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 UNITED STATES OF AMERICA 

 + + + + + 

 DEPARTMENT OF ENERGY 

 + + + + + 

 PUBLIC MEETING ON THE TEST PROCEDURE NOPR 

 FOR BATTERY CHARGERS AND EXTERNAL 

 POWER SUPPLIES 

 + + + + + 

 FRIDAY 

 MAY 7, 2010 

 WASHINGTON, D.C. 

 The Public Meeting on the Test 

Procedure NOPR for Battery Chargers and 

External Power Supplies convened at 9:00 a.m., 

pursuant to notice, in Room 8E-089, U.S. 

Department of Energy, 1000 Independence 

Avenue, S.W., Washington, D.C., Doug Brookman, 

moderator, presiding. 

PRESENT: 

DOUG BROOKMAN, Moderator, Public Solutions, 

 Inc. 

LARRY ALBERT, Black & Decker 

PAUL BENDT, Ecos Consulting 

LINDSAY DESTEFANO, Navigant Consulting 

RICK ERDHEIM, Philips Electronics 

KATE HOWARD, Natural Resources Defense 

 Council 

ROB HUDNALL, Euro-Pro 

DEBBIE JEFFERS, Energetics 

HOI YEE LAM, Energetics 

DANIEL LAUF, D&R International 

MATEUSZ MALINOWSKI, Navigant Consulting 

JOANNA MAUER, Appliance Standards Awareness 

 Project 

SARA MATTERN, ICF International 

PRESENT (Cont'd:) 

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WAYNE MORRIS, Association of Home Appliances 

 Manufacturers 

VICTOR PETROLATI, DOE 

ARI REEVES, D&R International 

KILEY ROBBINS, Navigant Consulting 

ERIC STAS, DOE 

IAN SWINK, Department of Justice 

ILYA TSINIS, Navigant Consulting 

MICHAEL VLADIMER, Navigant Consulting 

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 C-O-N-T-E-N-T-S 

WELCOME....................................4 

 Victor Petrolati 

INTRODUCTION AND AGENDA REVIEW.............4 

 Victor Petrolati 

STAKEHOLDER PRESENTATIONS.................14 

LEGAL AUTHORITY AND BACKGROUND............29 

 Victor Petrolati 

BC ACTIVE MODE TEST PROCEDURE.............35 

 Mateusz Malinowski, 

 Navigant Consulting 

BREAK....................................127 

BC ACTIVE MODE TEST PROCEDURE............128 

 Michael Vladimer, 

 Navigant Consulting 

BC AND EPS STANDBY AND OFF MODE TEST 

PROCEDURES...............................186 

 Mateusz Malinowski, 

 Navigant Consulting 

SINGLE-VOLTAGE EPS ACTIVE MODE TEST 

PROCEDURE................................189 

 Mateusz Malinowski, 

 Navigant Consulting 

MULTIPLE-VOLTAGE EPS ACTIVE MODE TEST 

PROCEDURE................................207 

 MATEUSZ MALINOWSKI, 

 Navigant Consulting 

CLOSING REMARKS AND ADJOURN..............252 

 Victor Petrolati 

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1 P-R-O-C-E-E-D-I-N-G-S 

2 9:06 a.m. 

3 MR. PETROLATI: Okay. Good 

4 morning. This is the NOPR, Notice of Proposed 

5 Rule meeting on Battery Chargers and External 

6 Power Supplies for Test Procedures. Let me 

7 immediately turn it over to our facilitator, 

8 Doug Brookman, to go over a few of the ground 

9 rules and other things associated with the 

10 meeting. Doug. 

11 MR. BROOKMAN: Thank you. Good 

12 morning. Glad to see you, appreciate your 

13 being here on time so we can really start. 

14 It's our tradition to do 

15 introductions around the room. If you'd say 

16 your name, and organizational affiliation. In 

17 order to be captured on the transcript, you 

18 need to push the little green LED button. 

19 We'll start over here with Deborah and go 

20 around the room. Name and organizational 

21 affiliations. 

22 MS. JEFFERS: Debbie Jeffers, 

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1 Energetics. 

2 MS. LAM: Hoi Yee Lam, Energetics. 

3 MR. BENDT: Paul Bendt, Ecos 

4 Consulting here on behalf of Pacific Gas & 

5 Electric. 

6 MR. HUDNALL: Ralph Hudnall, Euro7 Pro. 

8 MR. ALBERT: Larry Albert, Black & 

9 Decker on behalf of the Power Tool Institute. 

10 MR. MORRIS: Wayne Morris with the 

11 Association of Home Appliance Manufacturers. 

12 MR. ERDHEIM: Rick Erdheim with 

13 Philips Electronics. 

14 MS. HOWARD: Kate Howard with the 

15 Natural Resources Defense Council. 

16 MR. SWINK: Ian Swink with the 

17 U.S. Department of Justice, Antitrust 

18 Division. 

19 MS. MAUER: Joanna Mauer with the 

20 Appliance Standards Awareness Project. 

21 MS. MATTERN: Sara Mattern with 

22 ICF International on behalf of the ENERGY STAR 

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1 Program. 

2 MR. STAS: Eric Stas, DOE General 

3 Counsel's office. 

4 MR. BROOKMAN: If you can just 

5 speak loudly. 

6 MR. LAUF: Dan Lauf, D&R 

7 International. 

8 MR. MALINOWSKI: Matt Malinowski, 

9 Navigant Consulting. 

10 MS. DESTEFANO: Lindsay Destefano, 

11 Navigant Consulting. 

12 MR. REEVES: Ari Reeves, D&R 

13 International. 

14 MR. VLADIMER: Michael Vladimer, 

15 Navigant Consulting. 

16 MS. ROBBINS: Kiley Robbins, 

17 Navigant Consulting. 

18 MR. TSINIS: Ilya Tsinis, Navigant 

19 Consulting. 

20 MR. BROOKMAN: Again, welcome. 

21 Glad to have you all here. 

22 I think all of you received a 

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1 packet when you registered this morning at the 

2 front desk at the Department of Energy. I'm 

3 going to run through the agenda very briefly. 

4 Immediately following this agenda review, Vic 

5 is going to provide some opening remarks and 

6 overview of some of the issues that would be 

7 typically raised. Following that, there will 

8 be an opportunity for brief stakeholder 

9 presentations. I know of one or two 

10 individuals that have content that they've 

11 already prepared for the meeting today. 

12 After that, we're going to talk 

13 about legal authority and background, and go 

14 directly into the content of this meeting, BC 

15 active mode test procedure. We'll take a 

16 break midmorning around about 10:45, 10:55, or 

17 so, and then we will continue with the BC 

18 active mode test procedure. Following that, 

19 BC and EPS standby and off mode test 

20 procedures, and then single-voltage EPS active 

21 mode test procedure, multiple-voltage EPS 

22 active mode test procedure, and then closing 

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1 remarks and adjourning today, we hope or 

2 anticipate around about 1:00. 

3 There's typically an opportunity 

4 at the very end of the day for anybody to 

5 raise additional issues that they haven't 

6 covered during the course of the meeting. So 

7 that would be our general plan. Questions and 

8 comments on that? I see none. 

9 I'd just simply ask for your 

10 consideration during the conduct of the 

11 meeting. Please speak one at a time, please 

12 say your name for the record. You don't need 

13 to say your organizational affiliation every 

14 single time, but please do say your name. 

15 There will be a transcript of this meeting, a 

16 full rendering of what was said here. Please 

17 try to be concise, share the air time. If you 

18 have a cell phone, please put it on silent 

19 mode. And if you need to have a sidebar 

20 conversation with someone, it's okay to take 

21 it out of the room. That will work just fine. 

22 And I think that's about it. And when we get 

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1 to the break, we'll talk about where the rest 

2 rooms are, and other issues such as that. So, 

3 back to Vic. 

4 MR. PETROLATI: Thank you, Doug. 

5 Okay. Just a few opening remarks. 

6 First of all, my name is Victor Petrolati. 

7 I'm with the Appliance Standards Program in 

8 the Office of Energy Efficiency and Renewable 

9 Energy, and I am the Project Manager for 

10 Battery Chargers and External Power Supplies. 

11 I'd certainly like to welcome everybody that 

12 was able to attend here today, and I also want 

13 to welcome what generally has been a pretty 

14 large audience on our webcast here for today's 

15 meeting. 

16 This is our third webcast of our 

17 public meeting for Battery Chargers and 

18 External Power Supplies, and we're very glad 

19 to be able to provide the webcast for this 

20 particular product, since many of the 

21 manufacturers, private labelers, suppliers 

22 are, in fact, outside the country. 

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1 We have a very tight schedule here 

2 this morning, as you've probably noticed. 

3 It's been a recent trend within Appliance 

4 Standards to try to hold a public meeting for 

5 test procedures, generally, as a half-day 

6 meeting. We do have some flexibility. We 

7 would like to stay on schedule, but if we find 

8 that we've got some issues that need further 

9 discussion, we will allow that discussion to 

10 continue. We may have, and Doug will show us 

11 when we go through the agenda, we may have 

12 some flexibility. We may break for lunch, if 

13 we can't complete, but my hope is that we can 

14 complete it under schedule. 

15 Okay. We hope you have a good 

16 experience here at the public meeting, and we 

17 certainly hope those that are listening in the 

18 webcast don't have any problems in terms of 

19 the audio-video problems associated with the 

20 webcast, so we hope you also have a good 

21 experience here this morning. Thank you. 

22 Just quickly, I wanted to go over 

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1 some of the rules on the webcast. We are 

2 broadcasting this as a public meeting live 

3 over the internet. DOE is providing the 

4 webcast to accommodate stakeholders that are 

5 unable to attend the meeting. The webcast 

6 allows stakeholders to listen in and view the 

7 presentation slides. However, only 

8 stakeholders physically in attendance may 

9 provide questions, or comments during the 

10 meeting. So, this is our standard way of 

11 providing these webcasts, currently, and I 

12 want to apologize a little bit to the people 

13 who are coming into the meeting through the 

14 webcast, but we will not allow questions. 

15 However, we have a comment period, and we'll 

16 show you how long that comment period is in 

17 just a minute, so we are very interested in 

18 getting written comments from those people who 

19 are not here at the meeting today. Thank you. 

20 Okay. The introduction and the 

21 agenda review, basically, Doug has covered 

22 this, so we'll go right to the purpose of the 

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1 test procedure meeting. Okay. We are here to 

2 present an overview of the statute and all 

3 Departmental actions regarding battery 

4 chargers and external power supplies, want to 

5 present the proposed test procedure as part of 

6 our Notice of Proposed Rulemaking for Battery 

7 Chargers and EPSs, the amendments that we are 

8 making to the current test procedures. We 

9 seek oral and written comments on the proposed 

10 test procedure, and we want to discuss and 

11 respond to specific issues and questions 

12 related to our proposal here today. 

13 Okay. This is the most important 

14 thing for us, feedback. We are very 

15 interested in getting your feedback on our 

16 proposal, got a number of ways that can be 

17 done. Primarily, most of the comments come 

18 through our email box. We've got the email 

19 box there in front of you, 

20 BC&EPS_Test_Proc@ee.doe.gov, and comments can 

21 also be submitted through postal mail to Ms. 

22 Brenda Edwards at the address shown. 

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1 Okay. The comment period closes 

 th

2 June 16 , 2010, so we actually have a little 

3 over a month before the comment period closes. 

4 So, we've got plenty of time to get comments 

5 in from our stakeholders. Any questions? 

6 Okay. You'll see an issue box 

7 like this throughout all the presentations. 

8 This is, basically, indicating that this is an 

9 issue that we would like to get comments back 

10 from the stakeholders. We are not limiting 

11 the stakeholders’ comments in any manner, but 

12 these particular issues that we felt we needed 

13 some further information on from the 

14 stakeholders, and we will be displaying, 

15 during presentations today, comment boxes 

16 similar to this to make sure that we do get 

17 those comments in. 

18 Okay. The floor is now open for 

19 stakeholder comments. Okay. And we have, as 

20 far as I know, two that are going to be 

21 presenting some comments. We've got Mr. Paul 

22 Bendt from Ecos Consulting, and Mr. Wayne 

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1 Morris from AHAM. Paul. 

2 MR. BROOKMAN: He's got slides to 

3 queue. 

4 DR. BENDT: While they're getting 

5 slides, I'm Dr. Paul Bendt. I work for Ecos 

6 Consulting, which is serving as a technical 

7 consultant for Pacific Gas & Electric, so I am 

8 here on behalf of PG&E this morning. PG&E is 

9 also representing the interests of other 

10 California investor-owned utilities who are 

11 involved in Appliance Standards, and promoting 

12 energy efficiency for all the rate payers in 

13 California. 

14 We applaud DOE's basic approach in 

15 this test procedure. We're glad to see that 

16 they have adopted active mode, and have 

17 largely followed the CEC adopted test 

18 procedure. We feel this is a solid base for 

19 being able to do the battery charger testing 

20 that is the subject of today's meeting. 

21 We concur with having multiple 

22 measured outputs of the test procedure. This 

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1 enables easy use of the test procedure by 

2 other policy makers, even if they may be 

3 making different standards in other 

4 jurisdictions. 

5 We also agree that there should be 

6 no energy allowances made for battery chargers 

7 with extra functionality. Following the DOE's 

8 logic, we agree that that extra functionality 

9 should simply be turned off when the products 

10 are being tested. 

11 We also support DOE creating a 

12 separate multi-voltage test procedure for 

13 multi-voltage EPSs, so that it doesn't change 

14 the single-voltage EPS test procedure that's 

15 been used by many other jurisdictions. 

16 And I'm going to skip fairly 

17 quickly through some of my slides, because I 

18 have more comment than I have time to present 

19 this morning. 

20 We do, however, have some concerns 

21 on some of the issues in the test procedure, 

22 changes that were made from the CEC test 

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1 procedure. One is the order of testing, 

2 second is the handling of unrated batteries, 

3 changes in the reporting for tests that last 

4 24 hours will cause problems, and reducing the 

5 battery conditioning cycles reduces the 

6 repeatability and introduces additional 

7 errors. 

8 The first one has to do with 

9 reversing the order of testing. We feel that 

10 this should not be done, that the testing 

11 order is especially important for those 

12 battery chargers that take longer than 24 

13 hours to complete a charge cycle. There are a 

14 large number of battery chargers of this type 

15 within the scope of the test procedure, 

16 including emergency systems, a lot of 

17 universal chargers when charging larger 

18 batteries, a lot of small automotive chargers 

19 take more than 24 hours. 

20 This issue is really acknowledged 

21 in the Federal Register, where DOE states that 

22 "the order of these steps does not matter, as 

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1 long as the measurement compasses the entirety 

2 of a charge/discharge, or discharge/charge 

3 cycle, and all the energy consumed by the 

4 charger is accounted for during discharge, and 

5 vice versa." We completely agree with this. 

6 And just as a shorthand, I often refer to this 

7 as, that the measurement has to be a complete 

8 round-trip, that the battery must end in the 

9 same state as it started, or else one does not 

10 have a valid measurement. And, in fact, the 

11 DOE must then either make sure that this 

12 round-trip is accomplished. 

13 The issue was discussed thoroughly 

14 at a May 2007 stakeholder workshop for the CEC 

15 procedure, which resulted in acceptance of the 

16 current CEC order of testing. 

17 The next slides are from that. 

18 I'm going to skip over this one, because it 

19 just really makes the same issue. But the 

20 concern is battery chargers that can be 

21 discharged, I guess I don't have a pointer 

22 here. They discharge in the five hours, and 

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1 you get a full discharge, but in the 24-hour 

2 charge cycle, they are not fully charged 

3 again, so one ends up not having a complete 

4 round-trip. 

5 Ecos did a number of testing using 

6 the same sequence as DOE is proposing early in 

7 their process, and found battery chargers that 

8 were measuring as high as 170 percent 

9 efficiency, because we weren't really getting 

10 the full energy consumed during charging. We 

11 believe this is a serious problem, and that 

12 it's not easy to tell these battery chargers. 

13 Sometimes you can tell, obviously, because 

14 the efficiencies are absurd, but even this 

15 test procedure doesn't tell you what to do if 

16 your measured efficiency is absurd. 

17 So, the test sequence, we reversed 

18 it to going from the green, which is the same 

19 as the DOE of doing a discharge measure and 

20 then a charge, going instead to measuring a 

21 charge first, and then the discharge. The 

22 importance of this comes when one has a 

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1 battery charger that does not fully charge in 

2 24 hours. Instead of the green, which does 

3 not do a complete cycle, we get the red, which 

4 didn't completely charge, but at least it's a 

5 round-trip cycle. So, we get a valid 

6 efficiency measurement, even if we don't get a 

7 fully charged battery. And we believe this 

8 round-trip is an absolutely essential part for 

9 getting valid test results. 

10 And we, therefore, recommend that 

11 DOE either include the steps to verify that a 

12 full round-trip has been accomplished, or 

13 adopt the CEC procedure sequence, which does 

14 accomplish that. And I'll note that when we 

15 tried to figure out additional steps to verify 

16 that a round-trip had been accomplished, every 

17 idea that we came up with was much more 

18 complex, and took more testing than the 

19 procedure that the CEC eventually adopted. 

20 Thank you. 

21 I will skip quickly. This is, 

22 certainly, our most important concern, so I'll 

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1 go quickly through the remaining ones. 

2 Assessing unlabeled batteries, that is, 

3 batteries that don't have an amp hour rating 

4 on them from which one can get a discharge 

5 current, the one-half amp initial trial 

6 current is not suitable for a large number of 

7 batteries. The one-hour window that was 

8 allowed by the DOE test procedure allows for 

9 unacceptable errors, and the iterative 

10 procedure actually ends up with poorer 

11 repeatability than the CEC protocol. 

12 And I have an example here of a 

13 calculation that shows the iterative procedure 

14 doesn't help, but I'll skip over that one. 

15 The more important one is the half-amp trial 

16 current. This works well for batteries in a 

17 certain range of amp-hour capacities, about 

18 half an amp-hour to four amp-hours. But the 

19 scope of the test procedure is much wider than 

20 that. Very small products, such as Bluetooth 

21 headsets and MP3 players often use very tiny 

22 batteries that are made to deliver milliamps 

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1 of current, and you'll simply fry the internal 

2 contacts if you try to run half an amp through 

3 them. 

4 Similarly, for a lot of larger 

5 batteries, that half amp initial discharge 

6 requires an absurdly long length of time for 

7 the first trial test to get an idea of the 

8 battery capacity. The battery procedure needs 

9 to be able to adapt to the entire range of 

10 batteries within the scope of the test 

11 procedure. 

12 And, again, I'll skip kind of 

13 quickly through this. We believe that the 

14 recommendations should either be much broader, 

15 and that the window of acceptance needs to be 

16 narrower, that the CEC procedure used a half17 hour wide window. We believe DOE should stick 

18 with a half hour, or shorter. I'll actually 

19 see if I can skip back here. It looks like I 

20 -- the hour-wide window, we believe will cause 

21 test-to-test variations on the order of 5 

22 percent, and we believe that this is an 

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1 unacceptably wide variation in test results. 

2 And the half hour procedure cuts that -- if 

3 anything, we believe that the length of the 

4 window of time should be kept shorter than the 

5 half hour of the CEC procedure. 

6 Another issue is a comment in 

7 Clause 5.10(b), that states that "only the 

8 energy used in the first 24 hours should be 

9 considered." This guarantees that for longer 

10 battery -- for longer charge times, one does 

11 not use a full round-trip. And, again, if you 

12 use -- don't use a full round-trip, your 

13 energy and efficiency calculations will be 

14 totally invalid. 

15 Conditioning cycles we believe 

16 should not be reduced. Nickel-based batteries 

17 can take five to 100 cycles. The three cycles 

18 in the CEC test procedure was already a 

19 compromise. We believe this should not be 

20 further reduced to two conditioning cycles. 

21 And, finally, I'll leave the 

22 comments here. There are a few other issues. 

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1 The CEC test procedure deliberately had a 

2 broad definition of manufacturing 

3 instructions, so that there could be 

4 information that was not intended for 

5 consumers, but would still be available to the 

6 testing labs. 

7 Language for protective circuitry 

8 is one that actually, as an Ecos person, I 

9 have to apologize for, the CEC adopted an 

10 incorrect language for protection circuitry, 

11 because we sent them the wrong draft when they 

12 were doing their final adoption. And I have 

13 on the final slide the correct language, and 

14 you'll notice there are some small 

15 differences, but we would ask that DOE please 

16 not propagate the error that Ecos made with 

17 the Energy Commission. 

18 And, finally, there are a lot of 

19 products for which off-mode does not actually 

20 require disconnecting the battery. These 

21 might be computer UPS supplies, for example, 

22 that often do have an on-off switch, but the 

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1 battery is internal, and can't be removed. 

2 So, we would also recommend rewriting the off3 mode definitions to allow off-mode to be 

4 measured even when a battery is included. 

5 And with that, I will conclude, 

6 and appreciate the chance to talk, and 

7 appreciate the chance to continue to 

8 participate in this process. Thank you. 

9 MR. BROOKMAN: Paul, just a term. 

10 You were expanding written comments to 

11 supplement your PowerPoint slides. You'll 

12 send those in? 

13 DR. BENDT: Yes, we will send in 

14 written comments. There are also a number of 

15 minor issues that we'll send written comments 

16 on that we did not put in the PowerPoint at 

17 all. 

18 MR. BROOKMAN: Thank you. Wayne, 

19 do you have opening remarks? 

20 MR. MORRIS: I do. Thank you, 

21 Doug. Wayne Morris with the Association of 

22 Home Appliance Manufacturers. 

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1 We want to raise a few points at 

2 the beginning. They're general in nature, 

3 certainly not as detailed as Paul's, but I 

4 think that they're important to sort of set 

5 the tone for the meeting, as well. 

6 First, we believe that the test 

7 procedure that's been proposed contains 

8 several improvements to the test procedure. 

9 We're very pleased that DOE has included a 

10 number of these clarifications, also, the 

11 addition of active mode energy testing. AHAM 

12 has been supportive of that for several years 

13 now, and very encouraged by the Department 

14 taking that action, long overdue. 

15 Second, while this may be true in 

16 some areas, there are a few areas in the test 

17 procedure that have been proposed where we 

18 believe the Department's proposal has created 

19 confusion, where utilized methods that will 

20 result in less repeatability, unnecessary 

21 burdensome measurements, and reproducibility 

22 problems. 

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1 We've entered a new day with DOE 

2 and ENERGY STAR, where the U.S. Government is 

3 asking for greater proof of accuracy, 

4 repeatability, and most importantly, 

5 reproducibility, where each of the testing 

6 laboratories that will be performing these 

7 tests obtain the exact same results time after 

8 time. 

9 It's, therefore, crucial that the 

10 testing procedures be more accurate than 

11 they've ever been before, and that there be no 

12 opportunity for a certifying laboratory to 

13 conduct a test one way, and a verifying 

14 laboratory to conduct a different way, and 

15 obtain different results. Unfortunately, we 

16 think that the Department has proposed several 

17 of these options in the draft procedure, and 

18 we'll point them out as we go through. 

19 Third, we believe that there is a 

20 major issue with the effective date, and we 

21 need to talk about that. I know it's not, 

22 necessarily, on the schedule to be talked 

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1 about, but it should be a topic that we'd 

2 address today. 

3 Fourth, we believe that DOE has 

4 still not clearly explained how this test 

5 procedure integrates with the test procedure 

6 of Class A EPS, non-Class A EPS, or any 

7 combinations thereof. Until the DOE explains 

8 its full roadmap for these products, it's very 

9 difficult for manufacturers, or for that 

10 matter, anyone to react to a test procedure 

11 for battery chargers in an isolated state. 

12 AHAM has raised this issue at every workshop, 

13 and in every set of comments, and we still are 

14 groping around like the blind man with the 

15 elephant in the children's fable. 

16 Fifth, we believe that without a 

17 full resolution of the usage factor issue, DOE 

18 has not explained how this vitally important 

19 issue will be handled in the regulation. And, 

20 therefore, it makes it very difficult to react 

21 to a test procedure. In addition, without the 

22 explanation of usage factors and correct usage 

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1 factors, DOE will severely impact certain 

2 segments of the industry, and will cause them 

3 irreparable harm in the implementation of an 

4 energy efficiency standard. 

5 Sixth, I would mention that we 

6 thank the Department for making this meeting 

7 available to people by the internet in a web 

8 meeting, but we do believe that these meetings 

9 should be fully open meetings; that is, anyone 

10 participating in a web meeting should have the 

11 ability to ask questions, or make comments. 

12 If written only, that's fine, but this is a 

13 mark of openness and transparency to meetings 

14 that we think needs to be followed in every 

15 meeting. But, most importantly, people 

16 accessing the meeting by web participation 

17 should have full rights to ask questions, and 

18 make comments, as well. This is done in other 

19 government departments that have integrated 

20 web meetings now into their procedures. We 

21 don't think there's any reason that the 

22 Department of Energy should do less. 

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1 Overall, the industry is being 

2 asked by the Department to comment on a test 

3 procedure for a product which is inextricably 

4 linked to other products, but without a 

5 technically sound explanation of how this 

6 procedure will actually be used in the end. 

7 Thank you. 

8 MR. BROOKMAN: Thanks, Wayne. Are 

9 there other comments here at the outset, or 

10 brief overview remarks here before we launch 

11 into the more detailed content? I see no 

12 additional comments. Okay. So, we're going 

13 to proceed then. 

14 MR. PETROLATI: Okay. First of 

15 all, thanks for the commenters that we've had. 

16 We are going to very quickly cover the Legal 

17 Authority and Background associated with this 

18 particular product. 

19 Okay. First of all, the Energy 

20 Policy Conservation Act of 1975 established 

21 Energy Conservation Standards and methods of 

22 test procedure development for a variety of 

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1 consumer products. The Energy Policy Act of 

2 2005 amended our EPCA, adding battery 

3 chargers, and external power supplies, to the 

4 Appliance Standards program, and then the 

5 Energy Independence and Security Act of 2007 

6 further amended EPCA, resulting in the current 

7 rulemaking. The Department of Energy is the 

8 lead agency for implementing EPCA and the 

9 amendments associated with EPACT and EISA. 

10 Okay. Some of the things that we 

11 have already accomplished, we published a test 

12 procedure for standby and off mode for battery 

13 chargers and external power supplies March 27, 

14 2009. We published a final rule potentially 

15 amending Class A EPS standards -- we will 

16 publish a final rule amending Class A EPS 

17 standards. The EISA Class A EPS Standards 

 st

18 were effective on July 1 , 2008. We will 

19 also publish a final rule potentially setting 

20 BC Standards. Again, that rule is required to 

 st

21 be published by July 1 , 2011. 

22 We will publish a final rule 

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1 determining whether to set standards for what 

2 are called non-Class A EPSs, multiple-voltage 

3 EPSs, high-power EPSs, and others. We expect 

4 that final determination to actually be signed 

5 out this month. 

6 Okay. Additionally, EISA placed a 

7 requirement on us to amend -- amended EPCA 

8 requiring DOE to review its test procedures 

9 every seven years. This is to improve the 

10 measurement representativeness, or accuracy of 

11 the test procedure, to reduce the burden 

12 associated with the test procedure, or to 

13 determine that such amendments are 

14 unnecessary. By going forward with the Notice 

15 of Proposed Rule on the battery charger and 

16 external power supply test procedure as part 

17 of this rulemaking, we are planning on meeting 

18 that requirement as part of this, such that 

19 the next update would be due in approximately 

20 2017. 

21 Let me just go quickly through the 

22 time line associated with our rulemakings. 

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1 EPACT was published in 2005, requiring us to 

2 include battery chargers and external power 

3 supplies into the Appliance Standards program. 

4 In 2006, we published the EPACT en masse test 

5 procedure final rule, which included test 

6 procedures for battery chargers and external 

7 power supplies. 

8 EISA was passed in 2007. Okay. 

9 EISA established standards for external power 

10 supplies, for Class A external power supplies, 

 st

11 which became effective by July 1 , 2008. We 

12 were also required under EISA to propose that 

13 under the test procedure requirements for 

14 measurement of standby and off-mode for these 

15 products, and we finalized our rule for 

16 standby and off-mode measurements on March 

 th

17 27 , 2009. That also included reporting 

18 requirements associated with external power 

19 supplies needing to meet the Class A standards 

 st

20 of July 1 , 2008. 

21 Okay. Today's rule, our Notice of 

22 Proposed Rule for modification to the battery 

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1 chargers and external power supplies was 

 nd

2 published on April 2 . Okay. We expect to 

3 finalize this proposed rule for test 

4 procedures approximately at the end of the 

5 year, so we should have a final rule pretty 

6 close to the end of this year that 

7 incorporates the changes, or some of the 

8 changes that we are going to be discussing 

9 with you today. 

10 And finally, again, the battery 

11 charger and EPS standards final rule is 

12 required to be published by July of 2011. 

13 That will have an effective date of July 2013 

14 for external power supplies, and we are 

15 expecting the effective date for battery 

16 chargers to be the same. 

17 Okay. This is a viewgraph that 

18 you're going to see throughout the 

19 presentations. This is, more or less, our 

20 roadmap for what we currently have in place, 

21 and what we are proposing to change in certain 

22 areas for the different products associated 

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1 with our test procedure. As you see down the 

2 left-hand side under "Product Class," are the 

3 different types. We've got the Class A EPSs, 

4 the general and switch selectable, the non5 Class A EPSs, which we currently do not have 

6 standards for, and BCs. 

7 The green areas are associated 

8 with the areas of the test procedure that we 

9 already have in place, and we will be 

10 continually using this roadmap to show you 

11 where we're proposing to make changes in the 

12 test procedure. 

13 Okay. Before we go on to discuss 

14 the changes with the BC active mode, do we 

15 have any questions concerning the authority or 

16 legal background? Yes? 

17 MR. ERDHEIM: Vic, Rick Erdheim 

18 with Philips. You mentioned the BC and EPS 

19 standard being finalized July 2011. Do you 

20 have any idea when it's going to be proposed? 

21 MR. PETROLATI: It is six or eight 

22 months before that date? I forgot offhand, 

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1 but approximately six to eight months before 

2 that date. 

3 MR. ERDHEIM: So, sometime this 

4 fall? 

5 MR. PETROLATI: Yes. 

6 MR. ERDHEIM: Thank you. 

7 MR. PETROLATI: Okay. Any other 

8 questions before we get into the meat of the 

9 presentations on the changes for the test 

10 procedure? It doesn't look like it. Okay, 

11 very good. 

12 All right. I'd like to bring up 

13 Matt Malinowski from Navigant Consulting. 

14 MR. MALINOWSKI: Great. Thank 

15 you, Vic. My name is Matt Malinowski working 

16 for Navigant Consulting, and we assist DOE in 

17 the development of standards for consumer 

18 products, as well as test procedures. 

19 I'll be speaking to you today 

20 about the proposed changes to the BC active 

21 mode test procedure, and that should take most 

22 of the morning. And then in the -- shortly 

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1 after noon, we'll get into the other portions 

2 of the proposal, so any changes to the standby 

3 and off-mode test procedures, the single4 voltage EPS active mode test procedure, and, 

5 finally, the multiple-voltage EPS test 

6 procedure. 

7 So, this is the same slide that 

8 Vic just went through highlighting the 

9 existing test procedure, as well as what 

10 portions have been reserved in previous 

11 rulemakings. And, at the moment, I'll be 

12 talking about changes to the BC test 

13 procedure. So, DOE is proposing to eliminate 

14 the inactive mode test procedure, which was 

15 part of the original BC test procedure, which 

16 was enacted after EPACT 2005, as well as 

17 adding provisions to allow testing of BCS in 

18 active mode. 

19 MR. BROOKMAN: Wayne. 

20 MR. MORRIS: Matt, Wayne Morris 

21 with AHAM. Just a question for you for 

22 clarification. In the last Notice of Public 

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1 Rulemaking that the Department did on the non2 Class A EPSs, there were comments in there in 

3 regard to some of the motor4 operated/detachable battery EPSs with regard 

5 to those that had charge circuitry, charge 

6 control circuitry, I think, and there were 

7 comments in there that the Department was 

8 going to explain how those would be handled. 

9 In fact, I believe there were even comments in 

10 there that they were more like battery 

11 chargers in their usage pattern, and in their 

12 operation than like an EPS, and that the 

13 Department would explain what it was going to 

14 do with those. 

15 And in the notice that went out 

16 here, there was no explanation, so I'm looking 

17 to see what's the Department planning to do 

18 with those non-Class A EPSs that are, in our 

19 view, actually a battery charger, part of a 

20 battery charger system, but don't seem to be 

21 dealt with here. 

22 MR. BROOKMAN: Vic Petrolati. 

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1 MR. PETROLATI: Thank you, Doug. 

2 Wayne, we have certainly considered from our 

3 framework document all the comments that we 

4 have received concerning that issue. We do 

5 plan on addressing that issue as part of the 

6 next stage of the standards rulemaking, which 

7 will be the preliminary analysis. It is not 

8 addressed as part of the test procedure 

9 modifications. 

10 As you can see here, non-Class A 

11 EPSs are listed in terms of where we think 

12 they fit under the current test procedure. 

13 EPSs for motor-operated or detachable 

14 batteries we feel are included under the 

15 existing test procedure, with the caveat that 

16 we still need to clarify what an EPS is that 

17 is connected to either a motor-operated or 

18 detachable battery, and that will be explained 

19 in the preliminary analysis. And it will 

20 follow the same theories, or same concepts 

21 that we propose during the framework document 

22 that we feel that devices, wall adapters with 

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1 charge control measured in some manner will 

2 not be considered external power supplies 

3 under the definition of Congress. And we will 

4 clarify that further in the preliminary 

5 analysis. 

6 MR. BROOKMAN: Larry. 

7 MR. ALBERT: Larry Albert. So, 

8 interpreting the test procedure, we're looking 

9 at the portion that's dealing with EPSs. Part 

10 of the difficulty in assessing test procedures 

11 is understanding what the impact of these 

12 various tests are, and changes to the test 

13 upon whatever the final metric is that's going 

14 to be generated, or how it's going to impact 

15 the overall assessment of the product. So, 

16 that hampers stakeholders in being to make 

17 intelligent comments, because we're not always 

18 certain as to how the data is going to be 

19 used. 

20 MR. PETROLATI: Let me answer the 

21 first question, Larry. I'm not sure about the 

22 second, how the data is going to be used. 

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1 But, obviously, we're staying consistent from 

2 what we had in the framework document in terms 

3 of our definition of the EPS. And an EPS in 

4 this particular case, a wall adapter connected 

5 to a motor-operated or detachable battery, one 

6 that we feel has charge control within that 

7 wall adapter, would not be considered an EPS. 

8 We have not finalized the criteria of what 

9 tests the Department would use to make the 

10 determination as to whether or not that device 

11 has charge control. And we proposed a method 

12 in the framework document. We received a 

13 number of comments indicating our method was 

14 incorrect, and we will have to propose, 

15 probably, new methods in the preliminary 

16 analysis for making that decision. 

17 MR. ALBERT: Okay. But sort of 

18 jumping ahead, is that, some of the concerns 

19 that the Department indicated it had with the 

20 current EPS test procedure seem like they're 

21 related to the effect that charge control 

22 might have upon EPSs. For example, the 

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1 current limiting effect on EPSs. Right? So, 

2 it seemed to foreshadow that it's going to go 

3 the other way, that, in fact, these EPSs that 

4 have charge control will be evaluated 

5 separately as EPSs. Right? And the 

6 measurement difficulty then points to sort of 

7 the fundamental issue of whether these, in 

8 fact, are or are not to be considered as EPSs. 

9 MR. PETROLATI: Okay. And, again, 

10 our position is that just like the framework 

11 document, if the wall adapter has charge 

12 control, as a yet-to-be-determined measurement 

13 of how we make that determination, then we 

14 would not consider it to be an EPS. 

15 MR. ALBERT: Okay. 

16 MR. PETROLATI: Yes, and I can't 

17 give you any more information than that, 

18 because we haven't proposed anything yet in 

19 that area. 

20 MR. BROOKMAN: Wayne. 

21 MR. MORRIS: I appreciate what you 

22 said, Vic, and thanks. That does help, but, 

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1 in reality, a test procedure ought to have a 

2 scope, and the scope ought to clearly say what 

3 the test procedure covers. So, if the 

4 Department is still trying to determine how 

5 it's going to determine whether a battery 

6 charger, or, excuse me, in your view, an EPS 

7 with charge control will be tested, I think 

8 that that should have been done in this 

9 particular test procedure rulemaking, because 

10 it really -- I mean, this test procedure is in 

11 two parts. It is for clarifying, I believe I 

12 saw that in one of the slides, and for 

13 determining accuracy of this. So, I think 

14 it's a bit of a deficiency, if not to say how 

15 that's going to be determined in the test 

16 procedure. 

17 MR. PETROLATI: Let me go back to 

18 the Notice of Proposed Rule in 2006, which did 

19 have a scope for both battery chargers and 

20 external power supplies, and we received 

21 numerous comments that the scope of that 

22 procedure cannot be determined until we do the 

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1 standards analysis, and that we had not 

2 included products within that scope that are 

3 covered under the definition. That's why way 

4 back in 2008, excuse me, 2006, we took out the 

5 scope of this test procedure, and indicated 

6 that the scope would be handled in the 

7 standards. But, we do appreciate your 

8 comments in these areas, and we do appreciate 

9 your concern about not knowing exactly when an 

10 EPS is specifically under non-Class A EPS. We 

11 are hoping to actually come out with a 

12 preliminary analysis fairly soon, and I think 

13 if there are issues concerning this as to how 

14 it affects the test procedure with our current 

15 understanding that EPSs with charge control, 

16 excuse me, wall adapters with charge control 

17 are not EPSs, we would like to get your 

18 comments in this area, as to how that might 

19 affect the test procedure and its 

20 measurements. 

21 MR. ERDHEIM: So, just to clarify, 

22 Rick Erdheim with Philips. So, Vic, if you 

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1 come out with that after June 16 , then what 

2 will be the procedure for commenting, because 

3 the comment period on the test procedure will 

4 be closed? 

5 MR. PETROLATI: Yes. I think, 

6 Rick, you have to assume that what we 

7 indicated in the framework document is our 

8 position. And I'm indicating today that the 

9 same position that we had in the framework 

10 document is our position. The one area that 

11 we do have concerns over, when we proposed how 

12 you would test an EPS back at the framework 

13 document to determine whether it had charge 

14 control, we had numerous comments that our 

15 test was incorrect for making that 

16 determination. And we have asked for comments 

17 then as to how you would make that 

18 determination. The only comments that we got 

19 were, basically, through physical 

20 characteristics of the EPS, the same type of 

21 approach that has been used by EPA and CEC in 

22 the past. 

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1 MR. BROOKMAN: Go ahead. Larry. 

2 I think we're starting to double back. Larry, 

3 keep going, though. 

4 MR. ALBERT: The other part of the 

5 -- during the framework discussion, there was 

6 the other piece of this, which was, were you 

7 compelled in a case where you might have a 

8 battery charger that was powered by a wall 

9 adapter to then evaluate the battery charger 

10 as if it were to have a low-voltage, or DC 

11 input? Is that -- do you envision the battery 

12 charger piece of this now affecting those 

13 sorts of measurements? In other words, 

14 essentially, splitting the battery charger 

15 apart. You said you weren't going to evaluate 

16 the EPS as an EPS in those cases where a 

17 charge control is present. If the charge 

18 control is present with a battery charger, 

19 that would be evaluated without the EPS. 

20 MR. PETROLATI: Because of the 

21 language you're using, the question is a 

22 little confusing. But if the wall adapter is 

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1 not defined as an EPS - 

2 MR. ALBERT: Right. 

3 MR. PETROLATI: -- the wall 

4 adapter would be measured as part of the 

5 battery charging system. 

6 MR. ALBERT: And the battery 

7 charger would not be measured without the wall 

8 adapter. 

9 MR. PETROLATI: Correct. 

10 MR. ALBERT: Thank you. 

11 MR. PETROLATI: Yes. 

12 MR. ALBERT: Okay. 

13 MR. BROOKMAN: I'm eager for us to 

14 move on. 

15 MR. PETROLATI: Same here. 

16 MR. BROOKMAN: Very helpful 

17 clarifying comments. I think that's very 

18 helpful. 

19 MR. PETROLATI: Thank you. 

20 MR. BROOKMAN: So, shall we move 

21 on then? Matt, back to you. 

22 MR. MALINOWSKI: So, as I 

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1 mentioned, the inactive mode test procedure is 

2 based on the test procedure that was adopted 

3 in 2006, and is based on the ENERGY STAR test 

4 procedure from 2005. The proposal would 

5 remove all parts of that inactive mode test 

6 procedure, and then add an active and 

7 maintenance mode test procedure, which is 

8 based on the California Energy Commission test 

9 procedure, which was adopted in 2008, with 

10 some modifications that either ease burden, or 

11 improve accuracy. And just note, again, I'll 

12 get into all those modifications in the 

13 ensuing slides, but DOE would like to seek 

14 comment on the removal of the existing 

15 inactive mode test procedure. 

16 MR. BROOKMAN: Yes. I'll go with 

17 Wayne first. 

18 MR. MORRIS: Thanks. Well, since 

19 you asked, we appreciate that the Department 

20 is removing the aggregation of the non-active 

21 energy. In some form or fashion, that makes 

22 some sense, but we do believe that it is 

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1 important to have some aggregated value. And 

2 we believe that there should have been a re3 proposal, if you will, to have aggregated all 

4 three of the modes of their energy in order to 

5 have a value that can be used, and can be 

6 stated. 

7 This is important not only for 

8 DOE, but also for ENERGY STAR to regulate this 

9 value separately, and as part of the overall 

10 amount of energy. We think it's preferential 

11 to use that situation, and that would include 

12 usage factors which we believe are required by 

13 law. Thanks. 

14 MR. BROOKMAN: Larry. 

15 MR. ALBERT: So, to follow on to 

16 what Wayne was saying there. So, the 

17 questions are really, in removing the non18 active mode determination, you're also 

19 removing the representativeness of the 

20 standard's ability to generate a number that 

21 tells you something about the typical usage of 

22 the product. And, in the process, producing 

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1 other numbers that are disaggregated data that 

2 none of which, individually, represent the 

3 typical use of the product, nor do they -- is 

4 there any guidance in the test procedure on 

5 how they should be aggregated. 

6 Fundamentally, it seems like the 

7 test procedure is moving backwards with 

8 respect to its utility, because it makes it 

9 less -- makes consumers less capable of being 

10 able to assess the energy usage or efficiency 

11 of the product based upon the output of the 

12 test procedure, itself. 

13 I understand that -- I believe I 

14 understand that the output of the test 

15 procedure is then used in the standard, and 

16 compared against the standard level to 

17 determine acceptance or not, but it seems like 

18 that data ought to be something that, in and 

19 of itself, tells you something about the 

20 energy efficiency of the product. Since there 

21 is the presumption that with a national test 

22 procedure that it -- all other test procedures 

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1 now that may conflict with it would become 

2 invalid, and all other representations made on 

3 some other test procedure would also be 

4 invalid. There seems to be a responsibility 

5 to ensure that the test procedure provide data 

6 that truly tells you something about the 

7 relative energy efficiency of the product 

8 being measured. 

9 MR. BROOKMAN: Thank you. Yes, 

10 Wayne. 

11 MR. MORRIS: This also brings up 

12 the issue of representation, which is an 

13 important one to us, and to everyone, that, 

14 essentially, once the -- and this is where I 

15 believe that also we need to spend some time 

16 today talking about this effective date, 

17 because this requires that the manufacturers, 

18 once this becomes effective, can make no other 

19 representation of the energy, other than what 

20 is actually accomplished by this test 

21 procedure. And, therefore, no one could go 

22 out there and say the battery charger is 10 

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1 percent, or 20 percent more efficient, or 

2 anything, if, in fact, there are multiple 

3 numbers coming out of this test procedure. It 

4 would make it very difficult, I believe, for 

5 ENERGY STAR to calculate an energy savings 

6 over any particular period of time on this. I 

7 also think that it would lead to the consumer 

8 not having access to the information that they 

9 really need, so it really is a severe 

10 crippling effect on the overall energy 

11 efficiency to remove any measurement of any 

12 aggregation of the energy from its final form. 

13 There's real reason to be concerned here. 

14 MR. BROOKMAN: Yes. Paul. 

15 DR. BENDT: Yes. I would actually 

16 like to take the opposite view, that this move 

17 in the test procedure is a move in the right 

18 direction, that instead of reporting a single 

19 number, the new test procedure reports out 

20 multiple measures. Since consumers use 

21 products in very different ways, this allows 

22 consumers to look at those measures that most 

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1 closely represent how they use a product, and 

2 to actually better evaluate how energy -- how 

3 this product would consume energy in their 

4 particular use. It's easier to see that with 

5 the multiple measures than it would be to see 

6 it with the single measures that aggregate 

7 them together with a whole lot of other 

8 consumers who are using products in ways that 

9 aren't relevant to them. So, we believe this 

10 is a huge step forward, and we fully support 

11 the DOE in dropping the Inactive Mode 

12 measurement with its aggregation, and 

13 proceeding with an active mode measurement, 

14 and reporting out the measured values 

15 separately. 

16 MR. BROOKMAN: Thank you. Wayne, 

17 follow-on. 

18 MR. MORRIS: I truly appreciate 

19 Paul's view, because it's a view that he's 

20 articulated before, but I find the argument 

21 that he made now to be a little confusing to 

22 me, so I'm having a little trouble with that. 

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1 I wonder if Paul could elucidate on that 

2 situation, particularly with regard to, if a 

3 consumer has a value of the amount of energy 

4 used in active mode, and the amount of energy 

5 used in standby or no battery mode, and the 

6 amount of energy in maintenance mode, how a 

7 consumer is supposed to ever know how much 

8 time the battery charger spends in any one of 

9 those modes? I mean, it seems impossible to 

10 believe. I mean, no manufacturer is going to 

11 tell you that oh, in your particular usage 

12 pattern, in picking up Cheerios in the morning 

13 with your cordless vacuum cleaner, you spent 6 

14 hours in charge, 3 hours in maintenance mode, 

15 and zero minutes, or 1.2 minutes in no battery 

16 mode. Consumers don't know that. They're not 

17 going to ever be able to figure this. That's 

18 why usage factors applied against an 

19 aggregated value will, in fact, give the 

20 consumer accurate information on how the 

21 product is used, and how much savings there 

22 is. So, I'm having trouble understanding how 

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1 a consumer is ever going to know that, Paul. 

2 MR. BROOKMAN: Okay, Paul. 

3 DR. BENDT: Yes. One consumer 

4 when they're using their electric drill knows 

5 that they used their electric drill. They 

6 plug it in, recharge the battery, then they 

7 unplug it, and put it away. They know that 

8 most of their time is spent in active mode, 

9 and they would pay the most attention to the 

10 active mode number. Another consumer using 

11 that same product may use the tool, plug it in 

12 to recharge it, and leave it there on the 

13 charger for three weeks before they use it 

14 again. In their case, they would know that 

15 they are leaving it in maintenance mode most 

16 of the time. Whether they have an exact 

17 number of minutes that it's in maintenance 

18 mode isn't so much important, as the fact that 

19 they know that it's mostly maintenance mode, 

20 and that's the number they need to pay 

21 attention to. So, again, an aggregation that 

22 says the average consumer does this many 

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1 minutes in charge mode, and this many minutes 

2 in maintenance mode doesn't help either of 

3 those to determine what their particular usage 

4 pattern is going to consume. So, even -- and 

5 I don't think even the manufacturers can give 

6 us accurate numbers about how many minutes 

7 their products spend in each mode in a year. 

8 That's been a source of questions in the past, 

9 so if nobody knows that, but at least 

10 consumers know from their individual patterns 

11 what modes they use preferentially, then it is 

12 advantageous for the consumers to know what 

13 the energy use is in the separate modes. 

14 MR. BROOKMAN: Wayne. 

15 MR. MORRIS: Well, I'd submit 

16 that, Paul, if you have a Ph.D. in electrical 

17 engineering and work for Ecos Consulting, you 

18 probably would know that information, but I 

19 really question whether the average consumer 

20 is going to have access to that information. 

21 And I think that it's more important for us to 

22 be able to give the consumer one clear simple 

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1 value that they can take home, and say this is 

2 the energy usage of this product in its 

3 average, or approximately average, usage 

4 pattern. And, therefore, I know that if I'm 

5 comparing -- because that's when this is 

6 really valuable. This is valuable not after 

7 the consumer gets the product home. This is 

8 valuable when the consumer goes to the 

9 marketplace, and he sees Product A, and 

10 Product B. I mean, that's when it really 

11 becomes important, is in selecting the 

12 product. And for us to be able to tell a 

13 consumer that a product meets the Department 

14 of Energy's minimum threshold, and that the 

15 consumer has the ability to know that Product 

16 A is more efficient than Product B, that's 

17 what's most important for a consumer. Thanks. 

18 MR. BROOKMAN: I think we're 

19 starting to get redundant. Rick. 

20 MR. ERDHEIM: I just have one 

21 question for Paul, and that is, does Ecos have 

22 any data on how consumers use the different 

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1 energy values that would come out of a test 

2 procedure that you're proposing? 

3 MR. BROOKMAN: I'm not wanting to 

4 encourage a debate here. I feel like 

5 everybody has made their points now more than 

6 once. You want to respond briefly? 

7 MR. PETROLATI: If I could just 

8 respond. 

9 MR. BROOKMAN: Yes. 

10 MR. PETROLATI: Vic Petrolati, 

11 Department of Energy. And, yes, I think we 

12 did cover this adequately. We were actually 

13 going to bring this up as an issue a little 

14 later on during the presentations, but our 

15 feeling is, the aggregation method could be 

16 done either under the test procedure, or it 

17 could be done under the standard. Our 

18 approach is the aggregation method will be 

19 done under the standard. And from the 

20 comments that we received during the framework 

21 document, the overwhelming support for 

22 handling the aggregation was in the standards 

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1 approach. Obviously, that wasn't unanimous. 

2 Now, can I ask, Wayne, if the 

3 aggregation method is done under the 

4 standards, do you think manufacturers would 

5 know how they're supposed to take the results 

6 of the test procedure and determine whether or 

7 not their product meets the standard? 

8 MR. MORRIS: Well, thanks, Vic, 

9 and this is Wayne. I do appreciate what you 

10 said. And, certainly, that's the first sort 

11 of clear direction that I think we've had, 

12 other than proposing it in a framework 

13 directive, and asking how you felt about it. 

14 MR. PETROLATI: Yes. 

15 MR. MORRIS: I am much more 

16 encouraged that it would be dealt with in the 

17 standard once and for all, and that's good. I 

18 guess, to us, when you look at a number of 

19 other appliance energy efficiency test 

20 procedures, those usage factors are actually 

21 in the test procedure. It is in washing 

22 machines, it is in refrigeration in terms of 

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1 its cycling, it is in terms of what the 

2 Department has been proposing in clothes 

3 dryers, it is in terms of looking at standby 

4 power measurements, and those kind of 

5 situations, so we're used to seeing it in a 

6 test procedure. 

7 MR. PETROLATI: Right. 

8 MR. MORRIS: If the Department is 

9 going to include that type of situation in the 

10 standard, that's good. I guess, we're again 

11 at that same thing that I addressed in our 

12 opening comments. It's really hard to comment 

13 on sections of the test procedure until after 

14 you've seen what the standard is going to look 

15 like. Not that this is any different than any 

16 other procedure, although, lately there's been 

17 some mixtures where the test procedure has 

18 been modified after the standard has been 

19 proposed, but let's hope that that doesn't 

20 occur ever again. 

21 MR. PETROLATI: Right. 

22 MR. MORRIS: I think that it would 

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1 be very -- it's just -- we're shooting blanks 

2 here, because we have no idea what's going to 

3 come out in the actual framework of the 

4 standard, so I think it's probably best that 

5 we allow Matt to go ahead. I'm sorry. 

6 Thanks. 

7 MR. BROOKMAN: So, let's do that, 

8 Matt. 

9 MR. MALINOWSKI: Okay. Thank you 

10 for your comments. I'll go into - 

11 MR. MORRIS: You've got to say 

12 that like you mean it, Matt. 

13 (Laughter.) 

14 MR. MALINOWSKI: No, no. I'll 

15 just quickly go over -- it seems people are 

16 very familiar with the test procedure and the 

17 need for it, and all the different 

18 requirements for a successful test procedure. 

19 But from DOE's perspective, the most 

20 important are -- have a consistent method of 

21 evaluating BC consumption for standards, as 

22 well as for enforcing the standards once 

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1 they're established. And we've gone into the 

2 need for test procedure to be representative 

3 of typical use, so here's just a quick 

4 illustration of one typical use of one 

5 consumer product which involves both the 

6 charging mode in yellow, as well as the 

7 standby mode. And a test procedure should 

8 include as many of those steps as possible. 

9 And just a quick review of the 

10 existing BC test procedure. You have on the 

11 left just an illustration of an example 

12 system. The green symbol is the connection to 

13 mains, or DC input, battery charger, and then 

14 the battery. The current BC test procedure 

15 involves charging the battery over 24 hours, 

16 but doesn't measure that charging energy. 

17 Instead, it begins the measurement after the 

18 battery has been fully charged, and the 

19 charger is in maintenance mode. That energy, 

20 this maintenance mode energy is recorded, the 

21 battery is removed from the charger putting it 

22 in standby, or no-battery, mode, and then the 

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1 standby mode energy is recorded, that's the 

2 second step. And then, finally, the battery is 

3 discharged, that energy is recorded, and the 

4 two are compared to this discharge energy 

5 forming an energy ratio. So, just a quick 

6 summary of the existing test procedure. 

7 And the issue that has prompted 

8 this rulemaking is that that test procedure I 

9 just described is not suitable for standards 

10 because it does not measure energy consumed 

11 during active mode. And, furthermore, because 

12 it was developed with a limited scope in mind, 

13 it cannot repeatably test all manner of 

14 consumer battery chargers. 

15 And DOE researched other existing 

16 test procedures used by standards 

17 organizations, and other governing bodies 

18 around the world, and found three differing 

19 test procedures currently in use. The first 

20 is the ENERGY STAR test procedure, second is 

21 the Canadian Standards Association (CSA) test 

22 procedure, and finally, the California Energy 

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1 Commission test procedure. And the first two 

2 are very similar to the current DOE test 

3 procedure, the inactive mode test procedure 

4 that I just presented. Case in point, the DOE 

5 test procedure incorporates by reference the 

6 ENERGY STAR test procedure. And then the CSA 

7 test procedure is broadly similar to the 

8 ENERGY STAR test procedure. 

9 In addition, the interested 

10 parties expressed support for the CEC test 

11 procedure, which covers all modes of BC 

12 operation, so active mode, standby mode, 

13 maintenance, and also off mode. And DOE has 

14 performed numerous tests using this test 

15 procedure, and considers it to be both 

16 accurate and appropriate for this purpose. 

17 Therefore, DOE will be proposing 

18 to incorporate sections of the CEC test 

19 procedure; in particular, the sections 

20 regarding definitions, test conditions and 

21 setup, the charger maintenance mode test, 

22 which will form the core of the active mode 

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1 test that is required for assessing standards, 

2 and, finally, the discharge test. And any 

3 departures, or any major departures from these 

4 provisions of the CEC test procedure I'll 

5 discuss shortly. 

6 Finally, I'd like to note that DOE 

7 is proposing to retain its current standby and 

8 off mode test procedure, but slightly modify 

9 those. But those will be retained from what 

10 was enacted in the standby and off mode test 

11 procedure rulemaking. Any questions so far? 

12 Great. 

13 So, I will just briefly summarize 

14 the CEC test procedure, for those not familiar 

15 with it. And similar to the current DOE test 

16 procedure the CEC test procedure requires a 

17 24-hour charge test, or a 24-hour charge of 

18 the battery. In contrast to the DOE test 

19 procedure, that energy consumed during that 

20 charge is recorded. Here it's labeled E . 

 24

21 In addition, the maintenance mode energy is 

22 also recorded, and that's considered to be the 

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1 last four hours of the charge mode test. It's 

2 considered to be maintenance. And then, 

3 finally, the battery is discharged using a 

4 fixed rate, and that energy recording during 

5 that test is also measured and recorded. And 

6 DOE seeks comment on testing BCS in active 

7 mode, and, in particular, its proposal to 

8 adopt the various provisions of the CEC test 

9 procedure. 

10 MR. BROOKMAN: Wayne. 

11 MR. MORRIS: Thanks, Doug. This 

12 is Wayne Morris. I guess, from our 

13 standpoint, it's a bit of a difficult thing to 

14 say, just, “Are you in favor of adopting the 

15 active mode from the CEC test procedure?” 

16 It's not quite that simple. I mean, I think 

17 that that's why there's a number of slides 

18 that you're going to do individually on the 

19 changes, so I want to reserve most of my 

20 comments until you get to the individuals 

21 parts. But, I guess, overall, yes, I think 

22 that the CEC test procedure is meant in a good 

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1 solid way in terms of testing the active mode. 

2 As Paul said, it's been considered for quite 

3 a while, and I think that it has some basis of 

4 usage. I haven't heard of any major problems 

5 that have developed. But, as is always the 

6 case when you're doing a test procedure, after 

7 you've done it for a couple of years, and you 

8 start a new process of can you think of better 

9 ways of doing it, or can you look at some of 

10 the things, such as the Department has 

11 proposed in terms of shortening, and 

12 maintaining the accuracy, I think it's wise 

13 that we look at these individual parts. 

14 There are some approaches that I 

15 think have been taken in the measurement of, 

16 basically, the E measurement, which is a 

 24

17 sound way of getting at the active mode 

18 energy. So, in general, the answer is 

19 probably, from us, yes, but the devil is in 

20 the details. Thanks. 

21 MR. BROOKMAN: Other comments at 

22 this point? Okay, Matt. 

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1 MR. MALINOWSKI: Great. So, I'll 

2 structure the remainder of the presentation in 

3 terms of the current structure of the DOE test 

4 procedure. And this is in Appendix Y to 

5 subpart B of 10 CFR part 430. And the test 

6 procedure is divided into four sections. Scope 

7 defines which products can be tested under 

8 this test procedure; definitions explains and 

9 elucidates some key terms in order to clarify 

10 the remainder of the test procedure; and then 

11 test apparatus and general instructions deals 

12 with the setup of the test room, the 

13 conditions, environmental conditions, 

14 equipment accuracy, and selection and handling 

15 of the devices to be tested. And, finally, 

16 the test measurement section details, now that 

17 everything is set up, how do you perform the 

18 test? And that's divided by mode, starting 

19 with inactive mode, which DOE is proposing to 

20 remove, and then on to active mode, to standby 

21 mode, and off mode. 

22 And DOE is proposing to modify all 

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1 these sections of the test procedure, 

2 restricting the scope to chargers intended for 

3 U.S. operation only. The definition section -

4 - again, the non-active DOE definitions will 

5 be removed, and then CEC definitions with some 

6 modifications are proposed to be added. For 

7 the test apparatus and general instructions, 

8 again, deleting the non-active instructions, 

9 and adding some instructions from the CEC test 

10 procedure to allow testing in active mode, as 

11 well as to enable testing of a wide variety of 

12 battery chargers. And then, finally, for test 

13 measurement, again, deleting non-active DOE 

14 instructions, and adding instructions broadly 

15 based on the CEC test procedure. And just to 

16 summarize, those changes will be necessary for 

17 testing in active mode. 

18 So, I'll begin with the scope, and 

19 continue with each section in turn. The 

20 current DOE test procedure encompasses all 

21 battery chargers, regardless of their input 

22 voltage. And DOE is proposing to limit the 

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1 scope to only apply to AC input chargers 

2 operating at 115 volts and 60 hertz, as well 

3 as DC input chargers. But this would ensure 

4 that only BCS intended for operation in the 

5 United States are tested, as well as provide 

6 consistency with the EPS test procedure. 

7 MR. BROOKMAN: Paul. 

8 DR. BENDT: Yes. This is a 

9 question for Vic, or the Department of Energy. 

10 Does the legislation give the Department of 

11 Energy the authority to regulate the 

12 efficiency of products that are manufactured 

13 in the United States, but are intended for 

14 export? It's probably a definition of how 

15 they fit within consumer products, if the 

16 consumers are outside the United States. 

17 MR. STAS: This is Eric Stas from 

18 DOE. There is a specific provision of EPCA, 

19 and I don't have the citation right in front 

20 of me, but if a product is manufactured solely 

21 for export, and is marked as such, it doesn't 

22 have to comply with the standards. 

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1 DR. BENDT: Thank you. 

2 MR. BROOKMAN: Yes, Larry. 

3 MR. ALBERT: Larry Albert. A 

4 question as to why -- certainly, we support 

5 the restriction to 115 volts, but the question 

6 is, is why have we retained DC input as one of 

7 the categories covered by the scope? What's 

8 the DOE's interest in DC input battery 

9 chargers? 

10 MR. MALINOWSKI: Sure. There are 

11 a number of consumer products that have 

12 battery chargers embedded in them, that are 

13 only intended for DC input. So, some examples 

14 would be media players, MP3 players, and cell 

15 phones that are intended to be charged from a 

16 computer, for example, from a USB output. I 

17 think that those are probably some of the 

18 major categories. 

19 MR. ALBERT: Would that also 

20 include automotive and marine products? 

21 MR. MALINOWSKI: Intended for 12 

22 volt input applications, yes, it may. 

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1 MR. ALBERT: So, that's within the 

2 scope of the legislation that you'd be 

3 covering, for example, battery chargers that 

4 are intended for automotive use? 

5 MR. MALINOWSKI: It seems that at 

6 least -- maybe Vic will step in, but the EISA, 

7 or the EPCA definition of battery charger in 

8 contrast to the EPS definition does not set 

9 any limits on the type of input voltage, so, 

10 as a result, the scope is broader, and can 

11 include these products that are intended for 

12 DC input. 

13 MR. BROOKMAN: Okay. Ralph. 

14 MR. HUDNALL: Yes, Ralph Hudnall 

15 with Euro-Pro. If we're talking about energy 

16 efficiency to the consumer, how does, say, a 

17 car adapter impact a consumer's -- help the 

18 consumer with energy efficiency, when the 

19 electrical -- sorry, when the electricity made 

20 for the cigarette lighter is generated by the 

21 car? Are we talking about going forward with 

22 electric cars, or the - 

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1 MR. PETROLATI: Well, first of all 

2 -- Vic Petrolati, Department of Energy. Let 

3 me indicate that what Matt has explained to 

4 you is correct. We are not limited in terms 

5 of the scope under battery chargers by the 

6 legislation that we were provided, such that 

7 we will evaluate those products, and determine 

8 whether or not it's technically, economically, 

9 feasible to set standards for those products. 

10 We have, obviously, not concluded, or made 

11 that determination, but as part of our 

12 evaluation we will have to determine what the 

13 energy savings, if any, are for those 

14 products. 

15 MR. HUDNALL: Thank you. 

16 MR. PETROLATI: Yes. 

17 MR. MALINOWSKI: Great. And, 

18 again, thank you for the comments. DOE also 

19 seeks, of course, written comments on this 

20 limitation in scope. 

21 A second issue concerning scope 

22 involves golf cars, and chargers for golf 

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1 cars, and for other consumer motive equipment. 

2 I’ll just summarize how the CEC test 

3 procedure deals with this class of battery 

4 chargers. 

5 CEC test procedure is divided into 

6 two parts. Part 1 applies to BCS with input 

7 power of 2 kilowatts or less, so this would be 

8 the vast majority of consumer products, 

9 anything from power tools to notebook 

10 computers, et cetera. Whereas Part 2 applies 

11 to larger industrial chargers, and chargers 

12 for golf cars, and other consumer motive 

13 equipment. 

14 DOE is proposing to take a 

15 different approach, and in its scope include 

16 all consumer products, so that would involve -

17 - that would include the consumer products 

18 currently included in Part 1 of the CEC test 

19 procedure, as well as golf cars, and other 

20 consumer motive equipment. Because DOE's 

21 scope does not include industrial chargers, 

22 and so on, those would be excluded from the 

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1 scope of the test procedure. 

2 MR. BROOKMAN: Wayne Morris. 

3 MR. MORRIS: I think probably 

4 we'll need to take note of the fact that I'm 

5 probably going to agree with Paul Bendt on 

6 this one. I think that this is wrong. Our 

7 members believe that including these consumer 

8 motive equipment, that's a new one, we ought 

9 to make up a new acronym for that. CMEs, 

10 right? 

11 I believe that these products are 

12 significantly different than the household 

13 battery charger-type product that we're 

14 looking at. They're different in their 

15 chemistry, their battery chemistry, their 

16 usage, charging equipment. The voltage of 

17 these products that are used, the type of 

18 battery charging equipment is considerably 

19 different. We don't profess to have expertise 

20 in this area, but we do believe that there's 

21 significant difference enough that there ought 

22 to be a separate section for these products, 

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1 as well as other types of products, Segway2 type devices which are consumer motive 

3 equipment, household residential wheelchairs, 

4 and other types of motive equipment around 

5 have significant differences. 

6 I think it's an over7 simplification to put them in the same 

8 section. I'm also very disturbed that there's 

9 no one here representing -- seeming to 

10 represent that particular industry. And I 

11 know it's not the Department's requirement to 

12 go out and find people to get them to a 

13 workshop, and I can only hope that those 

14 people are actually listening on the web, and 

15 will be turning in comments. But I do believe 

16 that what we have heard from that industry at 

17 the hearings that were present at the 

18 California Energy Commission discussions on 

19 this, they agreed at the time that they wanted 

20 to have those viewed separately, and that they 

21 believed that there was significant difference 

22 in the charging apparatus and the mechanisms, 

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1 batteries, and so forth, that they should be 

2 viewed as a separate section. So, I believe 

3 that it's hard for us to make decisions on 

4 their behalf, if they're not going to speak 

5 up, but I think from our standpoint, we 

6 believe that this is radically different than 

7 a household appliance, and that it really 

8 ought to be tested in a different manner in a 

9 separate section. Thanks. 

10 MR. BROOKMAN: Paul. 

11 DR. BENDT: Paul Bendt. We've 

12 considered golf cars to kind of be a gray 

13 area. We have actually tested golf cars using 

14 both Part 1, and Part 2, and we believe they 

15 probably can be satisfactorily tested using 

16 either one of those. Since the California 

17 Energy Commission was adopting the Part 2 in 

18 order to be able to test industrial chargers, 

19 it did make sense for these sort of fence20 sitting golf cars to put those in with the 

21 Part 2. But we believe the golf cars can be 

22 tested satisfactorily with either the Part 1, 

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1 or the Part 2. 

2 MR. BROOKMAN: Okay. Thank you. 

3 MR. MALINOWSKI: Good. Maybe just 

4 as a follow-up issue, if golf cars are 

5 excluded from this test procedure, the 

6 proposed test procedure, which is based on 

7 Part 1, there is this issue that, I guess, 

8 Wayne alluded to, is, what other applications 

9 would then be -- what other products would 

10 then be in this new part? And that's 

11 something that I think the Department would be 

12 interested in receiving comment on. You 

13 mentioned, specifically, Segways and 

14 wheelchairs, but there's other consumer 

15 products that use lead acid batteries, marine 

16 chargers, electric lawnmowers. It's an 

17 interesting question, and I think the 

18 Department would welcome comments on that 

19 scope issue, as well as any other issues 

20 pertaining to this division. 

21 MR. BROOKMAN: Larry. 

22 MR. ALBERT: This is Larry Albert. 

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1 Question for Matt: what accommodations in the 

2 test procedure did you need to make to be able 

3 to provide coverage for the golf cars, and 

4 things of that nature? 

5 MR. MALINOWSKI: I think the main 

6 issues involved looking at electrolyte 

7 temperature for flooded lead acid batteries, 

8 and I think -- yes, electrolyte temperature, 

9 maybe testing full charge with -- by looking 

10 at specific gravity. I think those were -- so 

11 that would apply less to a lot of the smaller 

12 products, which use valve-regulated, and other 

13 sealed lead-acid chemistries. I think that 

14 would only apply specifically to golf cars. 

15 MR. ALBERT: Okay. 

16 MR. BROOKMAN: Wayne. 

17 MR. MORRIS: I guess the other 

18 question was, in the table that's near the end 

19 of the Notice of Public Rulemaking, was it 

20 Table 5.2? Is that the one with the different 

21 end voltages? 

22 MR. MALINOWSKI: That's correct, 

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1 5.2. 

2 MR. MORRIS: Geez, I actually did 

3 that out of memory. I'm surprised. 

4 MR. MALINOWSKI: Page 16984. 

5 MR. MORRIS: Yes, 5.2 on the 

6 required discharge voltages. I notice you've 

7 got flooded lead acids there, and the valve8 regulated lead acids, which you've given a 

9 0.2 C rate. I was just wondering if -- is 

10 that based on actual testing that you guys 

11 have done? 

12 MR. MALINOWSKI: I think that has 

13 been taken verbatim from the CEC test 

14 procedure. And maybe Paul can correct me, but 

15 I think that's based on industry standards for 

16 evaluating those batteries. 

17 DR. BENDT: Yes. This is Paul 

18 Bendt. All those end of discharge voltages 

19 are based on the various industry standard 

20 test procedures for the batteries. So, some of 

21 those are from IEC. I believe the one for 

22 flooded lead acid batteries is from the 

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1 Battery Council of the United States. 

2 MR. BROOKMAN: Thank you. 

3 MR. MALINOWSKI: Great. Next, 

4 I'll continue with the definition section. 

5 And DOE proposes updating definitions to 

6 increase clarity, or provide consistency with 

7 the CEC test procedure. And, as part of that, 

8 DOE will be removing -- I'm sorry, removing 

9 all its inactive mode definitions, as I 

10 mentioned earlier. 

11 In addition, DOE will be modifying 

12 some of its existing definitions, so those for 

13 active mode, multi-port charger, multi-voltage 

14 car charger, and standby mode. And, again, 

15 for consistency with the CEC test procedure. 

16 I won't go into the details here, but I do 

17 invite you to review the notice, and look at 

18 the applicability of the proposed definitions. 

19 Additionally, DOE proposes adding 

20 new definitions, and those would be necessary 

21 for testing battery chargers in active mode. 

22 And these are generally consistent with CEC, 

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1 or, in some cases, have been modified to be 

2 consistent with IEEE Standard 1515, or the 

3 definitions currently existing in the EPS test 

4 procedure. And those include the list here 

5 below. Again, I won't go into each one, but 

6 just as a quick example, is a definition for 

7 rated charge capacity, and that's a definition 

8 that's necessary, or a quantity that's 

9 necessary for calculating the discharge rate 

10 appropriate for the test. And, as you can 

11 see, the CEC definition is listed, as well as 

12 some additional clarification that DOE added 

13 to the definition prior to proposal for 

14 incorporation. And, again, DOE invites you to 

15 review all the definitions in the notice, and 

16 comment on their applicability and 

17 appropriateness to the test procedure. 

18 MR. BROOKMAN: Larry. 

19 MR. ALBERT: Larry. Matt, can you 

20 explain the reason for the inclusion of 

21 apparent power and power factor in the list of 

22 definitions? 

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1 MR. MALINOWSKI: Those are 

2 required for measuring the power factor during 

3 testing, and just the test procedure includes 

4 that measurement. It's not something that I 

5 think is currently -- yes, I don't think 

6 that's really the focus of the test procedure, 

7 but that is included in the test procedure, so 

8 those terms have to be defined. 

9 MR. ALBERT: And where is that 

10 data being used, power factor? 

11 MR. MALINOWSKI: At present, 

12 nowhere, but that's something that I think 

13 will be best discussed during the standards 

14 meeting. 

15 MR. ALBERT: Well, again, I think 

16 it's part of this general discussion, that if 

17 data is being collected, then we have to 

18 believe that it's being used later on. 

19 There's some anticipation that you have a 

20 purpose for it. Right? So, the power factor 

21 we know is being used, or is intended to be 

22 used in some of the proposals in California to 

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1 set a limit on power factor for battery 

2 charging systems. We expressed our concern 

3 about that as being well outside of the scope 

4 of the concern of product energy efficiency. 

5 So, we're just concerned as to why DOE would 

6 be considering even putting apparent power and 

7 power factor into the list of definitions 

8 without having a purpose for this information 

9 later on. 

10 MR. MALINOWSKI: Sure. I'll let 

11 Vic, as well, chime in, but, in general, I 

12 think both Navigant and DOE understand the 

13 concern for having a test procedure that's too 

14 broad. However, because this is something of 

15 an -- power factor is something of an open 

16 issue, and the measurement equipment records 

17 both real -- typically reports both real and 

18 apparent power, it's not much of a burden to 

19 measure those quantities, and will allow for 

20 greater flexibility in an eventual standard. 

21 MR. PETROLATI: Vic Petrolati, 

22 DOE. Matt, if you could remind me, I know the 

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1 ENERGY STAR program is using power factor in 

2 terms of its ENERGY STAR rating. 

3 MR. ALBERT: Yes, for EPSs. 

4 MR. PETROLATI: Is it strictly 

5 EPSs, and not battery chargers? 

6 MR. ALBERT: Yes. 

7 MR. PETROLATI: Okay. 

8 MR. MALINOWSKI: Yes, it's ENERGY 

9 STAR Version 2.0. 

10 MR. PETROLATI: All right. So, 

11 again, we would be supporting a test procedure 

12 that would be usable both by DOE and ENERGY 

13 STAR. So, at this point, that is one of the 

14 reasons that we are continuing to look at 

15 power factor being included in the test 

16 procedure. 

17 MR. ALBERT: Is the Department 

18 considering setting limits for power factor in 

19 the standard for battery charging systems? 

20 MR. PETROLATI: At this point, I 

21 can't provide you an answer on that, because 

22 we haven't discussed to the group what our 

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1 standard would look like for either external 

2 power supplies or battery chargers. So, we're 

3 retaining it currently in the test procedure, 

4 and we'll be making a determination as to 

5 whether or not it would be used as part of the 

6 standard in the future. 

7 MR. ALBERT: Thank you. 

8 MR. BROOKMAN: Wayne. 

9 MR. MORRIS: Well, I appreciate 

10 sort of the non-answer. I understand that 

11 that's a ways down the road a little bit, but 

12 I would just say, from our standpoint, we do 

13 object to this for a couple of reasons. One, 

14 there is no clear stated reason for measuring 

15 crest factor and power factor. There isn't 

16 anything that's been stated, so I guess an old 

17 principle of test procedures is, if you're not 

18 going to use it, why are you measuring it, and 

19 why are you defining it? So, I would say we 

20 disagree with having this definition here, 

21 just as much as we disagree with having it in 

22 the actual measurement cycle. 

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1 The premise of measuring power 

2 factor for the purpose of regulating presumed 

3 power losses in distribution wiring of a 

4 building or a power distribution system 

5 represents a significant departure from 

6 appliance energy efficiency standards within 

7 the DOE. And embarking on this should be 

8 undertaken by carefully considering the impact 

9 of the decision on public policy and technical 

10 substantiation. 

11 To date, there's been no real 

12 evidence presented by the Department as to why 

13 a measurement of power factor, power factor 

14 limits would be necessary. Non-displacement 

15 power factors have been a topic 

16 internationally with regard to the impact that 

17 power line harmonic currents may have on the 

18 integrity of the power distribution system, 

19 but not with respect to individual product 

20 energy efficiency. So, it's unclear to us why 

21 this test method would include these 

22 measurements where other ones have not. 

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1 We also don't believe that this 

2 particular method of measuring power factor is 

3 accurate. We have significant questions about 

4 this. We believe that power factor depends on 

5 the impedance of the line. And, therefore, if 

6 you're going to accurately measure power 

7 factor, you need to know the proper source 

8 impedance. The California test procedure has 

9 no defined source impedance. And as we've 

10 commented numerous times, we believe that that 

11 test procedure section is inaccurate, and 

12 unacceptable. Defining the source impedance 

13 is important, because it's the basis for 

14 anticipated appliance wiring losses in the 

15 house, not the individual appliance. Source 

16 impedance in the home can vary according to 

17 the type and quality of the home wiring, as 

18 well as the location of the receptacle on the 

19 branch circuit. So, actual losses would be 

20 considerably different, depending on where you 

21 plug the product in within the home. 

22 So, obviously, this is -- when 

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1 we're getting down to individual limits that 

2 then have to be measured by under 

3 certification and verification, there's 

4 complete inaccuracies that can develop in the 

5 situation, and we suggest that the Department 

6 conduct additional studies on home wiring to 

7 establish the range of impedance, and the 

8 impact of non-displacement power factors long 

9 before they ever enter into actually testing 

10 it in battery chargers, or EPS, or, for that 

11 matter, any other product. Thank you. 

12 MR. BROOKMAN: Thank you. Other 

13 comments on this matter? Okay, Matt. 

14 MR. MALINOWSKI: So, again, we've 

15 just gone over the scope and definition 

16 sections, and I'll be moving on to test 

17 apparatus and general instruction sections, 

18 which details the setup of the battery 

19 charger, and measurement equipment for the 

20 test. 

21 DOE proposes to modify -- well, 

22 first, DOE proposes to incorporate, in large 

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1 part, the CEC provisions pertaining to test 

2 apparatus and general instructions for use in 

3 its active mode test. And, however, it 

4 proposes to modify the following CEC 

5 provisions prior to incorporation: confidence 

6 intervals, temperature range, AC input voltage 

7 and frequency, the selection of the charge 

8 rate appropriate for the test, and, finally, 

9 the treatment of batteries with no rated 

10 capacity. 

11 In addition, DOE will be 

12 incorporating the remainder of the provisions, 

13 more or less verbatim, with some small 

14 changes, but would also like to discuss the 

15 selection of batteries for test, and treatment 

16 of devices that are incorporated -- treatment 

17 of battery chargers that are incorporated in 

18 other products that may provide additional 

19 functionality to the users. So, I'll be 

20 discussing those, and requesting comment. 

21 I'll begin with discussion of confidence 

22 intervals. 

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1 Confidence intervals, the 

2 temperature range, and the AC input voltage 

3 and frequency, the first three issues that 

4 I'll discuss apply to all the tests, while the 

5 other ones are sort of special cases, so they 

6 may be applicable to some tests, but not all. 

7 So, confidence intervals. 

8 Confidence intervals are necessary 

9 in the specification of uncertainty, and in 

10 this case we're dealing with measurement 

11 uncertainty. While the CEC test procedure 

12 specifies the uncertainty of measurement, for 

13 example, take the phrase on the left, “0.5 

14 watts or greater shall be made with an 

15 uncertainty of less than 2 percent.” That's a 

16 statement from the CEC test procedure. 

17 DOE is proposing to add a 

18 confidence level qualifier to that 2 percent 

19 at the 95 percent confidence level. And what 

20 this means is, say you're using a piece of 

21 measurement equipment that provides you a 

22 reading of 0.5 watts. Oftentimes, the 

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1 equipment also provides an uncertainty, a band 

2 of uncertainty. And what's necessary is to 

3 somehow quantify that. No measurement 

4 uncertainty is usually unlimited. It just --

5 in all likelihood, it will measure 0.5 watts, 

6 and then there will be a spread in the 

7 potential measurements. So, what DOE is 

8 proposing is to state that plus or minus 2 

9 percent that's currently in the CEC test 

10 procedure will occur 95 percent of the time 

11 for a given piece of measurement equipment. 

12 And this is consistent with standard 

13 engineering practice, as well as some industry 

14 test procedures. 

15 MR. BROOKMAN: Yes, Wayne. 

16 MR. MORRIS: Wayne Morris. Thanks 

17 for this, Matt. And I think it's very good to 

18 have this addition. I appreciate the addition 

19 of this confidence level, and this is an 

20 important addition to the standard, and we 

21 support you. 

22 I would recommend that you and the 

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1 Department take a look at the IEC 62301 Second 

2 Edition FDIS document, which will be going out 

3 probably for final vote within the next week 

4 or so. And that committee, of which I have 

5 the sort of dubious honor of sitting on, has 

6 been wrestling for the last six months on this 

7 issue of confidence level, and additional 

8 language in the standard to deal with this 

9 issue. 

10 It becomes critically important 

11 when you're dealing with very small 

12 measurements of energy, as you're going to be 

13 in some of these elements within the test 

14 procedure, that the confidence level has to be 

15 maintained. And if you're measuring washing 

16 machine energy in watts or kilowatts, your 

17 confidence level, while it's important, is not 

18 nearly as critical as when you're now starting 

19 to get down into the significantly less than 

20 one watt. And here, your confidence level has 

21 got to be maintained very highly, and that's 

22 not so easy. So, the committee has dealt with 

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1 this. And, in fact, has even gone so far as 

2 to recommend much broader language in this 

3 regard in the new edition. You may want to 

4 take a look at that, and see if that might be 

5 appropriate for incorporating some of that. 

6 In addition, the measurement 

7 equipment, which now becomes even more 

8 important in terms of sampling rate, and other 

9 kinds of things, that are included in that 

10 might be something that the Department will 

11 want to take a look at. Thanks. 

12 MR. BROOKMAN: Thank you. Larry. 

13 MR. ALBERT: Just a question, 

14 Matt. When you started implementing this 

15 requirement in your own testing, what impact 

16 did you see on your laboratory procedures? 

17 MR. MALINOWSKI: There really was 

18 no impact. What we did was we reviewed the 

19 specifications of the test equipment, and just 

20 read the fine print under the uncertainty of 

21 measurement that's provided by the 

22 manufacturer, making sure that would fit 

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1 within the requirements of the CEC test 

2 procedure. 

3 MR. ALBERT: One of the later 

4 questions I think deals with pulse charging 

5 and error associated with pulse charging. And 

6 it seems like this comes into that question, 

7 that is, the sampling rate, and sampling 

8 interval during the measurement of a charger 

9 that does pulse charging is going to affect 

10 your overall uncertainty of the measurement. 

11 Right? Did you have any occasions where you 

12 had to deal with that? 

13 MR. MALINOWSKI: So, I think this 

14 -- yes, this issue is maybe a little bit more 

15 broadly, if you have a constant power of say 5 

16 watts, how you will measure it. 

17 MR. ALBERT: Right. 

18 MR. MALINOWSKI: But in terms of 

19 pulse charging, I think just ensuring that the 

20 sample rate of the instrument is high enough, 

21 in the tens of kilohertz range, I think, is 

22 what we've been using. I think as -- it was 

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1 kind of our standard, but there's nothing in 

2 the test procedure, as proposed, that deals 

3 specifically with pulse charging. 

4 MR. ALBERT: But your 

5 understanding is this requirement applies to 

6 sampling issues, as well as any other 

7 measurement issues. Right? 

8 MR. MALINOWSKI: I suppose so. I 

9 think I've always viewed them as separate 

10 issues, but I guess yes, this could be applied 

11 to that, as well. Would you recommend that 

12 there be some -- also a requirement on the 

13 time that the instrument can react? 

14 MR. ALBERT: No, I think the 

15 reason why we started implementing this when 

16 we worked on 381.2, because we were looking 

17 for some sort of overall way of addressing 

18 error in the laboratory procedure, and the 

19 concern was that in each of these different 

20 cases, there is the possibility of having some 

21 other element that could introduce error. 

22 And, certainly, in the cases where you had not 

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1 a constant charge rate, the sampling windows, 

2 the sampling rates, and so on, as well as the 

3 A-to-D conversion process, all of those 

4 distributed to the uncertainty of the 

5 measurement. So, rather than to establish 

6 equipment requirements, the idea is, let's 

7 establish requirements for the overall error 

8 analysis. And, obviously, this proves it, but 

9 I just want to make sure that it's understood 

10 that this applies to that, as well. Right? 

11 And I think that would be our answer to how 

12 you handle the pulse charging question. 

13 Right? That it's already there. Right? 

14 MR. MALINOWSKI: Thank you. Next, 

15 I'll go into two additional requirements that 

16 apply to all tests, namely, temperature and 

17 input voltage to the unit under test. 

18 The current CEC test procedure 

19 requires a temperature range of 20 degrees 

20 Celsius, plus or minus 5 degrees. And DOE is 

21 proposing to raise that to 25 plus or minus 5 

22 to reflect better the typical temperatures in 

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1 testing environments. The range would still 

2 be the same, it would just be shifted up. 

3 DR. BENDT: Yes. This is Paul 

4 Bendt. And I guess I would like to address 

5 where that original specification of 20 

6 degrees plus or minus 5 came from. And it 

7 came, primarily, from all the IEC standards on 

8 batteries, and in particular, the testing of 

9 nickel-cadmium and lithium-ion batteries. 

10 And, in turn, the end of discharge voltages 

11 are from those same standards, and the end of 

12 discharge voltages in the table are applicable 

13 in the range of 20 plus or minus 5. 

14 I would question on that, if 

15 you're going to allow testing up to 30 degrees 

16 Celsius, that you need to confirm that the end 

17 of discharge voltages that were taken from 

18 standards doing testing only up to 25 degrees, 

19 that those voltages, in fact, are applicable 

20 to 30 degrees Celsius. I believe it's much 

21 simpler just to leave the temperature range 

22 where those standards were set, with the IEC 

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1 standards, rather than to try to verify that 

2 the chemistry of batteries is still the same 

3 at 30 degrees Celsius, and that will not 

4 affect the testing, or the discharging, and 

5 charging of the batteries. So, I would 

6 question whether it's appropriate to go to 

7 those higher temperatures without verifying 

8 the effect that has on the chemical reactions 

9 in the batteries. 

10 MR. BROOKMAN: Thank you. 

11 MR. MALINOWSKI: Thank you for 

12 that note. 

13 MR. MORRIS: Doug? 

14 MR. BROOKMAN: Yes, Wayne. 

15 MR. MORRIS: I agree with Paul. I 

16 think we have to look at that, but I think 

17 there's some other issues that we need to 

18 consider about Table 5.2, when we get to it, 

19 that call into question some of the values 

20 that are there. But I agree with Paul, that 

21 we need to watch that carefully at a 30 degree 

22 Centigrade, that's getting pretty warm. 

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1 MR. MALINOWSKI: Good. The other 

2 proposed modification would, again, require 

3 testing only at 115 volts and 60 hertz. And 

4 that would be consistent -- that would be the 

5 input voltage for testing AC chargers, and 

6 would be consistent with limitation of scope 

7 that I discussed previously. 

8 Great. So, we've gone through the 

9 first three. Next, I'll speak about the 

10 selection of charge rate for testing. And, as 

11 I mentioned previously, the next four only 

12 apply to some special cases. They may not be 

13 broadly applicable. Nonetheless, it's 

14 important for the test procedure to cover all 

15 consumer battery chargers, and that's why 

16 we're getting into these details today. 

17 In terms of charge rate, the test 

18 procedure states that if the battery charger 

19 has user controls that allow the user to 

20 select from two or more charge rates, the test 

21 shall be conducted with each of the possible 

22 chargers, I'm sorry, with each of the possible 

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1 choices. And DOE believes that the user will 

2 select the fastest charge rate recommended for 

3 everyday use in practice, in real life. And, 

4 therefore, to ease the testing burden, rather 

5 than require several tests, each of which can 

6 take over 24 hours, DOE is proposing 

7 conducting the test only at the fastest charge 

8 rate. And the Department welcomes comments on 

9 this proposal. 

10 MR. BROOKMAN: Okay. 

11 MR. MALINOWSKI: Okay. Next, how 

12 to deal with batteries with no rated charge 

13 capacity. This issue is important, because 

14 the rate at which a battery is discharged 

15 depends on the -- I'm sorry, the capacity, the 

16 measured capacity of the battery depends on 

17 the rate at which it is discharged. So, it is 

18 important to have a fixed rate that is a 

19 proportion of a rated capacity. 

20 The issue is that some batteries 

21 that are sold typically embedded inside of 

22 consumer products where no consumer can see 

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1 them do not list their rated capacity. So, it 

2 is not possible to immediately calculate that 

3 capacity. And the CEC test procedure has a 

4 provision to address this. It specifies how a 

5 technician shall determine the discharge 

6 current. However, it leaves it somewhat open7 ended. It just says the discharge current, 

8 and I don't have the test procedure in front 

9 of me, but I believe it says discharge current 

10 shall be determined such that it falls between 

11 4-1/2 to 5-1/2 hours. Yes, discharge time 

12 must be not less than 4 hours, and not more 

13 than 5 hours. 

14 And DOE, therefore, proposes a 

15 more explicit method, an iterative method, 

16 that gives the technician a charge current to 

17 start with, discharge the battery at that 

18 current, make an estimate of the capacity of 

19 the battery, and then iterate to improve his 

20 or her original estimate such that it falls 

21 within a window of, I believe, 4-1/2 to 5-1/2 

22 hours. And that iterative method I just 

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1 summarized it here briefly, but it's explained 

2 at length in the notice, and the Department 

3 welcomes comments on that iterative method. 

4 MR. BROOKMAN: Larry. 

5 MR. ALBERT: Yes, Larry Albert. I 

6 agree with Paul's opening comments regarding 

7 the potential inappropriateness of a half an 

8 amp as a starting current over the wide range 

9 of batteries that you might have. Even though 

10 the requirement in the CEC test procedure has 

11 sort of an objective as its method, it still, 

12 in fact, I think -- it ends up giving you 

13 better results, because it doesn't force you 

14 to use what could be either way too high a 

15 current, or way too low a current, given the 

16 situation. I mean, and, ultimately, it's 

17 going give you the kind of thing you're 

18 looking for. It does depend a little bit upon 

19 a little cut and try approach, you know, on 

20 the part of the technician, and a little bit 

21 of experience, and so on, but I think it's 

22 going to be a better approach, overall. 

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1 MR. BROOKMAN: Paul 

2 DR. BENDT: Yes, this Paul. And 

3 thank you, Larry. It's a delight to have 

4 agreement between us. 

5 I would also like to add that in 

6 testing some hundreds of products, we 

7 developed a procedure that is also sort of a 

8 trial and iterative procedure. And we would 

9 be happy to make that available to DOE. It's 

10 a procedure that ended up being safer, and 

11 more reliable for a broad range of products, 

12 and also getting a discharge current that met 

13 the requirements with fewer trial samples. 

14 And I'd be happy to write that up and include 

15 it. 

16 We feel that it should probably be 

17 a suggested procedure, rather than a mandatory 

18 procedure, that, ultimately, the requirement 

19 should be that you get a discharge that fits 

20 within a particular window. How you get there 

21 is less important than the fact that it's a 

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1 specified discharge time. 

2 MR. BROOKMAN: Thank you. 

3 MR. MALINOWSKI: Maybe just as a 

4 follow-up, so the commenters seem to agree 

5 that it's best to leave this issue up to the 

6 technician, to have them meet it as best they 

7 can, as long as the outcome is what is 

8 specified in the test procedure. Are there 

9 any concerns regarding repeatability, or what 

10 needs to be done in the test procedure to 

11 insure that a test will be repeatable? 

12 MR. BROOKMAN: Yes, Larry. 

13 MR. ALBERT: Well, in general, I 

14 think the question of repeatability in the 

15 amount of error you introduce by having --

16 obviously, you've bracketed the time it's 

17 going to take for discharge. Right? So, 

18 there's a potential that you could be at one 

19 end or the other end of that discharge time, 

20 and it could have an impact upon what capacity 

21 you measure. But, in general, I think it 

22 depends a little bit upon how the numbers are 

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1 going to be used later on, and how that 

2 impacts the overall measurement of efficiency. 

3 And that's the thing we don't have nailed 

4 down quite yet. 

5 MR. BROOKMAN: Paul. 

6 DR. BENDT: Again, Paul Bendt. 

7 And I would agree that you have to look at 

8 what happens if you hit the very ends of that 

9 allowed range. And that's true even with the 

10 iterative procedure that DOE is proposing. You 

11 can still end up with products that are almost 

12 identical, and still end up having very 

13 different discharge currents, if with one 

14 product you end up just barely hitting the 

15 edge of that acceptable range, and then 

16 another one you just barely miss it, so you do 

17 another iteration. You end up with very 

18 different discharge currents for two samples 

19 of the same product. So, one still has the 

20 repeatability problems, even with the DOE 

21 procedure. 

22 Our estimates are that the error 

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1 in the final measurements of battery energy or 

2 charger efficiency with the half-hour time 

3 window that was allowed in the CEC proposal, 

4 that that introduces an error in the 

5 measurements that can be about 2 percent, some 

6 cases maybe a little more, but roughly 2 

7 percent. And that makes it consistent with 

8 the other sources of uncertainty in the test 

9 procedure. 

10 The hour-wide window that DOE is 

11 suggesting, we believe would introduce errors 

12 in the order of 4 to 5 percent, and that 

13 that's probably an unacceptable source of 

14 error. Even the CEC procedure was definitely 

15 a compromise, and I think a good case could be 

16 made that one should allow a 15-minute 

17 interval, rather than a 30-minute interval. 

18 It may take another trial to get a current 

19 within that narrower range, but I think for 

20 repeatability, an argument could be made that 

21 it should be a tighter interval than the half22 hour that was allowed by CEC. 

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1 I should, perhaps, also address 

2 why the CEC procedure chose a biased interval; 

3 that is, it was 4-1/2 to 5, rather than 4-1/2 

4 to 5-1/2. And the reason is that among all of 

5 the batteries we tested that had rated 

6 capacities, the average discharge time was 

7 about 4.6 hours; that is, broadly stated, the 

8 batteries in the marketplace are over-rated, 

9 they're rated with more capacity than they 

10 actually deliver. So, we believe that trying 

11 to aim at a target time for the unrated 

12 batteries that was around 4.6 hours, actually 

13 provided the most level playing field between 

14 rated and unrated batteries. And that was the 

15 reason for choosing the period of 4-1/2 to 5 

16 hours as the final time period there. 

17 MR. BROOKMAN: Larry. 

18 MR. ALBERT: I'd just like to 

19 follow-on to Paul's comment regarding the 

20 error in measurement of capacity. The 

21 ultimate impact upon that error of measurement 

22 depends upon how that capacity is used in the 

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1 final objective equations that are part of the 

2 usage factors. So, that 2 percent error might 

3 translate into a quarter percent error in 

4 terms of the total impact it has upon the 

5 metric, depending upon what the Department 

6 elects to use with it, to use it for. If it 

7 has -- it could also go the other way, 

8 obviously, if battery capacity weighs very 

9 large in the overall metric, then, in fact, 

10 that could have a larger impact. So, again, 

11 this gets back to the earlier point, that 

12 knowing how the data is used has a bearing 

13 upon the level of accuracy you need to 

14 maintain throughout the test measurement 

15 process. 

16 MR. BROOKMAN: Okay. 

17 MR. MALINOWSKI: Great. Next, 

18 I'll touch on the selection of batteries for 

19 tests. And I'd just like to note that the 

20 following two issues that I'll be discussing, 

21 DOE is proposing approaches that are 

22 consistent with the current CEC test 

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1 procedure. However, there do exist 

2 alternatives, and DOE is, therefore, also 

3 considering those alternatives, and would seek 

4 comment on them. 

5 Great. Because there are chargers 

6 such as multi-voltage, multi-port, multi7 capacity chargers, say, for example, this 

8 universal AA/AAA charger illustrated here that 

9 can be tested with a wide variety of 

10 batteries, and sometimes these chargers do not 

11 ship with any -- aren't packaged with any 

12 batteries, CEC requires them to be tested 

13 using up to three different combinations of 

14 batteries. So, the lowest capacity-lowest 

15 voltage, highest capacity-highest voltage, so 

16 on. And this may result in up to three days 

17 of testing, probably more given resting 

18 periods, and discharges, et cetera, for a 

19 single charger. And even though DOE is 

20 proposing to incorporate this test, it is also 

21 considering testing using only the most 

22 typical battery combination for a given BC. 

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1 Again, the test procedure should be 

2 representative of typical use, so the 

3 Department would like comment on typical 

4 battery combinations, and both voltage and 

5 capacities used with these types of chargers. 

6 So, AA/AAA chargers, 12-volt kind of general 

7 purpose, lead acid chargers, et cetera. 

8 MR. BROOKMAN: Larry. 

9 MR. ALBERT: Larry Albert. Would 

10 the intention be that the data would then be 

11 averaged together later on, and that would 

12 form the value that represented some, again, 

13 weighted average of use for the product across 

14 all the different voltages, and types? 

15 MR. MALINOWSKI: Yes. So, the --

16 say you've given a charger like this one that 

17 doesn't come with any batteries, and you have 

18 an option how to test it. So, one choice is 

19 to test it with the smallest, the biggest, and 

20 then based on your information on what is the 

21 typical use, maybe somehow weight those two 

22 measurements, so that it's representative of 

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1 that most typical use. Say most people 

2 actually use a battery that's exactly in 

3 between those two, the two sizes that you 

4 tested, so maybe you average those two 

5 measurements. The alternative is to just 

6 perform the test with the most typical type of 

7 battery, which is the alternative that's being 

8 presented here. However, DOE would need 

9 submissions, need comments on what those most 

10 typical battery choices are. 

11 MR. BROOKMAN: Wayne Morris. 

12 MR. MORRIS: Thanks, Doug. Here, 

13 I'll speak as an individual, and not from 

14 AHAM. None of our members make these type of 

15 products, but I am a little concerned about 

16 the accuracy of this. And I think Larry's 

17 point is a good one, as to whether or not 

18 we're -- if you were presented with this type 

19 of battery charger, you could go out into the 

20 marketplace and buy, let's say this is AA, you 

21 could buy any of the rechargeable AA 

22 batteries. Now, this manufacturer of this 

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1 charger may, in fact, have batteries for which 

2 they provide with it, or sold separately, but 

3 of the same brand, and could be even 

4 configured to be used in this, and may even 

5 reference this charger, or the charger may 

6 reference the battery, as in the case of some 

7 manufacturers. But you could also buy other 

8 batteries that say they're rechargeable, no 

9 name, or off-brand, or retail store brand, or 

10 whatever. If you're averaging those values, 

11 though, then you're sort of, in a way, 

12 penalizing the manufacturer. If they say use 

13 only Battery X, Y, and Z in my charger, to 

14 average that with other ones, that raises a 

15 question. 

16 Do you take the worst case, do you 

17 take the best case? Do you take the average? 

18 I think that that needs to be thought out a 

19 little bit in terms of what the right thing to 

20 do is there to get the value for that. If the 

21 manufacturer recommends a particular battery 

22 to be used, and I guess I would suggest that 

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1 the Department consider using only that 

2 battery, and not any others for any 

3 measurement. Even though they may be 

4 available in the marketplace, we still would 

5 not know, necessarily, whether that's the 

6 right battery. 

7 MR. MALINOWSKI: Sure. Just as a 

8 point of clarification, the proposal does 

9 state that if a battery is recommended, that 

10 should be the one to be tested. But this is 

11 kind of the ultimate case, when you have this 

12 charger that no battery is explicitly stated 

13 is to be used with it. 

14 MR. ALBERT: So, just to clarify, 

15 this also covers those cases where the 

16 manufacturer recommends a number of different 

17 batteries that are intended for the charger, 

18 like a lot of power tool manufacturers do 

19 that. Right? So, in those cases, you might 

20 have an 18, a 14, a 12 volt, that all fit into 

21 the same charger, so in that case, you would 

22 charge the highest, the lowest, and the 

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1 typical. Is that the proposal? 

2 MR. MALINOWSKI: Well, the 

3 proposal, I think, let's see, the CEC test 

4 procedure has a nice table. Let me see if that 

5 one is -- I think it's reproduced as Table 4.1 

6 in the proposal, so page 16982. So, in that 

7 case, that might be either -- according to the 

8 proposal, that charger that you described 

9 might be either tested using the lowest 

10 voltage, lowest capacity battery, and the 

11 highest voltage, highest capacity battery, or 

12 if you have a variation of capacities, you 

13 have, for example, two highest voltage 

14 batteries, but with two different capacities, 

15 then you would test it three times. So, that 

16 would be the last line on the table, lowest 

17 voltage, lowest capacity, and then highest 

18 voltage, lowest capacity, and highest voltage, 

19 highest capacity. 

20 MR. BROOKMAN: So, that exchange 

21 was between Larry and Matt back and forth, for 

22 the record. Paul. 

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1 DR. BENDT: Yes, Paul Bendt. And 

2 I'll add that even before that table, that 

3 table you select combinations out of a 

4 universe of batteries that's already been 

5 limited, and it's already been limited by any 

6 information, or any instructions that the 

7 manufacturer has provided. So, if the 

8 manufacturer has recommended six different 

9 battery combinations, then of those six, you 

10 select two or three. But if the manufacturer 

11 has only recommended one battery combination, 

12 then you use only that one recommended 

13 combination. So, these are only -- that whole 

14 selection table happens only after you've 

15 already reduced the choices to what the 

16 manufacturer has recommended in their 

17 instructions. 

18 MR. BROOKMAN: Thank you. 

19 MR. MALINOWSKI: Sure. Just to 

20 circle back, the issue that DOE seeks comment 

21 on is, Is there a way to limit this even 

22 further by reducing the number of tests to say 

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1 just one, the most typical? So, any comment 

2 would be appreciated. 

3 Now, the final issue I'll touch on 

4 in the test apparatus and general instructions 

5 section involves dealing with battery chargers 

6 that are embedded in other products. These 

7 other products provide additional 

8 functionality to the consumer, functionality 

9 that consumes energy, and that may end up 

10 being lumped with the energy of the battery 

11 charger. 

12 DOE proposes to incorporate the 

13 CEC instructions regarding this additional 

14 functionality, and those involve either 

15 disconnecting the product, and any additional 

16 connections from the product, or switching off 

17 any additional functionality if it is present, 

18 if an on/off switch is present. And this, 

19 again, manufacturers could use these steps, 

20 these instructions in the test procedure to 

21 disable the additional functionality, either 

22 using the physical disconnection as a signal 

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1 to power down this additional functionality, 

2 as is the case, for example, in this cordless 

3 phone/answering machine combination that we 

4 see, or for products that already have a user 

5 interface providing an on/off switch to power 

6 off the functionality. 

7 MR. BROOKMAN: Larry. 

8 MR. ALBERT: First, I'd like to 

9 comment on your choice of cordless radio 

10 there. It's always -- generally, we like to 

11 see our products advertised, but this is not, 

12 necessarily, the most appropriate context. 

13 But, in general, when I saw these comments in 

14 this slide here, I had a question about -- I 

15 understand Case Two, but the case with the 

16 cordless phone, how is that supposed to work? 

17 What's the concept there, that if you 

18 disconnect the phone from the base? 

19 MR. MALINOWSKI: Sure. No, this 

20 would be -- yes, take a cordless phone, that's 

21 the base station that has the phone lines 

22 going into it. So, the answering machine has 

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1 the LED that shows you how many messages you 

2 have, and monitors the phone line constantly 

3 for incoming calls. Disconnecting the phone 

4 line could provide -- the manufacturer could 

5 use that as a signal to power down all that 

6 additional functionality that ends up 

7 consuming power, such that only the energy 

8 charging component would be tested. Sorry, 

9 the battery charging component would be 

10 tested. 

11 MR. ALBERT: So, in general, this 

12 is not, necessarily, consistent with the use 

13 and application of the products currently, 

14 this is something that you're proposing as a 

15 technological solution in order to be able to 

16 better measure the energy efficiency. 

17 MR. MALINOWSKI: Yes. This is all 

18 intended to isolate just the battery charging 

19 component, because that is what the 

20 Department's scope, or what's covered under -- 

21 MR. ALBERT: I would just say, in 

22 general, that the notion that the manufacturer 

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1 should add in signaling or switching purely to 

2 make it easier to measure battery charger 

3 energy efficiency, and not, necessarily, to 

4 provide better functionality to users should 

5 be seen as sort of contrary to the overall 

6 goal here. 

7 You know, almost always in many of 

8 these cases, battery charging is secondary to 

9 whatever the main function of the product is. 

10 And that main function of the product is 

11 often something that is something you want to 

12 leave on all the time. Right? That's why 

13 often you have battery backup, or battery 

14 support, or something like that. Suggesting 

15 that you should -- that you'd have a means of 

16 turning off that functionality that normally 

17 users would want all the time, and the only 

18 benefit to doing that is to pass a test, is 

19 inconsistent with our general approach in 

20 trying to satisfy user's requirements. 

21 You know, it seems to me there's 

22 got to be a better approach to getting to the 

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1 energy efficiency of the battery charging 

2 system without, necessarily, requiring 

3 manufacturers to design their products so they 

4 can be more testable. 

5 MR. BROOKMAN: Paul. 

6 DR. BENDT: Yes, Paul Bendt, 

7 again. And while Matt has covered two 

8 approaches that manufacturers can take of 

9 using disconnection as a signal, or providing 

10 a user interface, there's actually a third one 

11 that I think is going to become the 

12 predominant one, and that is, that in most 

13 cases, this additional functionality can be 

14 done with very, very little power. So, for 

15 example, in the cordless phone, where you're 

16 monitoring the input line, and providing a 

17 display that shows how many messages are 

18 there, that same functionality is provided in 

19 a cell phone when it's not being used to talk, 

20 and, as well, the cell phone at the same is 

21 monitoring the radio signals coming in, and 

22 doing that on just a few milliwatts of power 

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1 to get long battery life. So, in general, 

2 actually, the best way for manufacturers to 

3 approach this is to make this additional 

4 functionality so that the power consumption is 

5 so small that they have an easy time meeting 

6 the battery charger standards, even with that 

7 additional functionality turned on. And with 

8 modern electronics, the power required for 

9 these additional functions is generally in the 

10 order of a milliwatt, or a couple of 

11 milliwatts, and it's not -- it's a level that 

12 is so small that it actually isn't even 

13 detectible in the test. So, we believe that 

14 manufacturers, in fact, will probably not 

15 design their products specifically to meet the 

16 test, but will design them to be energy 

17 conserving products, in the first place, using 

18 technology that's already widely available. 

19 And, in fact, achieve not only good 

20 functionality for the user, but low energy 

21 consumption for the user at all times, whether 

22 it's charging the battery, or not. 

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1 MR. BROOKMAN: Additional comments 

2 on this one? Larry. 

3 MR. ALBERT: Just in -- Larry 

4 Albert. In the past, we've suggested an 

5 alternative approach that has one obvious 

6 shortcoming, but, in general, I think could 

7 provide much better information across a whole 

8 range of products. Appreciate Paul's 

9 comments, but, obviously, there's cases of 

10 products out there that are not mostly 

11 battery-operated, where the battery provides a 

12 standby function. Right? And while a product 

13 that's primarily battery-operated might drive 

14 the overall efficiency of the device, itself, 

15 to fulfill a consumer requirement, products 

16 that have a standby battery, that's not, 

17 necessarily, an essential user requirement. 

18 MR. MALINOWSKI: Can you provide 

19 an example? I'm sorry, Larry. 

20 MR. ALBERT: So, like UPSs, for 

21 example, would be. The battery charging in 

22 the UPS is a standby function. Emergency 

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1 lighting is a standby function. Right? Most 

2 of the time, those products operate off of the 

3 mains, and the battery is only functional in 

4 terms of driving the product only briefly, 

5 only under sort of exceptional circumstances. 

6 The case there, the case with 

7 other battery-operated products, where it's 

8 principally battery-operated, like a cell 

9 phone, is a different scenario, where there's 

10 an obvious advantage to designing extremely 

11 efficient loads for the battery-operated 

12 portion, because in that case, the battery 

13 charging occurs only during the kind of non14 use time, more or less. 

15 So, our suggestion in the past has 

16 been to conduct the battery charging tests 

17 with the entire unit connected, and then 

18 repeat those tests with the battery 

19 disconnected, and subtracting the difference 

20 of the two would then provide you with a 

21 measure of what the battery charging component 

22 has. 

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1 The disadvantage, as has been 

2 pointed out in the past, is that it excludes, 

3 effectively, the standby component, which does 

4 introduce an error, ultimately, but we believe 

5 that error is far less impactable than sort of 

6 treating all of these products as if they're 

7 just sort of augmented battery chargers. 

8 MR. BROOKMAN: Okay. Thank you. 

9 Final comments on this? Yes, Wayne. 

10 MR. MORRIS: I have a question in 

11 regard to an item that was covered on Slide 41 

12 for a second, and I apologize to go back, but 

13 I need to just sort of ask a question in 

14 regard to this. This has to do with those 

15 discharge currents where the battery capacity 

16 is not rated, or you can't find it, that type 

17 of situation. 

18 Is the Department open to adding a 

19 provision that if the manufacturer provides 

20 the capacity for the battery in instructions, 

21 or somewhere along that line, or in -- I mean, 

22 it could be buried in an instruction manual, 

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1 or something like that, that would be 

2 available, necessarily, to a technician, or 

3 something, rather than have to -- I mean, 

4 these battery chargers are getting awfully 

5 small, to sort of put it on the actual battery 

6 charger may be pretty difficult these days. 

7 But if they were able to provide it in 

8 literature, or on, say, the packaging of the 

9 product, or someplace like that, would that be 

10 an acceptable way to -- for the Department to 

11 have that available? And, therefore, go by 

12 that, rather than have to go through this long 

13 involved process? 

14 MR. MALINOWSKI: Sure. I can 

15 touch on that. That's okay. In the proposal, 

16 the rated charge capacity is defined as the 

17 capacity the manufacturer declares the battery 

18 can store under specified test conditions. 

19 And it just says that, typically, that 

20 information is printed on the battery. 

21 However, if it is provided by the manufacturer 

22 in, for example, a spec sheet, or other 

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1 declaration, I think that would be acceptable. 

2 MR. MORRIS: Excuse me. Wayne, 

3 again. Web pages are often used these days to 

4 provide spec sheets rather than have to print 

5 things, which then wastes paper, and gets us 

6 into other environmental problems. So, I 

7 think that web pages for these might be an 

8 effective way to allow the manufacturer to do 

9 that, to have a spec sheet that they could 

10 provide on the internet by a catalogue number, 

11 and manufacturer, and then whoever is doing 

12 the testing would have that available to them. 

13 Maybe a web site could be provided, or 

14 something like that. 

15 MR. PETROLATI: Wayne, we think 

16 that's a very good comment. Please provide it 

17 to us in writing, and it will be considered. 

18 MR. MORRIS: Thanks. 

19 MR. BROOKMAN: Okay. Other 

20 comments on this series of issues? I think 

21 we're now at a point where we're going to take 

22 a break. You've got one slide, which is 

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1 simply a summary slide. My watch it's just 

2 about 11:15, so we're just pretty close to 

3 being on schedule. We're a few minutes 

4 behind, not bad, we're making good progress 

5 here. So, let's take a break for 15 minutes. 

6 For those of you that are joining us via the 

7 web, I'm glad you're still with us. We'll 

8 resume at 11:30 here East Coast Time of the 

9 United States. And does everybody know where 

10 the coffee shop is? On the ground floor 

11 straight down pretty much underneath us. If 

12 you're going to make a run for the cafeteria, 

13 go quickly. It's a couple hundred yards. 

14 MR. PETROLATI: I wouldn't 

15 recommend going to the cafeteria. 

16 MR. BROOKMAN: Yes, I may sprint 

17 there. You can go with me, if you want. 

18 Anyway, so we'll resume at 11:30. I thank you 

19 for all the high-quality comments here this 

20 morning, very helpful to the Department. And 

21 we'll see you back here in 15 minutes. 

22 (Whereupon, the proceedings went 

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1 off the record at 11:15 a.m., and went back on 

2 the record at 11:32 a.m.) 

3 MR. BROOKMAN: Okay. We're going 

4 to hear about BC active mode test procedure 

5 continued. Mike Vladimer. 

6 MR. VLADIMER: Good morning. 

7 Hello, my name is Michael Vladimer. I'm here 

8 to present the last bit of the BC active mode 

9 test procedure. I'm from Navigant Consulting. 

10 I'll pick up where Matt Malinowski left off 

11 and then hand off to him to discuss external 

12 power supplies before we end the meeting. 

13 Just to briefly review how we got 

14 here. So the BC active mode test procedure 

15 has four parts. Matt let us know about the 

16 scope, what is and is not covered by the test 

17 procedure, definitions that specify the exact 

18 terms that we're going to be using, the test 

19 apparatus and general instructions, how the 

20 test room is going to be set up, how to 

21 prepare the equipment and so on. 

22 And now I'll talk about the test 

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1 measurement itself. Of course, DOE welcomes 

2 comments on any of the materials that I'll be 

3 presenting. 

4 What I want to talk about are both 

5 proposals and considerations. As for 

6 proposals, one issue is reordering the test 

7 procedure from the order that the CEC has. 

8 Paul Bendt, I know you've mentioned this 

9 before. I'll mention why DOE had proposed 

10 this and the goals it's trying to achieve and, 

11 of course, please comment on that. 

12 We also want to talk about end-of13 discharge voltage, what that means and how 

14 that would apply to the test procedure. 

15 There's also considerations. In 

16 this case, the active and maintenance mode 

17 test duration. 

18 I should just stress that when 

19 talking about DOE regulation there's a big 

20 different between a proposal and a 

21 consideration. A proposal is something that 

22 DOE intends to do and wants to get stakeholder 

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1 feedback on it. Consideration is something 

2 that DOE might do and that also depends on 

3 stakeholder feedback. So there's a lessening 

4 of degree between the two terms. 

5 So let me go forward and now talk 

6 about the test procedure order. So as Matt 

7 had mentioned earlier, he gave a quick 

8 overview of the CEC test procedure. The key 

9 thing with the CEC procedure is that it starts 

10 with a preparatory discharge step. Then it 

11 measures energy consumed into the battery 

12 charger while the battery charger charges the 

13 battery, and then it measures the energy 

14 output from the battery during a discharge. 

15 You can see that here in the 

16 graph. So the question mark shows that 

17 whenever you start to do this test the battery 

18 is going to be in an unknown state. The 

19 technician is going to take it and won't know 

20 if it's full, empty or somewhere in between. 

21 And the key aspect of the test procedure is to 

22 get the battery to a known state so that when 

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1 we start taking measurements that we know 

2 where we're beginning and where we're ending. 

3 Do you have a laser? 

4 MR. BROOKMAN: That was working. 

5 MR. VLADIMER: Okay. It's fine. 

6 MR. BROOKMAN: It needs a battery 

7 charger. 

8 (Laughter.) 

9 The laser must not work. 

10 MR. VLADIMER: Can we charge the 

11 battery charger on the laser? It's fine. 

12 So the question mark is -- 

13 Actually, we don't need the pointer. It's 

14 fine. So the issue is that the question shows 

15 that we're going to get from the unknown state 

16 to a known state and then we'll track the 

17 battery voltage as it goes up and down. 

18 The key issue that is going on 

19 here though is to discharge the battery 

20 requires a piece of equipment known as a 

21 battery analyzer. This discharges the battery 

22 at a specified rate. And the issue is that 

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1 that battery analyzer, it's a unique piece of 

2 lab equipment. When a lab is trying -- For 

3 instances, in DOE's case when the DOE lab 

4 tried to discharge a number of or prepare a 

5 number of battery charges for test at a time, 

6 the bottleneck largely was that battery 

7 analyzer because you could only use it on one 

8 product at a time. 

9 I will now show a great animation 

10 of how DOE wants to change the test procedure. 

11 Excellent. You can see now comes first and 

12 charge comes second. And so we'll start. 

13 Again, we need to get the battery -- We have 

14 to do a preparatory step. In this case, it 

15 would be a charge step to get the battery to a 

16 known state. In this case it would be full 

17 and then followed by discharge test and a 

18 charge test. The main driving reason here is 

19 to do away with the battery analyzer. By 

20 starting with a preparatory charge test you 

21 can use the battery charger itself. Instead 

22 of having only one piece of equipment that can 

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1 prep one battery charger at a time, you can 

2 now just use the battery charger itself and 

3 prep multiple battery chargers all at the same 

4 time which helps throughput in the lab. 

5 Any questions or thoughts on this? 

6 Yes, Paul. 

7 MR. BROOKMAN: I have comment box 

8 that's coming up here. 

9 MR. VLADIMER: Should I -- 

10 MR. BROOKMAN: Yes. 

11 MR. VLADIMER: I can go to the 

12 comment box. 

13 MR. BROOKMAN: Yes, let's do that. 

14 MR. VLADIMER: Just a brief 

15 comparison whether or not CEC starts with a 

16 discharge. DOE starts with a charge and then 

17 both measure charge and discharge in the 

18 following steps. 

19 Paul. 

20 DR. BENDT: This is Paul Bendt, 

21 and my obvious question is with the DOE 

22 procedure, How do you confirm that you ended 

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1 your charge test at the same state of charge 

2 as you began your discharge test? Or are you 

3 simply assuming that within 24 hours the 

4 battery will be fully charged and that that 

5 state is repeated? 

6 MR. VLADIMER: Sure. I think the 

7 best person to answer is probably Matt 

8 Malinowski who I see is stepping up to the 

9 table. I'll let Matt address it. 

10 MR. MALINOWSKI: Sure, Paul. Just 

11 to address your point. 

12 MR. BROOKMAN: Pop that mike up. 

13 MR. MALINOWSKI: Up a little 

14 higher? 

15 MR. BROOKMAN: Yes. 

16 MR. MALINOWSKI: Okay. Great. 

17 As long as the same procedures are 

18 followed in both preparatory charge test and a 

19 full charge test, in this case charging for 24 

20 hours, the battery is assumed to be at the 

21 same state of charge. 

22 DR. BENDT: I note the word, 

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1 assumed. Let's make a slightly different 

2 assumption. Let's assume that the battery 

3 arrives and it's, as you said, an unknown 

4 state which might be 50 percent or 80 percent 

5 charged. You then charge it for 24 hours. At 

6 the end of 24 hours, it's fully charged. You 

7 do a discharge. It's now fully discharged. 

8 The charger that you put into 

9 though in 24 hours only gives maybe 50 percent 

10 charge. So for the battery that began in an 

11 unknown state, that was enough to get it fully 

12 charged. But for the battery that begins 

13 fully discharged, it's not enough to get it 

14 fully charged. 

15 And we encountered this problem 

16 repeatedly in our testing. The early testing 

17 was done using the same procedure DOE is 

18 recommending and we found in a large number of 

19 cases that it did not result in a full cycle, 

20 that the battery would arrive even nearly 

21 fully charged. The 24 hours initially would 

22 top it off and that's fine. 

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1 But then when we do the final 

2 measured charge so the preparatory step is 

3 fine. But when you do the final actual 

4 measured charge that did not end up with a 

5 fully charged battery. And so the battery did 

6 not return to the same condition because it 

7 didn't start the 24 hour charge in the same 

8 condition. 

9 So I would note that you could 

10 also achieve a true round trip if you made 

11 sure that you always started the charging, 

12 that you started the preparatory charging, 

13 with a fully discharged battery and did it for 

14 exactly 24 hours. But then to know that 

15 you're starting the preparatory charging with 

16 a fully discharged battery requires a measured 

17 discharge in advance of that preparatory 

18 charge. 

19 It ends up in order to ensure that 

20 you're actually getting a round trip it 

21 actually becomes quite difficult. 

22 MR. BROOKMAN: Matt. 

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1 MR. MALINOWSKI: Just as point of 

2 clarification, can you give examples of the 

3 types of chargers that have this behavior that 

4 require more than 24 hours to charge? Where 

5 does this problem -- How prevalent is this 

6 problem? Where does it arise? 

7 DR. BENDT: Yes, the problems, the 

8 most obvious ones, are a lot of security 

9 systems. These are the computer backup 

10 batteries. Those are designed, you know, to 

11 be used only when the power fails. A consumer 

12 usually pays very little attention to how long 

13 they recharge after a power failure. And many 

14 of those take anywhere from one to four days 

15 to fully recharge their batteries after a 

16 power failure. 

17 Another common product are the 

18 universal chargers. Many of those actually 

19 trickle charge. They provide a constant 

20 current no matter what type of battery you put 

21 in. So the currents are designed for charging 

22 AA or AAA batteries. A hundred milliamps is a 

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1 common charge current. You can buy C and D 

2 cell batteries that have capacities up to 

3 about 10 amp hours now. When you put one of 

4 those in it still provides the 100 milliamps. 

5 It takes 100 hours to charge that battery. 

6 There's another common example. 

7 There are quite a few automotive 

8 chargers that are small capacity in the two to 

9 five amp range and if you're putting a two amp 

10 automotive charger on an 80 amp power 

11 automotive battery, logic tells you you're 

12 going to have 40 hours or more for a charging 

13 time. So there actually are quite a number of 

14 products that the consumer is not necessarily 

15 expecting to charge within 24 hours. 

16 That's probably less common in 

17 power tools and home appliances and cell 

18 phones. There we're used to rapid charges. 

19 But there are a lot of products out there that 

20 do not do a charge in 24 hours. 

21 MR. BROOKMAN: Thank you. 

22 MR. VLADIMER: Excellent. Thanks 

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1 for those comments. Anyone else before we 

2 move on? 

3 MR. BROOKMAN: Wayne. 

4 MR. MORRIS: Can I just make one 

5 remark and that is we don't find that either 

6 one as Paul pointed out for the household 

7 types of products make a difference. But we 

8 are concerned about accuracy. And so if 

9 there's an issue with the accuracy of the 

10 procedure that the Department has proposed, 

11 then I think that we ought to seriously 

12 consider an alternative that gives us more 

13 accuracy. Because at the end of the day, we 

14 want to make sure that everybody being tested 

15 the same way. Every test that is at the 

16 beginning of this and every then verification 

17 is going to be the same so that we don't have 

18 situations where manufacturers are accused of 

19 violating by verification organization when in 

20 fact they've complied. So if this is a small 

21 price to pay to reverse the cycle, then I 

22 don't think that this is a real serious 

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1 problem and we ought to consider that. 

2 Thanks. 

3 MR. BROOKMAN: Thank you. 

4 Yes, Paul. 

5 DR. BENDT: Thank you, Wayne. And 

6 just addressing the actual effect that this 

7 has when you go into using the results, as far 

8 as I can tell it always affects the results in 

9 one way. You end up measuring a full or 

10 mostly full battery energy but only a part of 

11 a charge. 

12 MR. BROOKMAN: In this case, this 

13 is the Department's approach. 

14 DR. BENDT: The Department's 

15 approach, yes. 

16 MR. BROOKMAN: Yes. 

17 DR. BENDT: It would measure only 

18 part of a charge. When one then tries to put 

19 that as normalized as an efficiency metric it 

20 always ends up making the battery charger look 

21 more efficient than it really is. And the 

22 fact that it makes a battery charger look more 

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1 efficient also means that it's a loophole that 

2 manufacturers can deliberately drive their 

3 products through. 

4 So, for example, Black and Decker may 

5 make drills that all consistently charge 

6 within 18 hours and do legitimate testing. 

7 But some Brand X decides they want to use this 

8 loophole. Instead of putting in an efficient 

9 charger, they just deliberately make their 

10 power drills so that it takes 40 hours to 

11 charge the battery and in 24 hours you measure 

12 only part of a charge cycle. That battery 

13 charger then looks much more efficient than it 

14 really is. 

15 For some of the products that we 

16 tested this way and one that I know is a UPS 

17 power supply, the actual efficiency of the 

18 unit was probably around 60 percent. The test 

19 result was nearly 170 percent. And it 

20 actually showed that you got more energy out 

21 of the battery than it took to recharge it. 

22 Now that one is plainly obvious. It's an 

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1 absurd result and it's plainly obvious that 

2 it's wrong, although the test procedure 

3 doesn't tell what you do if you get a truly 

4 absurd result. 

5 The more insidious one is the one 

6 that the battery charger is really 20 percent 

7 but the test procedure shows it as being 55 

8 percent. That's a product that should have 

9 failed the standard, for example, but might 

10 end up passing it. And unscrupulous 

11 manufacturers could take advantage of this in 

12 order to make slow charging products that 

13 deliberately look much better than they really 

14 are and leave honest manufacturers at a severe 

15 disadvantage. 

16 MR. BROOKMAN: Yes, Ralph. 

17 MR. HUDNALL: This may be -- Ralph 

18 Hudnall, Euro-Pro. This may be an 

19 oversimplification of the issue, but can't we 

20 just monitor the battery voltage either as 

21 being charged or at the end of the charge and 

22 then know that I have 24 volt battery that is 

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1 fully charged it can provide me 24 volts. 

2 Then I do my discharge and I charge it back to 

3 the 24 volts whether it takes 24 or 48 or 64 

4 hours. 

5 MR. BROOKMAN: Matt. 

6 MR. MALINOWSKI: That's certainly 

7 one approach that could be enlisted. 

8 MR. BROOKMAN: Yes, Larry. 

9 MR. ALBERT: I seem to remember, 

10 Paul, that in the CEC approach there was a 

11 provision for chargers that took longer than 

12 24 hours to charge. Is that correct? 

13 DR. BENDT: That's correct. There 

14 is a provision for chargers that take longer 

15 than 24 hours. But I should also say it's 

16 sort of a provision for chargers that you know 

17 ahead of time are going to take longer than 24 

18 hours because the battery capacity or the 

19 manufacturer has told you that. 

20 There are also presumably chargers 

21 out there that do take more than 24 hours, but 

22 it's not obvious. And we want to make sure 

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1 that even in those cases we get a valid 

2 measurement. 

3 MR. ALBERT: So is there another 

4 issue here with respect to the DOE proposal 

5 that it does not provide for charge cycles 

6 longer than 24 hours? 

7 DR. BENDT: The DOE proposal I 

8 believe does provide for charge cycles that 

9 are longer than 24 hours, although we have a 

10 concern with that one also, because their 

11 specification then is to report only the 

12 energy used in the first 24 hours which in the 

13 case clearly would not be the energy of a full 

14 charged cycle. 

15 We believe that the charging can 

16 be done effectively with a 24 hour charge 

17 cycle or a longer charge cycle but that it 

18 must always be a full round trip. That 

19 getting a complete round trip is absolutely 

20 crucial and one can't simply assume that it's 

21 going to be a round trip. 

22 MR. BROOKMAN: I think we're about 

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1 to get into this in a few more slides. 

2 MR. VLADIMER: Yes. We will at 

3 least talk more about this. 

4 MR. BROOKMAN: Final comments on 

5 this issue before we move on? 

6 Okay. Thanks for all that 

7 commentary. 

8 MR. VLADIMER: Excellent. Thanks 

9 so much. 

10 We were just talking now about the 

11 test procedure order and how that might reduce 

12 burden. Now we'll talk about a couple novel 

13 battery chemistries. So one issue that's very 

14 important is that there are always new battery 

15 chemistries coming out. DOE has identified 

16 two: nanophosphate lithium ion that are 

17 commonly used with power tools, and silver 

18 zinc that are possibly used with notebook 

19 computers. 

20 And, as was noted previously, 

21 Table 5.2 in the NOPR lists all of the end-of22 discharge voltages. And the end-of-discharge 

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1 voltage what that means is that when a battery 

2 charger or a product that uses batteries is 

3 consuming power from the battery it doesn't 

4 use all of the battery power until the voltage 

5 is zero. It typically cuts off at a certain 

6 point. 

7 So these would be the end-of8 discharge voltages on a volts per cell basis 

9 that DOE is proposing to use to characterize 

10 these chemistries such that when the 

11 technician conducts the test procedure it 

12 would stop at this voltage. It's a little bit 

13 of a complicated concept, but any questions? 

14 MR. BROOKMAN: Wayne. 

15 MR. VLADIMER: Or suggestions? 

16 MR. MORRIS: A question or 

17 comment. I don't know if it's your wish. Do 

18 you want to talk about Table 5.2 now or do you 

19 want to wait until later? 

20 MR. VLADIMER: Now is probably the 

21 best time I think. I think this is -- Table 

22 5.2 or forever hold your peace. Go for it. 

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1 MR. BROOKMAN: Do you want to say 

2 the page number again, Matt? 

3 MR. MALINOWSKI: It's on page 

4 16984. 

5 MR. MORRIS: This is Wayne Morris 

6 from AHAM. I would just say that we do have 

7 some issues with the values on 16984, Table 

8 5.2. We believe that DOE here is using only 

9 the cutoff voltage for these and we don't 

10 believe the end values for the lithiums are 

11 correct. Most lithium ion battery 

12 manufacturers do not recommend discharging 

13 below 3.0 volts. That's what SONY and B&D 

14 particularly recommend. 

15 I think it's important that we -- 

16 It's nice that we use something like an IEC 

17 table. That's great. But there are many 

18 manufacturers that set limits that are 

19 different than what's in an IEC standard and I 

20 think it's important that we represent that 

21 situation. 

22 Now granted, we want it to be as 

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1 low as is possible therefore in order to make 

2 sure that we're testing accurately. But I do 

3 think that we've got to be very careful that 

4 we represent the situation that the consumer 

5 is going to see, too. 

6 If we discharge too low, then what 

7 we end up with is a situation that in a 

8 practical atmosphere I mean once you can't 

9 pick up the Cheerio the vacuum cleaner isn't 

10 really of much use. So just because the fan 

11 continues to spin isn't representative of the 

12 real world out there. The same is true of 

13 many, many other products. There's a minimum 

14 efficiency in order to get a point where the 

15 product is actually performing some type of 

16 real function. 

17 And I recognize that that's 

18 difficult. But probably the best way of doing 

19 that is by looking at some of the 

20 manufacturers' recommendations for this. That 

21 will give us probably a more accurate 

22 situation than any of the others. We'd ask 

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1 that we watch very carefully in some of the 

2 values that are in 5.2 because we don't think 

3 that they're representative of what the 

4 battery manufacturers are telling the end-user 

5 manufacturers how to design their product. 

6 Thanks. 

7 MR. BROOKMAN: Okay. Ralph. 

8 MR. HUDNALL: Ralph Hudnall with 

9 Euro-Pro. On top of what Wayne was saying, 

10 we're starting to see some products out there 

11 that manufacturers are designing that the 

12 battery may not ever even reach these cutoff 

13 levels. A certain manufacturer's hand vac 

14 gives you five minutes of operation and that's 

15 it. It doesn't matter what the battery is, 

16 what the power, how much work to pick up. It 

17 just shuts off after a certain amount of time. 

18 We think it's to protect the 

19 battery because in many case if you discharge 

20 these batteries too deeply they won't recover. 

21 But we have seen situations where the 

22 manufacturers are designing products to stop 

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1 operation at a certain point. I don't want to 

2 say regardless of what the battery voltage is, 

3 but they don't reach these levels. 

4 MR. BROOKMAN: Okay. Matt. 

5 MR. MALINOWSKI: Maybe just a 

6 follow-up question for Wayne. Whereas I 

7 definitely appreciate that these may not be 

8 the end-of-discharge voltages in every 

9 situation, and I think Michael will touch on 

10 this issue in that it's difficult to model 

11 correctly the depth of discharge faced by 

12 consumers. And so I think in this case it's 

13 good to have some sort of authority to go back 

14 to especially since as far as I understand 

15 there isn't that much energy recovered from 

16 the battery towards the end of its discharge. 

17 And the discharge curve just kind of goes 

18 over a cliff. So whether it's 2.5 or 2.7, it 

19 isn't as important as just to have something 

20 we can all agree on. 

21 Is there any -- Are there any 

22 other downsides to having this voltage which 

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1 may be lower? I know that damaging the battery 

2 is an option. But if manufacturers put in 

3 protection circuitry, it will cut off the 

4 discharge if it goes too low. Are there any 

5 other concerns that DOE should be aware of? 

6 MR. MORRIS: Well, I mean Ralph 

7 brought up the fact that there is some design 

8 it in. But there are the opposite of that. 

9 There are some that don't design it in and if 

10 you discharge too much then the battery won't 

11 recover and when you do then you can't get a 

12 measurement. 

13 So is there a danger going too 

14 low? Yes. You could over-stress the battery. 

15 On the other hand, you don't want to go too 

16 high. So I mean this is not an easy 

17 situation. I just think that adherence to 

18 sort of an arbitrary table like this is not 

19 accurate and it's unfortunately going to -- 

20 If you're continuing to try to get 

21 to, for instance, a 2.5 on some of these 

22 things like lithium polymers on many batteries 

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1 you're not going to get there other than 

2 damaging the battery. You're not going to get 

3 there because the battery manufacturer says 

4 three and that's it. 

5 MR. BROOKMAN: What would you 

6 suggest the Department do in this case? 

7 (Off the record comments.) 

8 MR. ALBERT: See, he set me up. 

9 MR. BROOKMAN: Larry, thoughts on 

10 this? 

11 MR. ALBERT: Yes. A couple things 

12 that should be considered. If you're talking 

13 about a seven year review period for a test 

14 procedure, you're talking about technology as 

15 vibrant, I guess, as is rechargeable cell 

16 technology. It's probably fairly likely that 

17 there will be some new category of cells that 

18 will crop up in that interval. Right? 

19 And it seems like you should have 

20 sort of approach to handle cells that weren't 

21 contemplated at the time of the writing of the 

22 test procedure. And certainly some of this 

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1 again depends upon what was spoken about 

2 before which is if the cutoff voltage is such 

3 that as Paul pointed out it just provides sort 

4 of a stable reference point to make this round 

5 trip around and the capacity of the battery is 

6 effectively, or errors in the capacity of the 

7 battery are effectively removed by some future 

8 calculation that occurs during the standards 

9 phase, then the likelihood that you would 

10 essentially skew the results of the efficiency 

11 measurement by, let's say, picking a 

12 terminating voltage that was higher than maybe 

13 the ideal termination voltage, it would 

14 relatively small. 

15 If, however, the objective 

16 equation you guys settle on during the 

17 standards phase is highly dependent upon the 

18 absolutely capacity measurement, then 

19 obviously it could make a great deal of 

20 difference. It could probably exceed the two 

21 percent error that Paul was speaking about 

22 before in the sort of like the standard error 

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1 in the test procedure. 

2 And so in those cases the 

3 challenge becomes a little bit tougher. Plus 

4 we know that cells have a certain amount of 

5 variation with respect to capacity, part-to6 part. And so right there, there's a whole 

7 issue of error associated with the 

8 measurement. 

9 I think if the language of the 

10 test procedure were to, for example, accept 

11 cell manufacturer published values for 

12 recommended cutoff voltages it might be 

13 higher. And if the objective equation you 

14 guys come up with later on is somewhat 

15 independent of that the absolute value of the 

16 capacity is then it probably wouldn't make any 

17 difference if you could play it safe by 

18 permitting future chemistries to be considered 

19 under the test procedure without having to 

20 revise it. And at the same time it wouldn't 

21 materially affect the accuracy of the end 

22 result. So that's the question. 

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1 MR. BROOKMAN: Wayne, follow on. 

2 MR. MORRIS: I think that from 

3 what I remember reading in the popular press 

4 that U.S.'s plans to spend somewhere in the 

5 neighborhood of $5 billion in battery 

6 chemistry development mainly because of the 

7 electric vehicles and hybrid electric 

8 vehicles. That's Bs and not Ms as in the 

9 trader in Wall Street. I know the difference. 

10 But I think that could lead to a 

11 whole lot of new battery chemistries that will 

12 be out within the next year or two. And 

13 certainly if you read some of the prospectuses 

14 from some of the battery manufacturers these 

15 days these things are rapidly coming out. And 

16 the automobile industry is desperate for new 

17 chemistries, which is likely going to trickle 

18 down and be actually used in household 

19 products. I mean it's hard to believe, but 

20 many of the HEVs that are out there today use 

21 banks of batteries that don't look any 

22 different than what's in your vacuum cleaner. 

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1 I think it's imperative that we 

2 try and look at this. I think that Larry's 

3 point about the seven-year review cycle is 

4 what's going to catch if that's what we're 

5 after. 

6 I think that maybe we could work 

7 on some kind of language that would allow the 

8 manufacturer in their technical specification. 

9 We talked about having a spec sheet. Maybe 

10 if the manufacturer has available a spec sheet 

11 that they could in fact give what the end of 

12 the discharge voltage is for that particular 

13 product recommended, then that could be used 

14 for the testing purposes and you'd be able to 

15 get around some of these problems. I'm not 

16 sure that's perfect, but it's a heck of a lot 

17 better than just taking a table out of an IEC 

18 document that's probably more than seven years 

19 old. 

20 MR. BROOKMAN: Ralph. 

21 MR. HUDNALL: Ralph Hudnall with 

22 Euro-Pro. Just to give you an idea what we're 

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1 looking at is, how the problem kind of shakes 

2 up. I'm a member of ASTM's F11 Committee for 

3 Vacuum Performance and one of the 

4 subcommittees of that group is talking about 

5 battery rechargeable vacuum cleaners and 

6 performance testing on those products. We're 

7 struggling with this same issue right now, and 

8 that's just within the category rechargeable 

9 vacuum cleaners, how to determine the cutoff 

10 voltage. 

11 And I can imagine how bad it would 

12 be -- how difficult it would be with 

13 everything that's battery chargeable in the 

14 country. So it is a tough nut to crack. But 

15 I feel confident we'll get there. It's just 

16 going to take some time. 

17 MR. BROOKMAN: Okay. Other 

18 comments on these issues? 

19 (No audible response.) 

20 Mike. 

21 MR. VLADIMER: Excellent. Thanks 

22 for that discussion on end of discharge 

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1 voltage. 

2 So I will now move onto another 

3 issue which is how long the test takes. As 

4 Matt mentioned earlier, one of the key metrics 

5 coming out of this is an E , a 24-hour energy 

 24

6 measurement that accounts for both charge and 

7 maintenance mode. 

8 DOE is considering an optional 

9 shortened charge and maintenance mode test. 

10 The net result would still be an E 

 24

11 measurement, but the time in the lab would be 

12 reduced. The reasons for this are so that the 

13 majority of the battery chargers that DOE has 

14 tested have 13 hours or -- take 13 hours or 

15 less to charge. And once they do get into 

16 maintenance mode there's little new 

17 information. It's basically just a steady 

18 state. So it would be very easy to predict 

19 how much energy they would consume over 24 

20 hours. 

21 And again this comes to the idea 

22 of lessening burden on the laboratory, making 

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1 it easier for manufacturers to still provide 

2 the same results, the same useful information. 

3 How would it work? The way it 

4 would work is that the technician would run 

5 the test for at least four hours. If over an 

6 hour the charger is consuming power in steady7 state, then that could be considered the 

8 maintenance mode power and then that would be 

9 projected out for the remaining amount of 

10 time. So what you see here as E is that 

 charge

11 initial amount of energy consumed up until 

12 steady-state. And then once there's a steady13 state power consumption just take that power 

14 and multiply it out by the remaining time and 

15 then you'll get a number that's very 

16 comparable -- that's a projected E that's 

 24

17 very, very close to what it would have been 

18 had the technician run the full measurement 

19 for the full 24 hours. 

20 Just to show graphically what that 

21 would look like when it works is this 

22 situation. Here is the test result for a 

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1 product. It started out at about consuming 40 

2 watts while it was charging the battery. 

3 After about two hours, you can see that the 

4 input power of the battery dropped 

5 significantly. And then it was in maintenance 

6 mode where it's consuming maybe just a watt or 

7 two. 

8 The technician can just look at 

9 what's going on from hours four to five and 

10 say, okay, that's a steady-state power 

11 consumption. Let me just project that out 

12 over the rest of the 24 hours and calculate 

13 E . 

 24

14 The reason that this is a 

15 consideration and not a proposal is because 

16 there are possible complications that might 

17 arise and here's an example of that. So in 

18 this case, you can see that the battery 

19 charger, what we call, “woke up” in the middle 

20 of the maintenance mode. After about 10 to 11 

21 hours, it just turned on. We don’t know 

22 exactly what functionality was going on. It 

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1 might have been topping off the battery. 

2 There are a number of different things that 

3 could happen. 

4 But what matters is that if you 

5 would have applied the same methodology here, 

6 after five hours you could have then tried to 

7 project out what the E would have been, and 

 24

8 it wouldn't have accounted for these wake-up 

9 periods. In this exact example, there was a 

10 6.5 percent discrepancy between what you would 

11 have predicted and the energy actually 

12 consumed including these wake-up periods. 

13 As the issue says, DOE is 

14 proposing using a 24-hour charge and 

15 maintenance energy measurement consistent with 

16 the CEC test procedure, but is inviting 

17 interested parties to comment on incorporating 

18 an optional, shorter test period. Any 

19 thoughts on this? 

20 MR. BROOKMAN: Larry. 

21 MR. ALBERT: A question to Mike as 

22 far as the referee test, if there was a 

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1 dispute or anything like that, it would still 

2 be the 24-hour measurement. 

3 MR. VLADIMER: Yes, I would think 

4 so. Yes. 

5 MR. ALBERT: Right. So I guess my 

6 position would be you know while it's nice to 

7 have a shorter test when it gets down to it in 

8 terms of verification and stuff like that that 

9 it's still going to get down to the 24-hour 

10 test. Why would you go and take the chance of 

11 testing using any other method other than 

12 that? Right? I mean that would be kind of 

13 the stance that we'd take is that I would have 

14 data that I could produce to demonstrate they 

15 did the test correctly. Right? 

16 MR. VLADIMER: Matt, I think, 

17 wants to respond. 

18 MR. MALINOWSKI: Sure. It would 

19 be really at the manufacturer's discretion 

20 since DOE does not know in advance how a 

21 battery charger operates. And a manufacturer 

22 does. Your designers say that it doesn't wake 

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1 up. There might be some advantage to doing a 

2 shorter test. But if you say there isn't any 

3 -- 

4 MR. PETROLATI: Let me also add. 

5 Vic Petrolati, Department of Energy. What 

6 Larry proposed was our original proposal that 

7 we had changed before the notice of proposed 

8 rulemaking allowing the manufacturer to use 

9 the shorter test for certification and the 

10 indication that we would always use the longer 

11 test for enforcement. 

12 But I will have to say that based 

13 on the limited test results we have right now 

14 the variability associated with potentially 

15 using the shorter test is a major concern of 

16 ours. And that's only one product that we 

17 found that had this problem and results of 6.5 

18 percent are only from that one product. So we 

19 have no clue at this point what the 

20 variability might be by using the shorter test 

21 and are very reluctant without some 

22 significant data to go to a shorter test at 

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1 this point in time. 

2 MR. BROOKMAN: Wayne. 

3 MR. MORRIS: Thanks, Vic, for 

4 that. This is Wayne Morris. Thanks, Vic, for 

5 the clarification on that. 

6 Yes, obviously it's one of those 

7 things that you weigh the shorter test time 

8 and the burden and the testing laboratory when 

9 you're trying to do hundreds of these 

10 different configurations and especially with 

11 some of the ones that we talked about 

12 previously that Matt talked about where you're 

13 going to have to run some of these tests three 

14 days or more because of the configurations of 

15 the battery and the charger versus the 

16 accuracy issue and where do you come down on 

17 that. 

18 I guess the only thing that we've 

19 been able to suggest is for those 

20 manufacturers that choose to run this shorter 

21 because they believe that their unit in fact 

22 does what you showed in your previous slide -- 

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1 I guess it's slide 56 -- that it drops and 

2 stays down at that lowest level. If that's 

3 recorded somewhere in the test record, because 

4 according to part of this it is that you're 

5 going to keep a test record of what was done 

6 during your original certification testing, 

7 that if that denotes the method that you used, 

8 for instance, a shortened test procedure or 

9 something along that line, and that were then 

10 available to whomever is going to do the 

11 verification-type testing -- that's what you 

12 use -- then at least assuming you don't have 

13 the configuration of slide 57 and the 

14 manufacturer did it in good faith and thought 

15 that he was getting the value, the E 

 24

16 measurement in verification should show the 

17 same thing. And if it doesn't they can 

18 discuss that situation. 

19 But we would certainly agree with 

20 what you said, Vic, that we don't want to see 

21 those kind of error rates therefore for any of 

22 the chargers that would have this type of 

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1 pulsing, which is another subject I know. But 

2 basically that's the same thing we're talking 

3 about here is a pulse type maintenance mode 

4 charge cycle that we've got to err on the side 

5 of the accuracy. And if that means going all 

6 the way out to an E well then -- 

 24

7 As Larry said, if you know that 

8 the referee and you know that the verification 

9 is going to be done at E , why would a 

 24

10 manufacturer even suggest going to a smaller 

11 one? Well, it could be that they believe 

12 significantly because of testing that they've 

13 done, because of multiple repeated testing, 

14 that they get exactly the same value whether 

15 they do E or shorter. Then maybe they would 

 24

16 choose to do that. 

17 I could think that for some of not 

18 of the manufacturers of the end product, but 

19 manufacturers of battery chargers that are 

20 producing them on high volume and are putting 

21 them in catalogs and that type of thing -- for 

22 them it might be more valuable to do shorter 

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1 test cycles if they know that every single 

2 time they're going to get the same thing. And 

3 they ran a sampling in order to make sure that 

4 -- I don't see why they couldn't -- it needs 

5 to be denoted in the test record. And 

6 therefore I would suggest to you that the test 

7 record needs to align itself with that and 

8 allow the manufacturer to put that in there if 

9 the Department so chooses to allow that 

10 provision. 

11 Thanks. 

12 MR. BROOKMAN: Wayne, does AHAM 

13 have the kind of data that Vic was referring 

14 to? 

15 MR. MORRIS: No, we don't. No. 

16 Thank you. 

17 MR. BROOKMAN: Just thought I'd 

18 inquire. Okay. 

19 Yes, Paul. 

20 DR. BENDT: I would also -- Paul 

21 Bendt with Ecos -- add that the main 

22 justification for this is reducing testing 

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1 burden. And when we did a large number of 

2 tests, we did not find the 24-hour procedure 

3 to be burdensome. 

4 In particular, we were basically 

5 doing one shift a day on the testing bench and 

6 the five hours that's required for even the 

7 minimum shortest test still limits the 

8 technician to doing one test in a day. If you 

9 set up one test in a day, it's not additional 

10 problem to just let the recording equipment 

11 run overnight. You still get to start a test 

12 the next day. 

13 And so your through-put on tests 

14 really doesn't change even if you record for 

15 the full 24 hours. The equipment is running 

16 24 hours while the technician goes home and 

17 sleeps. So it really doesn't make that much 

18 savings in testing burden for the questions 

19 that it creates in accuracy and repeatability. 

20 MR. BROOKMAN: Thank you. 

21 Wayne. 

22 MR. MORRIS: Paul, that's probably 

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1 true in a consulting kind of situation where 

2 you're not up against a wall of trying to get 

3 a number of products through a laboratory in a 

4 very short period of time in order to make 

5 your production run. But there are some 

6 manufacturers where the charge time is really 

7 down to three or four hours. And for them to 

8 run, I mean they may be able to get multiple 

9 cycles within a normal testing day if it's 

10 three or four hours rather than have to wait a 

11 full 24 on every individual one. 

12 So for them it might make some 

13 sense if they know in point of fact that slide 

14 56 is what you have and you're going to have 

15 that every time because of your circumstance. 

16 Then I think they could see a value in that. 

17 I think that the option is still a 

18 very good one to consider with the 

19 understanding that E is going to be your 

 24

20 referee and that the test procedure or test 

21 record is going to show what you used. I 

22 think that it could be a very acceptable 

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1 methodology and not waste a lot of test time. 

2 Thanks. 

3 MR. VLADIMER: Excellent. So I 

4 will then proceed to the last slide I'm going 

5 to present, the last issues, which are 

6 actually non-issues. So in the framework 

7 document public meeting back on July 16th last 

8 year, stakeholders had mentioned issues they 

9 wanted DOE to deal with. We just want to 

10 acknowledge them explicitly in the 

11 presentation. But they are not dealt with in 

12 the NOPR. 

13 One of them was incorporating 

14 usage profiles. I know this was already a 

15 topic of discussion today. But as Vic 

16 mentioned, DOE's intention is to deal with 

17 that in the standard. 

18 Another issue was that DOE 

19 proposed measuring the output energy from the 

20 battery. That was a consideration, but DOE is 

21 not intending to go forward with that anymore. 

22 And then the last thing is various 

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1 depths of discharge. Of course, one of the 

2 goals of the test procedure is to do something 

3 that is as comparable as possible to reality. 

4 And most people don't discharge their 

5 batteries all the way every single time. But 

6 the challenges that would come from 

7 incorporating different depths of discharge 

8 into test procedure would be very, very 

9 burdensome, I think, in terms of how 

10 complicated it would be. It wouldn't return 

11 as much value in terms of trying to quantify 

12 how efficient the battery charger is. Because 

13 of that, DOE is not going to use different 

14 depths of discharge and only be using the full 

15 depth of the discharger. 

16 Any questions on these? 

17 MR. PETROLATI: Mike, Vic 

18 Petrolati, DOE. 

19 MR. VLADIMER: Sure. 

20 MR. PETROLATI: I may have heard 

21 it wrong, but the statement under two is we 

22 are not considering directly measuring the 

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1 output energy of the battery charger. I 

2 thought you might have said the battery. 

3 MR. VLADIMER: I'm sorry. Yes, 

4 the battery charger. I misstated. 

5 MR. BROOKMAN: Thanks for 

6 listening carefully. 

7 Larry. 

8 MR. ALBERT: I understand the 

9 Department's position with respect to putting 

10 usage profiles into the standard rather than 

11 the test procedure. I was wondering whether 

12 it would be possible for the test procedure to 

13 indicate that fact that the data produced by 

14 the test procedure is intended to be used with 

15 usage profiles that would be available in 

16 other documentation. The fear here is that 

17 the data could be misused from this test 

18 procedure by other jurisdictions and other 

19 people not understanding that these are 

20 intended to be sub-elements of an overall 

21 picture of energy usage for the chargers. 

22 MR. PETROLATI: Okay. Larry, we 

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1 will consider that as a comment and I need to 

2 discuss with our legal counsel the whole 

3 concern over representation. 

4 MR. ALBERT: Right. 

5 MR. PETROLATI: And whether or not 

6 there is an issue associated with that by not 

7 incorporating the usage profiles. But either 

8 way, I think that is a good comment that we 

9 will consider. 

10 MR. ALBERT: Thank you. 

11 MR. PETROLATI: Yes. 

12 MR. BROOKMAN: Thanks. 

13 Wayne. 

14 MR. MORRIS: Well, since this 

15 appears to be, if I understood you, Michael, 

16 the last gasp at dealing with battery charger 

17 test procedure, I think there are a number of 

18 still open issues that we haven't addressed. 

19 COURT REPORTER: Sir, can you use 

20 the microphone? 

21 MR. MORRIS: Sorry about that. 

22 MR. BROOKMAN: Wayne, thank you. 

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1 MR. MORRIS: Yes, Wayne Morris. 

2 If this is our last chance at looking at this, 

3 I do think that we need to talk a little bit 

4 about this depth of discharge issue. The 

5 Department's statement I believe is that due 

6 to the lack of support for measurement of 

7 battery charger energy consumption while 

8 charging batteries with different depths of 

9 discharge, DOE is not incorporating such 

10 measurement into today's proposal. That's 

11 what I understood. 

12 Originally, there was the 

13 discussion about the 40 percent depth-of14 discharge rate or, excuse me, measurement. 

15 Where does that stand? Are we still going to 

16 use that 40 percent depth of discharge level? 

17 MR. VLADIMER: That's -- I'll just 

18 quickly answer. That's what I'm trying to say 

19 is that 40 percent is no longer under 

20 consideration. Matt, if you want to clarify 

21 that. 

22 MR. MALINOWSKI: I think based on 

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1 the comments the Department received during 

2 the framework document meeting the consensus 

3 was that you can do a full discharge, 100 

4 percent depth of discharge, and then do any 

5 sort of modeling of behavior after the fact 

6 and that's a good compromise between having to 

7 do multiple tests at different depths of 

8 discharge and still getting a representative 

9 picture of actual energy consumption. 

10 MR. MORRIS: We would agree with 

11 that and I just wanted to make sure that was 

12 stated for the record and appreciate that the 

13 Department not only listened to the comments, 

14 but thought that through. Because for some of 

15 these battery configurations how do you know 

16 what’s 40 percent of X and you can't know X. 

17 It begins a little bit of an interesting 

18 situation. 

19 One of the other elements I 

20 believe is the issue of equalization. Can you 

21 comment about that situation on equalization 

22 and the measurement of equalization? I mean 

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1 it's a definition that you put into the test 

2 procedure and we're having trouble 

3 understanding where it's used. 

4 MR. MALINOWSKI: Sure. Again, 

5 this is Matt Malinowski. Equalization, just 

6 for everyone's reference, is a part of a 

7 battery charging cycle that may not always 

8 occur but involves overcharging the battery in 

9 such a way to balance the voltage across all 

10 the cells. 

11 The performance of a battery12 operated product is hampered when the cells 

13 are out of balance, meaning that one cell will 

14 reach its end of discharge before the others. 

15 So you do not get full capacity out of the 

16 pack. 

17 And equalization depending on the 

18 design of the charger can either be included 

19 during every active phase or may be specially 

20 -- the user may have to specially select that 

21 the charger do equalization in a given charge 

22 test. So DOE's proposal does not explicitly 

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1 address equalization. Rather if the charger 

2 designers decide to include equalization in a 

3 typical average charge, then it is included. 

4 If it's something that a user must select, 

5 then that energy, the equalization energy, is 

6 not measured according to the proposed test 

7 procedure. 

8 MR. BROOKMAN: Ralph. 

9 MR. MORRIS: I think I get that. 

10 MR. BROOKMAN: Let's hear from 

11 Ralph and we'll return to you. 

12 MR. HUDNALL: Ralph Hudnall with 

13 Euro-Pro. We're kind of going backwards a 

14 little bit, but back to the depth of 

15 discharge. If I understand it correctly the 

16 plan is to discharge the batteries completely. 

17 I would go back to my comment about 

18 manufacturers who have circuitry in their 

19 products that protect the batteries. Would 

20 they get I'll say an incorrect efficiency 

21 rating by discharging their batteries 

22 completely? When in actual practice the 

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1 consumer would never discharge them that far 

2 because they're protecting the battery. 

3 MR. MALINOWSKI: I think you do 

4 point out correctly. A limitation of the test 

5 procedure is that the actual use may differ 

6 from what's measured in the laboratory and as 

7 long as that's modeled somehow during the 

8 assessment for the potential of energy 

9 standards, then I think that can be -- DOE can 

10 correct for that. But to do that DOE would 

11 welcome any data on actual depths of discharge 

12 across products. 

13 MR. BROOKMAN: Are you saying that 

14 the manufacturer specifies it that way? 

15 MR. HUDNALL: No. What I'm 

16 saying, there are products without 

17 manufacturer specification that when the 

18 consumer uses them I've seen a competitor's 

19 product, a competitor's hand vac, that runs 

20 for five minutes and that's all. It does not 

21 discharge the batteries anywhere near the 

22 level of a complete discharge. 

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1 We think it's because of 

2 protection of the battery. They may have 

3 another plan in mind. I don't know because 

4 it's a competitor. So I would feel that if 

5 you discharge their batteries fully they would 

6 get a better efficiency rating than the 

7 consumer would actually see because they would 

8 only discharge the battery a third of the way 

9 in actual practice. Whereas if I don't have 

10 that in my -- if I don't have a circuit like 

11 that in my system, then my batteries are going 

12 to get a full discharge which they should 

13 because the consumer could discharge them 

14 further. 

15 But with the competitor's unit, 

16 the consumer couldn't discharge them that far. 

17 I'm concerned about how that then is going to 

18 bias one way or the other the efficiency of 

19 the product. They may get a better rating 

20 than they deserve because the consumer can't 

21 discharge that far. 

22 MR. PETROLATI: Ralph, do you have 

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1 -- VIC Petrolati, DOE. Do you have a 

2 recommendation as to how we should account for 

3 that in the test procedure? And if you do, 

4 written comments. 

5 MR. HUDNALL: Will do. 

6 MR. PETROLATI: Yes. 

7 MR. HUDNALL: I'll think about it 

8 and I'll get you something. 

9 MR. PETROLATI: Thank you. 

10 MR. BROOKMAN: Let me go to Larry 

11 and then I'll come back to you, Paul. Larry. 

12 MR. ALBERT: Just a point of 

13 clarification. In the proposed test procedure 

14 as in the CEC test procedure, there's a 

15 provision that addressing the UUT terminating 

16 the discharge early. Right? And so it's in -

17 - it's on page 16984 first column way on the 

18 bottom, number three. And it says, when the 

19 end of discharge voltage is reached or the UUT 

20 circuitry terminates the discharge -- 

21 MR. PETROLATI: Okay. 

22 MR. ALBERT: -- the test battery 

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1 shall be returned to an open circuit 

2 condition. So that' in there. My assumption 

3 in reading that was what it was supposed to be 

4 that basically there's circuitry present. It 

5 did do an early termination and that provided 

6 the reference point. And to Paul's comments 

7 or discussion earlier about the round trip, 

8 you know if you terminate down to a 

9 predetermined value, even if that 

10 predetermined value is established in the 

11 circuitry around the cells and then you return 

12 back to that same point, you effectively have 

13 done all the in and out piece. Right? 

14 MR. BROOKMAN: Paul, please. 

15 DR. BENDT: Yes. Paul Bendt, Ecos 

16 and representing PG&E. 

17 The intent with the CEC test 

18 procedure, it's partly the phrase that Larry 

19 just picked up on. But there's another phrase 

20 which is the one I put up on the slide earlier 

21 that if DOE takes the correct language from 

22 the CEC on protection circuitry the correct 

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1 language states that you do your discharging 

2 after the protect circuitry. So you would 

3 have the battery. Then you would have the 

4 protection circuitry and your product. You 

5 would actually do the discharge between the 

6 protection circuitry and the product. 

7 Usually the protection circuitry 

8 is included in the battery pack. So if you're 

9 just measuring the output of the battery pack 

10 you're actually measuring with the protection 

11 circuitry in place. 

12 This language was put in because 

13 the manufacturers of lithium ion batteries did 

14 not want testing labs opening their battery 

15 packs to get direct access to the battery 

16 terminals themselves fearing that they could 

17 get hazardous situations and recommended that 

18 always the battery pack be left intact and 

19 that the testing be done by measuring the 

20 output from the battery pack. 

21 So if we think for a minute about 

22 how that protection circuitry is going to 

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1 work, the battery voltage will drop and it 

2 will drop to whatever value the manufacturer 

3 set the protection circuitry at and maybe for 

4 a particular battery pack that's 3.1 volts. 

5 So the battery goes down to 3.1 volts. Then 

6 the protection circuitry kicks in and shuts 

7 off the load. So it stops delivering power 

8 from the battery to the load. 

9 At that point, what happens to the 

10 voltage that our tester is measuring? It goes 

11 all the way smoothly down to 3.1 volts. Then 

12 it suddenly drops to zero. 

13 When it drops to zero, it passes 

14 the 2.75 or 2.5 volt threshold very quickly 

15 and even if you say we're stopping the testing 

16 at 2.5, in fact when that protection circuitry 

17 drops in that does kick the voltage below the 

18 test -- the signal to stop testing. So even 

19 though the test says 2.5 at the end of the 

20 battery pack, the protection circuitry is, 

21 actually as soon as you pass 3.1, it's 

22 dropping the output voltage below the 2.5, and 

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1 the test effectively stops. 

2 That's the conception in here that 

3 when the circuitry terminates the discharge -- 

4 that the way the circuitry terminates the 

5 discharge is by disconnecting the voltage that 

6 you're trying to discharge from. And then 

7 your discharge has to stop because you no 

8 longer have any voltage and any circuit coming 

9 out of the battery pack. 

10 And I'll note that the incorrect 

11 language that did end up in the CEC and that I 

12 put on the screen earlier that I'm hoping DOE 

13 will skip actually states it the other way. 

14 It actually states that if there's protection 

15 circuitry you measure off the battery itself. 

16 And we would really like that rewritten that 

17 when there's protection circuitry you measure 

18 after the protection circuitry. So I don't 

19 think it's a controversial issue. We just 

20 want to make sure the language gets corrected 

21 all the way through. 

22 MR. BROOKMAN: Okay. 

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1 Larry. 

2 MR. ALBERT: We agree. We agree 

3 in concept as to what's going on. I guess 

4 again it gets back to this point that if your 

5 question is “Do you absolutely need an 

6 accurate value of battery capacity for judging 

7 the energy efficiency of the system or not,” 

8 the concept of the round trip, it doesn't 

9 matter because you're discharging down to a 

10 point. You're charging fully and then you go 

11 back and you discharge down to the same point 

12 or the other way around, whichever way it 

13 works out. 

14 But the long and short of it is 

15 that all of that, the actual capacity, kind of 

16 comes out of the equation. If that's, in 

17 fact, what happens downstream with respect to 

18 the standard then the issue as to whether 

19 you're overstating or understating the actual 

20 capacity of the battery pack becomes sort of 

21 immaterial. Right? 

22 MR. BROOKMAN: Okay. Thank you. 

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1 That seems complete to me. Yes? 

2 MR. VLADIMER: Excellent. 

3 MR. BROOKMAN: Okay. Keep going. 

4 MR. VLADIMER: So just to rehash 

5 everything we've touched on battery charger 

6 test procedure. We've talked about the scope 

7 and the definitions, what's going to be 

8 covered and what do we mean by the exact 

9 terms, how will we set up the lab and the test 

10 apparatus. And we've just concluded the test 

11 measurement section which describes exactly 

12 what the technician will be needing to do. 

13 There have been great comments so 

14 far. Thanks to everybody. And now I'll hand 

15 off to Matt Malinowski who will talk about 

16 changes to the EPS test procedure. 

17 MR. MALINOWSKI: Thank you, 

18 Michael. My name again is Matt Malinowski. 

19 I'll be finishing up today's presentation by 

20 going through some of the other items in the 

21 proposal that are not related specifically to 

22 battery chargers and these will be the standby 

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1 and off mode test procedures as well as the 

2 single-voltage and multiple-voltage EPS test 

3 procedures. 

4 Again, you've seen this slide. 

5 It's all the Department's test procedures for 

6 BC and EPS. We'll be dealing with standby and 

7 off mode test procedures which apply to all 

8 the products, Class A, non-Class A, EPS as 

9 well as BC. 

10 And just as an illustration of the 

11 standby and off mode test procedure, these 

12 procedures were I guess incorporated following 

13 the standby and off mode test procedure 

14 rulemaking in March of last year. And standby 

15 mode illustrated at the top involves the 

16 charger or EPS connected to its input, 

17 typically AC mains for EPS -- always AC mains 

18 for EPS sometimes for BC, and its load or 

19 battery disconnected as illustrated on the 

20 top. For EPS or BC that have manual on/off 

21 switches which is a small proportion, that 

22 switch is set to on and the energy into the 

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1 device is measured. 

2 Off mode is a similar setup. 

3 Charger or EPS connected to input voltage and 

4 disconnected from the battery. But its on/off 

5 switch is set to off. This only applies to 

6 chargers -- to BCs or EPSs that have on/off 

7 switches which is a very small proportion of 

8 them. 

9 Any questions on standby and off 

10 modes? 

11 MR. BROOKMAN: Yes, Paul. 

12 DR. BENDT: Paul Bendt. And again 

13 we would say for a large number of battery 

14 chargers that they could have an off mode even 

15 if the battery is still connected. There are 

16 battery chargers with an on/off switch and we 

17 believe the off mode should be tested even if 

18 the battery cannot be disconnected. 

19 MR. MALINOWSKI: Thank you. 

20 So I guess that's one comment. 

21 The Department is also seeking comment on its 

22 proposal to shorten the standby and off mode 

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1 test procedure, the duration of the 

2 measurement, and both the tests that I showed 

3 on the previous slide require a one-hour 

4 measurement period. And based on comments 

5 that DOE received during the NOPR public 

6 meeting for standby and off mode it is now 

7 proposing to shorten that test procedure to a 

8 30-minute warm-up period followed by only a 

9 ten-minute measurement. 

10 And the Department would welcome 

11 comments on this proposal. 

12 MR. BROOKMAN: No comments? 

13 (No audible response.) 

14 No comments on that. Okay. And, 

15 of course, if you change your mind you can 

16 submit them in writing. Okay. 

17 MR. MALINOWSKI: So absent any 

18 comment, I'll move onto proposed possible 

19 modifications to the single-voltage EPS test 

20 procedure which you can see applies to all 

21 Class A EPSs as well some of the non-Class A 

22 EPSs such as the high power, medical, and EPS 

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1 from motor-operated battery products. 

2 I'd just like to mention first 

3 that all the issues that will be discussed in 

4 this section are only issues, amendments, that 

5 DOE is only considering. So there are no set 

6 proposals. These are just possible 

7 ambiguities that DOE noticed in the test 

8 procedure and would welcome stakeholder 

9 comment on before proceeding. So if 

10 stakeholders feel that some of these are 

11 issues that will impact the test procedure, 

12 DOE encourages stakeholders to please speak up 

13 either at the meeting or in writing so that 

14 the Department can act on some of these. 

15 And again these issues only 

16 pertain to some EPSs, in particular, ones that 

17 communicate with their loads prior to 

18 operation, some EPSs that limit their output 

19 current below that listed on their nameplate, 

20 and finally EPSs, such as some high power 

21 EPSs, that list two possible nameplate output 

22 currents. 

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1 Again, the vast majority of EPSs 

2 would be tested as before according to the 

3 current EPS test procedure which has been 

4 adopted internationally. Some of these 

5 possible amendments would only apply to this 

6 limited set of EPSs for which some ambiguity 

7 may exist. 

8 I'll begin with the first set, 

9 EPSs that communicate with their loads. 

10 Again, DOE is considering amending its test 

11 procedure to permit testing of these EPSs. 

12 Currently the test procedure requires 

13 disconnection of the EPS, disconnection of all 

14 data lines leading to the EPS. And this is a 

15 problem in some cases such as this USB16 compliant EPS which requires the data 

17 connection with the load in order to operate. 

18 It must first identify the load. The load 

19 must request that the EPS provide current. 

20 And only then will the EPS operate. 

21 And this is again small 

22 substantive products, but they do exist. And 

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1 they may not operate once they've been 

2 disconnected, the data lines have been 

3 disconnected. 

4 MR. BROOKMAN: Larry. 

5 MR. ALBERT: Larry. Just a 

6 clarification, Matt. The scope of Class A 

7 EPSs right now covers single-voltage output 

8 EPSs. Right? But is that identified by 

9 having only a pair of interconnections? 

10 MR. MALINOWSKI: It's identified 

11 by having one pair of interconnections that 

12 provide power. 

13 MR. ALBERT: Okay. 

14 MR. MALINOWSKI: So it does 

15 include any data lines. 

16 MR. ALBERT: Thank you. 

17 MR. MALINOWSKI: And therefore DOE 

18 is considering amending its test procedure to 

19 allow manufacturers to provide an appropriate 

20 test fixture to test these EPSs. And the 

21 Department seeks comment on this proposal as 

22 well as how to specify the test fixture such 

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1 that it will lead to repeatable tests and 

2 appropriate tests. 

3 MR. BROOKMAN: Comment? No 

4 comments. 

5 Larry. 

6 MR. ALBERT: Just we don't do 

7 this, but do you know there's a USB 2.0 

8 standard out there? Right? And they describe 

9 the interface and the electrical requirements 

10 for the USB 2.0 connections. So I mean if 

11 you're only talking about USBs, then you could 

12 probably utilize that. 

13 MR. MALINOWSKI: Yes. The whole 

14 problem with these ESPs is that a manufacturer 

15 can do pretty much anything under the sun. So 

16 USB is just an illustration that folks here 

17 are familiar with. We found ones where 

18 there's no way to tell how to make this power 

19 supply operate. Only when it's connected to 

20 its intended load would it operate. So how to 

21 test that. 

22 MR. BROOKMAN: No additional 

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1 comment? 

2 (No audible response.) 

3 Okay. 

4 MR. MALINOWSKI: Next I'll speak 

5 about EPSs with output current limiting. 

6 There exist some EPSs that limit their output 

7 at less than the nameplate output current. 

8 And just as a reminder the EPS test procedure 

9 requires testing at 25, 50, 75 and 100 percent 

10 of nameplate output current. That's the 

11 current that's listed on the label of the EPS. 

12 So if the EPS cannot output 100 percent of 

13 nameplate output current, it's not possible to 

14 test this last loading point. 

15 Therefore DOE is considering some 

16 possible amendments to address this case. One 

17 would be to exclude this effective loading 

18 point from the average, in this case, only 

19 average the results at 25, 50, and 75 percent. 

20 Next would be to shift the loading point so 

21 that it is no longer affected. So move that 

22 100 percent loading point to 85 or wherever 

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1 the EPS is still operating normally. And 

2 finally report the efficiency at the affected 

3 loading point as zero percent and average it 

4 in with the rest. 

5 MR. BROOKMAN: Larry. 

6 MR. ALBERT: Larry again. And 

7 maybe Paul can help with this. It seems that 

8 when Ecos was developing these requirements 

9 they tested a whole bunch of EPSs and it seems 

10 strange that this problem is coming up now 

11 when all that background work was done back 

12 then. Paul, do you have any information on 

13 this I mean as to whether this was found back 

14 then or not? Because I thought it was 

15 something that was addressed at the time in 

16 California. 

17 MR. BROOKMAN: Paul. 

18 DR. BENDT: Yes. I'm Paul Bendt. 

19 I was not part of the EPS testing that led to 

20 the EPS standard. So I don't know how much of 

21 it was encountered at that time. 

22 MR. ALBERT: Yes. So it just 

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1 seems to me that if the standard is set up to 

2 look at nameplate as the absolute limit and 

3 you conduct the test at that point the problem 

4 is you're trying to load the thing down past 

5 its capability and maybe going to a thermal 

6 shutdown or something like that. But it 

7 doesn't necessarily mean you couldn't, for 

8 example, put the resistance -- if you're using 

9 a resistive load, put a resistor out there 

10 that would represent the 100 percent load 

11 current and then just measure what you're got. 

12 Right? 

13 MR. MALINOWSKI: Okay. So just to 

14 clarify, Larry. You're proposing maybe a 

15 fourth alternative which is to report whatever 

16 efficiency you get at that 100 percent loading 

17 point even if it is zero or even if it's some 

18 much lower efficiency than you would expect 

19 from the rest of the curve. 

20 MR. ALBERT: Well, the whole test 

21 procedure was predicated upon using the 

22 nameplate as the scale for measurement. 

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1 MR. MALINOWSKI: Yes. 

2 MR. ALBERT: To go and deviate 

3 from that now seems to be to question the 

4 whole premise of what the EPS test procedure 

5 was. I think what you may be seeing is a 

6 function of the fact that we all use 

7 electronic loads typically to dial up the load 

8 current. And when you do that if you don't 

9 have the current it doesn't work. Right? 

10 But certainly if you used, for 

11 example, fixed resistor values that were 

12 designed to provide the load current at each 

13 of the points you could put that resistance 

14 out there and whatever it was with respect to 

15 efficiency at that point it was. 

16 MR. BROOKMAN: Michael. 

17 MR. VLADIMER: This is Michael 

18 Vladimer from Navigant Consulting. So, Larry, 

19 we've dealt with this problem. This is coming 

20 directly from our test lab. And the issue, 

21 first of all, you're asking about the history 

22 and I think my best guess as to why this is 

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1 coming up now as opposed to earlier is that 

2 we're talking about a mandatory standard as 

3 opposed to voluntary specification under 

4 ENERGY STAR. So before perhaps that 

5 manufacturers that this didn't happen with, 

6 they just didn't want to volunteer. 

7 But we've had a number of problems 

8 where I think in some ways this does come back 

9 to the charge control issue because we've 

10 tested wall adapters that didn't seem to have 

11 charge control. But they had some type of 

12 voltage collapse at maximum input/output 

13 current. So in some cases they just couldn't 

14 reach what their nameplate said that they 

15 could reach. 

16 So whether or not we use a current 

17 source or a current sink rather or a resistor, 

18 we couldn't physically get any measurement at 

19 that value. Or in some cases we got next to 

20 nothing like a one percent or a two percent 

21 efficient because the voltage just shot down 

22 and the EPS basically shut off. It's really -

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1 - this problem has really had -- or what 

2 Matt's presenting is really how to deal with 

3 those situations. It's a special case. It's 

4 not very common. 

5 I don't know offhand how many of 

6 the tests that we've done to date that that's 

7 happened to, but I can tell you it's a very 

8 small amount. But it really is a question 

9 when this rare occurrence happens and how do 

10 you deal with it. 

11 MR. ALBERT: In these cases you've 

12 had it happen like, were they always cases of 

13 wall adapters that were used in conjunction 

14 with battery chargers or something other than 

15 this strict EPS? 

16 MR. VLADIMER: I can't say. We 

17 can definitely look into that. It's good. I 

18 appreciate the comment. It would be a good 

19 thing for us to look into and to study a 

20 little bit closer when these issues occurred 

21 and with which products. 

22 But remembering loosely, I think 

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1 that there wasn't a clear correlation. DOE 

2 has purchased and tested power supplies that 

3 have been used, designed for specific 

4 products. Sometimes they're just generic. 

5 And if I remember correctly, some of these are 

6 just generic EPSs that they seem to have -- my 

7 guess as to what we saw in the lab was that 

8 they have some type of cutoff so that they 

9 didn't go over nameplate because if the thing 

10 is supposed to go up only to 100 percent you 

11 don't want to go higher. And maybe that there 

12 was just some error in that manufacturing run 

13 that would let them get up to 90 percent or 85 

14 percent, but just wouldn't let it get up to 

15 the full 100 percent. 

16 MR. BROOKMAN: Wayne. 

17 MR. MORRIS: A couple of things 

18 here. Wayne Morris. Sorry. As AHAM has 

19 pointed out on numerous occasions both to 

20 California and to the Department, marking of 

21 nameplate output current was not done for 

22 energy efficiency purposes. I mean most of 

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1 the manufacturers that put an output current 

2 measurement on there or in some cases a 

3 wattage type of measurement, it's done because 

4 of the testing and safety certification in 

5 order to do the loading for purposes of 

6 reaching a temperature test limit that's 

7 there. 

8 And so the output nameplate 

9 current was not configured and thought of in 

10 terms of that. So it's done in order to 

11 understand and reach a value for insulation 

12 purposes and for safety. 

13 And there are some and we pointed 

14 this out before. There are some types of wall 

15 adapters for which, yes, you will load them 

16 and they will not reach that situation. It's 

17 done because the manufacturer wants to reach a 

18 maximum value for temperature purposes so that 

19 under even the worst case situations that the 

20 product would encounter it would not exceed 

21 those type of temperature ratings. 

22 It comes back if in fact this is 

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1 occurring with wall adapters that are part of 

2 a battery charger, it brings back the same 

3 point that we've been raising probably now for 

4 almost ten years and that is that they should 

5 not ever be tested in this configuration. 

6 They were not meant to be tested at zero, 25, 

7 50, 75 and 100 percent. These are constant 

8 current devices that are meant to be loaded to 

9 a particular value and then should be measured 

10 at that value and that value only. 

11 It's like we beat ourselves 

12 against the head many, many times trying to 

13 say this in some configurations where 

14 unfortunately erroneously some authorities 

15 have chosen to test constant current devices 

16 at multiple output currents which is 

17 absolutely wrong to do. But it persists and 

18 the fact that you're finding out that some of 

19 them don't do it well in this kind of 

20 configuration just points to the fact of what 

21 we've been saying all along. 

22 Thanks. 

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1 MR. BROOKMAN: Thank you. Larry, 

2 yes, go ahead. 

3 MR. ALBERT: Yes, just to -- it 

4 would just seem based upon what you said so 

5 far that if the product was truly intended to 

6 be an external power supply, a general purpose 

7 external power supply, then not fulfilling its 

8 rating would be a customer dissatisfaction 

9 issue. 

10 And so I'm more inclined to 

11 believe these are cases where these were wall 

12 adapters that were for a specific purpose. 

13 And there was a relationship between the 

14 performance of the wall adapter and the end 

15 product that was contemplated during the 

16 design of the wall adapter in which case the 

17 performance of the end product wouldn't have 

18 been affected by -- you would hope would not 

19 be affected by -- the early cutoff the wall 

20 adapter. And maybe it's because it only makes 

21 those excursions at those current levels on a 

22 transitory basis. Right. And what you're 

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1 seeing is a thermal overloading type of factor 

2 or something like that that you get under 

3 sustained load. 

4 In those cases, I guess perhaps 

5 the best argument would be if it doesn't see 

6 sustained loading at that load point then 

7 maybe you just don't test it there. And you 

8 just evaluate its sufficiency under those 

9 loading conditions, you know, the points that 

10 represent the continuous loading conditions. 

11 Right. 

12 The fundamental concept of the EPS 

13 is where they were generic commodity type 

14 products that found application across a whole 

15 bunch of different products and weren't 

16 specific for their application. As long as 

17 that founding premise holds true in the 

18 individual cases I think it's as good an 

19 approach as any. It's when that theory breaks 

20 down when the application of a wall adapter is 

21 married to a specific application where 

22 they've been engineered together that you 

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1 really can't count on it necessarily doing 

2 what you expect it to do. 

3 MR. VLADIMER: Excellent. This is 

4 Michael. So just to reiterate what you're 

5 saying. So you're I think suggesting one of 

6 the alternatives that's on the screen which is 

7 exclude the effective loading point from the 

8 average. 

9 MR. ALBERT: Yes. 

10 MR. VLADIMER: Excellent. 

11 MR. BROOKMAN: Thanks for that 

12 confirmation. 

13 So here we go. 

14 MR. MALINOWSKI: And the final 

15 types of EPSs that may present some difficulty 

16 with testing according to existing test 

17 procedure are some high power EPSs. These 

18 ones are -- the one illustrated here for 

19 example is typically used for ham radio 

20 operation and it specifies two different 

21 nameplate output currents. One is continuous 

22 while the other is for intermittent operation 

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1 or ICS, intermittent communication service. 

2 And again DOE is considering specifying that 

3 continuous current be used for the purposes of 

4 testing. However, it welcomes stakeholder 

5 comments on whether this is, you know, anybody 

6 would make the mistake of using the other one 

7 or is this something that needs to be 

8 clarified. 

9 MR. BROOKMAN: Larry. 

10 MR. ALBERT: Just following up on 

11 discussion earlier with Mike, again if the 

12 loading condition for the test is continuous, 

13 then it would make sense to use the continuous 

14 values. Right? I'm actually a little 

15 surprised that that falls under the EPS 

16 definition because that looks like a 

17 laboratory power supply or something like 

18 that. 

19 MR. MALINOWSKI: It's one of the 

20 high power. So it's outside of Class A. It's 

21 higher than 250 watts. 

22 MR. ALBERT: Right. 

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1 MR. MORRIS: But that's a consumer 

2 product? 

3 MR. MALINOWSKI: That's a consumer 

4 product for powering ham radio equipment. 

5 Great. So again DOE seeks 

6 comments on these possible modifications to 

7 address these special cases. 

8 And I'll finish today's 

9 presentation by speaking briefly about 

10 multiple-voltage external power supplies which 

11 are a type of non-Class A EPS. DOE originally 

12 proposed a test procedure for these power 

13 supplies during the 2008 Standby and Off Mode 

14 Test Procedure rulemaking. However, it 

15 delayed finalizing the test procedure just to 

16 address the concerns raised by stakeholders at 

17 that meeting. One of which was that averaging 

18 the efficiency measurements to 25, 50, 75 and 

19 100 percent of nameplate output as is done for 

20 single-voltage EPSs was not appropriate in 

21 this case. Particularly, stakeholders 

22 mentioned that it was not representative of 

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1 typical use for multiple-voltage EPSs. 

2 And therefore in today's notice, 

3 DOE still proposes measuring efficiency at 

4 each of those loading points, 25, 50, 75, 100, 

5 but without averaging the results. So the 

6 test procedure would report separate 

7 efficiency measurements for each loading 

8 point. And the results would be weighted in 

9 the standard to represent typical use. And 

10 this is consistent with the approach that's 

11 being proposed for battery chargers as well 

12 and would allow a more general test procedure 

13 that's applicable for a wide variety of 

14 applications. And those results would then be 

15 aggregated in the standard. 

16 MR. BROOKMAN: Larry. 

17 MR. ALBERT: You anticipated. 

18 Again, getting back to what we just discussed 

19 a little bit earlier about what the concept 

20 originally of what EPSs were and why it was 

21 meaningful to regulate those, it's because the 

22 perception was is they were general purpose 

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1 commodity type products that were available 

2 for a host of end-use applications. And the 

3 logic I think at the time in averaging the 

4 efficiencies was that you did not know for any 

5 particular EPS what its loading condition was 

6 going to be. Right. And that's where the 

7 idea of averaging came in. 

8 Now you could certainly make the 

9 argument that doing a strict arithmetic 

10 average is inappropriate since at each point 

11 the power drawn is different and perhaps it 

12 should be a weighted average. But if it's 

13 truly an EPS you're looking at and it follows 

14 the general philosophy of how it's to be used 

15 and it's not application specific, then it 

16 makes sense, I think, to come up with a single 

17 metric out of the test procedure even more so 

18 in this case where there was no presumption of 

19 differing applications and differing use 

20 factors and so on at least in the original 

21 concept of what an EPS was. 

22 Extending wall adapters to end 

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1 product considerations where they're 

2 specifically married together gets back to the 

3 whole question of whether they should be 

4 evaluated as a separate component or evaluated 

5 as part of the system to which it's attached. 

6 And obviously our position on that has always 

7 been and particularly with respect to battery 

8 chargers that they should be treated as a 

9 system and evaluated for their energy 

10 efficiency together. 

11 Again, I think this is moving 

12 maybe in the wrong direction if you're truly 

13 talking about Class A EPSs. If you're talking 

14 about this broader category of non-Class A 

15 EPSs where in fact there may be application 

16 specific wall adapters, then possibly this 

17 makes sense. Right? But only inasmuch as it 

18 might inform the final standard for whatever 

19 the specific application is. 

20 MR. BROOKMAN: Wayne. 

21 MR. MORRIS: Yes. Wayne Morris. 

22 We do have very few products under AHAM scope 

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1 that do use EPSs. On the basis of that, I'll 

2 comment and then I'm going to come back and 

3 comment on the battery charger side of this 

4 thing. 

5 But from the standpoint of those 

6 manufacturers that have true EPSs that operate 

7 we do object to reporting of the five values. 

8 We think that there was merit originally. 

9 The Department made a strong case as did 

10 ENERGY STAR as did everybody else in the world 

11 made cases of why it was that they ought to 

12 take measurements at no load, 25, 50, 75 and 

13 100 and average them out. 

14 Now it seems the Department is 

15 sort of talking out of the other side of its 

16 mouth and saying, "Oh, by the way, while we 

17 told you guys it was a good idea to average 

18 them together, now we're going to tell you 

19 that it's just as good an idea to report them 

20 separately." We think it's got to be one or 

21 the other, guys. 

22 Thanks. 

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1 MR. PETROLATI: Wayne. Vic 

2 Petrolati, Department of Energy. Larry's last 

3 statement was accurate. This proposal is only 

4 for the non-Class A EPS covered by the multi5 voltage category. 

6 MR. MORRIS: Okay. 

7 MR. PETROLATI: And that we are 

8 not proposing any changes to Class A EPSs in 

9 terms of its measurement and reporting. 

10 MR. MORRIS: Okay. That was not 

11 clear. Thank you. I appreciate it. 

12 MR. PETROLATI: Yes. 

13 MR. MORRIS: On the other hand, on 

14 the basis of those products that do have 

15 multiple-voltage output situations, I think 

16 that in that case Larry's other comment has 

17 some merit to consider which is the weighted 

18 average circumstance that may occur because 

19 then you get into the situation where you have 

20 multiple voltages and you're measuring them 

21 then across this span at five internals. Then 

22 you're going to get a situation maybe in three 

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1 or four output scenarios where they're going 

2 to be operating and probably they won't be 

3 exactly at 25 and exactly at 50 and exactly at 

4 75. They may be at 28, 52 and 73 percent. 

5 Okay. In that kind of situation, all the more 

6 reason why averaging may make more sense than 

7 taking a measurement because at 25, 50, 75 

8 you're going to miss the mark anyway. 

9 So either you need to measure at 

10 the actual values that they are being loaded 

11 and producing and do a weighted average. Or 

12 if you're trying to achieve sort of a generic 

13 situation in this then I think you go back to 

14 actually averaging them the way you originally 

15 did and not reporting separately. 

16 MR. PETROLATI: Your thought 

17 process -- Vic Petrolati, Department of 

18 Energy. Your thought process is exactly what 

19 we're going through in trying to make that 

20 determination, and we have decided that we'll 

21 make it in the standards for particularly non22 Class A EPS multi-voltage because of the 

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1 unique circumstances in the market currently 

2 with that product. 

3 MR. MORRIS: Okay. 

4 MR. PETROLATI: Yes. 

5 MR. ALBERT: I apologize in not 

6 understanding that that was restricted to 

7 multi-voltage. 

8 MR. PETROLATI: No problem. 

9 MR. ALBERT: Okay. 

10 MR. MALINOWSKI: Great. Thanks. 

11 MR. BROOKMAN: Larry, anything 

12 else? 

13 MR. ALBERT: Anywhere? Anytime? 

14 Or any subject? 

15 MR. BROOKMAN: We're nearing the 

16 end of these slides here. So now would be the 

17 time -- there is an opportunity for final 

18 comments for any other thing you wish to 

19 address. 

20 But, Larry, go ahead now. 

21 MR. ALBERT: Two questions related 

22 to the EPS requirements. One was, again, the 

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1 DC input EPSs. 

2 MR. MALINOWSKI: Chargers. 

3 They're DC input battery chargers. 

4 MR. ALBERT: So there's no 

5 anticipation that you'd have DC input EPSs, 

6 Right? 

7 MR. MALINOWSKI: No, those are 

8 specifically excluded from DOE's scope. 

9 MR. ALBERT: Okay. Good. 

10 And secondly in the table they 

11 speak of the derated nameplates. 

12 MR. PETROLATI: Reference which 

13 table, please? 

14 MR. ALBERT: Hold on. 

15 MR. MALINOWSKI: I think you might 

16 mean the table on the last page. 

17 MR. ALBERT: Yes, the last page, 

18 table one. Thank you. Table 1 on page 16986. 

19 And could you explain what is meant by 

20 derated nameplate output current? Is that 

21 related to what you were speaking about 

22 earlier? 

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1 MR. MALINOWSKI: No, this is a 

2 different issue, and this is one that we 

3 explained during the standby and off mode 

4 rulemaking. So let me just refresh everyone. 

5 MR. ALBERT: Okay. 

6 MR. MALINOWSKI: The multiple7 voltage EPSs have several different outputs 

8 typically at different voltages, each 

9 operating independently. And in contrast to 

10 the single-voltage EPS test procedure where 

11 you can typically load the output, the single 

12 output, at 100 percent of the EPSs nameplate 

13 rating, in the multiple voltage case, they 

14 often provide two ratings. One is for the 

15 entire EPS, and then it has separate ratings 

16 for each of the outputs. 

17 Say, for example, you have a 20 

18 watt EPS, and one output is rated to 15 watts 

19 while the other is rated to, say, 10 watts. 

20 As you can see, the sum -- if you were to load 

21 each output to 100 percent of its nameplate, 

22 you'd get up to 25, violating the nameplate 

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1 output rating of the entire unit. So this 

2 procedure is somewhat complicated, but it 

3 allows you to reach the limit of the unit 

4 itself and push each of the outputs 

5 proportionally as far as they can go. 

6 MR. ALBERT: Understood. Thanks a 

7 lot. Thanks, Paul. 

8 MR. MALINOWSKI: Okay. So I guess 

9 just as final note the Department welcomes 

10 comment on specifically this issue of loading 

11 the outputs and how it can do that in the 

12 standard, and so any data on typical loading. 

13 But it welcomes input on any portion of this 

14 proposed multiple-voltage test procedure. 

15 MR. BROOKMAN: Wayne. 

16 MR. MORRIS: Yes, I want to go 

17 back to two items. Actually one is -- I know 

18 we sort of beat to death the issue of usage 

19 factors. But from what I understand in 

20 reading the Federal Register notice, 

21 particularly pick page 16959, the second 

22 column, near the top. It says that "Section 

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1 323 of EPCA sets forth generally acceptable 

2 criterion procedures for DOE's adoption of the 

3 amendment of such test procedures. It states, 

4 for example, that the test procedures for 

5 covered product should measure energy use, 

6 energy efficiency or annual operating costs 

7 during a period that is representative of 

8 typical use." 

9 Now I appreciate the fact that 

10 this issue of usage patterns is a bit 

11 difficult and I appreciate that the Department 

12 has elected to put these into the standard 

13 rather than in a test procedure. But you know 

14 I just would point out that the law -- I mean 

15 everybody is -- that's why there's lawyers in 

16 the world -- are open to interpretation of 

17 what the law says. I think that's what 

18 they're there for. We haven't found any other 

19 use for them. 

20 (Laughter.) 

21 MR. BROOKMAN: You're about to 

22 provoke a bunch of jokes. 

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1 MR. MORRIS: That's okay. There's 

2 enough of them in Washington that they can 

3 take a joke. 

4 MR. BROOKMAN: Yes. Thanks for 

5 being so discreet. That's good. Keep going, 

6 Wayne. 

7 (Laughter.) 

8 MR. MORRIS: So I do think that we 

9 need to consider that situation a little bit, 

10 and as much as I appreciate what Vic has said 

11 today I do think that we need to at least 

12 watch that situation. 

13 The other thing that's in that 

14 same paragraph is it says, "A test procedure 

15 for covered products should measure energy 

16 efficiency." Now if the output of the test 

17 procedure is just a bunch of numbers, that's 

18 not energy efficiency. That's just a value 

19 during active mode, a value during standby 

20 mode and a value during maintenance mode. And 

21 that's not what the law says. So I'm just 

22 trying to make sure that we're careful on 

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1 that. 

2 The other thing that I would like 

3 to raise, and I certainly would like to have 

4 some comments particularly by Office of 

5 General Counsel is this issue on the effective 

6 date. And I appreciate the fact that it says 

7 that the Department is proposing a 30 day 

8 effective date, and I believe that it says 

9 that from the date that the standard is in 

10 effect which would lead us to understand that 

11 the test procedure, according to this, is not 

12 effective until the date when the standard is 

13 in effect. 

14 And if I remember what you said 

15 earlier, Vic, for battery chargers that would 

16 be July 1, 2013. I think that's what I heard 

17 you say when you were giving that before. So 

18 is that then the Department's position on this 

19 that the test procedure would not be effective 

20 until July 1, 2013? 

21 MR. PETROLATI: First of all, can 

22 you tell us -- 

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1 MR. MALINOWSKI: What page? 

2 MR. PETROLATI: Yes, point out to 

3 the page where we indicate the effective date 

4 if you can. Do you have it in front of you? 

5 MR. HUDNALL: I just saw it. 

6 MR. MORRIS: It's 16963, first 

7 column. 

8 MR. HUDNALL: Just under 

9 "Discussion." 

10 MR. MORRIS: 16963. 

11 MR. HUDNALL: Yes, I think so. 

12 First column. 

13 MR. MORRIS: Section A part 3 

14 Section A. 

15 MR. HUDNALL: First column. 

16 MR. MORRIS: Under section 

17 "Discussion." 

18 MR. PETROLATI: Under Roman 

19 numeral III, "Discussion." 

20 MR. MORRIS: Okay. 

21 MR. PETROLATI: Which is, 

22 “Effective Date . . . If adopted, the 

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1 amendments proposed today would become 

2 effective 30 days after publication of the 

3 final rule.” 

4 MR. PETROLATI: Okay. 

5 MR. MORRIS: Now what the question 

6 is final rule of the test procedure? Or final 

7 rule of -- 

8 MR. PETROLATI: Final rule of the 

9 test procedure, correct. That is the way it's 

10 being addressed. 

11 MR. MORRIS: Okay. Well, then I 

12 would mention that that becomes a bit of a 

13 problem because there are now test procedures 

14 in the State of California that are in effect 

15 now. 

16 MR. PETROLATI: Right. 

17 MR. MORRIS: Not for battery 

18 chargers, but unfortunately for what 

19 California considers to be an EPS which we 

20 don't agree. But that doesn't matter because 

21 that's the law. There is an ENERGY STAR test 

22 procedure that's out there and we don't know 

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1 yet whether the ENERGY STAR test procedure is 

2 going to be absolutely identical to this. 

3 They don't -- they're not required 

4 under law to adopt the DOE test procedure as 

5 their test procedure. And in fact in the past 

6 in some circumstances they have chosen not to 

7 do that. And in fact manufacturers would have 

8 to perhaps re-label product that is already in 

9 the marketplace with the statements or 

10 information. 

11 They are required by, I believe, 

12 at least seven states in the United States to 

13 comply with what purports to be the California 

14 regulation on this circumstance. And we have 

15 a disconnect. A manufacturer would be 

16 required to test and only test by the DOE test 

17 procedure. And any slight deviation from the 

18 California test procedure could then put 

19 manufacturers in jeopardy. And my members 

20 just don't like jails. I mean they have a 

21 particular allergic reaction to them. 

22 MR. BROOKMAN: Ralph. 

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1 MR. HUDNALL: Ralph Hudnall, Euro2 Pro. Just to add a little bit to what Wayne 

3 is saying, there's also a major retailer 

4 requiring manufacturers to adhere to ENERGY 

5 STAR requirements for these type products. If 

6 the DOE rule supersedes ENERGY STAR, then as a 

7 manufacturer I'm going to need -- 30 days is 

8 very difficult to re-label my product, let 

9 that manufacturer, let that vendor know that 

10 they have to modify their website. I have to 

11 modify my website, get the product on the 

12 water, get the product over here and get it 

13 sold and into the marketplace. 

14 MR. PETROLATI: Okay. Can I ask 

15 to make sure I fully understand this issue? 

16 Vic Petrolati, Department of Energy. Wayne, 

17 first of all, we're talking EPSs. Second of 

18 all, we have proposed some very minor 

19 modifications to the EPS test procedure. I'm 

20 not sure in all cases that we have determined 

21 that it would not affect the energy 

22 consumption of the device. But that was part 

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1 of our consideration in terms of proposing 

2 some of these minor changes to the EPS test 

3 procedure. 

4 So your concern is that any 

5 changes we make to the EPS test procedure may 

6 cause this problem even if we have determined 

7 at this point that it should not affect the 

8 energy efficiency rating. You do not have 

9 that certainty associated with these proposed 

10 changes. 

11 So consequently I think you're 

12 indicating that the Department, because of 

13 harmonization with the states, EPA, and other 

14 countries, should not propose any changes to 

15 the EPS test procedure. Is that correct? 

16 MR. MORRIS: No. 

17 MR. PETROLATI: Okay. Then could 

18 you clarify for me exactly what your concern 

19 is in terms of making changes such as those we 

20 proposed here to the EPS test procedure? 

21 MR. MORRIS: Well, I guess the 

22 first question would be is this only -- does 

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1 this paragraph the way it's written only apply 

2 to EPSs because -- no. This applies -- my 

3 understanding of that paragraph under Section 

4 III: Discussion applies to EPSs and battery 

5 chargers. 

6 MR. PETROLATI: Correct. Although 

7 we -- 

8 MR. MORRIS: But the Department's 

9 standards -- 

10 MR. PETROLATI: We have no 

11 standards out there for battery chargers at 

12 this point in time either within this country 

13 or other countries to the best of my 

14 knowledge. We do have an ENERGY STAR 

15 procedure which uses a different test 

16 procedure for battery chargers. 

17 MR. ALBERT: And that's 

18 acceptable. 

19 MR. MORRIS: California has a test 

20 procedure for battery chargers that -- 

21 MR. PETROLATI: Does not have a 

22 standard however. 

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1 MR. MORRIS: Does not have a 

2 standard, right. 

3 MR. PETROLATI: Right. 

4 MR. MORRIS: But under EPCA and 

5 NAECA I believe there's a rule that says that 

6 a manufacturer shall not make any 

7 representation other than in -- a test 

8 procedure in effect. 

9 MR. PETROLATI: Right. 

10 MR. MORRIS: So by placing a Roman 

11 numeral on a product that is tested in a 

12 different way -- 

13 MR. PETROLATI: Right. 

14 MR. MORRIS: -- they could be in 

15 violation of the Department's test procedure. 

16 MR. PETROLATI: So we're talking 

17 battery chargers. Are we talking battery 

18 chargers? 

19 MR. MORRIS: Yes. But your idea 

20 of a battery charger -- excuse me. This is 

21 Wayne Morris. 

22 MR. PETROLATI: Right. 

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1 MR. MORRIS: Your idea of a 

2 battery charger, the Department's idea of a 

3 battery charger, is not the same as a battery 

4 charger in California where the wall adapter 

5 portion of the battery charger in California 

6 is viewed as a state-regulated EPS, not a 

7 battery charger. And it's being held to that 

8 requirement as we speak today. So the 

9 nameplate and any marking of that wall adapter 

10 portion of that battery charger is being held 

11 to those requirements. And a statement that 

12 the manufacturer makes even in literature or 

13 in a sales piece of literature meets 

14 California class dah-dah-dah effective June of 

15 2008 would be a representation of a test 

16 procedure different from the test procedure 

17 here, especially if the scope is different. 

18 That's a problem. 

19 MR. BROOKMAN: I see Ari wants in. 

20 MR. REEVES: Yes, Ari from D&R. 

21 If you look down to the last sentence of that 

22 Section A -- this might help -- it says, "The 

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1 amendments to the BC and non-Class A test 

2 procedures would become binding following 

3 publication of a final rule," presumably a DOE 

4 final rule, "that establishes these 

5 standards." So it sounds to me that in the 

6 absence of BC or non-Class A federal standards 

7 the BC and non-Class A test procedure portions 

8 of this proposal when made a final rule would 

9 still not be effective. That's just what it 

10 looks like to me. 

11 MR. MORRIS: That's a good point, 

12 Ari. This is Wayne Morris. I'd like to sort 

13 of hear that from OGC and DOE. 

14 MR. MORRIS: It looks like we're 

15 in conflict in terms of statement. There are 

16 ambiguities. 

17 MR. STAS: Eric Stas, DOE, filling 

18 in for Michael Kido. 

19 (Off the record comments.) 

20 One thing I did want to point out 

21 though is when you're talking about the 30 

22 days under 6293 there is a provision giving 

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1 you 180 days to get your literature in order. 

2 With the new test procedure obviously that 

3 can't happen. 

4 MR. HUDNALL: I'm sorry. Where is 

5 that? 

6 MR. STAS: 6293. 

7 MR. HUDNALL: That's Code of 

8 Federal Regulation? 

9 MR. STAS: No. This is in the 

10 statute, 42 USC 6293(C) of the restrictions on 

11 representation. 

12 MR. BROOKMAN: Just restate it, 

13 Eric. 

14 MR. MORRIS: How long? 

15 MR. STAS: One hundred and eighty 

16 days. 

17 MR. BROOKMAN: To get their 

18 paperwork. 

19 MR. STAS: You know, to do your 

20 literature and things. 

21 MR. BROOKMAN: Updates. 

22 MR. STAS: Obviously printing 

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1 time. 

2 MR. BROOKMAN: And does that apply 

3 to some sort of a labeling on the product 

4 itself? 

5 MR. STAS: Yes, I think -- well, 

6 it says representations of writing including 

7 representations on a label. 

8 MR. MORRIS: Wayne Morris again. 

9 Eric, thank you. But honestly when you're 

10 dealing with the supply chains that we're 

11 dealing with -- 

12 MR. STAS: Right. 

13 MR. MORRIS: -- 180 days doesn't 

14 mean anything. In fact, if that applies to 

15 product on a store shelf, you're looking at a 

16 supply chain that -- now the Department has 

17 always seen that as being date of manufacture, 

18 and I would assume that that is true as well. 

19 So if a product is produced before that day, 

20 they don't view it that way. But still 180 

21 days is an incredibly short period of time. 

22 MR. PETROLATI: Vic Petrolati, 

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1 Department of Energy. Now that Ari has 

2 pointed out this additional statement here 

3 under paragraph A it certainly is potentially 

4 confusing as to when the test procedure would 

5 go into effect. 

6 Eric and I have discussed this 

7 during the break. It is not required that the 

8 test procedure go into effect 30 days after 

9 publication of the final rule. We have 

10 flexibility in that particular area. We could 

11 in fact as the statement at the end of the 

12 paragraph indicates require or allow the test 

13 procedure to become binding following the 

14 publication of a final rule that establishes 

15 standards for BCs and EPSs. And it is open to 

16 comment as when you think this test procedure 

17 should in fact go into effect in terms of a 

18 final rule. 

19 MR. BROOKMAN: I saw Ralph first. 

20 MR. HUDNALL: Ralph Hudnall with 

21 Euro-Pro. For safety issues, I know off the 

22 top a bit that it's not uncommon for the 

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1 regulatory agency to implement a date of 

2 manufacture. In other words, if I date code 

3 my product by a certain date or by this date, 

4 then I have to meet the new requirements. 

5 There can be some problems with 

6 that because then some people may stockpile 

7 early builds. But you could also minimize 

8 that as well with other methods of monitoring. 

9 MR. PETROLATI: Right. 

10 MR. HUDNALL: But that from a 

11 manufacturing standpoint if I know that when I 

12 build my thing on June 1, 2013, if I know on 

13 June 1 I have to meet the requirement, then I 

14 can meet the requirement. 

15 MR. PETROLATI: Right. 

16 MR. HUDNALL: If I have an 

17 arbitrary date out there that's 30 days after 

18 this arbitrary date, that becomes very 

19 difficult. I mean like Wayne said even 180 

20 days can be difficult. 

21 MR. BROOKMAN: Okay. 

22 Predictability matters a lot. 

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1 Larry. 

2 MR. ALBERT: This is really a 

3 question with respect to the test procedure. 

4 How does that interact with the test procedure 

5 that's used by ENERGY STAR? 

6 MR. PETROLATI: Yes, it's a good 

7 question, and let's talk about EPSs first. 

8 MR. ALBERT: Okay. 

9 MR. PETROLATI: And we are making 

10 some minor modifications to the EPS test 

11 procedure. I believe we had discussed all 

12 along that these minor modifications we're 

13 proposing we did not believe would affect 

14 energy efficiency. But I need to confirm that 

15 with Navigant, and we may need to take a 

16 closer look, and we would like to get comments 

17 as to whether or not any of our proposals that 

18 you think, whether you think, might affect 

19 energy efficiency in terms of the EPS test 

20 procedure. 

21 And obviously EPA is not required 

22 immediately to adopt our test procedure. In 

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1 terms of battery chargers, I think it's a 

2 little more straightforward. We're working 

3 very closely with EPA right now in terms of 

4 battery chargers. They do want to incorporate 

5 active mode. They have waited for us to go 

6 forward in terms of our test procedure before 

7 taking any steps in terms of going forward 

8 with new criteria for battery chargers. 

9 And unfortunately the individual 

10 from EPA who has been involved in both left 

11 within the last few weeks. So we don't have 

12 EPA. And I'm sorry. We do have ICF here. So 

13 is there anything that you would want to say 

14 in this particular area concerning battery 

15 chargers and EPSs? 

16 MS. MATTERN: This is Sara 

17 Mattern, ICF. We're going forward with the 

18 battery chargers specification development 

19 revision. But it has been delayed a little 

20 bit by Andrew Fanara leaving. 

21 MR. PETROLATI: Okay. And we have 

22 coordinated our schedules so that they go 

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1 forward with a test procedure for battery 

2 chargers that incorporates exactly what we 

3 have as well. 

4 MR. ALBERT: Okay. So on the EPS 

5 side when this is published 30 days after 

6 that, are they obliged then to adopt the DOE 

7 test procedure because it's like a competitive 

8 test procedure and only one thing exists? 

9 MR. PETROLATI: From a legal 

10 standpoint, do you know? 

11 MR. STAS: In the past -- 

12 MR. BROOKMAN: Eric Stas. 

13 MR. STAS: -- it seems like they 

14 have used their own test procedure in some 

15 circumstances. So I'm not -- 

16 MR. PETROLATI: Okay. I mean it 

17 comes down to representations again whether or 

18 not people are required to make 

19 representations in accordance with our test 

20 procedure and I think we'll have to get back 

21 to you. 

22 MR. MORRIS: Wayne Morris. I 

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1 think under the new MOU that was written 

2 earlier this year though there's more of an 

3 obligation than there was previously for 

4 ENERGY STAR to use the DOE test procedure if 

5 it's available. 

6 MR. PETROLATI: Right. 

7 MR. MORRIS: Now if they were to 

8 argue, for instance, that the test procedure 

9 is completely out of date or something along 

10 that line then that might give them the 

11 grounds to do so. But if the Department is 

12 willing going through a rulemaking process and 

13 it is adopting a new test procedure, I think 

14 there would be more of a -- I didn't say 

15 legally required -- I said more of an 

16 obligation that they would use the 

17 Department's test procedure. 

18 MR. PETROLATI: Right. 

19 MR. MORRIS: That's my 

20 understanding of that MOU. 

21 MR. PETROLATI: Right. 

22 MR. MORRIS: Larry, you may want 

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1 to comment. I don't know. 

2 MR. PETROLATI: No. Not being 

3 from EPA I don't know think I'm in a position 

4 to comment. Being from DOE, I will say that I 

5 agree with you in principle and we will 

6 definitely work with EPA to find out if they 

7 have a problem with that concept if we do make 

8 changes to the EPS test procedure. 

9 MR. MORRIS: Or BC. 

10 MR. PETROLATI: Yes. 

11 MR. ALBERT: And on the battery 

12 charger side, I mean -- 

13 MR. BROOKMAN: Larry. 

14 MR. ALBERT: I'm sorry. Larry. 

15 MR. BROOKMAN: Go ahead. 

16 MR. ALBERT: On the battery 

17 charger side, currently there's -- between 

18 what's being proposed and what's currently the 

19 test procedure for ENERGY STAR there are some 

20 big differences. 

21 MR. PETROLATI: Right. 

22 MR. ALBERT: And obviously 

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1 manufacturers who have already gone through 

2 that process, got their products approved and 

3 so on would not want this to be invalidated 

4 overnight. 

5 MR. PETROLATI: Right. 

6 MR. ALBERT: But by the same 

7 token, having a Federal test procedure and 

8 then it preempting others is, I think, of 

9 value given the fact that there's a lot of 

10 entities out there that of course want to 

11 create their own version of things. So as 

12 long as there could be some protection I guess 

13 for the ENERGY STAR approvals, I think it 

14 would be appropriate maybe to move forward. 

15 MR. PETROLATI: And it sounds like 

16 having an effective date for this test 

17 procedure that coincides with the effective 

18 date for the new ENERGY STAR criteria would 

19 resolve that potential problem. 

20 MR. ALBERT: Yeah. That sounds 

21 right. Good. Thank you. 

22 MR. BROOKMAN: Yes. Rick. 

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1 MR. ERDHEIM: Rick Erdheim with 

2 Phillips. So I understand there's some 

3 confusion as to when we say 30 days after the 

4 publication of the final rule. We're not sure 

5 which rule whether it's the standard or the 

6 test procedure. If it's the test procedure, 

7 then we've got this sentence that goes on that 

8 says, any representation regarding all of 

9 these things must be based on the amended test 

10 procedures in Appendices Y and Z. And this 

11 gets back to the concerns that we've had 

12 before that the test procedures and Y and Z 

13 give you these disaggregated energy factors 

14 rather than an aggregated energy factor and 

15 you can't make any claims regarding cost and 

16 efficiency because you don't have usage 

17 factors figured in. 

18 So we would prefer to have the 

19 usage factors in the test procedure. I 

20 understand that's not the way you want to go. 

21 But then we get to the point that Larry 

22 raised earlier that if you're not going to put 

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1 it in the test procedure could you at least 

2 reference saying the test procedure plus the 

3 usage factors and the aggregated energy that's 

4 applied in the final standard. Because right 

5 now -- 

6 MR. PETROLATI: Provide us a 

7 comment. 

8 MR. ERDHEIM: Okay. 

9 MR. PETROLATI: And we'll consider 

10 it. 

11 MR. ERDHEIM: Okay. Just so you 

12 know that right now we cannot make a claim 

13 based on usage factors or aggregated data 

14 because they're not in the test procedure. 

15 MR. PETROLATI: Under battery 

16 chargers. 

17 MR. ERDHEIM: Battery chargers. 

18 MR. PETROLATI: Right. 

19 MR. ERDHEIM: Right. 

20 MR. PETROLATI: And any claim you 

21 would be making under battery chargers at this 

22 point in time would be under the ENERGY STAR 

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1 criteria which incorporates a completely 

2 different test procedure anyway. 

3 MR. ERDHEIM: Right, but suppose -

4 - 

5 MR. PETROLATI: If it's an ENERGY 

6 STAR product. 

7 MR. ERDHEIM: But suppose I wanted 

8 to say that I have an ENERGY STAR product and 

9 my battery charger is 30 percent more 

10 efficient than X Company, my competitor. I 

11 don't know how I'd do that now because I don't 

12 have -- There's no usage factors. There's no 

13 aggregated data. There's all these 

14 disaggregated components. 

15 MR. PETROLATI: Well, I can answer 

16 that problem for you, but I don't think that's 

17 going to give the answer you want. The answer 

18 that you would be providing is using the same 

19 test procedure for both ENERGY STAR and for 

20 your client's product at this point in time 

21 because that's the only one in existence. 

22 MR. ERDHEIM: Right. 

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1 MR. PETROLATI: If in fact we 

2 coordinate the effective date of our test 

3 procedure with the effective date of ENERGY 

4 STAR's criteria that should also eliminate 

5 that problem. 

6 MR. ERDHEIM: We'll have to see. 

7 Since they haven't proposed anything, it's 

8 hard to know for sure. 

9 MR. PETROLATI: Okay. I propose 

10 something that nobody can seem to argue with 

11 at this point. 

12 MR. MORRIS: This is Wayne. I'm 

13 not arguing with you, Vic. In fact, I would 

14 encourage that that is a very good solution to 

15 think about. The only thing then I would ask 

16 that ENERGY STAR correspondingly think about 

17 is that very often they announce changes with 

18 rather rapid enforcement dates or effective 

19 dates. I mean it's not uncommon to have three 

20 month or four month windows from the time that 

21 ENERGY STAR announces a new program to the 

22 time that it becomes effective. 

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1 Now granted I understand why they 

2 do that. Because they want to allow 

3 manufacturers to then list their product and 

4 get them on the market especially to hit 

5 seasonal kind of situations. In this case, 

6 though, people may want to think about that 

7 one because that means that all 

8 representations will now have to be by this 

9 new test procedure. And it also means that 

10 they would have to watch their supply chain 

11 situation. 

12 I think that that may lend those 

13 people who comment back to ENERGY STAR to 

14 think about perhaps having a little bit longer 

15 time to meet that, or to have an effective 

16 date then maybe as traditional. And 

17 especially when ENERGY STAR just revises a 

18 test procedure. Very often then it's a fairly 

19 quick effective date. And in this case that 

20 could have a lot of repercussions. 

21 MR. PETROLATI: Obviously, this is 

22 a major modification to the BC test procedure. 

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1 MR. MORRIS: Yes. 

2 MR. PETROLATI: Huge. 

3 MR. BROOKMAN: Paul. 

4 DR. BENDT: Yes, Paul Bendt. My 

5 understanding of the ENERGY STAR is that when 

6 they are creating a new program for a product 

7 they have not covered before that they can 

8 make that effective immediately. And because 

9 it's a voluntary program, there's nobody out 

10 there with a history that it affects. 

11 My understanding is that if they 

12 are changing the specification for a product, 

13 and this would include changing the test 

14 procedure, that they are required to have at 

15 least a nine month lag time before the change 

16 becomes effective. But that applies only to 

17 products that had a previous ENERGY STAR 

18 specification. 

19 MS. MATTERN: This is Sara 

20 Mattern. Yes, I can confirm that. For new 

21 product categories for which there is not a 

22 current ENERGY STAR program, they do become 

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1 effective immediately upon publication and for 

2 revisions there's typically a nine month lag 

3 period for manufacturers to meet the new 

4 specification. 

5 MR. BROOKMAN: Thank you. Okay. 

6 That's helpful. 

7 So we've covered a lot of ground 

8 in this last segment. I think you're now done 

9 with your presentation. 

10 MR. MALINOWSKI: I am. 

11 MR. BROOKMAN: So now is an 

12 opportunity for anybody to raise any 

13 additional issues that we haven't covered 

14 already at this point especially novel issues. 

15 Anything else before I -- yes, Paul. 

16 DR. BENDT: One item I would like 

17 to address, and it actually fits in comments 

18 under the revised definitions, that one of the 

19 definitions that was getting revised was the 

20 definition of manufacturer's instructions. I 

21 believe DOE was expanding that definition to 

22 include information provided by manufacturers 

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1 on their websites. We would support that. 

2 The second revision was a change 

3 to remove a clause that was allowing service 

4 instructions and I'll note there was a 

5 specific reason for providing those service 

6 instructions. And that was that in many cases 

7 the lab has to disassemble the product to get 

8 access to the battery and they may be 

9 disassembling products that normally consumers 

10 would not disassemble. 

11 So we wanted to provide a way that 

12 manufacturers could provide information that's 

13 not generally made available to consumers, but 

14 might be made available to service technicians 

15 or to the testing laboratory on how to gain 

16 access to a battery and a particular internal 

17 battery or a battery that's protected by 

18 protective circuitry. So that's information 

19 that again they don't normally provide to 

20 consumers, but we wanted to make sure they did 

21 have a way of providing that to the testing 

22 laboratory. And so we would again encourage a 

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1 broader definition of manufacturing 

2 instructions so that the testing lab can look 

3 for access to battery information, for 

4 protective circuitry information, perhaps for 

5 battery discharge or battery capacity 

6 specifications that may not be made more 

7 broadly available. 

8 MR. BROOKMAN: Okay. 

9 MR. ALBERT: I could just provide 

10 some comment from -- 

11 MR. BROOKMAN: Larry. 

12 MR. ALBERT: Sorry. Larry. I can 

13 just bring some comment that we provided at 

14 the time about our position. Generally 

15 speaking, we're concerned about folks opening 

16 up products particularly with certain battery 

17 systems out there that it might introduce a 

18 risk of injury to the people doing the 

19 testing. 

20 And so we were -- I think this is 

21 a way of sort of addressing that with the 

22 presumption that the people doing the testing 

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1 are professional technicians and are competent 

2 to do this provided they have adequate 

3 instruction. And so service literature 

4 providing that it remains with the technician 

5 doesn't become necessarily public, right, is a 

6 good way of transferring that information so 

7 that someone could conduct the test safely. I 

8 guess generally I suggest we'd support that. 

9 MR. BROOKMAN: Okay. Thank you. 

10 We're coming to the end of what 

11 the Department had intended to cover. So 

12 final remarks. Other issues that we haven't 

13 raised so far. 

14 Yes. Larry. 

15 MR. ALBERT: During the course of 

16 the day we were focusing on the differences 

17 between the CEC test procedure and the 

18 proposed DOE test procedure and certainly 

19 looking at what the issues are with respect to 

20 the proposed changes and so on. But I think 

21 it would be fair to mention that the CEC test 

22 procedure brings a lot of value to the DOE 

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1 proposal inasmuch as it provides a fairly 

2 rigorous series of laboratory methods and so 

3 on, and data analysis. 

4 And inasmuch as the data, with 

5 respect to the data it produces, I think it 

6 does a much better job than what we had in the 

7 past. So I certainly think it was a good idea 

8 to borrow as heavily as the Department did 

9 from the CEC providing the other concerns that 

10 were addressed. 

11 MR. BROOKMAN: Okay. Thank you. 

12 Wayne. 

13 MR. MORRIS: Thank you, Doug. 

14 This is Wayne Morris. The other side of this 

15 which I agree with Larry on is the issue of 

16 harmonization if you will with our friends 

17 north of the border in Canada. And I think 

18 I'm encouraged that the Department plans to 

19 publish a final rule for the test procedure by 

20 the end of the year because I think that will 

21 assist us in maintaining harmonization with 

22 the Natural Resources Canada as well. And I'm 

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1 hoping that this will allow us to then take a 

2 number of these items as the C381.2 Committee 

3 is meeting this summer and use those in the 

4 development of a CSA test procedure that can 

5 then be used by Natural Resources Canada. 

6 I also believe that since 

7 currently there is no battery charger test 

8 procedure in Europe and they are considering, 

9 rapidly considering, the adoption of some type 

10 of an energy test procedure, the Department's 

11 procedure could actively give impetus to a 

12 harmonization test procedure there, given it 

13 wouldn't be tested at 115 volts. But still 

14 the important thing is that we would have a 

15 procedure that would have the basic elements. 

16 It's taken a long and painful time 

17 to get to a test procedure that has active 

18 mode in here. And I do appreciate the fact 

19 that the Department did this rather rapidly in 

20 comparison to some other test procedure 

21 revisions. 

22 But this is a good undertaking and 

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1 I particularly appreciate that the Department 

2 and its contractors have asked a lot of 

3 excellent questions as we go through this 

4 presentation today and in the previous 

5 meetings. So I believe that we've had a good 

6 opportunity to raise a lot of issues here and 

7 I want to thank you and the staff and the 

8 contractors for all the work that they've 

9 done. 

10 Thank you. 

11 MR. BROOKMAN: Thank you. Back to 

12 Vic Petrolati for closing remarks. 

13 MR. PETROLATI: Okay. Feedback is 

14 requested, as Doug has pointed out here, and 

15 this is again the information for providing 

16 written comments. I think the oral comments 

17 we got at this meeting were excellent as a 

18 first start in terms of us understanding some 

19 of the issues and problems associated with our 

20 rulemaking. 

21 I think we do have some issues 

22 that were identified here that we are 

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1 obviously going to have to rethink. I do 

2 request that all of the things that you 

3 mention here today you follow up in terms of 

4 written comments and we will address every 

5 written comment in terms of our final rule. 

6 So, first of all, I appreciate the 

7 attendance here today. And to the people who 

8 participated during the webcast, we appreciate 

9 the amount of time that they have spent with 

10 us today, too. And please, again, people on 

11 the webcast, provide us your comments in 

12 writing with the information -- through the 

13 information that we're providing here. 

14 And thank you again for all of 

15 your time here for the public meeting. It's 

16 well appreciated. 

17 MR. BROOKMAN: Okay. Off the 

18 record. 

19 (Whereupon, at 1:34 p.m., the 

20 above-entitled matter was concluded.) 

21 

22

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105:5 107:17

108:16 110:8

111:11 114:20

115:18 117:7

120:5 122:1 124:8

126:19 127:16

128:3 131:4,6

133:7,10,13

134:12,15 136:22

138:21 139:3

140:3,12,16

142:16 143:5,8

144:22 145:4

146:14 147:1

149:7 150:4 152:5

152:9 155:1

156:20 157:17

161:20 164:2

167:12,17 168:20

172:5 173:12,22

177:8,10 178:13

180:10 181:14

184:22 185:22

186:3 188:11

189:12 192:4

193:3,22 195:5,17

197:16 200:16

203:1 205:11

206:9 208:16

210:20 214:11,15

217:15 218:21

219:4 223:22

228:19 230:12,17

230:21 231:2

232:19 233:21

236:12 238:13,15

239:22 245:3

246:5,11 248:8,11

249:9 250:11

252:11 253:17

brought 151:7

Bs 155:8

build 233:12

building 86:4

builds 233:7

bunch 195:9

204:15 218:22

219:17

burden 31:11

47:10 83:18 100:4

145:12 158:22

164:8 168:1,18

burdensome 25:21

168:3 171:9

buried 124:22

button 4:18

buy 111:20,21

112:7 138:1

B&D 147:13

C

C 79:9 138:1

cafeteria 127:12,15

calculate 51:5

101:2 160:12

calculating 81:9

calculation 20:13

153:8

calculations 22:13

California 14:10

14:13 47:8 62:22

75:18 76:16 82:22

87:8 195:16

200:20 222:14,19

223:13,18 226:19

228:4,5,14

call 98:19 160:19

called 31:2

calls 118:3

Canada 250:17,22

251:5

Canadian 62:21

capability 196:5

capable 49:9

capacities 20:17

107:6 110:5

114:12,14 138:2

capacity 21:8 81:7

89:10 100:13,15

100:16,19 101:1,3

101:18 104:20

107:9,20,22 108:8

109:7 114:10,11

114:17,18,19

124:15,20 125:16

125:17 138:8

143:18 153:5,6,18

154:5,16 176:15

185:6,15,20 248:5

capacity-highest

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capacity-lowest

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captured 4:17

car 71:17,21 80:14

careful 148:3

219:22

carefully 86:8

98:21 149:1 172:6

cars 71:22 72:22

73:1,12,19 76:12

76:13,20,21 77:4

78:3,14

case 40:4 45:7

54:14 63:4 66:6

90:10 106:15

112:6,16,17

113:11,21 114:7

117:2,15,15 123:6

123:6,12 129:16

132:3,14,16

134:19 140:12

144:13 149:19

150:12 152:6

160:18 194:16,18

199:3 201:19

203:16 207:21

209:18 211:9

212:16 216:13

244:5,19

cases 45:16 81:1

90:5 95:20,22

99:12 106:6

113:15,19 119:8

120:13 122:9

135:19 144:1

154:2 191:15

198:13,19 199:11

199:12 201:2

203:11 204:4,18

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38:2 58:10 70:4

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certainty 225:9

certification 88:3

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certifying 26:12

cetera 73:10

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chain 231:16

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challenge 154:3

challenges 171:6

chance 24:6,7

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change 15:13 33:21

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changes 15:22 16:3

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35:9,20 36:2,12

39:12 65:19 68:16

89:14 186:16

212:8 225:2,5,10

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changing 245:12

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characteristics

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characterize 146:9

charge 16:13 18:2

18:20,21 19:1,4

22:10 37:5,5 39:1

40:6,11,21 41:4

41:11 42:7 43:15

43:16 44:13 45:17

45:17 53:14 55:1

64:17,17,20 65:1

78:9 81:7 89:7

96:1 99:10,17,20

100:2,7,12 101:16

113:22 125:16

131:10 132:12,15

132:18,20 133:16

133:17 134:1,1,18

134:19,21 135:5

135:10 136:2,4,7

136:18 137:4,19

138:1,5,15,20

140:11,18 141:5

141:11,12 142:21

143:2,12 144:5,8

144:16,17 158:6,9

158:15 159:10

161:14 166:4

169:6 176:21

177:3 198:9,11

chargeable 157:13

charged 18:2 19:7

61:18 70:15 134:4

135:5,6,12,14,21

136:5 142:21

143:1 144:14

charger 14:19 17:4

19:1 31:15 33:11

37:19,20 42:6

45:8,9,12,14,18

46:7 50:22 53:8

54:13 61:13,19,21

63:21 71:7 80:13

80:14 88:19 94:8

99:18 106:2 109:8

109:19 110:16

111:19 112:1,5,5

112:13 113:12,17

113:21 114:8

116:11 119:2

121:6 125:6

130:12,12 131:7

131:11 132:21

133:1,2 135:8

138:10 140:20,22

141:9,13 142:6

146:2 159:6

160:19 162:21

164:15 171:12

172:1,4 173:16

174:7 176:18,21

177:1 186:5

187:16 188:3

202:2 211:3

227:20 228:2,3,4

228:5,7,10 238:12

238:17 242:9

251:7

chargers 1:5,10 4:5

9:10,17 12:4,7

15:6 16:12,14,17

16:18 17:20 18:7

18:12 27:11 30:3

30:13 32:2,6 33:1

33:16 37:11 42:19

62:14 68:2,12,21

69:1,3 70:9,12

71:3 72:5,22 73:4

73:11,11,21 76:18

77:16 80:21 84:5

85:2 88:10 89:17

99:5,15,22 109:5

109:7,10 110:5,6

110:7 116:5 124:7

125:4 133:3 137:3

137:18 138:8

143:11,14,16,20

158:13 165:22

166:19 172:21

186:22 188:6,14

188:16 199:14

208:11 210:8

215:2,3 220:15

222:18 226:5,11

226:16,20 227:17

227:18 235:1,4,8

235:15,18 236:2

241:16,17,21

charger-type 74:13

charges 130:12

132:5 138:18

charge/discharge

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charging 16:17

18:10 46:5 61:6

61:15,16 74:16,18

75:22 83:2 84:19

94:4,5,9,19 95:3

96:12 98:5 118:8

118:9,18 119:8

120:1 121:22

122:21 123:13,16

123:21 134:19

136:11,12,15

137:21 138:12

142:12 144:15

160:2 174:8 176:7

185:10

Cheerio 148:9

Cheerios 53:12

chemical 98:8

chemistries 78:13

145:13,15 146:10

154:18 155:11,17

chemistry 74:15,15

98:2 155:6

children's 27:15

chime 83:11

choice 110:18

117:9

choices 100:1

111:10 115:15

choose 164:20

166:16

chooses 167:9

choosing 107:15

chose 107:2

chosen 202:15

223:6

cigarette 71:20

circle 115:20

circuit 87:19

179:10 181:1

184:8

circuitry 23:7,10

37:5,6 151:3

177:18 180:20

181:4,11,22 182:2

182:4,6,7,11,22

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clarification 36:22

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clarifications 25:10

clarified 206:8

clarify 38:16 39:4

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clarifying 42:11

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clarity 80:6

class 27:6 30:15,16

30:17 32:10,19

34:2,3,5 37:2 73:3

187:8 189:21

192:6 206:20

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clause 22:7 247:3

cleaner 53:13

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cleaners 157:5,9

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clearly 27:4 42:2

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client's 242:20

cliff 150:18

close 33:6 127:2

159:17

closed 44:4

closely 52:1 235:3

closer 199:20

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closes 13:1,3

closing 3:20 7:22

252:12

clothes 59:2

clue 163:19

CMEs 74:9

Coast 127:8

code 230:7 233:2

coffee 127:10

coincides 239:17

collapse 198:12

collected 82:17

column 180:17

217:22 221:7,12

221:15

combination

109:22 115:11,13

117:3

combinations 27:7

109:13 110:4

115:3,9

come 12:17 43:11

44:1 57:1 60:3

110:17 154:14

164:16 171:6

180:11 198:8

209:16 211:2

comes 18:22 94:6

132:11,12 158:21

185:16 201:22

236:17

coming 11:13 51:3

120:21 133:8

145:15 155:15

158:5 184:8

195:10 197:19

198:1 249:10

comment 11:15,16

13:1,3,15 15:18

22:6 29:2 44:3

47:14 59:12 65:6

77:12 81:16 89:20

107:19 109:4

110:3 115:20

116:1 117:9

126:16 129:11

133:7,12 146:17

161:17 173:1,8

175:21 177:17

188:20,21 189:18

190:9 192:21

193:3 194:1

199:18 211:2,3

212:16 217:10

232:16 238:1,4

241:7 244:13

248:10,13 253:5

commentary 145:7

commented 87:10

commenters 29:15

104:4

commenting 44:2

comments 8:8 11:9

11:18 12:9,17,20

13:4,9,11,17,19

13:21 22:22 24:10

24:14,15 27:13

28:11,18 29:9,12

37:2,7,9 38:3

39:17 40:13 42:21

43:8,18 44:14,16

44:18 46:17 57:20

59:12 60:10 65:20

66:21 72:18,19

75:15 77:18 88:13

100:8 102:3,6

111:9 117:13

122:1,9 124:9

126:20 127:19

129:2 139:1 145:4

152:7 157:18

175:1,13 180:4

181:6 186:13

189:4,11,12,14

193:4 206:5 207:6

214:18 220:4

229:19 234:16

246:17 252:16,16

253:4,11

Commission 23:17

47:8 63:1 75:18

76:17

committee 92:4,22

157:2 251:2

commodity 204:13

209:1

common 137:17

138:1,6,16 199:4

commonly 145:17

communicate

190:17 191:9

communication

206:1

Company 242:10

comparable 159:16

171:3

compared 49:16

62:4

comparing 56:5

comparison 133:15

251:20

compasses 17:1

compelled 45:7

competent 249:1

competitive 236:7

competitor 179:4

242:10

competitor's

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complete 10:13,14

16:13 17:7 18:3

19:3 88:4 144:19

178:22 186:1

completely 17:5

19:4 177:16,22

237:9 242:1

complex 19:18

compliant 191:16

complicated

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217:2

complications

160:16

complied 139:20

comply 69:22

223:13

component 118:8,9

118:19 123:21

124:3 210:4

components 242:14

compromise 22:19

106:15 175:6

computer 23:21

70:16 137:9

computers 73:10

145:19

concept 117:17

146:13 185:3,8

204:12 208:19

209:21 238:7

conception 184:2

concepts 38:20

concern 17:20

19:22 43:9 83:2,4

83:13 95:19

144:10 163:15

173:3 225:4,18

concerned 51:13

83:5 111:15 139:8

179:17 248:15

concerning 34:15

38:4 43:13 72:21

235:14

concerns 15:20

40:18 44:11 104:9

151:5 207:16

240:11 250:9

concise 8:17

conclude 24:5

concluded 72:10

186:10 253:20

concur 14:21

condition 136:6,8

181:2 206:12

209:5

conditioning 16:5

22:15,20

conditions 63:20

67:13,13 125:18

204:9,10

conduct 8:10 26:13

26:14 88:6 123:16

196:3 249:7

conducted 99:21

conducting 100:7

conducts 146:11

confidence 89:5,21

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connection 61:12

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Conservation

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considerations

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considered 22:9

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considering 83:6

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109:21 158:8

171:22 190:5

191:10 192:18

194:15 206:2

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considers 63:15

222:19

consistency 69:6

80:6,15

consistent 40:1

60:20 80:22 81:2

91:12 99:4,6

106:7 108:22

118:12 161:15

208:10

consistently 141:5

constant 94:15

96:1 137:19 202:7

202:15

constantly 118:2

consultant 14:7

consulting 1:16,17

1:21 2:3,4,5 3:8

3:11,14,16,19 5:4

6:9,11,15,17,19

13:22 14:6 35:13

35:16 55:17 128:9

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consume 52:3 55:4

158:19

consumed 17:3

18:10 62:10 64:19

130:11 159:11

161:12

consumer 30:1

35:17 51:7 53:3,7

53:20 54:1,3,10

54:22 55:19,22

56:7,8,13,15,17

61:5 62:14 69:15

70:11 71:16,18

73:1,8,12,16,17

73:20 74:7 75:2

77:14 99:15

100:22,22 116:8

122:15 137:11

138:14 148:4

178:1,18 179:7,13

179:16,20 207:1,3

consumers 23:5

49:9 51:20,22

52:8 53:16 55:10

55:12 56:22 69:16

150:12 247:9,13

247:20

consumer's 71:17

consumes 116:9

consuming 118:7

146:3 159:6 160:1

160:6

consumption 60:21

121:4,21 159:13

160:11 174:7

175:9 224:22

contacts 21:2

contains 25:7

contemplated

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content 7:10,14

29:11

context 117:12

continually 34:10

continue 7:17

10:10 24:7 68:19

80:4

continued 128:5

continues 148:11

continuing 84:14

151:20

continuous 204:10

205:21 206:3,12

206:13

contractors 252:2

252:8

contrary 119:5

contrast 64:18 71:8

216:9

control 37:6 39:1

40:6,11,21 41:4

41:12 42:7 43:15

43:16 44:14 45:17

45:18 198:9,11

controls 99:19

controversial

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Cont'd 1:23

convened 1:11

conversation 8:20

conversion 96:3

coordinate 243:2

coordinated 235:22

cordless 53:13

117:2,9,16,20

120:15

core 63:22

correct 23:13 27:22

46:9 72:4 78:22

79:14 143:12,13

147:11 178:10

181:21,22 222:9

225:15 226:6

corrected 184:20

correctly 150:11

162:15 177:15

178:4 200:5

correlation 200:1

correspondingly

243:16

cost 240:15

costs 218:6

Council 1:18 5:15

80:1

counsel 173:2

220:5

Counsel's 6:3

count 205:1

countries 225:14

226:13

country 9:22

157:14 226:12

couple 66:7 85:13

121:10 127:13

145:12 152:11

200:17

course 8:6 72:19

129:1,11 171:1

189:15 239:10

249:15

COURT 173:19

cover 29:16 57:12

99:14 249:11

coverage 78:3

covered 8:6 11:21

43:3 70:7 118:20

120:7 124:11

128:16 186:8

212:4 218:5

219:15 245:7

246:7,13

covering 71:3

covers 42:3 63:11

113:15 192:7

crack 157:14

create 239:11

created 25:18

creates 168:19

creating 15:11

245:6

crest 85:15

crippling 51:10

criteria 40:8 235:8

239:18 242:1

243:4

criterion 218:2

critical 92:18

critically 92:10

crop 152:18

crucial 26:9 144:20

CSA 62:21 63:6

251:4

current 12:8 17:16

20:5,6,16 21:1

30:6 38:12 40:20

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currents 86:17

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cutoff 147:9 149:12

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cycles 16:5 22:15

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damaging 151:1

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danger 151:13

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49:18 50:5 56:22

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date 26:20 33:13,15

34:22 35:2 50:16

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dates 243:18,19

day 8:4 26:1 139:13

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231:19 249:16

days 109:16 125:6

126:3 137:14

155:15 164:14

222:2 224:7

229:22 230:1,16

231:13,21 232:8

233:17,20 236:5

240:3

DC 45:10 61:13

69:3 70:6,8,13

71:12 215:1,3,5

deal 92:8 94:12

100:12 153:19

170:9,16 199:2,10

dealing 39:9 90:10

92:11 116:5

173:16 187:6

231:10,11

deals 67:11 73:3

94:4 95:2

dealt 37:21 58:16

92:22 170:11

197:19

death 217:18

debate 57:4

Debbie 1:19 4:22

Deborah 4:19

decide 177:2

decided 213:20

decides 141:7

decision 40:16 86:9

decisions 76:3

Decker 1:16 5:9

141:4

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linked 29:4

list 81:4,21 83:7

101:1 190:21

244:3

listed 38:11 81:11

190:19 194:11

listen 11:6

listened 175:13

listening 10:17

75:14 172:6

lists 145:21

literature 125:8

228:12,13 230:1

230:20 249:3

lithium 145:16

147:11 151:22

182:13

lithiums 147:10

lithium-ion 97:9

little 4:18 11:12

13:2 45:22 52:21

52:22 57:13 85:11

94:14 102:18,19

102:20 104:22

106:6 111:15

112:19 120:14

134:13 137:12

146:12 154:3

158:16 174:3

175:17 177:14

199:20 206:14

208:19 219:9

224:2 235:2,19

244:14

live 11:2

load 183:7,8 187:18

191:17,18,18

193:20 196:4,9,10

197:7,12 201:15

204:3,6 211:12

216:11,20

loaded 202:8

213:10

loading 194:14,17

194:20,22 195:3

196:16 201:5

204:6,9,10 205:7

206:12 208:4,7

209:5 217:10,12

loads 123:11

190:17 191:9

197:7

location 87:18

logic 15:8 138:11

209:3

long 11:16 17:1

21:6 25:14 88:8

104:7 121:1

125:12 134:17

137:12 158:3

178:7 185:14

204:16 230:14

239:12 251:16

longer 16:12 22:9

22:10 143:11,14

143:17 144:6,9,17

163:10 174:19

184:8 194:21

244:14

look 35:10 51:22

58:18 59:14 66:9

66:13 80:17 84:14

85:1 92:1 93:4,11

98:16 105:7

140:20,22 142:13

155:21 156:2

159:21 160:8

196:2 199:17,19

228:21 234:16

248:2

looking 37:16 39:8

59:3 74:14 78:6,9

95:16 102:18

148:19 157:1

174:2 209:13

231:15 249:19

looks 21:19 141:13

206:16 229:10,14

loophole 141:1,8

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mail 12:21

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majority 73:8

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28:6 40:16 44:15

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35:13,14,15 46:22

60:9,14 67:1

70:10,21 71:5

72:17 77:3 78:5

78:22 79:4,12

80:3 82:1,11

83:10 84:8 88:14

93:17 94:13,18

95:8 96:14 98:11

99:1 100:11 104:3

108:17 110:15

113:7 114:2

115:19 117:19

118:17 122:18

125:14 128:10

134:8,10,13,16

137:1 143:6 147:3

150:5 162:18

174:22 176:4,5

178:3 186:15,17

186:18 188:19

189:17 192:10,14

192:17 193:13

194:4 196:13

197:1 205:14

206:19 207:3

214:10 215:2,7,15

216:1,6 217:8

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man 27:14

Manager 9:9

mandatory 103:17

198:2

manner 13:11 39:1

62:13 76:8

manual 124:22

187:20

manufacture

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manufactured

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manufacturer

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111:22 112:12,21

113:16 115:7,8,10

115:16 118:4,22

124:19 125:17,21

126:8,11 143:19

152:3 154:11

156:8,10 162:21

163:8 165:14

166:10 167:8

178:14,17 183:2

193:14 201:17

223:15 224:7,9

227:6 228:12

manufacturers 2:1

5:11 9:21 24:22

27:9 50:17 55:5

58:4 112:7 113:18

116:19 120:3,8

121:2,14 139:18

141:2 142:11,14

147:12,18 148:20

149:4,5,11,22

151:2 155:14

159:1 164:20

166:18,19 169:6

177:18 182:13

192:19 198:5

201:1 211:6 223:7

223:19 224:4

239:1 244:3 246:3

246:22 247:12

manufacturer's

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246:20

manufacturing

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233:11 248:1

March 30:13 32:16

187:14

marine 70:20 77:15

mark 28:13 130:16

131:12 213:8

marked 69:21

market 214:1

244:4

marketplace 56:9

107:8 111:20

113:4 223:9

224:13

marking 200:20

228:9

married 204:21

210:2

masse 32:4

materially 154:21

materials 129:2

Mateusz 1:21 3:8

3:13,16,18

Matt 6:8 35:13,15

36:20 46:21 60:5

60:8,12 66:22

72:3 78:1 81:19

83:22 88:13 91:17

93:14 114:21

120:7 128:10,15

130:6 134:7,9

136:22 143:5

147:2 150:4 158:4

162:16 164:12

174:20 176:5

186:15,18 192:6

matter 16:22 27:10

88:11,13 137:20

149:15 185:9

222:20 253:20

Mattern 1:22 5:21

5:21 235:16,17

245:19,20

matters 161:4

233:22

Matt's 199:2

Mauer 1:21 5:19

5:19

maximum 198:12

201:18

mean 42:10 53:9,10

56:10 60:12 65:16

102:16 124:21

125:3 148:8 151:6

151:16 155:19

162:12 169:8

175:22 186:8

193:10 195:13

196:7 200:22

215:16 218:14

223:20 231:14

233:19 236:16

238:12 243:19

meaning 176:13

meaningful 208:21

means 90:20

119:15 129:13

141:1 146:1 166:5

244:7,9

meant 65:22 202:6

202:8 215:19

measure 18:19

61:16 62:10 83:19

87:6 91:5 94:16

104:21 118:16

119:2 123:21

133:17 140:17

141:11 184:15,17

196:11 213:9

218:5 219:15

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18:16 24:4 39:1

46:4,7 50:8 52:14

65:5 88:2 100:16

136:2,4,16 177:6

178:6 188:1 202:9

measurement 17:1

17:7,10 19:6

31:10 32:14 41:6

41:12 51:11 52:12

52:13 61:17 66:15

66:16 67:16 68:13

82:4 83:16 85:22

86:13 88:19 90:10

90:12,21 91:3,11

93:6,21 94:8,10

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meetings 28:8,9,13

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meets 56:13 58:7

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member 157:2

members 74:7

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memory 79:3

mention 28:5 129:9

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messages 118:1

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method 40:11,13

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60:20 86:21 87:2

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methodology 161:5

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methods 25:19

29:21 40:15 233:8

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metric 39:13 108:5

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metrics 158:4

Michael 2:5 3:11

6:14 128:7 150:9

173:15 186:18

197:16,17 205:4

229:18

microphone 173:20

middle 160:19

midmorning 7:16

mike 128:5 134:12

157:20 161:21

171:17 206:11

milliamps 20:22

137:22 138:4

milliwatt 121:10

milliwatts 120:22

121:11

mind 62:12 179:3

189:15

minimize 233:7

minimum 56:14

148:13 168:7

minor 24:15

224:18 225:2

234:10,12

minus 91:8 96:20

96:21 97:6,13

minute 11:17

182:21

minutes 53:15,15

54:17 55:1,1,6

127:3,5,21 149:14

178:20

misstated 172:4

mistake 206:6

misused 172:17

mixtures 59:17

mode 3:7,10,12,15

3:17 7:15,18,19

7:21,22 8:19

14:16 24:3 25:11

30:12 34:14 35:21

36:4,14,18 47:1,5

47:7,15 48:18

52:11,13 53:4,5,6

53:14,16 54:8,10

54:15,18,19 55:1

55:2,7 61:6,7,19

61:20,22 62:1,11

63:3,12,12,13,21

63:22 64:8,10,21

65:1,7,15 66:1,17

67:18,19,20,21,21

68:10,17 80:9,13

80:14,21 89:3

128:4,8,14 129:16

158:7,9,16 159:8

160:6,20 166:3

187:1,7,11,13,15

188:2,14,17,22

189:6 207:13

216:3 219:19,20

219:20 235:5

251:18

model 150:10

modeled 178:7

modeling 175:5

moderator 1:13,15

modern 121:8

modes 48:4 53:9

55:11,13 63:11

188:10

modification 32:22

99:2 244:22

modifications 38:9

47:10,12 68:6

189:19 207:6

224:19 234:10,12

modified 59:18

81:1

modify 64:8 67:22

88:21 89:4 224:10

224:11

modifying 80:11

moment 36:11

monitor 142:20

monitoring 120:16

120:21 233:8

monitors 118:2

month 13:3 31:5

243:20,20 245:15

246:2

months 34:22 35:1

92:6

morning 4:4,12 7:1

10:2,21 14:8

15:19 35:22 53:12

127:20 128:6

Morris 2:1 5:10,10

14:1 24:20,21

36:20,20 41:21

47:18 50:11 52:18

55:15 58:8,15

59:8,22 60:11

65:11,12 74:2,3

78:17 79:2,5 85:9

91:16,16 98:13,15

111:11,12 124:10

126:2,18 139:4

146:16 147:5,5

151:6 155:2 164:3

164:4 167:15

168:22 173:14,21

174:1,1 175:10

177:9 200:17,18

207:1 210:21,21

212:6,10,13 214:3

217:16 219:1,8

221:6,10,13,16,20

222:5,11,17

225:16,21 226:8

226:19 227:1,4,10

227:14,19,21

228:1 229:11,12

229:14 230:14

231:8,8,13 236:22

236:22 237:7,19

237:22 238:9

243:12 245:1

250:13,14

motive 73:1,12,20

74:8 75:2,4

motor 37:3

motor-operated

38:13,17 40:5

190:1

MOU 237:1,20

mouth 211:16

move 46:14,20

51:16,17 139:2

145:5 158:2

189:18 194:21

239:14

moving 49:7 88:16

210:11

MP3 20:21 70:14

multi 109:6 212:4

multiple 14:21 51:2

51:20 52:5 133:3

166:13 169:8

175:7 202:16

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nameplate 190:19

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nanophosphate

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narrow 103:22

narrower 21:16

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national 49:21

Natural 1:18 5:15

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Navigant 1:17,21

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near 78:18 178:21

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nearing 214:15

nearly 92:18

135:20 141:19

necessarily 26:22

113:5 117:12

118:12 119:3

120:2 122:17

125:2 138:14

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necessary 68:16

80:20 81:8,9

86:14 90:8 91:2

need 4:18 8:12,19

10:8 26:21 38:16

50:15 51:9 54:20

60:17 61:2 74:4

78:2 87:7 97:16

98:17,21 108:13

111:8,9 124:13

131:13 132:13

173:1 174:3 185:5

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needing 32:19

186:12

needs 21:8,15

28:14 104:10

112:18 131:6

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net 158:10

never 178:1

new 26:1 40:15

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77:10 80:20 93:3

145:14 152:17

155:11,16 158:16

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237:1,13 239:18

243:21 244:9

245:6,20 246:3

nice 114:4 147:16

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Nickel-based 22:16

nickel-cadmium

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nine 245:15 246:2

non 34:4 37:1

48:17 123:13

213:21

non-active 47:20

68:4,8,13

non-answer 85:10

non-Class 27:6

31:2 37:18 38:10

43:10 187:8

189:21 207:11

210:14 212:4

229:1,6,7

non-displacement

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non-issues 170:6

noon 36:1

NOPR 1:5,10 4:4

145:21 170:12

189:5

normal 169:9

normalized 140:19

normally 119:16

195:1 247:9,19

north 250:17

note 19:14 47:11

64:6 74:4 98:12

108:19 134:22

136:9 184:10

217:9 247:4

notebook 73:9

145:18

noted 145:20

notice 1:11 4:4 12:6

23:14 31:14 32:21

36:22 37:15 42:18

78:19 79:6 80:17

81:15 102:2 163:7

208:2 217:20

noticed 10:2 190:7

notion 118:22

novel 145:12

246:14

no-battery 61:22

number 12:16

16:14 18:5 20:6

24:14 25:10 40:13

48:20 51:19 54:10

54:17,20 58:18

65:17 70:11

113:16 115:22

126:10 132:4,5

135:18 138:13

147:2 159:15

161:2 168:1 169:3

173:17 180:18

188:13 198:7

251:2

numbers 49:1 51:3

55:6 104:22

219:17

numeral 221:19

227:11

numerous 42:21

44:14 63:14 87:10

200:19

nut 157:14

O

object 85:13 211:7

objective 102:11

108:1 153:15

154:13

obligation 237:3,16

obliged 236:6

obtain 26:7,15

obvious 122:5

123:10 133:21

137:8 141:22

142:1 143:22

obviously 18:13

40:1 58:1 72:10

87:22 96:8 104:16

108:8 122:9

153:19 164:6

210:6 230:2,22

234:21 238:22

244:21 253:1

occasions 94:11

200:19

occur 59:20 91:10

176:8 212:18

occurred 199:20

occurrence 199:9

occurring 202:1

occurs 123:13

153:8

offhand 34:22

199:5

office 6:3 9:8 220:4

off-brand 112:9

off-mode 23:19

24:3 32:14,16

36:3

Oftentimes 90:22

OGC 229:13

oh 53:11 211:16

okay 4:3 8:20 9:5

10:15 11:20 12:1

12:13 13:1,6,18

13:19 29:12,14,19

30:10 31:6 32:8

32:21 33:2,17

34:13 35:7,10

40:17 41:9,15

46:12 54:2 60:9

66:22 71:13 77:2

78:15 84:7 88:13

100:10,11 108:16

124:8 125:15

126:19 128:3

131:5 134:16

145:6 149:7 150:4

157:17 160:10

167:18 172:22

180:21 184:22

185:22 186:3

189:14,16 192:13

194:3 196:13

212:6,10 213:5

214:3,9 215:9

216:5 217:8 219:1

221:20 222:4,11

224:14 225:17

233:21 234:8

235:21 236:4,16

241:8,11 243:9

246:5 248:8 249:9

250:11 252:13

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original 36:15 97:5

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originally 174:12

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201:1,8 202:16

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216:18,21 217:1

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outside 9:22 69:16

83:3 206:20

overall 29:1 39:15

48:9 51:10 65:21

94:10 95:17 96:7

102:22 105:2

108:9 119:5

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overcharging

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overdue 25:14

overloading 204:1

overnight 168:11

239:4

oversimplification

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overstating 185:19

overview 7:6 12:2

29:10 130:8

overwhelming

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over-rated 107:8

over-stress 151:14

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pack 176:16 182:8

182:9,18,20 183:4

183:20 184:9

185:20

packaged 109:11

packaging 125:8

packet 7:1

packs 182:15

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215:16,17,18

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painful 251:16

pair 192:9,11

paper 126:5

paperwork 230:18

paragraph 219:14

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part 12:5 19:8

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37:19 38:5,8 39:9

45:4 46:4 48:9

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talk 7:12 9:1 24:6

26:21 120:19

128:22 129:4,12

130:5 145:3,12

146:18 174:3

186:15 234:7

talked 26:22 156:9

164:11,12 186:6

talking 36:12 50:16

71:15,21 129:19

145:10 152:12,14

157:4 166:2

193:11 198:2

210:13,13 211:15

224:17 227:16,17

229:21

target 107:11

technical 14:6 86:9

156:8

technically 29:5

72:8

technician 101:5

101:16 102:20

104:6 125:2

130:19 146:11

159:4,18 160:8

168:8,16 186:12

249:4

technicians 247:14

249:1

technological

118:15

technology 121:18

152:14,16

tell 18:12,13,15

53:11 56:12 140:8

142:3 193:18

199:7 211:18

220:22

telling 149:4

tells 48:21 49:19

50:6 138:11

temperature 78:7,8

89:6 90:2 96:16

96:19 97:21 201:6

201:18,21

temperatures

96:22 98:7

ten 202:4

tens 94:21

ten-minute 189:9

term 24:9

terminals 182:16

terminate 181:8

terminates 180:20

184:3,4

terminating 153:12

180:15

termination 153:13

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181:5

terms 10:18 38:11

40:2 58:22 59:1,3

66:1,11 67:3,9

72:4 82:8 84:2

93:8 94:18 99:17

108:4 112:19

123:4 128:18

130:4 162:8 171:9

171:11 186:9

201:10 212:9

225:1,19 229:15

232:17 234:19

235:1,3,6,7

252:18 253:3,5

test 1:5,10 3:7,10

3:12,15,17 4:6

7:15,18,19,21,22

10:5 12:1,5,8,10

14:15,17,22 15:1

15:12,14,21,22

16:15 18:15,17

19:9 20:8,19 21:7

21:10 22:1,18

23:1 25:6,8,16

26:13 27:4,5,10

27:21 29:2,22

30:11 31:8,11,12

31:16 32:4,5,13

33:3 34:1,8,12

35:9,18,21 36:3,4

36:5,9,12,14,15

38:8,12,15 39:8

39:10,12 40:20

42:1,3,9,10,15

43:5,14,19 44:3

44:12,15 47:1,2,3

47:5,7,8,15 49:4,7

49:12,14,21,22

50:3,5,20 51:3,17

51:19 57:1,16

58:6,19,21 59:6

59:13,17 60:16,18

61:2,7,10,14 62:6

62:8,13,16,19,20

62:21 63:1,2,3,5,6

63:7,8,10,14,18

63:20,21 64:1,2,4

64:8,10,14,15,16

64:17,18 65:1,5,8

65:15,22 66:6

67:3,5,8,10,11,12

67:16,18 68:1,7,9

68:12,15,20 69:6

73:2,5,18 74:1

76:18 77:5,6 78:2

79:13,20 80:7,15

81:3,10,17 82:3,6

82:7 83:13 84:11

84:15 85:3,17

86:21 87:8,11

88:16,20 89:1,3,8

89:15 90:11,16

91:9,14 92:13

93:19 94:1 95:2

96:17,18 99:14,17

99:20 100:7 101:3

101:8 102:10

104:8,10,11 106:8

108:14,22 109:20

110:1,18,19 111:6

114:3,15 116:4,20

119:18 121:13,16

125:18 128:4,9,14

128:16,18,20,22

129:6,14,17 130:6

130:8,17,21 132:5

132:10,17,18,20

134:1,2,18,19

139:15 141:18

142:2,7 145:11

146:11 152:13,22

154:1,10,19 158:3

158:9 159:5,22

161:16,18,22

162:7,10,15 163:2

163:9,11,13,15,20

163:22 164:7

165:3,5,8 167:1,5

167:6 168:7,8,9

168:11 169:20,20

170:1 171:2,8

172:11,12,14,17

173:17 176:1,22

177:6 178:4 180:3

180:13,14,22

181:17 183:18,19

184:1 186:6,9,10

186:16 187:1,2,5

187:7,11,13 189:1

189:7,19 190:7,11

191:3,10,12

192:18,20,20,22

193:21 194:8,14

196:3,20 197:4,20

201:6 202:15

204:7 205:16

206:12 207:12,14

207:15 208:6,12

209:17 216:10

217:14 218:3,4,13

219:14,16 220:11

220:19 222:6,9,13

222:21 223:1,4,5

223:16,16,16,18

224:19 225:2,5,15

225:20 226:15,19

227:7,15 228:15

228:16 229:1,7

230:2 232:4,8,12

232:16 234:3,4,10

234:19,22 235:6

236:1,7,8,14,19

237:4,8,13,17

238:8,19 239:7,16

240:6,6,9,12,19

241:1,2,14 242:2

242:19 243:2

244:9,18,22

245:13 249:7,17

249:18,21 250:19

251:4,7,10,12,17

251:20

testable 120:4

tested 15:10 42:7

67:7,15 69:5 76:8

76:13,15,22 107:5

109:9,12 111:4

113:10 114:9

118:8,10 139:14

141:16 158:14

188:17 191:2

195:9 198:10

200:2 202:5,6

227:11 251:13

tester 183:10

testing 14:19 16:1,9

16:10 17:16 18:5

19:18 23:6 25:11

26:5,10 36:17

65:6 66:1 68:10

68:11,17 78:9

79:10 80:21 82:3

88:9 93:15 97:1,8

97:15,18 98:4

99:3,5,10 100:4

103:6 109:17,21

126:12 135:16,16

141:6 148:2

156:14 157:6

162:11 164:8

165:6,11 166:12

166:13 167:22

168:5,18 169:9

182:14,19 183:15

183:18 191:11

194:9 195:19

201:4 205:16

206:4 247:15,21

248:2,19,22

tests 16:3 26:7

39:12 40:9 63:14

90:4,6 96:16

100:5 108:19

115:22 123:16,18

164:13 168:2,13

175:7 189:2 193:1

193:2 199:6

test-to-test 21:21

th 13:1 32:16

thank 4:11 9:4

10:21 11:19 19:20

24:8,18,20 28:6

29:7 35:6,14 38:1

46:10,19 50:9

52:16 60:9 70:1

72:15,18 77:2

80:2 85:7 88:11

88:12 93:12 96:14

98:10,11 103:3

104:2 115:18

124:8 127:18

138:21 140:3,5

167:16 168:20

173:10,22 180:9

185:22 186:17

188:19 192:16

203:1 212:11

215:18 231:9

239:21 246:5

249:9 250:11,13

252:7,10,11

253:14

thanks 29:8,15

41:22 47:18 48:13

56:17 58:8 60:6

65:11 66:20 76:9

91:16 93:11

111:12 126:18

138:22 140:2

145:6,8 149:6

157:21 164:3,4

167:11 170:2

172:5 173:12

186:14 202:22

205:11 211:22

214:10 217:6,7

219:4

theories 38:20

theory 204:19

thereof 27:7

thermal 196:5

204:1

thing 12:14 59:11

65:13 102:17

105:3 112:19

130:9 164:18

165:17 166:2,21

167:2 170:22

196:4 199:19

200:9 211:4

214:18 219:13

220:2 229:20

233:12 236:8

243:15 251:14

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66:10 78:4 93:9

126:5 151:22

152:11 155:15

161:2 164:7

200:17 230:20

239:11 240:9

253:2

think 6:22 8:22

25:4 26:16 28:14

28:21 37:6 38:11

42:7,13 43:12

44:5 45:2 46:17

48:10 51:7 55:5

55:21 56:18 57:11

58:4,11 59:22

60:4 65:16,21

66:3,8,12,15

70:17 74:3,6 75:6

76:5 77:11,17

78:5,8,10,13

79:12,15 82:5,5

82:12,15 83:12

91:17 94:4,13,19

94:21,22 95:9,14

96:11 98:16,16

102:12,21 104:14

104:21 106:15,19

111:16 112:18

114:3,5 120:11

122:6 126:1,7,15

126:20 134:6

139:11,22 144:22

146:21,21 147:15

147:20 148:3

149:2,18 150:9,12

151:17 154:9

155:2,10 156:1,2

156:6 162:3,16

166:17 169:16,17

169:22 171:9

173:8,17 174:3,22

177:9 178:3,9

179:1 180:7

182:21 184:19

197:5,22 198:8

199:22 204:18

205:5 209:3,16

210:11 211:8,20

212:15 213:13

215:15 218:17

219:8,11 220:16

221:11 225:11

231:5 232:16

234:18,18 235:1

236:20 237:1,13

238:3 239:8,13

242:16 243:15,16

244:6,12,14 246:8

248:20 249:20

250:5,7,17,20

252:16,21

third 9:16 26:19

120:10 179:8

thoroughly 17:13

thought 112:18

165:14 167:17

172:2 175:14

195:14 201:9

213:16,18

thoughts 133:5

152:9 161:19

three 22:17 48:4

54:13 62:18 90:3

99:9 109:13,16

114:15 115:10

152:4 164:13

169:7,10 180:18

212:22 243:19

threshold 56:14

183:14

throughput 133:4

through-put

168:13

tight 10:1

tighter 106:21

time 4:13 8:11,14

8:17 13:4 15:18

21:6 22:4 26:7,8

31:22 50:15 51:6

53:8 54:8,16

75:19 91:10 95:13

101:11 104:1,16

104:19 106:2

107:6,11,16

119:12,17 121:5

123:2,14 127:8

132:5,8 133:1,4

138:13 143:17

146:21 149:17

152:21 154:20

157:16 158:11

159:10,14 164:1,7

167:2 169:4,6,15

170:1 171:5

195:15,21 209:3

214:17 226:12

231:1,21 241:22

242:20 243:20,22

244:15 245:15

248:14 251:16

253:9,15

times 22:10 87:10

114:15 121:21

202:12

tiny 20:21

today 7:11 8:1 9:12

11:19 12:12 13:15

27:2 33:9 35:19

44:8 50:16 99:16

155:20 170:15

219:11 222:1

228:8 252:4 253:3

253:7,10

today's 9:14 14:20

32:21 174:10

186:19 207:8

208:2

token 239:7

told 143:19 211:17

tone 25:5

tool 5:9 54:11

113:18

tools 73:9 138:17

145:17

top 135:22 149:9

187:15,20 217:22

232:22

topic 27:1 86:15

170:15

topping 161:1

total 108:4

totally 22:14

touch 108:18 116:3

125:15 150:9

touched 186:5

tough 157:14

tougher 154:3

track 131:16

trader 155:9

tradition 4:14

traditional 244:16

transcript 4:17

8:15

transferring 249:6

transitory 203:22

translate 108:3

transparency

28:13

treated 210:8

treating 124:6

treatment 89:9,15

89:16

trend 10:3

trial 20:5,15 21:7

103:8,13 106:18

trickle 137:19

155:17

tried 19:15 132:4

161:6

tries 140:18

trip 136:10,20

144:18,19,21

153:5 181:7 185:8

trouble 52:22

53:22 176:2

true 25:15 105:9

136:10 148:12

169:1 204:17

211:6 231:18

truly 50:6 52:18

142:3 203:5

209:13 210:12

try 8:17 10:4 21:2

98:1 102:19

151:20 156:2

trying 42:4 107:10

119:20 129:10

132:2 164:9 169:2

171:11 174:18

184:6 196:4

202:12 213:12,19

219:22

Tsinis 2:4 6:18,18

turn 4:7 68:19

97:10

turned 15:9 121:7

160:21

turning 75:15

119:16

two 7:9 13:20 22:20

42:11 62:4 63:1

73:6 96:15 99:20

105:18 108:20

110:21 111:3,3,4

114:13,14 115:10

117:15 120:7

123:20 130:4

138:8,9 145:16

153:20 155:12

160:3,7 171:21

190:21 198:20

205:20 214:21

216:14 217:17

type 16:14 44:20

59:9 71:9 74:17

75:2 87:17 111:6

111:14,18 124:16

137:20 148:15

165:22 166:3,21

198:11 200:8

201:3,21 204:1,13

207:11 209:1

224:5 251:9

types 34:3 75:1,4

110:5,14 137:3

139:7 201:14

205:15

typical 48:21 49:3

61:3,4 96:22

109:22 110:2,3,21

111:1,6,10 114:1

116:1 177:3 208:1

208:9 217:12

218:8

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83:17 100:21

125:19 146:5

187:17 197:7

205:19 216:8,11

246:2

U

ultimate 107:21

113:11

ultimately 102:16

103:18 124:4

unable 11:5

unacceptable 20:9

87:12 106:13

unacceptably 22:1

unanimous 58:1

uncertainty 90:9

90:11,12,15 91:1

91:2,4 93:20

94:10 96:4 106:8

unclear 86:20

uncommon 232:22

243:19

underneath 127:11

understand 49:13

49:14 83:12 85:10

117:15 150:14

172:8 177:15

201:11 217:19

220:10 224:15

240:2,20 244:1

understanding

39:11 43:15 53:22

95:5 169:19

172:19 176:3

214:6 226:3

237:20 245:5,11

252:18

understating

185:19

understood 96:9

173:15 174:11

217:6

undertaken 86:8

undertaking

251:22

unfortunately

26:15 151:19

202:14 222:18

235:9

unique 132:1 214:1

unit 96:17 123:17

141:18 164:21

179:15 217:1,3

United 1:1 69:5,13

69:16 80:1 127:9

223:12

universal 16:17

109:8 137:18

universe 115:4

unknown 130:18

131:15 135:3,11

unlabeled 20:2

unlimited 91:4

unnecessary 25:20

31:14

unplug 54:7

unrated 16:2

107:11,14

unscrupulous

142:10

update 31:19

Updates 230:21

updating 80:5

UPS 23:21 122:22

141:16

UPSs 122:20

usable 84:12

usage 27:17,22,22

37:11 48:12,21

49:10 53:11,18

55:3 56:2,3 58:20

66:4 74:16 108:2

170:14 172:10,15

172:21 173:7

217:18 218:10

240:16,19 241:3

241:13 242:12

USB 70:16 191:15

193:7,10,16

USBs 193:11

USC 230:10

use 15:1 20:21

22:11,12,12 40:9

48:11 49:3 51:20

52:1,4 54:11,13

55:11,13 56:22

61:3,4 62:19 71:4

77:15 78:12 85:18

89:2 100:3 102:14

108:6,6 110:2,13

110:21 111:1,2

112:12 115:12

116:19 118:5,12

123:14 132:7,21

133:2 141:7 146:4

146:9 147:16

148:10 155:20

163:8,10 165:12

171:13 173:19

174:16 178:5

197:6 198:16

206:13 208:1,9

209:19 211:1

218:5,8,19 237:4

237:16 251:3

useful 159:2

user 99:19,19 100:1

117:4 120:10

121:20,21 122:17

176:20 177:4

users 89:19 119:4

119:17

user's 119:20

uses 146:2 178:18

226:15

usually 91:4 137:12

182:7

utilities 14:10

utility 49:8

utilize 193:12

utilized 25:19

UUT 180:15,19

U.S 1:11 5:17 26:2

68:3 155:4

V

vac 149:13 178:19

vacuum 53:13

148:9 155:22

157:3,5,9

valid 17:10 19:5,9

144:1

valuable 56:6,6,8

166:22

value 48:1,5,9 53:3

53:19 56:1 110:12

112:20 154:15

165:15 166:14

169:16 171:11

181:9,10 183:2

185:6 198:19

201:11,18 202:9

202:10,10 219:18

219:19,20 239:9

249:22

values 52:14 57:1

98:19 112:10

147:7,10 149:2

154:11 197:11

206:14 211:7

213:10

valve 79:7

valve-regulated

78:12

variability 163:14

163:20

variation 22:1

114:12 154:5

variations 21:21

variety 29:22 68:11

109:9 208:13

various 39:12 65:8

79:19 170:22

vary 87:16

vast 73:8 191:1

vehicles 155:7,8

vendor 224:9

verbatim 79:13

89:13

verification 88:3

139:16,19 162:8

165:16 166:8

verification-type

165:11

verify 19:11,15

98:1

verifying 26:13

98:7

versa 17:5

version 84:9

239:11

versus 164:15

vibrant 152:15

Vic 7:4 9:3 34:17

35:15 36:8 37:22

41:22 43:22 57:10

58:8 69:9 71:6

72:2 83:11,21

163:5 164:3,4

165:20 167:13

170:15 171:17

180:1 212:1

213:17 219:10

220:15 224:16

231:22 243:13

252:12

vice 17:5

Victor 2:2 3:2,4,6

3:20 9:6

view 11:6 37:19

42:6 51:16 52:19

52:19 231:20

viewed 75:20 76:2

95:9 228:6

viewgraph 33:17

violating 139:19

216:22

violation 227:15

vitally 27:18

Vladimer 2:5 3:11

6:14,14 128:5,6,7

131:5,10 133:9,11

133:14 134:6

138:22 145:2,8

146:15,20 157:21

162:3,16 170:3

171:19 172:3

174:17 186:2,4

197:17,18 199:16

205:3,10

volt 70:22 113:20

142:22 183:14

voltage 36:4 68:22

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71:9 74:16 89:6

90:2 96:17 99:5

109:15,15 110:4

114:10,11,13,17

114:18,18 129:13

131:17 142:20

146:1,4,12 147:9

150:2,22 153:2,12

153:13 156:12

157:10 158:1

176:9 180:19

183:1,10,17,22

184:5,8 188:3

198:12,21 212:5

216:7,13

voltages 78:21 79:6

79:18 97:10,12,17

97:19 110:14

145:22 146:8

150:8 154:12

212:20 216:8

volts 69:2 70:5 99:3

143:1,3 146:8

147:13 183:4,5,11

251:13

volume 166:20

voluntary 198:3

245:9

volunteer 198:6

vote 92:3

W

wait 146:19 169:10

waited 235:5

wake 162:22

wake-up 161:8,12

wall 38:22 40:4,7

41:11 43:16 45:8

45:22 46:3,7

155:9 169:2

198:10 199:13

201:14 202:1

203:11,14,16,19

204:20 209:22

210:16 228:4,9

want 9:12 11:12

12:4,10 25:1 57:6

65:19 93:3,11

96:9 119:11,17

127:17 129:4,12

139:14 141:7

143:22 146:18,19

147:1,22 150:1

151:15 165:20

170:9 174:20

182:14 184:20

198:6 200:11

217:16 229:20

235:4,13 237:22

239:3,10 240:20

242:17 244:2,6

252:7

wanted 10:22 75:19

170:9 175:11

242:7 247:11,20

wanting 57:3

wants 129:22

132:10 162:17

201:17 228:19

warm 98:22

warm-up 189:8

washing 58:21

92:15

Washington 1:9,12

219:2

wasn't 58:1 200:1

waste 170:1

wastes 126:5

watch 98:21 127:1

149:1 219:12

244:10

water 224:12

watt 92:20 160:6

216:18

wattage 201:3

watts 90:14,22 91:5

92:16 94:16 160:2

206:21 216:18,19

way 11:10 26:13,14

41:3 43:3 66:1,17

95:17 102:14,15

108:7 112:11

115:21 121:2

125:10 126:8

139:15 140:9

141:16 148:18

159:3 166:6 171:5

173:8 176:9

178:14 179:8,18

180:17 183:11

184:4,13,21

185:12,12 193:18

211:16 213:14

222:9 226:1

227:12 231:20

240:20 247:11,21

248:21 249:6

Wayne 2:1 5:10

13:22 24:18,21

29:8 36:19,20

38:2 41:20 47:17

48:16 50:10 52:16

55:14 58:2,9

65:10,12 74:2

77:8 78:16 85:8

91:15,16 98:14

111:11 124:9

126:2,15 139:3

140:5 146:14

147:5 149:9 150:6

155:1 164:2,4

167:12 168:21

173:13,22 174:1

200:16,18 210:20

210:21 212:1

217:15 219:6

224:2,16 227:21

229:12 231:8

233:19 236:22

243:12 250:12,14

ways 12:16 51:21

52:8 66:9 85:11

198:8

web 28:7,10,16,20

75:14 126:3,7,13

127:7

webcast 9:14,16,19

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2006 32:4 42:18

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2007 17:14 30:5

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2008 30:18 32:11

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2009 30:14 32:17

2010 1:8 13:2

2011 30:21 33:12

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2013 33:13 220:16

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2017 31:20

207 3:18

24 16:4,12,19 19:2

22:8 61:15 64:20

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7 1:8

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EERE-2009-BT-TP-0019 1.2.002
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288

CERTIFICATE

This is co certify that the foregoing rranscript

in the matter of: Test Procedure NOPR for BatLery

Chargers and External Power

S uppl ies

Be fore :

Date:

-^^-^-^-r ^ FL^ rsy!s-s]]L- Lrrs

aforement ioned

1- \/nourri ]- i nDoug Brookman

May I, 2010

w a s n l n g c o n , u . u .

Frr'l l rnrl -^mhl AFa nrnnoarli nac aF tl-ra

nal-rer. as rennrfed and reduced to

NEAL R. GROSS

COURT REPORTERS AND TRANSCRIBERS

1323 RHODE ISLAND AVE., N.W.

wASHTNGTON, D.C. 20005-370 1

Mawhi nney

(202) 234-4433 www.nealrgross.com

EERE-2009-BT-TP-0019 1.2.002