18 provide clarity on how to apply the test procedure in

19 certain cases where it may have previously been

20 somewhat unclear.

21 So, the couple brief summaries of what

22 we're changing, one is we're harmonizing the

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November 21, 2014

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1 resolution and measurement uncertainty requirements

2 with the latest version of the IEC 62301 standard.

3 We are defining and clarifying how to test what we're

4 calling adaptive external power supplies. We're

5 clarifying the test setup to avoid the introduction

6 of additional losses, clarifying how to test EPSs

7 that are not capable of measuring one or more loading

8 conditions.

9 We're adding two optional tests, one

10 testing the efficiency at a 10 percent loading

11 condition and the other measuring the power factor.

12 And then finally, we are updating the sampling plan

13 so it's applicable to all EPSs subject to standards

14 and not just the EPSs that had previously been

15 subject to the existing standards.

16 So, here's a brief look at the timeline.

17 So, on February 10, 2014, DOE finalized new energy

18 conservation standards for direct operational

19 external power supplies. Though compliance with

20 those standards begins February 10, 2016, last month

21 on October 9, 2014, DOE issued a Notice of Proposed

22 Rulemaking on the EPS test procedure, which is the

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1 subject, obviously, of today's public meeting.

2 We are hoping to finalize that test

3 procedure by summer 2015. So, what that means is

4 that representations that are made 180 days after

5 publication of a final rule must be made in

6 accordance with the new test procedure. However,

7 it's important to note that manufacturers may opt to

8 begin using the new test procedure earlier. But

9 given that timing of 180 days after estimated final

10 test procedure in summer 2015, certification to the

11 new and amended standards will be made using the

12 updated test procedure. So, that's the timeline that

13 we're looking at here.

14 So, throughout today's presentation, as I

15 present some of the clarifications that we will be

16 making, you'll see these issue boxes, which is our

17 cue to open up the floor to those in attendance or

1$ via the Webinar to provide comments or data or

19 information concerning that proposed amendment.

20 So, with that out of the way, I think at

21 this point we could open it up for those in

22 attendance to make some of your own opening remarks.

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1 MR. BROOKMAN: We should maybe do one

2 thing before we go with the opening statements. A

3 few of you did not get a chance to introduce

4 yourselves, so we'll give you a chance to do that

5 now.

6 MR. BOESENBERG: I'm Alex Rosenberg,

7 manager of Regulatory Affairs for the National

8 Electrical Manufacturers Association.

9 MR. BROOKMAN: And here in the corner?

10 MR. MOO: I'm Dan Mou with the Consumer

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11 Electronics Association.

12 MS. LOGAN: Apologies for being late.

13 Erica Logan with the Information Technology Industry

14 Council.

15 MR. BROOKMAN: Thank you. Everyone get a

16 chance? Yes?

1 7 MR. GOERING: Steve Goering, DOE.

1 8 MR. BROOKMAN: Welcome. Okay, then

19 opening statements, comments here at the outset,

20 issues that are of concern to you.

21 Yes. Please.

22 MR. FRYE: Anthony Frye with the Advanced

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1 Standards Awareness Project.

2 MR. BROOKMAN: Thank you.

3 MR. FRYE: First of all, I'd like to thank

4 DOE for hosting the meeting, and for issuing the

5 proposed rule.

6 Generally speaking, we're very supportive

7 of the proposed changes, but three issues are raised

8 in the rule that we have particular interest in.

9 The first is the optional measurement of

10 the 10 percent loading condition. We share the

11 Department's concern that there are many devices that

12 spend a considerable amount of time below the 25

13 percent load, and this is where EPS active mode can

14 tend to decrease -- the efficiency can tend to

15 decrease and that the current test procedure doesn't

16 measure this or account for this.

17 The second issue is the optional recording

18 of power factor. We also agree with the Department

19 that power factor is a critical component in

20 establishing the overall efficiency profile of an

21 EPS. And again, this is something that's not

22 captured in the current test procedure.

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1 And for both of these issues, we'd like to

2 stress the importance that the Department be able to

3 collect data, or enough data to consider their

4 inclusion in future EPS conservation standards.

5 And then the third issue we have

6 particular interest in is the testing of adaptive

7 EPSs, and we'll raise specific questions on that as

8 the agenda allows, but we look forward to hearing the

9 Department's thoughts on these issues and those by

10 the stakeholders.

it MR. BROOKMAN: Thank you.

12 MR. FRYER: Thanks.

13 MR. BROOKMAN: Additional comments here at

14 the outset?

15 Yes, Erica?

16 MS. LOGAN: Good morning. Erica Logan

17 with ITI again. We, too, would like to thank the DOE

18 for having this meeting and initiating the rulemaking

19 to amend the test procedure for external power

20 supplies.

21 We, too, are generally supportive of the

22 rulemaking process, particularly, alignment of

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1 tolerances with IEC 62301. We also support the

2 inclusion of adaptive EPSs. We have some questions

3 regarding how the DOE set limits for adaptive EPSs

4 based on conventional non-adaptive EPSs, which we

5 hope to discuss today. And we also plan to provide

6 more detailed recommendations in our written

7 comments, such as nameplate labeling. Thank you.

8 MR. BROOKMAN: Thank you.

9 Many of you, typically, have additional

10 statements. Alex?

11 MR. BOESENBERG: Alex Boesenberg, NEMA.

12 Well, I did submit a presentation --

1 3 MR. BROOKMAN: You did?

14 MR. BOESENBERG: -- for consideration, and

15 so I could discuss the timing of that.

16 MR. BROOKMAN: Where do you think it would

17 fit in the context of these slides?

18 MS. ARMSTRONG: I'm of the opinion we

19 should probably -- let's tee it up when we tee-up the

20 SSL EPSs. They're in the slides.

21 MR. BOESENBERG: Having just seen that

22 slide, that certainly does seem to be the best place.

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MS. ARMSTRONG: Seem fitting?

MR. BOESENBERG: Yes.

MS. ARMSTRONG: And then we'll turn it

over to you.

MR. BROOKMAN: Okay. Great. Other

comments here at the outset before we get into the

more detailed content?

Okay, let's launch into it. Jeremy Dommu.

MR. DOMMU: Okay, so this is Jeremy Dommu

again. The first section that I am going to present

on is the external power supplies definition and 9

scope of coverage.

We took the opportunity with the Notice of

Proposed Rulemaking to address some frequently asked

questions that we receive as it relates to scope of

coverage and EPS definitions within the preamble of

the notice of proposed rulemaking. So, I'm going to

go through those issues now.

So, the Energy Policy and Conservation Act

defines external power supplies as an external power

supply circuit that is used to convert household

electrical current into DC current or lower voltage

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1 AC current to operate a consumer product.

2 So, to be clear, while any device that

3 meets the definition of an external power supply

4 would be considered a covered product, DOE has only

5 established energy conversation standards for certain

6 types of external power supplies.

7 Currently, external power supplies that

8 meet the definition of a Class A external power

9 supply are required to meet specific energy

10 conversation standards that are in the Code of

II Federal Regulations Section 430.32. So, the

12 definition for a Class A external power supply is a

13 device that meets six of these bullet points you see

14 on the slide.

15 It's designed to convert line voltage AC

16 input into a lower voltage AC or DC output. It's

17 able to convert to only one AC or DC output voltage

18 at a time. It's sold with or intended to be used

19 with a separate end-use product that constitutes the

20 primary load. It's contained in a separate physical

21 enclosure from the end-use product. It's connected

22 to the end-use product via a removable or hardwired

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I male/female electrical connection cord, cable, or

2 other wiring. And finally, it has a nameplate output

3 power that is less than or equal to 250 watts. All

4 six of these criteria must be met in order for the

5 EPS to be considered a Class A EPS.

6 Now, beginning in 2016, DOE has

7 established energy conservation standards for direct

8 operation external power supplies. So, these new

9 standards cover additional external power supplies

10 that may not have previously been required to meet

11 the Class A external power supply standards. It also

12 increases the stringency of the standards for many

13 types of external power supplies that had previously

14 been required to meet Class A standards.

15 So, specifically, DOE has established a

16 definition for direct operation external power

17 supplies, and these are external power supplies that

18 operate a consumer product that is not a battery

1 9 charger without the assistance of a battery.

20 Likewise, DOE has also established a definition for

21 an indirect operation external supply. These are

22 external power supplies that cannot operate a

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1 consumer product that is not a battery charger

2 without the assistance of a battery.

3 So, the amended regulations pertain to

4 direct operation external power supplies regardless

5 of whether they are actually Class A external power

6 supplies.

7 Indirect operation external power supplies

8 are not subject to the new standards for direct

9 operation external power supplies, but maybe subject

10 to the existing Class A external power supply

11 standards if they meet the definition for a Class A

12 EPS, but not the definition for a direct operation

13 EPS.

14 So, the table that you see here on the

15 bottom of the slide I think does a good job of

16 showing exactly what standard the EPS would have to

17 meet. And collectively, a lot of folks refer to the

18 new direct operation EPS standards as Level 6

19 standards and that's because the international energy

20 efficiency marking protocol requires manufacturers to

21 mark their EPS with Roman Numeral VI. So, that's why

22 it's commonly used Level 6 to mean the standards for

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1 direct operation EPSs.

2 So, in the table you could see all direct

3 operation EPSs are subject to Level 6 standards. A

4 Class A EPS that's not direct operation, but is still

5 Class A if it's indirect operation EPS it would still

6 be required to meet the Level 4 standards, which have

7 been in effect since 2008. And then if it's not a

Class A, and if it's an indirect operation, then

9 there would be standards for those external power

10 supplies.

11 So, here on the next slide is the

12 definition for an indirect operation external power

13 supply. And as part of the definition, we included a

14 method to determine whether an EPS is actually an

15 indirect operation EPS, and that method is

16 essentially to remove the batteries from the EPS and

17 then attempt to operate the product. And if it

18 cannot operate -- so, if you remove the batteries and

19 you attempt to operate it, but it cannot operate,

20 it's an indirect operation EPS.

21 If the batteries cannot be removed, then

22 you do two things. One, you take the product with

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1 the batteries completely charged and attempt to

2 operate it and record the time necessary for the

3 product in off mode to turn on. And then you take

4 the consumer product with the batteries completely

5 discharged, attempt to operate it, and record the

6 amount of time it takes to turn on and become

7 operational.

8 So, if the difference between those two

9 conditions is greater than five seconds, then the EPS

10 is an indirect operation EPS. So, that's the

11 criteria if the batteries cannot be removed.

12 Now, DOE intended that the term "indirect

13 operation EPS" and "direct operation EPS" be

14 mutually exclusive and collectively exhausted so that

15 any EPS would be either a direct operation or an

16 indirect operation EPS, but not both.

17 So, questions have arisen as to whether

18 battery charges contained in a separate physical

19 enclosure are direct or indirect operation. So, if

20 you go back to this previous slide that says a direct

21 operation EPS is an EPS that cannot operate a

22 consumer product that is not a battery charger, you

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1 also see in the indirect operation it means an

2 external power supply that cannot operate a consumer

3 product that is not a battery charger.

4 Just questions have come up of whether if

5 the consumer product is a battery charger, and here

6 we're talking about a battery charger that's a

7 consumer product in and of itself. It's primary

8 function is to charge batteries. It was unclear

9 where these fall into, so what we're doing is we're

10 modifying the definition of an indirect operation EPS

11 to specify that indirect operation EPSs are one of

12 two things. One, which is cannot operate a consumer

13 product that is not a battery charger without the

14 assistance of a battery, and we put that is not a

15 battery charger in brackets for clarification; but

16 then we added the second criteria that it solely

17 provides power to a battery charger that is contained

18 in a separate physical enclosure from the end-use

19 product.

20 So, if the product that this EPS is

21 providing power to is a battery charger, then it

22 would be considered an indirect operation EPS.

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MR. BROOKMAN: Yes. Please.

2 MR. ALBERT: Larry Albert from PTI.

3 So, the alternative interpretation of this

4 would be that EPSs that power battery chargers would

5 not at all be considered to fall under either

6 category and therefore would not be regulated at all;

7 is that correct? So, in a way you're modifying the

8 definitions that are provided in statute, right, to

9 include a class of products that was not considered

10 to be covered prior to that because, presumably,

11 they've been covered under the battery charger

12 standards or those seem to be.

13 MR. DOMMU: Yes, I mean we're talking

14 about the EPS here, so you're right that it was

15 unclear where a battery charger contained in a

16 separate physical enclosure would fall into. So,

17 what we're proposing is it would not be subject to

18 the new, direct operation EPS standards. It would be

19 considered indirect and there is no standards that we

20 have for indirect operation EPSs.

21 However, as I stated previously in this

22 slide, an indirect operation EPS could still be

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I subject to the Class A EPS standards Level 4.

2 MR. ALBERT: Right. But battery chargers

3 were explicitly excluded from Class A, right?

4 MS. ARMSTRONG: Where do you see that they

5 were explicitly excluded?

6 MR. ALBERT: Does it not say that under

7 Class A EPSs the two exceptions to that were

8 motor-operated appliances and battery chargers. No?

9 MS. ARMSTRONG: We'll pull up the statute

10 and look.

11 MR. ALBERT: All right. But in any case,

12 so the alternative interpretation would be that EPSs

13 themselves were not covered for battery chargers at

14 all. So, you're fundamentally altering the

15 definition that's provided for indirect operation,

16 right, to include battery chargers?

17 MR. DOMMU: Yes, I mean, really we're

18 altering it to say that EPSs that provide power to a

19 battery charger that's contained in a separate

20 physical enclosure from the EPS is not subject to the

21 new, direct operation EPS standards. So, that's all

22 we're saying. We're not making any claim about what

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1 the Class A standards are. Those have been in effect

2 according to the statute for many years now.

3 MR. ALBERT: Okay.

4 MR. DOMMU: So, really it's just the new

standards for direct operation EPSs, a battery, an

6 EPS that provides power to a battery charger

7 contained in a separate physical enclosure would not

8 be subject to those new, direct operation EPS

9 standards.

10 MR. ALBERT: All right.

11 MR. BROOKMAN: Ashley Armstrong.

12 MS. ARMSTRONG: Just to follow on, one

13 thing is DOE is clarifying its regulations as they've

14 existed all along. So, DOE is not changing it's

15 interpretation at all. I think that should be clear.

16 We're not re-interpreting anything to bring in more

17 products. This is how it has always been.

18 Now, that being said, I think what you are

19 trying to refer to is there are exclusions in the

20 statute with regards to the EPS definition, and I'm

21 just going to read them. It's not as broad as

22 battery charger as you are referring to it, or as we

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l refer to it in our regulations; but there is one for

2 "powers the charger of a detachable battery pack or

3 charges a battery of a product that is fully or

4 primarily motor-operated." So, that's not all the

5 world of battery charges as we know it, but it would

6 be some of the ones that we call battery chargers.

7 MR. ALBERT: So, they'd be excluded as

8 Class As, right?

9 MS. ARMSTRONG: They're excluded from

10 EPSs.

11 MR. KIDO: They're excluded from the Class

12 A, EPS definition by statute.

n

13 MR. ALBERT: By statute, right.

14 MR. BROOKMAN: That was Michael Kido.

15 Thank you, Michael.

16 MR. ALBERT: Thank you.

17 MS. ARMSTRONG: That's a limited subset,

18 so I just want to make clear that's not a battery

19 charger as we refer to it, exclusion across the

20 board. And what we're clarifying here also is just a

21 clarification in nature of what the Class A

22 definition is in the statute and how it has been

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1 interpreted by the Department all along.

2

MR. BROOKMAN: Thank you, Ashley.

3 MR. ALBERT: Thank you.

4

MR. BROOKMAN: Pekka?

5 MR. HAKKARAINEN: Pekka Hakkarainen,

6 Lutron Electronics.

7 Jeremy, I think you said on page 12 you

8 said the definition that you showed there for

9 external power supply is a statutory definition; is

10 that correct?

11 MR. DOMMU: Right.

12 MR. HAKKARAINEN: Can you provide the

13 reference for that, please? And I just remark here

14 that what's little bit difficulties of this

IS definition of the external power supply is different

16 from the definition that the Environmental Protection

17 Agency uses in their Energy Star Program.

18 MR. BROOKMAN: Interesting. Okay, Michael

19 Kido.

20 MR. KIDO: Yes, to follow up, the location

21 of that particular statutory cite is in 42 U.S.C.

22 6291, Subsection 36, and that will give you the

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1 overall definition for external power supply. And

2 then within that subsection under -- I guess it's

3 Subsection C that's got the specific criteria for a

4 Class A external power supply.

5 MR. HAKKARAINEN: Thank you.

6 MR. BROOKMAN: Thank you.

7 MR. DOMMU: I would also add that the

8 table that is on the slide that I've already talked

9 about, this is within the preamble of the notice of

10 proposed rulemaking, and there is several paragraphs

11 in there that discuss what the definition is and have

12 all the proper citations. So, if you want to look at I

13 the note for that, that's another good place to look

14 to find where the statutory language exists.

15 Okay, I have another slide on the scope as

16 it relates to indirect and direct EPSs, so I'll do

17 that now and then we could open the floor again.

18 So, one of the questions we get is whether

19 an EPS that can be used with multiple end-use

20 applications, some of which the EPS operates the

21 end-use product directly and in other cases where it

22 operates the end-use product indirectly, but the EPS

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is otherwise the same would that EPS be treated by

2 DOE as an indirect or a direct operation EPS?

3 So, if in the NOPR preamble we clarified

4 that as long as the EPS can operate any consumer

5 product directly, even if the EPS is only capable of

6 operating the consumer product it ships with

7 indirectly the DOE would still consider that EPS to

8 be a direct operation EPS.

9 MR. BROOKMAN: Larry?

10 MR. ALBERT: Sorry. So, how would you be

11 able to determine that in looking at a -- I'm sorry.

12 Larry Albert from Stanley, Black & Decker.

13 How could you determine that by looking at

14 a particular EPS, whether it could operate some other

15 consumer product other than the one it's shipped

16 with?

17 MR. DOMMU: ( A) it'd be the responsibility

18 of the manufacturer to certify what standard the EPS

19 applies to based on its understanding of the EPS.

20 MR. ALBERT: So, again, if a manufacturer

21 supplies an EPS with a consumer product, and that's

22 what it's intended to be used with, right, and it

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1 qualifies as an indirect operation, and that

2 manufacturer does not ship it with any other product

where it would qualify as direct then the

4 manufacturer would be correct in stating that that's

5 an indirect operation EPS regardless of the fact that

6 it may be able to operate some other product in

7 direct mode?

8 MR. DOMMU: Now, if the EPS is capable of

9 operating any consumer product directly, it would be

10 considered by DOE a direct operation EPS.

11 MR. ALBERT: Really. That's interesting.

12 MR. BROOKMAN: Yes. Alex?

13 MR. BOESENBERG: Alex Boesenberg, NEMA.

14 As a guy who does a lot of playing with

15 stuff in my house, that begs the question of is there

16 some point at which you define or take a stance on

17 misapplication. I mean I reuse stuff all the time

18 and it definitely -- I really don't pay attention to

19 what it was meant to power. If it says on it it's

20 going to give me enough voltage -- I sympathize with

21 those who don't know if a product will be misapplied.

22 MR. BROOKMAN: Additional comments here.

1

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I You see a comment box there at the bottom of Slide

2 15. DOE seeks comments on its proposed revision to

3 the definition and applicability of indirect

4 operation external power supply. And maybe we've

5 covered this, but let's try one more time.

6 Okay. Ashley?

MS. ARMSTRONG: So, we had a question on

8 the Webinar. I'm just going to address it now.

9 Craig Stevens asked. He wanted us to use an example,

10 which is a cell phone with an EPS that cannot operate

11 the phone without the battery being charged, and he

12 wanted to know is that indirect. And you can chime

13 in here, but my understanding is that it would be

14 indirect.

15 MR. DOMMU: Yes, so in that case --

16 MS. ARMSTRONG: Based on what he said

17 here.

18 MR. DOMMU: Yes. And then the question

19 comes up is could that same EPS be used to power

20 another consumer product directly?

21 MS. ARMSTRONG: And what we're hearing

22 from you all, I guess, at least in the room, the

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1 points you've made is you ask the Department to at

2 least consider clarifications on what the

3 manufacturer intends or designed the products to be

4 used for versus what it could be used for when it

5 gets into the field by any consumer and picked up.

6 And so, I think that's a fair ask of us.

7 MS. BROOKMAN: Okay. Larry?

8 MR. ALBERT: Sorry. Because the problem

9 is, obviously, is that if an EPS is created for a

10 particular end product and that's how the

11 manufacturer ships it with that end product, and he

12 qualifies as being indirect operation the

13 manufacturer can't possibly certify that it would

14 never be used with some other product for which it

15 would not qualify as being indirect because, you

16 know, you're really asking the question is could it

17 be connected in some manner to some other product

18 that might be out there manufactured by someone else

19 entirely, right? And since my understanding is the

20 consumer product is the thing which is the covered

21 product is the thing that the EPS is powering, right,

22 that's the thing that falls under the responsibility

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1 of the manufacturer, not the EPS itself if the EPS

2 could be misapplied.

3 MR. KIDO: I just have a quick

4 clarification.

5 MR. BROOKMAN: Larry Kido.

6 MR. KIDO: Hi. I just have a --

7 MR. BROOKMAN: Pardon, Michael Kido.

8 MR. KIDO: -- quick clarification question

9 since I'm one of the laypersons in the room. Are you

10 suggesting that there are actually instances where an

11 indirect operation EPS can double its role? It can

12 operate as a direct operation EPS as well?

13 MR. ALBERT: The nature of the

14 qualification to establish what is an indirect EPS

15 involves the EPS connected to the end use product.

16 So, therefore the interaction of the EPS to the end

17 use product that's a defined relationship, right?

18 That the manufacturer can only establish that it

19 qualifies under those conditions or not, right?

20 The question of whether with another end

21 use product that EPS, right, could qualify -- might

22 not qualify as indirect that manufacturer can't

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1 possibly certify that because that's the establishing

2 criteria, right?

3 MR. GOERING: Steve Goering, DOE.

4 So, I think the question was more

5 technical. Something that normally is shipped with

6 and intended to be operated as an indirect would that

7 be capable of being used in another consumer product,

8 technically, as a direct EPS.

9 MR. ALBERT: Since the relationship is

10 between the EPS and the end-use product, it would

11 depend, to a great extent, upon how those two

12 individual components were intended to interact. So,

13 you can't possibly certify that the EPS is indirect

14 in of itself because the very establishment of the

15 criteria is based upon its interaction with the

16 end-use product that intended to use, by definition.

17 So, a manufacturer of an end product that is a

18 covered product, right, that is shipped with an EPS

19 where the EPS qualifies with that particular end

20 product as being indirect could not then broadly

21 certify, right, that with any other possible product

22 that might exist in the marketplace that it would no

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1 longer qualify because all that would have to happen

2 is someone would be able to find something that they

3 hooked it up to and said for whatever reasons this

4 particular product doesn't work that way.

5 MS. ARMSTRONG: So, I'm going to ask when

6 you send in your written comments or to the extent

7 you want to make further clarifications today, I

think there are some nuances, at least in my mind,

9 between what Alex was describing, which is a consumer

10 or anyone just picking up a device in the field and

11 connecting it with whatever versus a manufacturer who

12 may have designed an EPS for a given application, but

13 has also elected to sell it to other people for use

14 in other products.

15 We have seen those cases too, and we have

16 gotten those questions, which is part of why we are

17 clarifying today. There's a difference between

1$ Ashley the consumer in her garage and a manufacturer

19 who is selling its products maybe for use on its own,

20 but also for use in other end applications. It knows

21 all the different things it's selling too. I do

22 think there's a difference there.

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MR. ALBERT: Just for clarification, and

2 maybe this is my misunderstand, the very nature of

3 what an EPS is requires that it be married to a

4 consumer product; right, to qualify it as a covered

5 EPS, right? So, the EPSs all by themselves not

6 associated with a consumer product would not

7 therefore be covered?

8 MS. ARMSTRONG: I think we clarified this.

9 I mean DOE just issued guidance, I think, that

10 clarifies DOE's position on that matter.

11 MR. BROOKMAN: Thank you, Ashley.

12 Additional questions here?

13 MR. DOMMU: Okay. Great. So, we will

14 move on to the next scope issue that DOE clarified in

15 the preamble to the notice of proposed rulemaking.

16 This relates to power over Ethernet POE adopters, so

17 power over Ethernet describes a system which passes

18 electrical power along with data on Ethernet cabling,

19 allowing a single cable to provide both data

20 connection and electrical power.

21 So, we get questions of whether an EPS

22 that uses an Ethernet cable would be considered a

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1 Class A EPS. And if we go back to the definition of

2 a Class A EPS, the fifth one is connected to the end

3 use product via a removable or hard wired male/female

4 electrical connection cable, cord, or other wiring.

5 So, I think it's pretty clear that if it connects to

6 the end use application using any type of electrical

connection cable, cord, or Ethernet wiring, including

8 Ethernet cables, then it would meet the criteria.

9 So, an EPS that connects to the end use product via

10 an Ethernet cable or any other cable, for that

11 matter, would still be considered a Class A EPS if it

12 meets those other five criteria of a Class A external

13 power supply.

14 MS. ARMSTRONG: Before you go on to that,

15 we have one more, I guess, comment on the

16 indirect/direct issue. And I apologize if I've

17 mispronounced anything. This is from Perry Maneto on

18 the line. And he just states that considering what

19 we are discussing a dedicated plug or other

20 mechanical means would need to be in place for the

21 EPS to be considered indirect, at least that's his

22 opinion.

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1 MR. BROOKMAN: Okay. Thank you, Ashley.

2 MR. DOMMU: Okay, so the next issue that I

3 wanted to provide clarification on here is an

4 exemption for security or life safety alarm or

5

surveillance systems to the no-load mode

6 requirements. So, under the U.S. Code an EPS that is

7

an AC to AC EPS has nameplate output of 20 watts or

8 more and is certified to the Secretary as being

9 designed to be connected to a security or life safety

10 alarm or surveillance system component does not have

11 to meet the no-load requirement provided that EPS was

i2 manufactured before July 1, 2017.

13 So, the question that we get is what does

14 a security or life safety alarm or surveillance

15 system mean? And fortunately, there is a definition

16 in the statute for that term, which is "It's

17 equipment designed and marketed to perform certain

18 functions on a continuous basis, such as monitoring

19 intrusion to real property, providing notification of

20 threat to life safety or physical property,

21 controlling access to real property or physical

22 assets and preventing unauthorized removal of

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1 physical assets."

2 So, the term "security or life safety

3 alarm or surveillance system" does not include

4 products with a principal function other than life

5 safety, security or surveillance that are designed

6

and marketed with built-in alarm or self-deterrent

7 features, but do not operate necessarily and

8 continuously in active mode.

9 So, examples of such products that would

10 not be eligible for this exemption would be products

11 with principal functions other than life safety,

12 security, or surveillance. And those include, and we

13 provided these examples in the NOPR, landscape

14 lighting that have motion sensors, video cameras, or

15 Smartphones with theft deterrent features. Those

16 would be examples of products that have a principal

17 function other than life safety, security, or

18 surveillance and therefore would not be eligible for

19 this exemption to the no-load mode requirement.

20 Okay, so another clarifying scope issue

21 that we discussed in the NOPR is within the Class A

22 criteria, the fact that a Class A EPS is designed to

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1 convert to only one lower voltage AC or DC output

2 voltage at a time. So, we get a lot of questions on

3 this issue.

4 So, if an EPS can provide two or more

5 outputs that are the same voltage at the same time,

6 so it's not two or more different AC or DC outputs.

7 It's the same output voltage providing at the same

8 time then it would still meet the requirement of

9 design that you can convert to one AC or DC output

10 voltage at a time. So, if it's two or more, but

11 they're the exact same output voltage, then it would

12 still be designed to convert to only one AC or DC

13 output voltage at a time.

14 The other situation is an EPS that can

15 provide two or more different output voltages, but

16 not at the same time. So, it's capable of providing

17 different output voltage, but it can't do it

18 simultaneously it would still be designed to convert

19 to only one AC or DC output voltage at a time.

20 So, this requirement would not be met,

21 something would not be considered a Class A EPS if

22 the EPS can provide two or more different lower

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I voltage AC or DC output voltages at the same time.

2 So, these EPSs are considered multiple voltage EPSs

3 and they may be subject to the direct operation

4 multiple voltage EPS standards.

5 MR. BROOKMAN: Question.

6 MR. DOMMU: Yes.

7 MR. SHEIKH: So, essentially --

8 MR. BROOKMAN: Please say your name for

9 the record.

10 MR. SHEIKH: Shahid from Intel.

11 So, there are three scenarios. One is you

12 have simultaneous voltage be the same, simultaneous

13 voltage to be different, and then you have the third

14 scenario that you'll maybe talk about later is

I5 adaptive where you have multiple voltages, but not

16 simultaneous, right?

1 7 MR. DOMMU: Yes. Right. If it could

18 provide multiple output voltages, but cannot provide

19 them at the same time it would still meet the

20 criteria to be a Class A EPS based on that criteria.

21 MR. SHEIKH: So, if it's simultaneous, but

22 different voltages that would be a Type X, right?

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MR. DOMMU: That would be a multiple

voltage direct operational EPS.

MR. SHEIKH: A Type X, right?

MR. DOMMU: Yes.

MS. ARMSTRONG: (Off mike.)

MR. BROOKMAN: Ashley, you want to say

that on the record? Sorry.

MS. ARMSTRONG: We call them something

different. I think it's -- but yes.

MR. BROOKMAN: Thank you.

You look like you're not finished.

MR. SHEIKH: What do you call it, ma'am?

MR. DOMMU: Multiple voltage direct

operational EPS. That's what actually the statutory

language is for it. I think when we did the

standards analysis we referred to them as product

class X, but in terms of what we actually put in the

statute it's a direct operational multiple voltage

EPS.

MR. BROOKMAN: Larry.

MR. ALBERT: Jeremy, does that conflict

with the definition for multiple voltage EPS because

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1 that just says two simultaneous outputs. It doesn't

2 refer to them as being different, does it?

3 MR. DOMMU: Yes. I mean I think it's just

4

a different way of wording the same thing. I don't

5 have the statutory definition of multiple voltage in

6 front of me right now, but it says a simultaneously

7 lower voltage AC or DC output.

MR. ALBERT: So, the first bullet item

9 there would qualify as being -- would qualify as a

10 Class A, which would be a single output is what

11 you're saying, right?

12 MR. DOMMU: Yes, a single voltage -- well,

13 a Class A EPS must be designed to convert to only one

14 AC or DC output voltage at a time.

15 MR. ALBERT: So, that does not exclude

16 multiple outputs.

17 MR. DOMMU: No, it does not if the

18 multiple outputs are the same output voltage.

19 MR. ALBERT: And with respect to the test

20 procedure, then you'd follow the multiple output

21 portion of the test procedure rather than the single

22 output portion of the test procedure?

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MR. DOMMU: Could you clarify that, Chris,

about how to apply the test procedure in that case?

MR. SKAHAN: Chris Skahan, Navigant

Consulting.

External Power Supply Test Procedure NOPR Meeting

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In that case, we would try to load down

both buses simultaneously. So, you would try and

load -- if you have two multiple outlets that means

there should be one total current rating for the

power supply itself. So, at 100 percent load, we

would take that total current from both outputs and

load it down in one at the same time. So, it would

be a single voltage procedure, but we would be

drawing power from both at the same time.

MR. ALBERT: Okay, because the procedures

are slightly different between multiple and single

output.

MR. SKAHAN:

factor for the multiple

MR. ALBERT:

that are the same volta

current ratings, right?

MR. SKAHAN:

Yes, there's a derating

voltage.

And you did have two outputs

ge, but different maximum

Correct.

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MR.

MR.

MR.

MR.

Lutron Electrc

apologize.

SKAHAN: Yes.

ALBERT: Okay. Thank you.

BROOKMAN: Yes, Pekka?

HAKKARAINEN: Pekka Hakkarainen with

nics. I'm still a little confused. I

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MR. ALBERT: Correct.

MR. SKAHAN: But in that case we would

load both -- since they're the same output, in our

opinion from a single voltage EPS the way that we're

looking at it from a load perspective it's one output

voltage and one current, even if they're multiple

outputs. So, we're still trying to load down 100

percent of the current, so we would load both buses

to 100 percent at the same time.

MR. ALBERT: With individual loads.

MR. SKAHAN: I'm sorry?

MR. ALBERT: With individual loads,

though.

Jeremy, on the definition of a direct

operation external power supply, does DOE consider

that to be a device that's in a separate enclosure

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1 from the end use product? It's not clear.

2 MR. DOMMU: Yes. The definition does not

3 explicitly state here that it's a separate enclosure,

4 so I will say that, and otherwise, welcome comment.

5 MR. HAKKARAINEN: So the word "external"

6 is really not necessary here.

7 MS. ARMSTRONG: The word "external" is

8 part of the external power supply name of the

9 product, but it's not part of the direct operation.

10 We've gotten this question. Let's put it that way.

11 I don't think our intent is going to be to clarify it

12 here today, but to the extent you have opinions about

13 whether it should be an external box, an internal

14 box, an integrated product, part of a fixture, we'll

15 get to this part of the lamp, you know, please feel

16 free to share your opinions with us.

17 And obviously, we sense the need to

18 clarify internal integrated versus external in a

19 separate box or enclosure.

20 MR. DOMMU: Okay, any other comments on

21 this issue here before we get to the next scoping

22 issue on solid-state lighting?

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Okay. Great. So, we will move along to

2 the clarifications on solid-state lighting.

3 So, to DOE's understanding, solid-state

4 lighting products contain components that are

5 typically referred to as LED drivers or LED

6 transformers that use constant current or constant

voltage to drive LEDs with direct current or in some

8 cases alternating current.

9 These components, while they may not be

10 referred to as external power supplies of what

11 typically would be called a driver or a transformer,

12 they may otherwise meet the definition of an external

13 power supply per the statutory definition.

14 Therefore, they may be subject to either the Class A

15 or the direct operation EPS standards if they do, in

16 fact, meet the criteria to be considered a Class A

17 EPS or a direct operation EPS.

18 So, as DOE stated in our rules -- we

19 stated this in both the final rule establishing

20 conservation standards for direct operation EPSs last

21 February and we reiterated it in the recent Notice of

22 Proposed Rulemaking for the EPS test procedure, which

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1 is the subject of today's meeting.

2 DOE, to this point, has been unable to

3 identify any technical differences that would

4 preclude some of these EPSs used with LEDs to be

5 considered an EPS per the statutory definition or the

6 definition of the Class A direct operation, and

7 therefore, they may be subject to the applicable

8 Energy Conservation Standards.

9 So, to provide some more details when DOE

10 looks at the statutory definition of Class A or

11 direct operation, things that we think could be in

12 scope we've seen drivers and transformers that are

13 used with LED task lighting, desk lamps, landscape

14 lighting, where it seems very clear that the

15 component meets all the criteria to be considered a

16 Class A and/or direct operation. So, those

17 components that are used in those specific

18 applications, though, do seem that many of those meet

1 9 the criteria.

2

0 Examples that would be out of scope, so

21 drivers with florescent ballasts those output higher

22 voltage AC wave forms and as I've stated many times,

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the definition of an EPS is that it outputs lower

2 voltage AC. So, if it outputs higher voltage AC, it

3 would be out of scope for that reason.

4 And then the other example, the Class A,

5 as we've talked about, is contained within a separate

6 physical enclosure from the end use product. So, to

7 be considered a Class A EPS, the external power

8 supply must be contained in a separate physical

9

enclosure from the end use product. So, to the

10 extent that an LED driver is contained within the

11 same end use product or the same physical enclosure

12 of the end use product, and if you use a luminaire as

13 an example, then it would be out of scope for the

14 Class A standards.

15 So, that is where we stand on the issue

16 now, but I do realize that are many folks here in

17 attendance who will likely want to comment on this.

18 MR. BROCKMAN: Alex?

19 MR. BOESENBERG: Alex Boesenberg, NEMA.

20 First, I want to thank the Department for

21 these two slides, particularly, 20. That it's good

22 to see something more concrete. I can't say, as yet,

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I whether we would agree, but it is good to have a

2 starting point for the discussion, and I appreciate

3 that.

4 In light of this information, which I just

5 saw this morning, before I give my brief, I would

6 like five minutes with my members, if I could. The

7 brief is still very relevant, but I think I will

8 change the aim, the ask a little bit.

9 MR. BROOKMAN: You want to do that right

10 now?

11 MR. BOESENBERG: Yes.

12 MR. BROOKMAN: Yes. Just take a

13 five-minute break. Sure.

14 MS. ARMSTRONG: Why don't we take a

15 10-minute break.

16 MR. BROOKMAN: Okay, we'll take a

17 10-minute break. Why not? Luxury.

18 (Whereupon, a 10-minute recess was taken.)

19 MR. BROOKMAN: Alex Boesenberg.

20 MR. BOESENBERG: Well, thank you.

21 So, as I stated, I'm Alex Boesenberg,

22 Manager of Regulatory Affairs for the National

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1 Electrical Manufacturers Association. And we would

2 like to take the opportunity today to do some

3 education and clarification on our interpretations

4 and understanding of external power supplies and also

5 our deep industry knowledge of solid-state lighting

6 drivers with a goal of continuing a conversation and

7 dialogue to make sure that we understand the scope

8 and application. And then based on that, we can feed

9 in the necessary information to the test procedures

10 NOPR, and that discussion to assure that the products

are tested correctly.

12 I'm on Slide 3. We agree with the

13 Department. of Energy's statement that certain SSL

14 products are covered. As I've already stated, we do

15 feel some uncertainty still as to exactly the details

16 or the scope. Slide 20, in today's presentation from

i7 the Department does help. And so, as I said, to fuel

18 that we have some things we wanted to mention.

i9 We sympathize with the Department's

20 challenge in applying the congressionally determined

21 definition of external power supplies, and we look

22 forward to working together to clarify that. I'm not

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1 going to read every one of these bullets, except for,

2 I guess, the last one. There are significant

3 multi-million, if not billion dollar investments in

4 solid-state lighting. So, obviously, our goal is to

5 minimize that disruption with the understanding that

6 significant investments are being made in every one

7 of these products is arguably more efficient than its

8 predecessor.

9 So, we've already talked about the six

1 0 points that determine a Class A external power supply

11 today in the brief, so I don't need to belabor that.

12 We have underlined a few points there that are what

13 we think the key phrases to as we consider how it

14 applies to NEMA lighting products.

15 We've also talked about the other power

16 supply definitions -- indirect, direct, et cetera. I

17 don't need to belabor that today.

1$ So, the first bullet here is one that has

19 already been mentioned, and it's the continued

20 dialogue to understand that will allow us to provide

21 our comments regarding the technical differences for

22 our products that fall in scope so that we can

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1 provide comment to the test procedures so that the

2 products are tested accurately.

3 Second bullet is where we say, yes, there

4 are technical differences, and we offer some

5 beginning comments there. So, I'll just keep moving.

6 And so the slides that follow are some

7 things we prepared to help identify the operation and

8 how they're applied in the field. An external power

9 supply, I think as we've already discussed, and by

10 the way, this is a picture of one of my member's

11 products. We didn't just pull something off the

12 Internet. It's separate. It provides power, has an

13 option to unload. We understand that typically

14 they're plug loads, but obviously, the definition

15 does include hard wire or other wiring, and we

16 recognize that.

17 SSL drivers, of course, tend to be part of

18 a system. They provide multiple functions. They are

19 not unloaded in the classic sense. They tend to be

20 hard wired, and a point that I'll make later, and

21 I'll mention it now is these tend not to be user

22 serviceable, if you will.

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Ashley, you have a question?

2

MS. ARMSTRONG: I hate to interrupt you.

3 MR. BOESENBERG: Go ahead.

4

MS. ARMSTRONG: Can you go back slide?

5 So, I will just note I think we appreciate the

6 differences that you're pointing out here. I will

say, in my opinion, these two buckets are not

mutually exclusive. In other words, just because

9 there are things on the right that they may do in

10 addition to doesn't necessarily exclude them from the

11 EPS definition. So, I am making that point as to say a

12 your descriptions on the right for SSL drivers are

13 not necessarily exclusions in the EPS definition.

14 So, I think we appreciate the fact that,

15 and can understand that there are differences and

16 that this issue is complex and that we need to work

17 together, but just to be clear just because they may

18 function as part of a system doesn't necessarily

19 exclude them from the definition. They don't have to

20 be separate from the system altogether. I mean EPSs

21 are used for other things.

22 MR. BOESENBERG: Thank you.

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I Moving on, this dovetails right into

2 Ashley's statement, separate component versus a

3 system component. As we've stated, solid-state

4 drivers tend to be part of a system hard wired

5 directly in typically by an electrician. And again,

6 they tend to provide multiple functions --

7 intelligent dimming, DMX, which is color control, and

8 increasingly often network capabilities for greater

9 control, participating and demand response and things

10 like that.

11 The increased function -- now the point we

12 want to make to Ashley's statement, a good

13 counterpoint is that increased functionality

14 typically comes with increased power needs.

15 I already mentioned unloading. Typically,

16 the external power supply as used in consumer product

17 has an option to be unplugged or unloaded. With

18 solid-state drivers, particularly, the examples we're

19 using here in the picture there is not an option for

20 a user unloading. They're hard wired and often

21 installed and not user serviceable.

22 This slide summarizes some of the design

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1 differences that we've already mentioned, and a few

2 others. The Department's already displayed an

3 understanding of constant current and constant

4 voltage. That's one of the things in here. Again,

5 controllability and building integration features or

6 the multiple functions that I mentioned earlier are

7 very important to solid-state lighting and to

8 satisfying consumer demands and even government

9 demands for increased controllability.

10 The tunable outputs, that's one of those

tt functions I mentioned like DMX. Color control that

12 allows for customization, but again, that comes with

13 increased circuitry and increased power needs. There

14 are also thermal shutdown features in many

15 solid-state drivers that protect the system, whereas

16 our understanding of external power supplies, and one

17 of other trade associations might chime in at this

18 point, is a thermal protection for an external power

19 supply. And our experience is that it protects the

20 power supply from overheating, but in terms of

21 solid-state lighting drivers it protects the system,

22 protects the LEDs from burning out.

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We already mentioned unloading and the

2 functions and network communications, so it all comes

3 down to defining the word "certain." And the

4 Department in the presentation today has given a good

5 starting point to continue a dialogue and that helps

6 us to know where to start.

7 And so, as I mentioned, as we identify the

8 technical differences and the different features,

9 then we can better understand the application of the

10 scope and then comments to the test procedure.

11 We did want to mention, briefly, some

12 issues regarding testing, you know, the current test

13 procedure. We find difficulty in applying the test

14 procedure to constant current to pology products

15 because of the way it's set up. That doesn't mean

16 that we can't offer corrections to it, but the scope

17 of coverage was one of the stumbling blocks for us

18 because different products behave in different ways.

19 It was also important to us to point out

20 that we use products that are capable of accepting

21 multiple input voltages; [JNV, universal voltage, and

22 we want to discuss or find a good way for the test

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1 procedure to take that into account.

2 And I've already mentioned no-load

3 operation. Most of our drivers are not designed to

4 function in that way, not that you can't supply power

5 to it and see what happens, but that isn't their job.

6 If it's luminaire it is going to be switch or network

7 controlled, and it's not stuck in a wall socket with

8 nothing attached to it, for instance.

9 We wanted to point out that the Department

10 is extremely active in the solid-state lighting arena

11 and has been a guiding force in a galvanizing teeming

12 force for the U.S., and has made the United States

13 and contributed to the United States being the world

14 leader in solid-state lighting development. From the

15 government's own issuances from this building there's

16 several quotes that clearly show the involvement.

17 And so with that, I open it up for any

18 questions. Great. Thank you.

19 MR. BROOKMAN: Thank you, Alex.

20 So, shall we return to the slides?

21 MR. DOMMU: Okay, everyone, this is Jeremy

22 Dommu again. We will continue on with the

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1 presentation at this point. So, everything we've

2 heard today has been on the definitions and the

3

clarifications we've provided in the preamble on the

4 scope of coverage.

5 Now, I'm actually going to get into the

6 items that within the Notice of Proposed Rulemaking

7 DOE's proposing clarifications to the language of the

iE

8 test procedure for how to test external power

9 supplies.

10 So, the first item that we are proposing

11 relates to measurement accuracy and precision. So,

12 the International Electrical Technical Commission

13 published 62301 standard for measuring standby power

14 of household appliances originally in June 2005.

15 When we finalized the test procedure for external

16 power supplies on June 1, 2011, we adopted the

17 instrument and resolution measurement uncertainty

18 requirements identical to those that are in IEC62301.

19 However, the second edition of IEC62301 was published

20 on January 2011 and it made several revision to the

21 standard, including refine the test equipment

22 specifications, provide the clarification to

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I measurement techniques required, and made revisions

2 to the uncertainty determination method for measuring

3 loads with high cost factors and/or low power

4 factors.

5 So, what we did in NOPR is propose to

6 incorporate by reference the resolution parameters

7 for power measurements and uncertainty methodologies

8 that are in this second edition of IEC62301 for the

9 application of testing external power supply energy

10 consumption.

11 So, on that issue, I could now open it up

12 with this issue box that's shown here to any comments

13 on this proposed revision that we're making in the

14 notice of proposed rulemaking.

15 MR. BROOKMAN: Larry?

16 MR. ALBERT: Jeremy, just a quick

17 question. I seem to remember, by statute, were you

18 not already required to have to adopt the most recent

19 edition of IEC62301? So, you would've had to do this

20 anyway, right, or it would've applied anyway even

21 without a change to the test procedure?

22 MR. ARMSTRONG: So, it doesn't just apply.

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1 We do have to go through rule to update it

2

officially, but yes, the statute requires us to use

3 the latest version.

4

MR. ALBERT: Okay. Great. Thanks.

5 MR. BROOKMAN: Thank you, Ashley.

6 Additional comments on this slide? Okay.

7 MR. DOMMU: Okay, that brings us to the

$ next issue on testing configuration.

9 MR. BROOKMAN: Yes. Ernest?

10 MR. MENDOZA: Ernesto Mendoza from Philips

11 Electronics.

12 Will be a requirement to report

13 uncertainty on DOE's reporting?

14 MS. ARMSTRONG: So, at this time it's not

15 a requirement to report it.

16 MR. DOMMU: Okay, anything else?

17 Okay, so onto testing configuration. So,

18 the test method for calculating the energy efficiency

19 of single-voltage external power supplies in the

20 Federal Regulatory Test Procedure incorporates by

21 reference certain sections of the California Energy

22 Commission's test. Specifically, Section 5 of that

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1 CEC test procedure are the measurement approach

2 states the following, and you could see it there.

3 That essentially says there are two options --- and

4 this is as it relates to connecting the metering

5 equipment.

6 So, there are two options for connecting

7 metering equipment to the output of this type of

8 power supply. You could either cut the cord

9 immediately adjacent to the DC output connector or

10 attach leads and measure the efficiency from the

11 output connector itself.

12 So, one of the things that we found is

13 that it's not exactly clear in this section how the

14 volt meter and amp meter connections should be made

15 to ensure testing accuracy. So, while it says where

16 to connect the equipment along the cord, there is

17 some ambiguity on exactly the order of how the

18 testing equipment be connected. So, we actually

19 examined a couple different ways that you could

20 configure the testing equipment per the CEC test

21 method, and we found that there could be some

22 differences that result if the test meter is not

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connected properly.

2 I'll hand it over to my colleague, Chris

3 Skahan from Navigant to discuss the exact test

4 results.

5 MR. SKAHAN: So, as Jeremy said, we found

6 to be two possible interpretations of what the test

7 procedure that we're referencing means when they try

8 to determine what the test setup is. So, you can see

9 we tried two different configurations.

10 The one on the left we're referring to as

11 our lossy configuration because while the current

12 meter and volt meter are connected to the output

13 cable what the voltage meter is actually reading is

14 further down the DC transmission line to the load.

15 So, you're getting voltage drops throughout the

16 connections from the EPS cable. So, while they're

17 electrically connected, this is not really the intent

18 of the test procedure, and it's not measuring right

19 at the DC output connector of the EPS cable.

20 So, when the power measurement is

21 calculated, it shows a lower output power and

22 therefore it seems less efficient than it actually

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1 is, whereas the one on the right has the volt meter

2 measuring the voltage right at the end of the EPS

3 cable and the current meter lower output current

4 meter measuring output current to the load, whereas

5 in that configuration there's no DC transmission line

6 losses. There's nothing introduced there.

7 So, what we really want to do here with

8 this section, and you can see by the table below, we

9 did some quick calculations about what the efficiency

10 differences can be with one example. We did with a

11 couple different ones, but this is the one we chose

12 to publish.

13 In the lossless configuration, that is

14 really what we're trying to get at. And really the

15 only thing we're trying to do with this section of

16 the NOPR is clarify if you're going to use 2 meters

17 to calculate the output power this is how they should

18 be hooked up for ensuring testing accuracy and

19 getting 100 percent accurate results.

20 MR. BROOKMAN: Okay, thank you. Larry?

21 MR. ALBERT: Chris -- Larry again.

22 Did you actually encounter issues with

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this, with people actually measuring things

2 incorrectly? This seems like such basic --

3 MS. ARMSTRONG; Yes.

4 MR. SKAHAN: Yes, we did.

5 MS. ARMSTRONG: Yes, significant issues.

6 MR. ALBERT: All right

7 MS. ARMSTRONG: Like widespread issues.

8 MR. ALBERT: Really, because this seems

9 basic lab technician.

10 MS. ARMSTRONG: Leave it at that.

11 MR. DOMMU: Okay, so with that in mind, we

12 are proposing to amend the section in the Appendix E,

13 the test method, to require the equipment necessary

14 to measure the active mode efficiency at the specific

15 loading conditions must be directly connected to the

16 output cable. This will serve to clearly outline the

17 intended metering connections and ensure that any

18 unintended losses and the test measurement introduced

i9 by the metering equipment are not included in the

20 active mode efficiency calculation.

21 Any other comments on this clarification

22 that we are making on how to attach the testing

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I equipment?

2 Great. Okay. We will now move on to the

3 next section on EPSs with current limit. So, the

4 average active mode efficiency, which is one of the

5 metrics for which there are conservation standards

6 for, that is calculated by using the average of the

7 active mode efficiencies that are measured at 25

8 percent, 50 percent, 75 percent, and 100 percent of

9 the rated load of the EPS under test.

10 So, we have counted situations where the

I1 power supply is unable to operate properly at certain

12 loading conditions. They could implement something

13 that's referred to as "hiccup protection" under the

14 specific loading conditions so it's not possible to

15 actually measure the efficiency at that loading

16 point.

17 So, we're proposing to test only the

18 loading conditions at which an EPS can maintain the

19 necessary output current. And to do this we are

20 clarifying and we're seeking to define average active

21 mode efficiency within the test procedure as the

22 average of the loading conditions, 100, 75, 50, and

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I 25 percent of its nameplate output current for which

2 the BPS can sustain the output current. So, if it's

3 not possible to measure the efficiency at one of

4 those loading conditions, you simply don't use it in

5 the calculation of average active mode efficiency.

6 MR. ALBERT: This is Larry Albert again.

7

What's been the consequence of this hiccup

8 mode measurements up until now? Have you've been

9 recording these as zero outputs or how have you guys

10 been recording the data when you've encountered these

11 kinds of power units?

12 MR. DOMMU: Well, I think one of the

13 loading conditions I think it was 100 percent there

14 was already language in there that if it was

15 incapable of measuring 100 percent then you wouldn't

16 use it.

17 MR. ALBERT: Right.

18 MR. DOMMU: So, now we've just gotten

19 questions on, well, what happens if one of these

20 other loading conditions is not capable of operating,

21 and what would we do then? So, that's what we're

22 clarifying here.

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I MR. ALBERT: So, your feeling is you're

2 incapable of measuring the output under these

3 conditions, given the language of the standard -- the

4 language of the regulation right now?

5 MR. DOMMU: Yes. So, what we're proposing

6 is that if you can't measure that efficiency at that

7 loading point that it would not be included.

8 MR. ALBERT: This doesn't conflict -- the

9 only concern here is would people misinterpret this

10 so that it conflicts with the stability requirements

11 that are already in the test procedure, that 1

12 percent deviation that establishes stability, right,

13 because this particular phenomenon here is related to

14 a particular type of topology that's used with

15 certain kinds of power conversion methods, right?

16 But normally, you might have a certain amount of

17 drift in output voltage that occur, right, just as a

18 result of thermal effects and so on. But that's

19 been, I think, covered in the test procedure

20 currently through the stability requirements, right?

21 MR. DOMMU: Okay. Sure. That's seems

22 reasonable if there's stability requirements in

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I there.

2 MR. ALBERT: So, you wouldn't want someone

3 to misinterpret this with respect to the stability

4 requirements.

5 MR. DOMMU: Yes. So, do you have a

6 suggestion of how to make this even more clear?

7 MR. ALBERT: Well, if you're specifically

concerned with this scenario here, right, then maybe

9 there could be some clarifying language so that you

10 didn't cross over with the other requirements that

II are already in the test procedure, right, because

12 someone could misinterpret this, right?

13 MR. DOMMU: That's a good suggestion.

14 Thank you.

15 MR. ALBERT: But this is the only area of

16 concern, this particular hiccup mode that you've had

17 an issue with?

18 MR. DOMMU: I mean we're saying this is

19 related to any loading condition for which you can't

20 measure the efficiency. So, if the topology of, I

21 guess, hiccup protection issue exists that makes it

22 impossible to measure the efficiency of that loading

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1 condition then that would be one reason that you

2 wouldn't be able to measure it, and therefore we're

3 proposing here that you wouldn't use the average

4 active mode efficiency. But I think the way that

5 we're wording this is -- it's not specifically hiccup

6 protection, but it's any loading condition where the

7 EPS is incapable of operating at, which you would

8 necessarily not measure and then you would use the

9 other loading points, which you could measure, to

10 calculate the average active mode efficiency.

11 MR. ALBERT: Okay. Up until now, you've

32 had only the 100 percent loading point that was

13 affected by the overload requirement or an overload

14 connection, right?

15 MR. DOMMU: That was the only loading

16 point that was specifically addressed within the test

17 methods, so now this clarification provides how to

18 test for the other loading conditions if you're

19 incapable of operating --

20 MR. ALBERT: It encompasses that as well,

21 is that right? Is that your understanding?

22 MR. DOMMU: Encompasses what?

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I MR. ALBERT: It would encompass also the

2 condition under -- that you currently have covered

3 only for 100 percent as well?

4 MR. DOMMU: Right. So, now it's if any of

5 these you can't measure, you would just calculate it

6 using the other ones, including 100.

7 MR. ALBERT: All right. Thank you.

8 MR. BROOKMAN: Rick Hiben who is joining

9 us via the Web has a question or a comment. Rick,

10 un-mute your phone, and hopefully, we'll hear you in

II the room.

12 MR. HIBEN: Can you hear me?

13 MR. BROOKMAN: Yes, you sound good.

14 MR. HIBEN: So, I was wondering if we

IS could go back to the loading condition, the last

16 slide there on how to measure?

17 MR. BROOKMAN: Which slide number?

18 MR. HIBEN: I believe -- yes, that slide

19 right there.

20 MR. DOMMU: Slide 25 with the cable?

21 MR. HIBEN: Go back. No, I think it's

22 down -- yes, that one there, Number 26. So, I just

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I want to make sure that we're clear here that the

2 condition -- but what we're wanting is we wanting the

3 measurement to be -- the definition to be clear that

4 the measurement is taken from the exit of the EPS and

5 not the cable that's attached to the EPS should not

6 be included in that. And the reason that we feel

7 strongly about this is there's different devices that

8 have different applications which may require a

9 longer or shorter cord. So, we manufacture some pet

10 clippers that use an EPS. The people for the dog

11 grooming industry and whatever they want a very long

12 cord to make it convenient to plug in their outlet

13 and still have enough room to get around the dogs and

14 the tables. Well, when you put an extremely long on

15 the end of an EPS, it can directly affect the

16 efficiency. So, we would like to have some type of

17 language so that the measurement is taken at the exit

18 of the EPS and does not include the cord.

19 MR. DOMMU: Right. Thank you for that

20 comment. So, that would be different than what is on

21 this slide of how the CEO approach, which we

22 incorporate by reference, specifies how to connect

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1 the metering equipment and where exactly on the

2 cord. Is that what you're suggesting?

3 MR. HIBEN: Right. So, right now the way

4

it's stated is that you take it at the end of the EPS

5 cord.

6 MR. DOMMU: Right.

7 MR. HIBEN: And we don't feel that is

S accurate because there are some EPSs that the cord

9 actually plugs in through the EPSs, so they have no

10 cord attached to them. It makes it very unfair for

II the ones that do have an attached cord do not.

12 MR. BROOKMAN: Ashley Armstrong.

13 MS. ARMSTRONG: So, I think our answer is

14 going to be the intent of this NOPR is really just to

15 clarify the existing procedures. Now, your comment

16 has been well taken, but I don't think that's

17 necessarily going to be on the table for

18 consideration as part of this rule. And the

19 rationale for that would be this would be a major

20 departure from how they are tested today and would

21 impact their values; thus, it would impact the

22 stringency of the standard. So, that's something I

e72

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1 think we would have to consider in a different

2 effort, but we could consider it in the future.

3 MR. BROOKMAN: Okay. Thank you.

4

MR. HIBEN: Well, in the CEC measurement

5 it's stating that there are two options for

6 connecting the metering equipment and one is to cut

7 the cord immediately adjacent to the DC output

8 connector or attach the leads, so I guess it's the

9 definition of the output connector. Does that

10 include the cord, or are you just talking about the

11 plug on the end? So, I think there's ambiguity

12 currently in that. And I thought the purpose of this

13 was to clarify it.

14 MS. ARMSTRONG: You're correct about the

15 purpose. This is Ashley from DOE. We'll take a look

16 at the exact wording itself and see if there's any

17 ambiguity.

18 MR. HIBEN: Okay. Thank you.

19 MR. BROOKMAN: Okay, thanks, Rick. We're

20 going to proceed. Yes.

21 MR. DOMMU: So, we already covered the

22 current limits, which brings us to Section 6 here on

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adaptive charging EPSs.

2 So, some EPSs have the ability to rapidly

3 charge depleted batteries by boosting their output

4 voltage during charging to reduce overall charging

5 time. So, this adaptive charging relies on a

6 specific communication protocol between the EPS and

7 certain end use products, so only when the EPS is

8 paired with an end use product for which a specific

9 communication protocol exists would this adaptive

10 charging functionality exist. So, absent that

11 communication protocol, an adaptive charging EPS may

12 still be capable of charging other products without

13 adaptive charging features using standard, universal

14 charging solutions.

15 So, I think we actually covered this

16 earlier. So, because these EPSs are only capable to

17 converting to one output voltage at a time, even

18 though what that output voltage is could change, but

19 it's only converting to one output voltage at a time,

20 these would be considered single voltage EPSs or meet

21 that criteria to be a Class A external power supply.

E

22 We are proposing a definition for these

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1 type of adaptive charging EPSs, whereas an adaptive

2 EPS means an EPS that can alter its output voltage

3 during active mode based on an established

4 communication protocol with the end-use application

5 without any user generated action.

6 And we are also proposing how these should

7 be tested where the test procedure should be able to

8 capture the efficiencies at the various output

9 conditions in which these EPSs will operate. So,

10 we're proposing that we'd be tested once at their

11 highest achievable output voltage that is utilized

12 while communicating with a load and once at the

13 lowest voltage, regardless of what voltage is

14 actually on the nameplate.

15 Additionally, the metrics that would be

16 reported for these adaptive EPSs are listed here. I

17 think the first two I just stated the efficiencies at

18 the lowest voltage achieved during charging and the

19 highest voltage achieved during charging, and then

20 nameplate output power and watts, output current in

21 amps and highest and lowest achievable output

22 voltage, and the no-load power mode consumption in

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1 watts. This is very similar to how switch-selectable

2 EPSs are tested already.

3 The no-load testing for these is also

4 addressed within --

5 MR. SHEIKH: Shahid from Intel.

6 So, you're essentially using the formula

7 to calculate the lowest voltage efficiency output

8 levels and you have to meet it at both levels then,

9 right?

1 0 MR. DOMMU: Right. So, these things just

11 like switch selectables. You would report them and

i2 the results would be compared to the applicable

i3 energy conservation standards for each situation.

14 MR. SHEIKH: Okay. Thank you.

15 MR. BROOKMAN: Yes. Larry?

16 MR. ALBERT: So, Jeremy, I guess my

17 concern here is we'd want to make sure that what

18 you're talking about here in terms of these adaptive

19 battery charger or adaptive power supplies, right,

20 are not confused with conventional power supplies,

21 right? Because in conventional power supplies you

22 can have a variation of voltage, right. But I think

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1 what my understanding is this is done through a

2 serial communication protocol that occurs between the

3 power unit and the end product. That's correct? Is

4 that how that works?

5 MR. DOMMU: Yes, that's right. So, as we

6 put in this proposed definition, it would be based on

7 an established communication protocol at the end use

8 application that happens without any user-generated

9 action.

I0 MR. ALBERT: So, let's say a technician

11 that you're using to verify that someone's, in fact,

12 complying with the requirements goes and picks up an

13 EPS, how would they be able to establish on the base

14 of looking at that EPS that it, in fact, follows ones

15 of these established protocols? And this protocol,

16 this universal charging solution that's the one

17 you're talking about, right?

18 MR. DOMMU: No. I mean we're talking

19 about any specific communication protocol that the

20 EPS would use with what that end use product is.

21 MR. ALBERT: But specifically, a digital

22 communication protocol, not just the interaction

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1 between line and load that would occur with any power

2 supply.

3 MR. DOMMU: Yes. We didn't specify

4 digital in the definition here, so that's not

5 clarification that's provided. Are you suggesting

6 that additional clarification is needed?

MR. ALBERT: My concern is that someone

8 who is unfamiliar with this, reading this, might say,

9 well, I'm seeing the voltage change, so therefore it

10 must be changing as a result of the communication

11 protocol, right, rather than saying I have to

12 establish that there's a communication protocol

13 first, right? And then if it's there, then it meets

14 the definition of the adaptive power supply, right?

15 That's really what the concern is. I just wouldn't

16 want non-adaptive power supplies to be drawn into

17 this definition accidentally because of some question

18 about whether it was or whether it did or did not

19 have a communication protocol.

20 MR. DOMMU: Yes. I mean what we're seeing

21 is that these adaptive EPSs charge an end-use product

22 using this communication protocol in a different way

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I than they would charge a product that does not have

2 this communication protocol. So, that's what we're

3 really focusing on here, and that's why we used the

4 example that even though you have this adaptive EPS,

5 which is capable of charging some end use products

6 using a communication protocol that essentially would

7 increase the charging time, obviously, therefore

8 providing benefit to the consumer; but that EPS could

9 also be used to charge other consumer electronics or

10 other end use products that that communication

11 protocol doesn't exist with. So, that's what we're

12 trying to get at.

i 3 So, because their output voltage could

14 vary, we want to make sure that we're capturing all

15 the efficiencies of how this EPS would operate with

i6 the product that it has a communication protocol with

17 versus the one that doesn't. So, I think to the

18 extent that you think that this definition could be

19 even clearer to get at focusing on those where there

20 is this communication protocol, we certainly welcome

21 any input you have.

22 MR. ALBERT: I'm pretty unfamiliar with

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1 it. So, these are all USB-type chargers, or USB-type

2 power units; is that what they are?

3 MR. DOMMU: Again, we're not specifying

4 what the cable is. I'm sure some of the other folks

5 in this room do have a better understanding, and

6 maybe they can enlighten us further.

7 MR. ALBERT: Yes, I don't because that's

$ not our product, I don't think.

9 MR. DOMMU: Sure.

10 MR. ALBERT: But, anyway, I wouldn't want

11 this to be drawn into that just because there was

12 voltage variation taking place in the power unit.

13 There would have to be the requirement that you

14 identify that there's a communication protocol. And

15 so if the Department were, let's say, doing field

16 verification, or whatever it is, right, then you

17 would go and take products off the shelf and you

18 would try to determine whether, in fact, it complied

1 9 with the standard or not, right? And if you obtain a

20 product like that, unless there was information

21 provided by the manufacturer that this process was

22 taking place how would you know that to be the case

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I when you were evaluating it yourselves?

2 MR. DOMMU: Yes. I mean if the

3 manufacturer would be required to certifying

4 compliance based on their understanding of their

5 product in light of these definitions.

6 MR. ALBERT: Okay. All right. Thank you.

7 MR. BROOKMAN: Rick Hiben has another

8 question or comment. Rick, go ahead.

9 MR. HIBEN: Thank you. Going back to the

10 last slide there, maybe to help with this is I have

11 some of the similar concerns as Larry has. Maybe

12 after the word "established" you could add in the

13 words "pre-programmed." That would be clear that

14 this was an intentional thing and not just something

15 that it naturally happened with a charger and a

16 battery communication and voltage fluctuation, so if

17 you put in the word "pre-programmed" to me that would

18 tell you that this was something that was intentional

1 9 with the device.

20 MR. DOMMU: Okay. Thank you for that

21 suggestion. Any other feedback on the definition or

22 response to that suggestion? Okay.

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I So, we did make some clarifications

2 regarding no-load testing as well. So in the test

3 procedure we require the input power measurement be

4 taken at a zero percent loading condition and that's

5 measured and recorded as the no-load mode power

6 consumption.

7 The test procedure for single-voltage EPSs

8 does not instruct technicians to explicitly remove

9 any external loads or to put the EPS into no-load

10 mode in order to conduct the test of a zero percent

11 loading condition. It just says "Test the EPS at a

12 zero percent loading condition." So, we suspect,

13 although we didn't identify this fully, but we

14 suspect that it is possible that if the current

15 demand is decreased to zero electronically, i.e.,

16 adjusting the end use load. It was at 100, then you

17 moved it to 75, then 50, then 25, and now presumably

18 you could adjust it down to zero.

19 If you do it that way versus physically

20 disconnecting the product, that it's possible that

21 there could be some differences in the efficiency

22 power recorded, the no-load power consumed. So, what

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1 we're doing here is that we're specifying and

2 clarifying. We're posing to modify the test

3 procedure to state that any unit under test must be

4 in no-load mode and any additional signal connections

5 be disconnected before taking a measurement at zero

6 percent. So, we're saying let's just test this by

7 removing the end-use load and let's not move the test

8 equipment down to a zero percent electronically.

9 So, any comments on that?

10 MR. BROOKMAN: Larry?

11 MR. ALBERT: So, again, in these examples

12 that you've seen of this, are there separate signal

13 connections in addition to the power connections on

14 the power unit?

15 MR. DOMMU: Again, we suspect this. We

16 just want to clarify that instead of testing no-load

17 by electronically bringing the load down to zero,

18 we're going to test it by disconnecting the product

19 altogether so there's no connections.

20 MR. ALBERT: Okay.

21 MR. BROOKMAN: One individual joining us

22 online, Pierre DeForge has a question or a comment.

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I Pierre, go ahead.

e84

2 MR. DEFORGE: I'm sorry. Can you hear me?

3 MR. BROOKMAN: Yes.

4 MR. DOMMU: Yes, we could hear you now.

5 MR. DEFORGE: So, I had a clarification

6 when you test with -- be that a --

7 MR. DOMMU: You are breaking in and out a

8 little bit there.

9 MR. BROOKMAN: Pierre, you're garbled.

10 Try it again.

11 MR. DEFORGE: -- Sorry.

12 MR. DOMMU: While we're waiting for

13 Pierre, are there any other comments on this? Okay.

14 We have one coming in from the Webinar. I

15 don't if this is Pierre or someone else's.

16 MR. SHEIKH: This is Shahid from Intel.

17 This no-load testing is applicable just

18 for the way you're describing for adaptive, or it's

1 9 applicable for others as well?

20 MR. DOMMU: I believe the way that we

21 propose it is actually applicable for all EPSs, not

22 just adaptive, but it came to light because of the

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1 adaptive issue that it may be more relevant to make

2 sure that it's disconnected for adaptive EPSs. But

3 when we proposed to add this language, we made this

4 applicable for no-load testing for all EPSs.

5 MR. SHEIKH: Got it.

6 MR. BROOKMAN: Pierre, you want to try

7 again on a different line?

8 I guess we're going to move on. Okay.

9 MR. DOMMU: Okay, so we'll go on to the

10 sampling plan. So, for certification and compliance

11 manufacturers are required to rate each basic model

12 according to the sampling provisions that are in the

13 Code in Section 429. So, the way that it's currently

14 worded within 429 it states that the sampling

15 provisions are only applicable to Class A external

36 power supplies. So, now that we have conservation

17 standards in place for power supplies, for external

18 power supplies that are non-Class A that are direct

19 operation external power supplies we are simply

20 proposing to amend that section so that the sampling

21 plan, which is currently applicable to Class A

22 external power supplies would also apply to any

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1 external power supply subject to the conservation

2 standard.

3 So, in the end, we're just changing the

4 language there to make that sampling provision and

5 sampling plan applicable to all external power

6 supplies within the scope.

7 Any questions on that? All right.

8

Okay, so now we'll move on to the optional

9 10 percent loading and power factor tests that we are

10 proposing to add to the test procedure.

11 So, currently, the DOE test procedure does

12 not consider external power supply loading points

13 below 25 percent when calculating the average active

14 mode efficiency, but we are aware of smarter consumer

15 products that do operate in lower operating loads,

16 standby modes in the field, many of which do fall

17 below this 25 percent load threshold.

18 So, measuring the efficiency at the 10

19 percent load helps DOE to understand the efficiency

20 at all loading points that we would anticipate the

21 external power supply operating at. We do think this

22 is particularly relevant because we have seen that

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1 efficiencies tends to fall off at lower loading

2 conditions.

3 I'd note that the European Union code of

4 conduct on EPSs includes a separate calculated

5 performance level using an additional loading point

6 at 10 percent, so that does help harmonize with this.

7 I'd also want to absolutely stress that by adding an

8 optional 10 percent loading test we are not at all

9 changing the way that the average active mode

10 efficiency is calculated. Average active mode

11 efficiency will continue to be calculated by

12 averaging the efficiencies at 25, 50, 75, and 100

13 percent, as applicable. This additional measurement

14 will have no impact on measuring compliance to the

15 current energy conservation standard for EPSs.

16 In the future, DOE may consider whether

17 future revisions to energy conservation standards

18 should include the efficiency at this new loading

19 condition, either as part of the calculation of

20 average active mode efficiency or as a separate,

21 independent standard. So, for now we are proposing

22 to add this 10 percent loading test as an optional

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1 test. It is not required as part of what is reported

2 to DOE to certify compliance with conservation

3 standards for external power supplies.

4 Any questions on this?

5 MR. BROOKMAN: Alex Boesenberg?

6 MR. BOESENBERG: Alex Boesenberg, NEMA.

7 Jeremy, to make sure I understood your

8 statement, this optional test, and DOE may elect in

9 the future, essentially, you're gathering data for

10 future rulemaking if -- maybe?

11 MR. DOMMU: Yes. Yes, that's correct. I

12 mean the data that is provided to us could help us

13 evaluate what efficiencies these operate at a lower

14 loading condition, but as we stated, we do hope that

15 manufacturers would provide this information to us

16 and that's why we're including it as part of the test

17 procedure. But as I will stress, at this point we

18 are only proposing to make this test optional.

19 MR. BROOKMAN: Pierre DeForge I think is

20 going to try to speak with us here in the room again.

21 And Pierre, if you're garbled again this time, then

22 you can write to our Webmaster and we'll read your

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1 comments here in the room, but try it. Let's see if

2 that works.

3 Pierre, we can't hear you yet. Okay, so I

4 guess that's not working.

Rick Hiben also has a question or comment.

6 Rick, go ahead.

7 MR. HIBEN: Yes. Thank you again for the

8 opportunity to comment.

9 We are opposed to adding this 10 percent

10 level in. And I guess some of the reasons behind

II this is that when the EPS efficiencies standard had

12 come out it takes in a broad array of products, and

13 so different products typically run at different

14 percentages of load, regarding their transformer or

15 EPS output, and so it was agreed that you would do

16 the 25, 50, 75, and 100 because you're trying to

17 encompass all the different products that are in this

18 category.

19 And so, I think as we all know is that

20 when you go lower in relationship to your maximum 100

21 percent efficiency output the efficiencies drop. So,

22 at 10 percent, it's going to be much worse than at 25

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or 50 or 75 and definitely much worse than 100. So,

2 by adding this and then having the option for

3 regulator to incorporate this because it's already in

4 the standard to me is a big issue.

5 Our products, we don't run at that low

6 efficiency, and we feel it's not right to be

7 penalized on the efficiency of our units when we're

8 running anywhere from 70 to 80 percent output of our

9 transformer. And I just think that if you're going

10 to start going this route, then you need to start

11 breaking down all the other categories. And if we

12 run our products between 70 and 100 percent

13 efficiency, then we should only have to take those

14 two numbers and get the efficiency at those levels.

15 So, I think this opens up a big can of

16 worms for a lot of us that aren't running at that,

17 and once it's in the test procedure then it's opening

18 it up for regulators to say this is now what you have

19 to comply with, and especially with the levels

20 continuing to go up this 10 percent really puts a big

21 window where it makes it not very good.

22 The last point I'd like to make is it just

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1 seems to us not very cost-effective to potentially

2 buy an EPS that, for example, is capable of producing

3 1 amp of current on the nameplate output, but your

4 product normally only uses less than 100 milliamps,

5 which would be the 10 percent. I mean the expense of

6 those EPSs is going to be much more expensive to buy

7 a 1 amp output versus 100 milliamp output.

8 So, we just don't see the sense in this

9 and are opposed to it, I guess, across the board. If

10 there is a specific application, then I think it

11 should be written specifically for that application

12 and not as an across-the-board requirement.

13 MR. BROOKMAN: Okay. Thank you. Rick,

14 you said "we," who is "we"?

15 MR. HIBEN: I'm sorry? Could you give me

16 further context where I said?

17 MR. BROOKMAN: Well, you said "we" oppose•

18 this?

19 MS. ARMSTRONG: What company are you =:

20 representing? Who are you speaking on behalf of?

21 MR. HIBEN: Wahl Clipper Corporation.

22 Thank you.

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MS. ARMSTRONG: Thank you.

2 MR. BROOKMAN: Thank you. Thanks for that

3 comment. We have another comment.

4 MS. ARMSTRONG: Yes, let me just say, I

5 have a variety of things that came in from the

6 Webinar, but after we had already passed the specific M®

7 section. So, when we go to the end where we recap,

8 I'm just going to read them all, and if people want

9 to chime in at that point for additional discussion

10 just so we don't leave anyone out.

11 MR. BROOKMAN: That sounds good. Thank

12 you.

13 We have another individual online who

14 wishes to ask a question or comment. Bing Lu, please

15 un-mute your phone and let's hear from you, or maybe

16 it's Ping. I guess it's Bing.

17 MR. LU: Yes, this is Bing. So, the

i8 comment I would have is for this 10 percent load

19 point for some of the power supplies. For example,

20 we just mentioned these rapid charge adaptors that

21 can change out to voltage for different loading,

22 right? So a 10 percent loads it might be a valid

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1 operation point because they might automatically

2 switch to another setting if you force it to operate

3 at 10 percent load.

4 So, while you're making the rule, you

5 might to leave the door open that if you cannot

6 measure at that point you give up or something like

7 that so you don't cause people to measure at that

8 point.

9 MR. BROOKMAN: Okay.

10 MR. DOMMU: Thank you for that comment. I

11 would just reiterate again this is an optional test.

12 No one would be required to measure and report this

I 13 loading condition. And again, this is optional to

14 add it to the test method. We are not proposing

15 anything at all at this point related to how or if

16 DOE would consider 10 percent load as part of any

17 future revision to a conservation standard. We are

lx

only talking about how an EPS should be tested and

19 the proposal is to make it optional to test at 10

20 percent. That is it.

21 MR. BROOKMAN: Thank you. Yes, Larry.

22 MR. LU: All right. Thank you.

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MR. ALBERT: Yes, so a couple of

2 questions. One is based on what you just mentioned

3 there, obviously, if you have a test procedure and

4 you're introducing an optional test, and even in your

5 discussion you indicate that this, in fact, could

6 foreshadow a future standard, right? So, it would be

7 appropriate for stakeholders to treat this as if,

8 right, it were to become a future requirement of the

9 test procedure and ultimately a standard. So, that

10 would just be the kind of appropriate thing for us to

it do.

12 With respect to the 10 percent, it's

13 unclear what the interest is in the Department in

14 focusing on a very low loading point of EPSs,

15 regardless of what the efficiency is because the

16 power level at that point that you're actually are

17 at, and therefore the potential savings, right, from

18 a conservation standpoint, would be relatively small.

19 So, why additional focus on this when you've already

20 addressed much higher load points?

21 MR. DOMMU: Yes. I think we've stated it

22 in the preamble, and I thought I discussed it

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1 earlier. The second bullet here is that we are aware

2 of many smarter consumer products that do operate

3 more frequently in the lower load, and that is why we

4 went ahead and made this proposal to optionally test

5 it.

6 MR. ALBERT: I understand that, but the

7 point being is that if it's at 10 percent, then the

S potential savings available in terms of energy by

9 regulating that, which is, what we're looking forward

10 to with this, right, would be relatively small

11 compared to the load points you've already are

12 regulating effectively through the arithmetic average

13 of the 25, 50, 75, and 100 percent, right, which

14 represent much higher power levels and therefore much

15 more energy savings. So, why focus on 10 percent

16 since that represents a very small potential savings.

i7 MS. ARMSTRONG: I'm going to chime in

18 here, Jeremy, if you don't mind.

19 MR. DOMMU: Yes.

20 MS. ARMSTRONG: This is Ashley from DOE.

21 So, your point's well taken. And I think

22 what we've done here is propose a method to try to

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1 get to that answer on our own. We've had various --

2 I would say we've received various comments that low

3 loading does matter, and perhaps, you're not in

4 agreement with that. What the Department has done

5 with this proposal is proposed a method of tests, and

6 you're accurate in saying -- this will be our test

7 procedure, even though it's optional tests.

8 That being said, it's not a foregone

9

conclusion that we will in the next standard

10 iteration, whenever that may be, will include this

11 loading point or any loading points for that matter.

12 They may be all different. We are trying to inform

13 those decisions. So, we're trying to do this early

14 on in the process. If you guys were to run the

15 optional test and have data, we would welcome you to

16 share that data us to inform our decisions about

17 whether 10 percent does matter. I think that's what

18 we're trying to do.

19 Your opinion is that it doesn't. We've

20 had other opinions stated that it does, and we're

21 trying to inform our own opinion through this method.

22 MR. ALBERT: But clearly, the issue here

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1 is is that if an end product ---- and this kind of what

2

Rick was alluding to -- if an end product spends all

3 of its time between 25 and 75 percent or 25 and 100

4 percent, right, then the 10 percent point really

5 doesn't matter with respect to the end product.

6 So, without having this data decoupled

7 from the end product that it's used with and the

8 loading points that that end product applies to the

9 EPS, right, provides you with really no useful

10 information because all you're doing is getting data

11 about a particular load point you can't possibly

12 estimate what the potential energy savings would be

13 as a result of having that piece of information and

14 regulating to it, which is ultimately what you're

15 going to have to do, right, to be able to prove the

16 necessity of having this additional requirement,

17 right?

i8 MS. ARMSTRONG: To the extent we went down

19 the pathway of evaluating or including this load

20 point or any other load point, for that matter, and 3

21 the standards rule we would have to show why it

22 matters, and we would do, as part of our rule, any

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1 estimates of savings would be the amount of time that

2 the units --- estimated amount of time the units would

3 spend at that particular load point.

4 But first, would be the difference in

5 efficiency that it makes. And if people submit data

6 to us, optionally, I'm sure they would be more than

7 willing to inform us if that end-use product could

8 actually see that loading condition in the field.

9

Like you said, EPSs covers a wide variety

10 of different end uses. I imagine would be very

11 different than others.

12 MR. ALBERT: So, currently, right now the

13 metric that you look at with respect to regulation is

14 the arithmetic average of all of the efficiency

15 levels at the four different load points. And so

16 what that does not take into account, obviously, is

17 the waiting that each of those load points have,

18 which would be, in fact, much more reflective of the

19 actual efficiency of the EPS.

20 So, the Department chose to do a straight

21 arithmetic average, presumably, as a proxy for the

22 different potential loads that could be adopted by

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the end product and use with that EPS. And in taking

2 that course of action, walked away, in my opinion

3 anyway, from being able to go back later on and

4 saying, well, we didn't capture a particular load

S point. We didn't capture the losses associated with

6 that. So, is the Department reconsidering then their

7 point of view with respect to straight arithmetic

8 average of the percentages of efficiencies?

9 MS. ARMSTRONG: So, I would say we're not

10 reconsidering for these standards. The current

11 standards that have been established are the ones

12 that will come in. Sure, in response to comments, in

13 response to changing markets, in response to

14 innovative technologies, we can always change the way

15 we do things in the future, but we would do it

16 through rule in response to comments as long as it's

17 not prohibited by statute.

18 MR. ALBERT: Thank you.

19 MR. BROOKMAN: We have another comment

20 from Rick Hiben. Rick, please, go ahead.

21 MR. HIBEN: So, I guess I want to comment

22 back to -- I think it's Ashley from DOE -- is that it

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1 just seems like going down this direction -- if

2 you're going to go this direction, then you also need

3 to then look at the efficiency of the power supplies

4 and where their load ratings are on the ones that are

5 the higher levels. So, effectively, our EPSs have

6 been, in a sense, penalized with the requirement

7 because we do run at higher load levels. We don't

8 run down the 25 percent, but yet, we've got to take

9 that 25 percent reading into account when we're doing

10 our efficiency level even though we never run there.

11 So, I guess if you're going to go back --

12 if you're going to focus on the 10 percent load, then

13 I think open up the whole door, or you should open up

14 the whole door that those of us that run on the

15 higher levels we shouldn't have to be held

16 accountable for the ones that are at 25 percent. But

17 T guess I'm just saying that if you're going to go

18 this route let's make it a two-way street instead of

1 9 a one-way street where we're only focused on the 10

20 percent and penalized down there and not look at the

21 ones that are the upper level.

22 MR. BROOKMAN: Okay. Thanks Rick.

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1 MS. ARMSTRONG: I think that's fair.

2

Thank you.

3 MR. BROOKMAN: Final comments before we

4 move on?

5 MR. DOMMU: Okay, this is Jeremy Dommu

6 again from DOE. We are moving on to the next

7 optional test that DOE proposed in the Notice of

8 Proposed Rulemaking to include that relates to power

9 factor. Power factor is a relative measure of

10 transmission losses between the power plant and an

11 item plugged into AC mains.

12 We feel that the widespread adoption of

13 switch-mode power supplies and other nonlinear loads

14 has brought overall system efficiency into further

15 consideration. So, to make the measurements that are

16 being reported more representative of the average use

17 cycle of EPSs, we would like to propose that power

18 factor be included as an optional test and be

19 examined at each loading condition.

20 So, we proposed within the Notice of

21 Proposed Rulemaking to include power factor

22 measurements each loading condition in the test

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I procedure for EPSs as an optional measurement that is

2 reported.

3 So, again, we are seeking comment on this.

4 And I will reiterate, just like with the 10 percent

5 loading condition, this is an optional data

6 measurement that we are proposing to include as part

7 of this test procedure Notice of Proposed Rulemaking.

8 Questions on power factor?

9 MR. ALBERT: Just so I have some

10 background information, is this the only consumer

11 product category that DOE covers where our factor

12 would be recorded or measured or regulated, or are

13 there other categories that you know of, right?

14 MS. ARMSTRONG: There are other

15 categories.

16 MR. ALBERT: So, what are they?

17 MS. ARMSTRONG: You're not the only ones.

18 So, there are other categories were, at least, in

19 statute power factor is mentioned. There are certain

20 lighting products where power factor is mentioned,

21 and then it was also mentioned in TVs.

22 MR. ALBERT: In TVs and lighting products,

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1 but for example --

2 MS. ARMSTRONG: So, it's like consumer

3 electronic-type/electrical equipment type products.

4 MR. ALBERT: So, for example, cases where

5 you have high displacement power factors, induction

6 motors, for example, or white goods, for example,

7 have induction motors in them. They are not

8 regulated with respect to power factor.

9 MS. ARMSTRONG: That is accurate.

10 MR. ALBERT: So, if in general, the

11 Department is concerned about the losses in

12 transmission, right, due to low power factor, right,

13 why would they not then go after those cases out

14 there that already have covered products, right,

15 where the power factors are low, right? The currents

16 are very high, and so therefore the effect of power

17 factor would have a much more dramatic impact? Why

18 would those not be top priority rather than small

19 EPSs all under 250 watts?

20 MR. DOMMU: I don't have an answer to that

21 question. The focus for me is on this rulemaking

22 initiative. And what is happening with other rules,

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1 to me, is outside the scope of what we're talking

2 about with EPSs as it relates to power factor.

3 MR. ALBERT: Okay, so the proposal is to

4 do a power factor measurement at each loading point?

5 MR. DOMMU: Yes.

6 MR. ALBERT: Okay. And without regard as

7 to whether it's displacement or non-displacement,

8 correct? Thank you.

9 MR. BROOKMAN: Okay. Pekka?

10 MR. HAKKARAINEN: Pekka Hakkarainen,

11 Lutron Electronics.

12 So power factor is defined in the statute

13 for certain products, as Ashley already pointed out,

14 but not specifically for external power supplies and

15 not in general. So, there's no general definition of

16 power factor.

17 Jeremy, given the way that you are

18 introducing this topic here, then you are talking

19 about power factor relative to items that are plugged

20 into wall outlets. So, I would then interpret this

21 to mean that, to the extent that certain solid-state

22 lighting drivers are determined to be in the scope,

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1 then this optional power factor measurement would not

2 apply to those certain products because they don't

3 fit the definition given here.

4 MR. DOMMU: Sure. I mean this is an

5 optional test, so there is nothing that would be

6 required to report power factor to begin with.

7 MR. BROOKMAN: Keith?

8 MR. COOK: I think for this to be

9 meaningful, though, you also need to note whether or

10 not it's an inductive load or a capacitive load

11 because they do offset each other, and so the net

12 effect could be zero if you're looking at a total

13 building. And as far as the power company or utility

14 is concerned. So just measuring this in itself has

15 no value.

16 MR. BROOKMAN: Okay, thanks. Ernest.

17 MR. MENDOZA: Ernesto Mendoza, from

18 Philips Electronics.

19 This is a very difficult topic because

20 power factor is a complex metric that includes two

21 aspects, displacement and harmonics. So, if you make

22 this gathering of that whether you end up with some

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I power factor values it will be very difficult to

2

discompose and know is the root cause. So, you're

3 going to have these values and then what do we do

4 with those?

5 And as he was pointing out is the concern

6

is the losses on the transmission from the utilities

7 to the house I'm not sure how knowing the power

8 factor of the power supply will lead to know the

9 whole load power factor.

10 MR. BROOKMAN: Okay. Thank you. Yes,

11 Larry?

12 MR. ALBERT: So, just is the concern of

13 the Department with respect to losses in the branch

14 circuits or in the whole transmission system because

15 the point made earlier is that frequently power

16 factors are cancelled, right, when they get to the

17 distribution backed up to the high tension lines and

18 so on, right? But if your concern is the losses

19 associated with branch circuit losses and so on, then

20 that has a different model that you have to follow.

21 So, I guess that ties into maybe the

22 broader question is is this even within the authority

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1 of the Department when you're regulating the energy

2 efficiency of our product itself, right? Here you're

3 considering losses that might exist in the power

4 distribution system as a result of, perhaps, high

5 impedance in circuitry and so on that's included in

6 building wiring and so on, which is outside of the

7 scope of the -- outside of the control of the

8 manufacturer.

9 MR. DOMMU: Okay. Thank you for that.

10 Yes. I mean, as we stated, we're considering overall

ti

11 system efficiency. And again, this is just a

12 measurement that we are proposing to be taken as part

13 of the test procedure and is not a proposal to do

14 anything other than simply measure this data, this

15 measurement point. If a manufacturer so choose to

16 perform and report this optional test that we're

17 proposing.

18 MR. SHEIKH: Shahid with Intel.

19 Sorry. Going back to the adaptive EPS

20 briefly, did DOE conduct any data analysis to

21 establish the single-voltage efficiency requirements

22 properly apply for the adaptive EPS if it's low?

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1 MR. DOMMU: I mean we looked at the

2 definition of singl -voltage, Class A EPS and

3 compared it what we have come to know about adaptive

4 EPSs and made a determination that based on what

5 we've seen that because they are only outputting one

6 output voltage at a time they would be considered a

7 single-voltage EPS.

8 MR. SHEIKH: But was there any data

9 collection done?

10 MR. DOMMU: No, we haven't done any data

11 collection yet. We welcome data that you have on

12 these types of EPSs, though. I think that would be

13 helpful if you have information that you could share

i4 with us.

15 MR. SHEIKH: Whether this communication

16 protocol whether that made any difference in

17 efficiency levels or anything like that?

18 MR. DOMMU: Yes, that would be useful

19 information if you could submit that.

20 Okay, so that was the optional tests.

21 We're getting towards the end of what we are doing.

22 In fact, I just covered all of the proposed changes

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1 that DOE made in this Notice of Proposed Rulemaking

2 to the test procedure.

3 1 do have one more agenda item as it

4 relates to a guidance document that DOE just issued

5 last week that I wanted to just briefly touch on

6 because it relates to external power supplies.

7 I think, hopefully, many of you have seen

this. There was an email that went out with this

9

guidance document last week on November 14. That is

10 a live link, but you probably can't click on it

11 during the Webinar, but that would bring you to the

12 guidance document if you haven't seen it. You could

13 also find it under the guidance section of the

14 Department of Energy's appliance standards website.

15 I will stress this is outside the scope of

16 the Notice of Proposal Rulemaking. This is a

17 completely different procedure that we're following

18 here. It's a guidance document. What a guidance

19 document is essentially just represents DOE's

20 interpretation of existing regulations. It is a

21 draft guidance document. It is not yet finalized.

22 So, we are welcoming comments on it. And if you do

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I have comments, there is the email address to submit

2 those comments to within the guidance document itself

3 that you could find that information as well.

4 Comments on it are due December 15.

5 So, again, this is a separate process.

6 Please keep comments to this issue separate from the

7 Notice of Proposed Rulemaking and reply specifically

8 on this issue to this email address and keep any

9 other comments to the test procedure and what we're

10 proposing in the other docket.

11 But essentially, in a nutshell, and I

12 encourage you to read the guidance document, what

13 we're saying is as long as an EPS is of a type which

14 is capable of operating a consumer product, even if

15 that EPS is packaged with and used to operate

16 commercial or industrial equipment, it would still be

17 considered a covered product by DOE and possibly

18 subject to DOE's energy conservation standards

19 regardless of whether that EPS was, in fact,

20 distributed into commerce to operate a consumer

21 product.

22 Only EPSs that have identifiable design

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1 characteristics that would make them incapable of

2 operating a consumer product would be considered to

3 not meet this definition of an EPS.

4

That's essentially what we said in the

5 guidance document. Again, it's a separate process,

6 and we just put this out last week with a 30-day

7 comment period. We do have an issue box here, so if

8 anyone have any specific comments they want to bring

9 up now, by all means, we're here. We'll take them.

10 But again, this is a guidance document and not a

11 rulemaking proposal.

12 MR. BROOKMAN: Yes. Larry?

13 MR. ALBERT: So, this does tie into

14 something we were discussing a little bit earlier

15 about what qualifies a EPS for being covered or not

16 covered, right? And I believe my understanding was

17 is that the EPS is covered because it is associated a

18 consumer product, right, and therefore then the

19 question of whether it's -- the question about being

20 indirect earlier was if that consumer product that it

21 is associated with then qualifies it, essentially, as

22 being indirect then it's indirect, right?

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1 So, this then seems to suggest the

2 opposite, which is the EPS all by itself is covered,

3 right, independent of whether it is associated with a

4 consumer product or not if it is of a type that could

5 be connected to a consumer product. Is that

6 essentially the understanding here?

7 MS. ARMSTRONG: So, first of all, I think

8 to clarify an EPS is a covered consumer product

9 period. It is set forth in the consumer product

10 section of our regulations. It is a covered product.

11 Now, the definition of an EPS encompasses

12 some different things, which try articulate how a

13 particular model or how a manufacturer should

14 determine if a particular model falls into that

15 definition. One of those has to do with its end-use

16 and being used with an otherwise consumer product.

17 You should read the guidance. The

1$ guidance is carefully worded, but the intent of the

i9 guidance, and obviously we welcome comments on this,

20 would be that it's the same as our earlier discussion

21 was if you have an EPS that is used in multiple

22 applications, 1 of those being consumer, 50 of those

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1 being commercial, it is of a type that meets the EPS

2 definition. It is picked up. It is used in a

3 consumer end use product.

4 There's a difference between capability

and intended use, and that's the, in my opinion, the

6 discussion we had earlier that we need to take back

7 and potentially think about clarifying further; but I

8 think the intent of the guidance was we have gotten a

9 lot of questions -- to be perfectly honest, we've

10 gotten a lot of questions -- that I have an EPS, it

11 works for a variety -- I make a single EPS that works >

12 for a variety of end-use applications. Some are

13 consumer. Some are commercial. Some are industrial.

14 Well, I think our clarification here is if

15 it can be used in one consumer application it's

16 picked up.

17 MR. ALBERT: That was by the same

18 manufacturer when those questions came up, right?

19 MS. ARMSTRONG: Correct.

20 MR. ALBERT: But the question here would

21 be would it -- if that EPS could conceivably be used

22 by another manufacturer's product is the question.

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1 MS. ARMSTRONG: I get that part.

2 MR. ALBERT: Okay. And then the third

question was is this --

4 MS. ARMSTRONG: Alex and his garage.

5 MR. ALBERT: Yes. And the third part of

6 it is it's identifiable design characteristics,

right? What did you guys have in mind by that

8 statement? So, you'd have some design characteristic

9 that would put it into one bucket or the other? I

10 mean a type of connector or some other feature? What

11 were you thinking about?

12 MS. ARMSTRONG: I don't know that we had

13 specifics in mind, or at least specifics that -- I

14 mean there's a reason we left it with that wording.

15 I would say what we were trying to distinguish with

16 the guidance -- the intent of the guidance, and

17 perhaps we can work on the words, but the intent of

18 the guidance was exactly the scenario I described.

19 That to distinguish how you, as a manufacturer,

20 decide if something is going to be intended for a

21 consumer or commercial or industrial application.

22 MR. ALBERT: I get that. That's perfectly

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clear, right?

2 MS. ARMSTRONG: Yes.

3 MR. ALBERT: It's just that if I have then

4 point to -- if I have a particular EPS and it could

5 be used, right, in a consumer application and the

6 only way I can get out of that, basically, is by

7 pointing to some design feature of the EPS -- what's

8 on the list of acceptable design features, right,

9 that qualify me to get out of that, right?

10 MS. ARMSTRONG: That gets to the term of

11 capability. I get it.

12 MR. ALBERT: Right.

13 MS. ARMSTRONG: Thanks.

14 MR. BROOKMAN: Okay. Additional comments?

15 MR. ALBERT: Nothing additional.

16 MR. DOMMU: Okay, that brings us to the

17 end of the presentation. I have a couple more slides

18 that just go over the details of how to submit

19 comments and some other relevant blanks --

20 MS. ARMSTRONG: Hang on one second,

21 Jeremy.

22 MR. DOMMU: -- but I do know we do have a

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1 lot of other comments from the Webinar. So, before

2 we get to that let's go through them.

3 MS. ARMSTRONG: Yes. So, I'm going to try

4 to put these in somewhat of an order, but they're

5

kind of throughout the whole presentation.

6 And I don't know if we'll be able to

7 answer them all, but there's been a question

8 submitted by Pierre.

9

What happens if an BPS is low voltage and

10 non-communicating mode, but basic voltage in adaptive

11 mode? Would the EPS then have to meet the basic

12 voltage requirements at the highest voltage?

13 MR. DOMMU: That's a good question. The

14 direct operation BPS standards do differentiate

15 between basic voltage and low-voltage, and there's

16 different conservation standards in place for both of

17 those. That is a question that we will certainly

is consider and provide guidance on as we move forward

19 with (A) understanding adaptive EPSs and (B)

20 considering all relevant comments. So, thank you for

21 that Pierre.

22 MR. BROOKMAN: Is your microphone on?

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1 MS. ARMSTRONG: Yes, basically, in one

2

mode it's low-voltage and then it's basic voltage in

3 adaptive mode is what he's saying. That's all I

4 have.

5 So, Arnold Offner, from Phoenix Contact

6 had a variety of different questions. I'm going to

7 start with my favorite first, which is "We concur

8 with Ashley." I have no idea what I said, but I'm

9 glad you agree with me.

10 Basically, I think this has to do with

11 back when we were talking about solid-state lighting

12 and drivers. His comment was we concur with Ashley

13 with respect to the position I took on --- it's on

14 Alex's slide with the two columns, one on the EPS

15 definition and one on solid-state drivers definitions

16 and how I commented that they may not be mutually

17 exclusive. That you could still fall into the other

18 bucket for some or depending on how we end up

19 clarifying this issue together.

20 But his point was since the technology

21 does exist to satisfy the Level 6 in 2016 and beyond,

22 he agrees -- I think he agrees that some solid-state

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1 drives could potentially meet the EPS standards. I'm

2

kind of reading between the lines there.

3 So, Arnold, please chime in if I

4

mischaracterized you in any way.

5 So, further on, his comment would be there

6

are power supply manufacturers who sell power

7 supplies to the industrial market. These power

8 supplies could be used to power 5-volt DC or 12-volt

9 DC or 24-volt DC or 48-volt DC loads, which could

10 also be a consumer load. So, I think this gets to

11 the point that we were talking about capability

12 versus intended use, and he asked for the Department

AI

13 to clarify that.

14 Last issue had to do with the hiccup mode.

15 Hiccup of a switch-mode power supply occurs when the

16 power output is above the 100 percent design limit.

17 Hiccup means the power is not operating at 100

18 percent, but rather at a design level at about 110

19 percent or higher. Examples of a communication

20 protocol should be provided as an example in this

21 adaptive EPS power supply. And that's also from

22 Arnold, so thank you for those comments.

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1 So then there's a question from Daniel

2 Jackal.

3 Will communication protocol also include

4

an analog feedback signal? From a mechanical

5 engineer, I don't even know what that means.

6 MR. DOMMU: Yes, I would ask for more

7 detail also. I mean what we did propose we just used

& the term "communication protocol," so, presumably,

9 any communication protocol would be included there,

10 but we do welcome comments if more clarification is

11 necessary on what communication protocol means.

12 MS. ARMSTRONG: So, Daniel, to the extent

13 you could follow up with us, we'd be happy to take

14 your feedback on that.

15 And that's all I got.

16 MR. DOMMU: Is there anything else before

17 we get to these last couple of wrap-up slides?

18 MR. BROOKMAN: Larry?

19 MR. ALBERT: Two other kind of comments

20 here. First of all, it deals with the definition of

21 indirect EPS, right? In that definition is included

22 a sequence of steps, right?

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MR. DOMMU: Yes.

2 MR. ALBERT: That area effectively like a

3 test procedure in of themselves, right? And so the

4 problem with that is that in the definition they are

5 then, therefore, outside of the scope of the general

6 conditions for tests that would apply to the test

7

procedure as a whole, right? And my belief is that

8 if, in fact, you're doing testing there to establish

9 that it's indirect or not that it should be part of

10 the test procedure proper, right, and therefore be

11 subject to all the general conditions for tests, the

12 accuracy measurements and so on that would apply to

13 all other measurements, right? And that's really

14 more like a technical detail, right?

15 MR. DOMMU: Yes. I mean we included it as

16 part of the definition as way for the manufacturers

17 to have a way to determine whether it's direct or

18 indirect. I wouldn't call it tests in that sense.

19 I'd just test call it -- you know, it's the way to

20 determine whether things are direct or indirect.

21 It's not a required test.

22 MS. ARMSTRONG: I think your point is well

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1 taken. There are certain products, lighting is one

2 example, where we do have test procedures or certain

3 methods of tests referred to, to define certain types

4 of covered products -- or certain categories of

S covered products, but to link to specific conditions

6 in a test procedure is never a bad idea.

7 MR. ALBERT: Okay. And my second question

8 deals with -- it's also a testing issue, right? In

9 these other product categories where you define

10 limits, for example, for power factor do those test

11 procedures call it a specific source impedance for

12 the testing?

13 MR. DOMMU: I didn't catch the last part

14 of that.

15 MR. ALBERT: So, in those test procedures

16 that you have for those product categories where

17 there is a measurement of power factor required, is

18 there a source impedance identified that DOE uses

19 across the board, I would imagine, for those cases

20 that would apply in this case as well?

21 MS. ARMSTRONG: I don't know the answer

22 off the top of my head. I'll have to go look. I

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1 don't know if you guys know. I know ballast is one

2 where it gets picked up too, so electronic ballast.

3 MR. MENDOZA: I can comment on that. An

4 electronic ballast --

5 MR. BROOKMAN: Ernest.

6 MR. MENDOZA: I'm sorry. Ernesto Mendoza

from Philips Electronics.

8

I also chair the RCD 2.11 for electronic

9 ballast. We do have a specified source impedance .4S

10 ohms --- that came out from buildings, but I don't

11 know how it's going to relate to this because that

12 meant impedance that is on the luminaire units in

13 the ceiling, not from your outlet.

14 MS. ARMSTRONG: So, we have one more

15 question from the Webinar. It's from Daniel Jackal

16 again.

17 Back to direct versus indirect operation.

18 What is the definition of "operate" in reference to

19 consumer product? Not sure this is well defined,

20 given in 10 C.F.R. 430.2.

21 I think this is broader than just direct

22 and indirect, as least in my opinion. So, I think

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I this is something we'll clarify, but operate a

2 consumer a consumer product, just generally speaking,

3 just means to be -- it works with a consumer product.

4 It's used with a consumer product. So, to the extent

5

that you believe specific wording to clarify the word

6 "operate" is needed, we welcome that.

7 MR. DOMMU: Okay. So, this wraps up the

8 meeting on this final slide here. DOE seeks comments

9

on its test procedure. Here -- it looks like we may

10 be having one more Webinar comment come in, so let me

11 just hold off on this and see. I want to make sure

12 that everyone does have a chance to provide any

13 comments that they wish.

14 MS. ARMSTRONG: It's Daniel again.

15 MR. DOMMU: Good.

16 MS. ARMSTRONG: Just to follow up, Daniel,

12 we can un-mute you if you want to have a dialogue,

18 but he's asking 100 percent of the features. So, in

19 my opinion, the way I read this again it gets you

20 capable of operating versus intended use. And so it

21 gets back to the same thing that we need to

22 potentially think about clarifying manufacturers

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1 intended use and can operate in a manner that the

2

manufacturer intended it to use versus just capable

3 via being plugged in even though it may not be

4

optimal or intended to be used that way.

5 MR. DOMMU: Okay, so here's the

6

information on how to submit comments. I would note

7 that we did push back the comment deadline per

8 stakeholder request, so we are providing additional

9 time. Originally, I think it was December 8, but we

10 got a request, and in the Notice of Public Meeting

11 announcing today's meeting we did announce that we

12 are pushing back the comment date. So, comments are

13 due December 23. The Notice of Public Meeting states J,

14 that, so we do have some extra time. So, I hope you

15 guys all have a good time prior to your Christmas

16 break to get your comments in.

17 Here's all the information on how to

18 submit them to the email address there directly onto

19 regulations.gov . There are instructions if you wish

20 to use them on how to send them via postal mail or

21 hand delivery. And then finally, this slide has some

22 relevant URLs so you could find additional

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1 information. You could find all the notices. Public

2

comments will be available on the rulemaking docket.

3 So, here are links to various different websites and

4 regulations.gov and energy.gov about DOE's external

5 power supply program.

6 And that will conclude today's public

7 meeting. I do greatly appreciate everyone's

8 participation today. Thank you so much for coming.

9 T look forward to reading all of your written

10 comments and appreciate very much and look forward to

11 working with all of you to finalize and make these

12 clarifications and consider your comments as they

ip

13 relate to the test procedure for external power

14 supplies.

15 MR. BROOKMAN: Thank you. A final.

16 MR. DOMMU: One comment.

17 MR. CHRIS: Jeremy Chris from Universal.

18 Is this already posted on the website?

19 MR. DOMMU: The slides? I don't know. If

20 they're not up there right now, they will be up there

21 very soon. And if the third link here on the

22 rulemaking website is where you will go to find a

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1 direct link to them. They'll be on the docket as

2 well, but these slides will be made publicly

3 available.

4 MR. BROOKMAN: As well as Alex's slides.

5 MR. DOMMU: As well as Alex's slides will

6 be submitted to the docket.

7 MR. BROOKMAN: Thanks to all of you.

8 (Whereupon the meeting adjourned at 11:36

9 a.m.)

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12

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15

16

17

18

19

20

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TRANCRIPTION CERTIFICATE

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attached document(s) are, to the best of my abilities, an

accurate transcription of tape recordings provided to the

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recording(s), and that I have no financial or other

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TRANSCRIBER