December 23, 2010 

Mr. Victor Petrolati 

U.S. Department of Energy 

1000 Independence Ave. 

Washington, DC 

Subject: Ex Parte Meeting with DOE and Navigant Consulting on Battery Charger Energy 

Standards, December 6, 2010 

Dear Mr. Petrolati: 

This memo memorializes the meeting between AHAM, PTI and the Department of Energy on 

December 6, 2010 for inclusion in the public docket. 

In summary, during the meeting, we were able to cover several topics that are related to DOE 

setting the standards for consumer battery chargers that apply to power tools and other 

appliances and fall under the category of Motor Operated and or Detachable Battery (MADB) 

chargers. 

1. AHAM and PTI noted that some of the Candidate Standards Levels for Product Classes 2, 3, 

and 4 appear to be set dependent upon the type of cell chemistry. It looked in the initial 

evaluation that CSL 2 was only achievable with Lithium-based cell chemistries. 

2. AHAM and PTI noted that most of the consumer products marketed are still composed of 

nickel-based battery chemistries which continue to offer great consumer value. Often, 

consumers do perceive the value that lithium-based batteries might bring them. This restricts the 

value for consumers and makes it difficult to market them. 

3. Most of the products in Product Class 3 are computer devices and they mask the cost and 

performance of the consumer MADB battery chargers. AHAM and PTI asked DOE and 

Navigant to investigate what would happen to the LCCA of Product Classes 2, 3, and 4 if the 

computer products (non-MADB) were backed out of the equations. 

4. AHAM and PTI noted that the preponderance of the BCS’s are under 50 Wh and asked that 

DOE and Navigant consider a minimum value on the line slopes that could be drawn horizontal 

to allow for fixed energy losses of lower power systems. 

5. AHAM and PTI asked DOE to look again at the usage profiles, particularly for the Class 2 infrequently charged products. In addition, there seems to be a wide split of products in Class 2, 
p 2 

with many digital devices already at CSL 1 or 2, but most nickel-chemistry consumer MADB 

devices at CSL 0. This would mean that any increase should consider the impact on the MADB 

and not factor in the products that are already well beyond CSL 1 or 2. 

6. AHAM and PTI pointed out that there are additional costs that may not have been considered 

in the original LCC. 

 a. UL 2575 is being implemented in 2010 and 2011 and will have an effect requiring 

additional safety redundancies for lithium power cells that are used in MADB applications but 

not in computer devices. 

 b. In order to meet consumer expectations on cell life, manufacturers using Lithium 

chemistries may install discharge control devices. It seems as if the samples that Navigant and 

DNR considered for the costing analysis may not have included this functionality that would 

provide constant utility compared to nickel based systems. AHAM and PTI asked DOE to look 

at the LCC again. 

The attendees at this meeting were, Mr. Larry Albert representing Power Tools Institute (PTI) 

and Wayne Morris, representing the Association of Home Appliance Manufacturers (AHAM) 

were present in addition to Michael Vladimir, Matt Nardotti and Michael Rivest of Navigant, 

Victor Petrolati from DOE and Toby Swope of DNR. 

We appreciate the opportunity to meet with DOE on this subject. We are enclosing a set of 

PowerPoint slides that were used in the discussion. 

Sincerely, 

Wayne Morris 

Vice President, Division Services