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U.S. DEPARTMENT OF ENERGY

+ + + + +

PUBLIC MEETING ON THE FRAMEWORK DOCUMENT FOR 

CERTAIN SMALL DIAMETER, ER AND BR

INCANDESCENT REFLECTOR LAMPS

+ + + + +

WEDNESDAY,

MAY 26, 2010

+ + + + +

 The meeting convened at 9:00 a.m. 

in Room 8E-089 of the U.S. Department of 

Energy, located at 1000 Independence Avenue, 

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

Facilitator, presiding.

PRESENT:

DOUG BROOKMAN, Facilitator, Public Solutions,

Inc.

TIMOTHY BALLO, Earthjustice

LANE WESLEY BURT, National Resources Defense

Council

KEITH COOK, Philips Lighting

JOHN CYMBALSKY, Department of Energy

JOHN D. GREEN, Cooper Lighting

MAHIMA (MIMI) GUPTA, Navigant Consulting

S. PEKKA HAKKARAINEN, Lutron Electronics

JEFF HARRIS, Alliance to Save Energy

MATTHEW HARTLEY, Navigant Consulting

PAMELA K. HORNER, Osram Sylvania

JOSEPH G. HOWLEY, General Electric

BIJIT KUNDU, Energy Solutions

AMANDA KORANE LOWENBERGER, American Council

for an Energy-Efficient Economy

ALISON LEHR, Navigant Consulting

JOANNA MAUER, Appliance Standards Awareness

Project
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PRESENT: (CONT.)

JUSTIN NEUMANN, National Electrical

Manufacturers Association

LURLINA PASSE, Con Edison

ANNA RALPH, Earthjustice

ERIC STAS, Department of Energy

MARGARET SULLIVAN, Department of Energy

BRIAN VEDDER, Philips Lighting
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T A B L E O F C O N T E N T S

Welcome 4 

Introductions 5 

Agenda Review 7 

Summary Comments 11

Regulatory History and Rulemaking Overview 11

Market Technology Assessment and Screening 21

Analysis

Engineering and Product Price

Determination 30

Energy Use/Life-Cycle Cost Analysis and 74

Payback Analysis

Shipments Analysis and National Impacts 89

Analysis

Other NOPR Analyses 114

Comment Period 118

Closing Remarks 126
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1 P-R-O-C-E-E-D-I-N-G-S 

2 9:02 a.m.

3 MS. SULLIVAN: Good morning, 

4 everybody.

5 (Chorus of good mornings.)

6 So welcome to the Department of 

7 Energy's meeting for the Framework Document on 

8 Energy Conservation Standards for ER and BR 

9 and Small Diameter Incandescent Lamps.

10 I'm Meg Sullivan with the 

11 Department of Energy and I'm here with my 

12 team, Mimi Gupta, Matt Hartley and Ali Lehr. 

13 And they'll be presenting information about 

14 how we're going to -- the methodologies for 

15 our analyses of these lamps. And I'm looking 

16 forward to hearing all of your comments, 

17 questions and seeing your exciting 

18 demonstrations. And if you want to comment 

19 feel free to speak today or give us a written 

20 submission before the end of the comment 

21 period. 

22 And with that, I'll turn it over to 
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1 -- Oh, John, do you want to speak? John.

2 FACILITATOR BROOKMAN: John 

3 Cymbalsky.

4 MR. CYMBALSKY: Hi, John Cymbalsky. 

5 I am the Appliance Standard Team Supervisor 

6 and I just want to welcome everybody to the 

7 meeting and likewise I can't wait to see what 

8 all these lighting products are going to --

9 And if you have a little air conditioner in 

10 here, too, it would help me.

11 (Off the record comments.)

12 FACILITATOR BROOKMAN: Okay. Well, 

13 it's our tradition to do introductions. So 

14 we'll start on this side of the room and say 

15 your name and organizational affiliation.

16 MR. HOWLEY: Joe Howley. I'm 

17 Manager of Industry Relations for General 

18 Electric and I also chair the NEMA Lighting 

19 Division.

20 MR. COOK: Keith Cook with Philips 

21 Lighting.

22 MR. HAKKARAINEN: I'm Pekka 
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1 Hakkarainen with Lutron Electronics and Vice 

2 Chair of the Lighting Division at NEMA.

3 MR. NEUMANN: Justin Neumann with 

4 NEMA, National Electrical Manufacturers 

5 Association.

6 MR. VEDDER: Brian Vedder with 

7 Philips Lighting.

8 MR. KUNDU: Bijit Kundu at Energy 

9 Solutions here on behalf of Pacific Gas and 

10 Electric.

11 MS. MAUER: Joanna Mauer, Appliance 

12 Standards Awareness Project.

13 MR. BALLO: Tim Ballo, 

14 Earthjustice.

15 MR. GREEN: John Green with Cooper 

16 Lighting and I'm also Vice Chair of NEMA

17 Ballast Section.

18 MS. HORNER: Pam Horner with Osram 

19 Sylvania and I chair the Lamp Section at NEMA.

20 MR. STAS: Eric Stas, DOE.

21 MR. CYMBALSKY: John Cymbalsky, 

22 DOE.
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1 MS. SULLIVAN: Meg Sullivan, DOE.

2 FACILITATOR BROOKMAN: Please.

3 MR. HARTLEY: Matthew Hartley, 

4 Navigant Consulting.

5 FACILITATOR BROOKMAN: These won't 

6 show up on the record.

7 MR. HARTLEY: Matt Hartley, 

8 Navigant Consulting.

9 MS. GUPTA: Mimi Gupta, Navigant 

10 Consulting.

11 MS. LEHR: Ali Lehr, Navigant 

12 Consulting.

13 FACILITATOR BROOKMAN: Jeff, do you 

14 want to introduce yourself?

15 MR. HARRIS: Jeff Harris, Alliance 

16 to Save Energy.

17 MS. DEBUTTS: Lucy Debutts, DOE.

18 FACILITATOR BROOKMAN: Thank you. 

19 Would you introduce yourself please?

20 MS. PASSE: My name is Ivy Passe.

21 FACILITATOR BROOKMAN: Thank you.

22 Okay. I think all of you have a 
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1 copy of the agenda as well as the PowerPoint 

2 slides that will be the focal point for 

3 discussion today and a copy of the proposed 

4 rule. I'm going to go through this very 

5 briefly and then we'll jump right straight 

6 into the content of the day.

7 Following this agenda review, there 

8 is an opportunity for opening remarks, an 

9 opening for anybody who wishes to do so to 

10 make brief summary comments about issues that 

11 are of concern to you. Following that we'll 

12 have a review of the regulatory history and a 

13 rulemaking overview and then moving to market 

14 technology assessment and screening analysis, 

15 engineering and product price determination.

16 We'll take a break midmorning. 

17 Following that, energy use, life-cycle cost 

18 analysis and payback period analysis, 

19 shipments analysis, national impacts analysis, 

20 and then other NOPR analyses. At the end of 

21 the day, we'll describe next steps and there's 

22 yet another opportunity for individuals to 
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1 comment and raise issues that may not have 

2 been raised sufficiently during the course of 

3 the meeting today.

4 Our intention as reflected in the 

5 agenda is to finish today right about noon. 

6 So that's an ambitious schedule. We'll just 

7 see how efficiently we can do this. Okay.

8 I'm Doug Brookman by the way from 

9 Public Solutions in Baltimore. And so I'd ask 

10 your consideration. If you can see, I've 

11 written some of what I think are norms or 

12 common courtesy. Please speak one at a time 

13 if you would.

14 Please say your name for the 

15 record. You don't need to say your 

16 organizational affiliation. All of you 

17 registered when you entered the building today 

18 and the Department knows who's here. Just say 

19 your name. 

20 I'm going to be calling people as 

21 best I can by name. I wish to encourage 

22 follow-on comments. Sometimes it's very 
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1 helpful for the Department to get the back and 

2 forth between different perspectives and 

3 contiguous in the record itself.

4 Please keep the focus here. If you 

5 could turn your machines on silent mode and if 

6 you need to have a sidebar conversation with 

7 someone that's going to last for more than 

8 about ten seconds you can take it out of the 

9 room. We'll understand this part of the 

10 process.

11 If you could be concise, please 

12 share the air time. There's a lot to be said. 

13 And we want to provide time for everybody to 

14 do that today.

15 So that's what I would ask for. 

16 Questions or comments here before we get into 

17 the content?

18 Do you want to do this first slide, 

19 Meg? The purpose of the public meeting.

20 MS. GUPTA: I could do that.

21 FACILITATOR BROOKMAN: You could do 

22 that one, Mimi. Okay. And then after that 
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1 we'll --

2 MS. GUPTA: All right. Good 

3 morning. My name is Mimi Gupta. And today's 

4 public meeting is going to be presenting the 

5 framework document that was made available on 

6 the web. And the framework document basically 

7 presents the procedural and analytical 

8 approaches that DOE plans on taking in 

9 conducting this rulemaking on incandescent 

10 reflector lamps, specifically the ER, BR and 

11 small diameters that are exempt from current 

12 standards.

13 At this public meeting, DOE will be 

14 seeking comment from interested parties on a 

15 variety of issues and discussing the next 

16 steps of the rulemaking. And DOE welcomes 

17 comments on all aspects of the framework 

18 document. I'll be queuing up or the 

19 presenters will be queuing up a couple of 

20 specific issues for comment. And feel free to 

21 make any verbal or written comments. Thank 

22 you.
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1 FACILITATOR BROOKMAN: As I 

2 promised, now is an opportunity for anybody 

3 that wants to make brief remarks here at the 

4 outset, key issues, a summary of things you 

5 wish to raise. And whoever would like to 

6 start with that.

7 MR. NEUMANN: Yes, sure. On behalf 

8 of NEMA and our member companies, we just 

9 appreciate this opportunity to be here and 

10 offer our resources and what we can do to help 

11 out in this continual process. And I look 

12 forward to working with DOE on this matter.

13 FACILITATOR BROOKMAN: Okay. Thank 

14 you, Justin. Please say your name when you 

15 speak.

16 MR. NEUMANN: I'm sorry. My 

17 apologies.

18 FACILITATOR BROOKMAN: Not at all. 

19 We'll get in the habit of doing this.

20 Other comments here at the outset?

21 (No verbal response.)

22 None? Nothing additional? No?
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1 (No verbal response.)

2 Then let's go straight into the 

3 content. Mimi.

4 MS. GUPTA: Okay. I'll be starting 

5 off with a brief background of these products 

6 and this rulemaking. As many of you know, the 

7 Energy Policy Act of 1992 established energy 

8 conservation standards for incandescent 

9 reflector lamps excluding ER and BR bulb 

10 shapes and lamps with diameters of 2.75 inches 

11 or less.

12 Then the Energy Independence and 

13 Security Act of 2007 expanded the definition 

14 of incandescent reflector lamps to include 

15 smaller diameter lamps, namely the ones with 

16 diameters between 2.25 inches and 2.75 inches 

17 and the ER and BR bulb shapes. However, it 

18 also exempted several lamps from standards and 

19 these are the lamps rated 50 watts or less 

20 that are ER, BR of diameter 30 and 40, lamps 

21 rated at 65 watts that are BR30, BR40 and ER40 

22 and the R20 of 45 watts or less. And these 
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1 are the subject of this rulemaking.

2 In July of 2009, DOE issued a final 

3 rule amending existing standards for 

4 incandescent reflector lamps. In an early 

5 stage of that rulemaking, in the ANOPR, DOE 

6 had preliminarily determined that it didn't 

7 have authority to set standards for these 

8 exempt IRL. But in the July 2009 final rule, 

9 it concluded that based on a reexamination of 

10 its authority DOE would conduct a separate 

11 rulemaking to assess energy conservation 

12 standards for these currently exempt products.

13 FACILITATOR BROOKMAN: Meg 

14 Sullivan.

15 MS. SULLIVAN: Yes, Meg Sullivan. 

16 That comment period is going to be extended by 

17 the way until July -- This one. Yes. Two or 

18 three weeks until July 8th.

19 (Off the record conversation.)

20 Okay. Yes, we're going to give two 

21 or three extra weeks on the comment period. 

22 So July 1st or July 8th. Yes.
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1 FACILITATOR BROOKMAN: And that 

2 will be posted on your website or -- Yes. 

3 Okay. Good. Thank you.

4 MS. GUPTA: And then lastly the 

5 Federal Register Notice for this framework 

6 document and public meeting was published on 

7 May 3rd and with a comment period TBA or TBD.

8 All right. In the framework 

9 document, DOE determined that it has the 

10 authority to regulate these exempt IRL and it 

11 provides a detailed description of the 

12 analytical approaches and tools and models 

13 that DOE plans to use to evaluate the 

14 standards for incandescent reflector lamps. 

15 Because DOE believes that much of the analysis 

16 conducted for the July 2009 final rule is 

17 relevant to these types of lamps, DOE is 

18 attempting to do this rulemaking on an 

19 accelerated schedule, namely going from 

20 framework documents straight to the notice of 

21 proposed rulemaking. And DOE plans to publish 

22 a final rule for this rulemaking by December 
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1 2011.

2 Just as a little bit more 

3 background as many of you know, the Energy 

4 Policy Act of 1992 and a Test Procedure Final 

5 Rule in 1997 established test procedures for 

6 incandescent reflector lamps by incorporating 

7 several ANSI and IESNA standards. And then 

8 DOE adopted that test procedure or adopted 

9 amendments to that test procedure updating 

10 several of those industry standards in 2009.

11 DOE welcomes comment on whether any 

12 further amendments are necessary to the 

13 incandescent reflector lamp test procedure.

14 FACILITATOR BROOKMAN: The comment 

15 box, it's an explicit request for comment 

16 should anyone wish to do so.

17 Pam Horner.

18 MS. HORNER: Pam Horner on behalf 

19 of the NEMA Lamp Section in this case. 

20 Basically, we agree with the DOE in terms of 

21 the test procedures. We do want to insert a 

22 comment here which you always hear from us 
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1 which is that it's okay since lumens per watt 

2 is the metric. But we do not agree that 

3 lumens per watt is the correct metric for this 

4 product. So we want to make certain that that 

5 is once again on the record.

6 FACILITATOR BROOKMAN: Thank you.

7 Yes, Pekka.

8 MR. HAKKARAINEN: I'm wondering if 

9 it's appropriate to make a comment on an 

10 earlier part of the framework document where 

11 the rulemaking procedure is described.

12 FACILITATOR BROOKMAN: Go ahead. 

13 Let's do it now.

14 MR. HAKKARAINEN: So I'm concerned 

15 that in the process or the rulemaking process 

16 there is no explicit assessment of consumer 

17 impact analysis. And the reason why I'm 

18 saying that is because after the introduction 

19 of compact fluorescent lamps in the market 

20 there were several lessons that we learned 

21 from that experience and we have now been --

22 NEMA had a task force for I think about a year 
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1 studying consumer dissatisfiers that have 

2 resulted in particular from the 

3 incompatibility of compact fluorescent lamps 

4 and dimmer controls.

5 And therefore my main concern that 

6 I want to express here is that the consumer 

7 impact should be evaluated in this rulemaking. 

8 And in our final -- And in our written 

9 comments, I will describe the dissatifiers 

10 that the NEMA task force has identified. 

11 And I just wanted to make a 

12 reference to a comment in the framework 

13 document in Section 2.3.2.1 in the context of 

14 -- in a different context that discusses I 

15 guess it discusses the different spectrum 

16 lamps. There's a statement that says the 

17 statute prohibits DOE from prescribing a 

18 standard if such standard is likely to result 

19 in the unavailability of performance 

20 characteristics or features for a covered 

21 product line or product type.

22 So I would just like DOE to take 
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1 this incompatibility of the replacement lamps 

2 with dimmer controls into account as part of 

3 the consumer impact analysis and, in 

4 particular, also look at whether this will 

5 result in fewer permanently installed lighting 

6 fixtures being installed in homes to be 

7 replaced by plug-in type devices, plug-in 

8 table and floor lamps and what the energy 

9 impact of that is going to be.

10 Certainly as far as we can from a 

11 NEMA perspective, we will be very willing to 

12 help DOE in this analysis. Thank you.

13 FACILITATOR BROOKMAN: What will 

14 you submit will be NEMA's reflections.

15 MR. HAKKARAINEN: Correct.

16 FACILITATOR BROOKMAN: On this 

17 point.

18 MR. HAKKARAINEN: Correct.

19 FACILITATOR BROOKMAN: Okay.

20 MR. CYMBALSKY: This is John 

21 Cymbalsky, DOE. So in a broad sense you're 

22 talking about the consumer utility of the 
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1 product as opposed to the economic impact to 

2 the consumer.

3 MR. HAKKARAINEN: That's correct.

4 MR. CYMBALSKY: That distinction.

5 MR. HAKKARAINEN: Yes.

6 MR. CYMBALSKY: Thank you.

7 FACILITATOR BROOKMAN: Yes, thank 

8 you. 

9 Other comments at this juncture?

10 (No verbal response.)

11 MS. GUPTA: And just as a last 

12 procedural related slide, EISA 2007 requires 

13 that DOE assess the standby mode and off mode 

14 energy use of its regulated products. And as 

15 concluded in the July 2009 final rule, DOE 

16 does not believe standby mode and off-mode are 

17 applicable modes of operation to incandescent 

18 reflector lamps and, therefore, is not 

19 incorporating those modes of energy use in its 

20 energy conservation standards.

21 And DOE welcomes comments on those 

22 conclusions.
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1 FACILITATOR BROOKMAN: Pam.

2 MS. HORNER: Pam Horner. NEMA 

3 agrees with DOE.

4 FACILITATOR BROOKMAN: Let me say 

5 for the record that the Department loves it 

6 when the stakeholders agree with its 

7 conclusions.

8 PARTICIPANT: You can make that 

9 comment.

10 FACILITATOR BROOKMAN: So it's 

11 helpful. No, it's nice to get affirmation as 

12 well as addition thoughts.

13 MS. HORNER: Exactly.

14 FACILITATOR BROOKMAN: Okay.

15 MS. GUPTA: All right. So this 

16 slide here maps out the different analyses DOE 

17 conducts in the notice of proposed rulemaking 

18 stage. Today we'll be discussing mostly the 

19 top portion of the analyses which include the 

20 market and tech and screening analysis which 

21 develop product classes and design options 

22 that feed into the engineering analysis and 
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1 product price determination which develops a 

2 cost efficiency relationship which is then fed 

3 into the life-cycle cost and national impact 

4 analysis that are used to assess consumer 

5 impacts.

6 There are also several NOPR 

7 analyses that DOE conducts including a life8 cycle cost subgroup analysis and manufacturer 

9 impact analysis, utility, employment, 

10 environmental assessments, and a regulatory 

11 impact analysis. And we'll go through each 

12 one of these today.

13 So for the market and technology 

14 assessment, DOE characterizes the exempt IRL 

15 market and industry, establishes product 

16 classes and identifies technology options to 

17 improve efficacy of incandescent reflector 

18 lamps. Then in the screening analysis, DOE 

19 takes these technology options and screens 

20 several of them out based on four screening 

21 criteria.

22 Here I would just like to highlight 
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1 an issue for comment from the framework 

2 document in which DOE invites interested 

3 parties to submit data relevant to the market 

4 assessment in the form of a written comment. 

5 This includes historical shipments of exempted 

6 incandescent reflector lamps by lamp type, 

7 lamp wattage and market sector.

8 Later today, my colleague, Ali 

9 Lehr, will be discussing the national impact 

10 analysis where we'll discuss several of the 

11 assumptions that DOE has used in the past to 

12 characterize this market. So we'll also be 

13 requesting comment on those assumptions.

14 FACILITATOR BROOKMAN: Comments 

15 here? Pam.

16 MS. HORNER: This is Item 4, right? 

17 Likely -- Pam Horner. Sorry. Likely in our 

18 written comments due in July, we will not have 

19 massive and copious amounts of data that we 

20 will submit with the comments. But we wanted 

21 to assure DOE that throughout NEMA Business 

22 Information Systems which we fondly call NEMA 
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1 BIS we would like to extend a cooperative 

2 attitude and we'd like to help with the 

3 historic data that you seek.

4 FACILITATOR BROOKMAN: Thank you.

5 Yes. Keith.

6 MR. COOK: Keith Cook. Did I miss 

7 Item 3?

8 MS. HORNER: No, it's coming up.

9 MR. COOK: Oh, it's coming up.

10 MS. HORNER: If you look ahead 

11 you'll see it's after four.

12 FACILITATOR BROOKMAN: Other 

13 comments related to data submissions?

14 (No verbal comments.)

15 Okay.

16 MS. GUPTA: So one main task in the 

17 market and technology assessment is to 

18 establish product classes and DOE generally 

19 establishes a separate energy conservation 

20 standard for each product class. DOE divides 

21 these product classes by the type of energy 

22 used, the capacity of the product, or any 
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1 other performance related features such as one 

2 related to utility that would justify a 

3 separate standard level.

4 In the July 2009 final rule, DOE 

5 established a product class structure for the 

6 incandescent reflector lamps that were 

7 addressed in that rule and it divided product 

8 classes by spectrum, diameter and voltage. In 

9 consideration of the seeming technological 

10 similarity between the products regulated in 

11 July and those under consideration right now, 

12 DOE is considering using the same product 

13 class structure for the exempt IRL products 

14 and welcomes comment on whether these are 

15 appropriate criteria to use.

16 FACILITATOR BROOKMAN: Pam.

17 MS. HORNER: Pam Horner. Regarding 

18 two of the three categories, NEMA agrees with 

19 DOE and that would be the diameter and the 

20 spectrum. However, we would like to repeat 

21 ourselves regarding the voltage issue. We 

22 strongly disagree with the establishment of 
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1 two voltage categories, the option of dimming 

2 an incandescent reflector lamp to achieve 

3 longer life and what we mean by that is 

4 operating 130 volt lamps on 120 circuits in 

5 many cases. 

6 That reduced efficacy is always 

7 available regardless of the rate of voltage. 

8 We don't believe that the Department of Energy 

9 should limit the utility for users that really 

10 require 130 volt lamps.

11 And our main point here which we 

12 will also express in our written comments is 

13 that all incandescent reflector lamps should 

14 be tested at their voltage rating and be 

15 subject to the same standards. This is what 

16 we do now. If you have a 130 volt lamp it's 

17 tested at 130 volts for its performance 

18 characteristics and the same for 120.

19 We believe that the effort to 

20 justify two voltage categories is erroneous. 

21 And in practical 130 volt lamps the filament 

22 is designed for 130 volt application. It 
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1 tends, yes, to have a slightly reduced 

2 efficacy compared to the 120 volt design, but 

3 it's insignificant.

4 And bottom line rather than reading 

5 on here is in summary this. Yes, 130 volt 

6 lamps are used on 120 volt circuits in order 

7 to extend life. That is true. Efficacy goes 

8 down. That is true. But so does the wattage 

9 and therefore the energy consumption. Thank 

10 you.

11 FACILITATOR BROOKMAN: Okay. Thank 

12 you.

13 Other comments on the structure of 

14 the product classes?

15 (No verbal response.)

16 Okay.

17 MS. GUPTA: All right. Another 

18 goal of the market and technology assessment 

19 is to identify several technology options to 

20 improve the efficacy of incandescent reflector 

21 lamps and here on this slide you can see 

22 several of the technology options that were 
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1 identified in the July 2009 final rule. Some 

2 to note are the use of tungsten-halogen 

3 capsules, improved reflectors, halogen 

4 infrared coatings. And DOE welcomes comment 

5 on whether the technology options listed on 

6 the previous slide are applicable to the lamps 

7 under consideration in this rulemaking or if 

8 any should be added.

9 FACILITATOR BROOKMAN: Maybe if you 

10 go back to the previous slide. Comments? 

11 Pam.

12 MS. HORNER: Pam Horner. NEMA 

13 agrees that the list is comprehensive and we 

14 also believe it is complete.

15 FACILITATOR BROOKMAN: Additional 

16 thoughts and comments?

17 (No verbal response.)

18 Okay.

19 MS. GUPTA: Then in the screening 

20 analysis, technology options are screened 

21 using the following criteria: technological 

22 feasibility; practicability to manufacturer 
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1 install and service; adverse impacts on 

2 product utility or availability to customers; 

3 and adverse impacts on health and safety.

4 Again in the July 2009 final rule, 

5 DOE screened out several technology options 

6 listed here on this slide and plans to screen 

7 out the same ones for this rulemaking and 

8 requests comment on that screening analysis.

9 FACILITATOR BROOKMAN: Pam.

10 MS. HORNER: Pam Horner. We agree 

11 that the correct technologies have been 

12 screened out. Just a side mark, we did have a 

13 discussion on trihedral corner reflectors and 

14 we're actually wondering what those were. No, 

15 we agree that the correct ones have been 

16 screened out. We agree with DOE.

17 MS. GUPTA: There's a description 

18 in the TSD.

19 MS. HORNER: I guess we don't talk 

20 about those every day.

21 FACILITATOR BROOKMAN: Other 

22 comments on the results of the screening 
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1 analysis?

2 (No verbal response.)

3 Okay.

4 MS. GUPTA: All right. Next I'll 

5 be discussing the engineering analysis and the 

6 product price determination. So the purpose 

7 of these two analyses is basically to 

8 establish a cost efficacy relationship for 

9 these exempt IRL.

10 In the engineering analysis, we 

11 also established the efficacy levels for 

12 analysis. These outputs of the engineering 

13 and product price determination are inputs 

14 into the life-cycle cost and national impact 

15 analysis.

16 And the slide depicts a general 

17 methodology that DOE took in the July 2009 

18 final or July 2009 rulemaking and intends to 

19 take again for this rulemaking in which the 

20 first step of the engineering analysis is to 

21 choose the representative product classes from 

22 the full eight product classes discussed 
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1 earlier.

2 Then for each of the representative 

3 product classes DOE will define a baseline 

4 model from which it will assess changes due to 

5 more stringent standards. Then DOE will 

6 develop efficacy levels that range from the 

7 baseline to the maximum technologically 

8 feasible level. DOE will then identify higher 

9 efficacy substitutes from a database of 

10 commercially available lamps and also when 

11 necessary by developing model lamps. And 

12 finally DOE will scale the results from the 

13 representative product classes to the product 

14 classes not directly analyzed.

15 So for the baseline models, DOE 

16 analyzed commercially available products and 

17 found that the 65 watt BR30 and the 45 watt 

18 R20 lamps were the highest number of models 

19 sold and therefore DOE has preliminarily 

20 chosen these two as the baseline lamps for 

21 analysis. DOE is also choosing the standard 

22 spectrum and 120 volt versions of these lamps.
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1 To develop efficacy levels in the 

2 July 2009 rule, DOE observed natural divisions 

3 that corresponded to more efficacious 

4 commercially available technologies found in 

5 PAR-shaped lamps. Based on much of the 

6 discussion in the July 2009 rulemaking, DOE 

7 believes that there's no clear utility 

8 difference between PAR, ER, BR and R-shaped 

9 lamps. It's DOE's understanding that there's 

10 already a significant amount of market 

11 shifting going on from PAR to BR and that's 

12 why it's unaware of a clear utility 

13 difference.

14 In considering that assumption, DOE 

15 intends to use the same efficacy levels as

16 established in the July 2009 final rule. And 

17 you see here the efficacy levels established 

18 for the large diameter standard spectrum 120 

19 volt lamps. At the bottom of the slide you 

20 see the 65 watt BR30 baseline which is a non21 halogen incandescent technology. EL1 

22 represents a halogen level. This is a new 
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1 level that was not analyzed in the July 2009 

2 final rule, but rather was the baseline of 

3 that rulemaking. Then EL2 through EL6 

4 represent higher efficacy halogen, halogen 

5 infrared options.

6 After establishing efficacy levels, 

7 DOE will then choose higher efficacy lamp 

8 substitutes that will attempt to achieve the 

9 same lumen output by increasing efficacy and 

10 using reduce wattage lamps. In general, DOE 

11 used commercially available lamps when 

12 possible when creating their initial list of 

13 replacement lamps. But when commercially 

14 available lamps were not available in the 

15 wattages or the efficacies that were required 

16 by the efficacy level, DOE developed model 

17 lamps to fill in the technology gaps based on 

18 technological literature and relationships 

19 between lamp lumen output, wattage and 

20 lifetime.

21 For the 65 watt BR30 baseline, DOE 

22 noted that the lumen output was very similar 
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1 to the 50 watt PAR lamp it analyzed in the 

2 July 2009 final rule. And therefore the 

3 replacement lamp analysis is nearly identical 

4 to the analysis in the July 2009 final rule.

5 For the 45 watt R20 baseline, 

6 however, DOE had to develop a replacement lamp 

7 analysis. And in order to do that, as I said 

8 earlier, DOE analyzed commercially available 

9 products and tried to use those commercially 

10 available products wherever possible.

11 However, one thing to note here is 

12 as you can see all of the higher efficacy 

13 options have a wattage of 40 watts here and 

14 that's primarily due to the limitations of the 

15 scope of coverage on this product. The 

16 definition of incandescent reflector lamp is 

17 limited to only those lamps greater than or 

18 equal to 40 watts. As you move to higher 

19 efficacy, though a reduction in wattage may 

20 allow you to equalize lumens, DOE's scope is 

21 only limited to 40 watts. So therefore as you 

22 can see, EL6 has a significantly higher lumen 
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1 output than the baseline.

2 And finally as a last step to the 

3 engineering analysis, DOE scales the efficacy 

4 levels established for the two representative 

5 product classes to the product classes not 

6 directly analyzed. DOE intends to use the 

7 same scaling factors established in the July 

8 2009 final rule, namely, a 15 percent 

9 reduction for modified spectrum lamps and a 15 

10 percent increase for high voltage lamps.

11 And now we will open the floor for 

12 comments on the engineering analysis.

13 FACILITATOR BROOKMAN: Joe.

14 MR. HOWLEY: Joe Howley. Well, 

15 this is a big one. The engineering analysis 

16 and the assumptions - we view this part as 

17 critical to this rulemaking. To go down 

18 through, there are certain questions presented 

19 here and I wish to comment on some of these. 

20 We'll have more extensive written comments.

21 With regard to the representative 

22 product classes, we already had mentioned that 
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1 we agree with those except for the use of the 

2 120 volt and 130 volt product classes which 

3 Pam referred to before. With regard to the 

4 baseline lamps, we do agree that these 

5 baseline lamps represent the highest volume 

6 lamps of those types. So we believe those are 

7 the correct baseline lamps to use.

8 When looking at the tables, 

9 specifically we are trying to match up table 

10 2.4 with table 2.6, we were unable to match 

11 the equations with the lumen per watt values 

12 listed. For example, if you look at EL5 in 

13 table 2.6 and you did the calculation based on 

14 that equation, it does not calculate to 17 

15 lumens per watt which is what is shown for EL5 

16 in table 2.4. So we're not exactly sure why 

17 these tables don't match. It would appear to 

18 us that they should be the same and they're 

19 not the same. The values that are calculated 

20 are much higher than what the equation or 

21 they're not much higher, but they are higher 

22 than what the equations would calculate.
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1 MS. GUPTA: Right. I can maybe 

2 provide a little bit of background on that. 

3 In the July 2009 final rule, DOE received 

4 comments that the rated lamp efficacies did 

5 not always correctly correlate to the 

6 compliance, the value submitted for 

7 compliance, due to the reporting procedure. 

8 And so those efficacy levels were reduced from 

9 the rated efficacies in catalogs. So we 

10 applied those same reductions. Does that?

11 MR. HOWLEY: Okay.

12 PARTICIPANT: This one is higher.

13 MS. GUPTA: So the rated values in 

14 the lamp replacement table should be higher 

15 than the equation values.

16 MR. HOWLEY: They are. Okay. 

17 Well, thank you for that explanation of why 

18 they don't match.

19 FACILITATOR BROOKMAN: Is that okay 

20 from that correct?

21 MR. HOWLEY: I understand the 

22 rationale. But I think from a pure analysis 
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1 standpoint, just from a pure engineering 

2 standpoint that they should match from a pure 

3 engineering standpoint, I understand why you 

4 derated the equation. I guess that's all I 

5 have to say about that.

6 FACILITATOR BROOKMAN: Okay.

7 MR. HOWLEY: It is what it is.

8 And a couple other topics before I 

9 get into the large topic here. You had 

10 mentioned about a 15 percent efficiency change 

11 for modified spectrum. We would agree with 

12 that same type of percentage for these 

13 products. Although we understand why you're 

14 applying the 15 percent for the 130 volt, 

15 again we go back to the fact that should you 

16 even be doing this at all. But we understand 

17 your logic behind that percentage.

18 And just a comment. In viewing 

19 your last chart about comparison of R20 lamps 

20 with lamps with significantly higher lumen 

21 output, generally the industry looks at 

22 products with the same utility as being about 
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1 plus or minus 10 percent in lumen output. 

2 Therefore, we would not view a product that 

3 had twice the light output as having the same 

4 utility. I don't think any consumer would as 

5 well. For instance, pretty much anything 

6 above EL2 would not be viewed as having the 

7 same utility. EL1 and EL2 would. You could 

8 argue they'd be similarly close. But as you 

9 get into EL3 to EL6, especially EL6 with 

10 almost twice the light output, that would not 

11 be viewed as the same lamp type and we don't 

12 think that would be fair comparison to say a 

13 consumer would be just as happy with the lamp 

14 with twice as much light as half as much 

15 light. They would have to put on a dimmer to 

16 get the same light output. It wouldn't 

17 provide the same utility.

18 Okay. Now we move into an area 

19 where we're going to try to use some visual 

20 aids as well, some more demonstrations here to 

21 explain that the one assumption that DOE makes 

22 that there is no clear utility difference 
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1 between BR, R and PAR lamps and therefore 

2 using PAR lamps as the direct replacements. 

3 We believe this assumption is inaccurate and 

4 the reason these lamps exist. If indeed that 

5 statement was true, we would argue these 

6 different lamp types would not exist. If they 

7 had exactly the same utility or even similar 

8 utility, there would be no reason for all of 

9 our companies to make these various lamp 

10 types.

11 The reason these various lamp types 

12 exist is there is a clear and marked utility 

13 difference between these types and that 

14 because of this you really need to analyze R 

15 lamps within R lamps, ER lamps within ER 

16 lamps. Well, R and ER lamps are close enough 

17 from an efficiency standpoint. You probably 

18 could analyze them together.

19 You would have to have a different 

20 diameter analysis as you're suggesting. But 

21 you clearly wouldn't want to analyze the same 

22 as PAR lamps. PAR lamps because of their 
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1 nature have a much better reflector technology 

2 and therefore we can get more efficiency out 

3 of this, significantly more efficiency out of 

4 a PAR lamp than we can out of an R lamp. Even 

5 if we use the same halogen capsule or halogen 

6 IR capsule inside both of these technologies, 

7 we would still get significantly more 

8 efficiency out of a PAR lamp. Treating them 

9 the same would essentially be eliminating the 

10 function, the utility, of the R lamp and the 

11 ER lamp technology.

12 Also we would say that this 

13 analysis, the analysis for PAR lamps, was done 

14 primarily for commercial products and indeed 

15 they're heavily used in retail establishments. 

16 And so the commercial analysis, commercial 

17 operating hours, commercial price points made 

18 sense.

19 However, the R lamp is primarily 

20 used by residences. That would be 70, 75 

21 percent of these products are used in 

22 residential applications. That means they 
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1 should be analyzed based on residential 

2 operating hours. They should be analyzed on 

3 residential price points. And that is a 

4 completely different analysis than the 

5 analysis done for PAR lamps which is primarily 

6 based on a commercial analysis. And so many 

7 different reasons.

8 As we'd like to demonstrate, the 

9 spots in the flood distributions of reflector 

10 lamps and especially lighting distribution of 

11 an ER lamp is very different than the spot and 

12 flood distribution of a PAR lamp. So we can 

13 say that, but you really don't understand what 

14 this is until you actually see it. So that's 

15 why we brought out show and tells because we'd 

16 actually like to demonstrate this versus just 

17 saying that they're different. A picture is 

18 worth a thousand words. Or seeing is 

19 believing. So we thought we would show this.

20 Is that appropriate for you now?

21 FACILITATOR BROOKMAN: Yes. Just I 

22 want to make sure that your show and tell is 
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1 fully captured in the record. Do you want to 

2 use this thing here?

3 (Off the record comments.)

4 MR. HOWLEY: I guess I would first 

5 like to start out with just the basic 

6 difference between a reflector lamp and 

7 elliptical reflector lamp. You've heard R 

8 lamps. You've heard BR lamps. You've heard 

9 ER lamps. But most people unless you're a 

10 lighting person you would not know what the 

11 difference was.

12 Perhaps just to on paper to 

13 illustrate this, I know it's going to be hard 

14 to capture in the record. ER stands for 

15 elliptical reflector and if you look at an 

16 ellipse, an ellipse has two focal points. And 

17 the way an elliptical reflector works is the 

18 filament of the lamp is placed at the focal 

19 point, the first focal point. And the 

20 reflector is quite a bit larger than a regular 

21 R lamp and that is because all the light beams 

22 that reflect off the reflector then are re-
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1 reflected through the second focal point of 

2 the ellipse so that you have a situation where 

3 you can direct a lot of the light from this 

4 product straight through a relatively small 

5 opening or a deep down light or a down light 

6 with a small opening.

7 And that was why this product was 

8 developed back in the mid '70s was to operate 

9 in such fixtures that may have a very deep 

10 recess or it may have a very small opening at 

11 the bottom of the recess. And these fixtures 

12 still exist today as they were installed 

13 mostly in the '70s and '80s. But the 

14 replacement lamps are still used for energy 

15 efficient purposes. If indeed you were to 

16 replace it with a different type of lamp, a 

17 flood or a PAR, you wouldn't get much light 

18 out of that fixture.

19 Pekka is going to demonstrate. 

20 This is the beam pattern and this would be a 

21 reflector flood. And maybe you could move 

22 that a little bit closer. Pekka, move that a 
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1 little bit closer to the screen if it will 

2 work. I don't know if we can turn some of the 

3 lights off. Great.

4 FACILITATOR BROOKMAN: Thank you.

5 MR. HOWLEY: So that's a reflector 

6 flood trying to go through a small opening. 

7 Now you can remove that and that's just -- If 

8 you could see the distribution of that lamp. 

9 Again, just show that. Again, look at how 

10 smooth that is. I just want to point out it's 

11 a very broad distribution on a reflector lamp. 

12 It provides a very smooth distribution. 

13 Homeowners like to use these over the kitchen 

14 counter tops because it provides even 

15 distribution across a very wide surface. 

16 Okay.

17 The elliptical reflector lamp looks 

18 like it has similar, a little tighter beam 

19 pattern when you just show it straight when 

20 it's just in space. But if you get it closer 

21 to the focal point what you'll find is that 

22 you get -- and we may have to do this like 
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1 this. I'll turn this on as well. So about 

2 one or two inches away you'll notice that you 

3 get still a pretty distribution of light out 

4 of it. Whereas if I tried it with this, I 

5 don't know if you could do that. A lot of 

6 that is blocked.

7 FACILITATOR BROOKMAN: The problem 

8 is the bottom one is still on.

9 MR. HOWLEY: Oh. That's the 

10 problem.

11 (Laughter.)

12 Why is there so much light on this 

13 screen?

14 (Off the record comments.)

15 But you can see there's very little 

16 light coming out of if you just put a standard 

17 flood light in there.

18 FACILITATOR BROOKMAN: So restate 

19 your conclusion.

20 MR. HOWLEY: Well, the conclusion 

21 is that the elliptical reflector lamp is used 

22 for very specific fixture types to get maximum 
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1 light out of the fixture, where the reflector 

2 flood is used for other fixture types. That's 

3 used for maximum distribution of light across 

4 the surface.

5 Now to contrast the reflector lamp 

6 types that have been used and developed for 

7 many years are the PAR lamps. The PAR lamps 

8 were developed more to get maximum light punch 

9 or maximum candle power on an object and this 

10 is primarily where you want to highlight an 

11 object either in your home or in retail. This 

12 is why they're so popular in retail because in 

13 the retail environment we typically like to 

14 get the maximum punch on an object that 

15 they're trying to sell.

16 Generally, the rule of thumb is to 

17 get three times the light on the object than 

18 the ambient light. So the object is to focus 

19 the light dramatically in one area. If we 

20 show the -- Let me show the PAR 30 right now. 

21 Okay. And you can see that's a PAR 30 flood. 

22 If we were to put that in a fixture with a 
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1 narrow opening, we would get something like 

2 this. So you get just a lot of light in a 

3 small area coming out of that. But you get no 

4 distribution.

5 The difference with the ER lamps is 

6 you get light out of it plus you get your 

7 distribution across a wider area. And that is 

8 a BR lamp. That's a BR lamp which is similar 

9 to an R lamp. It's a little tighter than a 

10 regular reflector flood and it was designed 

11 for energy efficiency purposes so that in the 

12 center area you have about the same light 

13 output on a 65 watt as you do on the old 75 

14 watt R30. And that product, the 75 watt R30, 

15 was eliminated by the 1992 Energy Policy Act. 

16 So these are all sold as 65 watts. And, of 

17 course, there were further exemptions in the 

18 2007 EISA law.

19 Now with the PAR lamps we could 

20 also show the difference of two spots. These 

21 are flood designs and we could also compare 

22 and contrast two spots. You can get a 
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1 reflector lamp in a spot and you can get a PAR 

2 lamp in a spot. And this is where you really 

3 want to concentrate the light.

4 But again saying "Is the reflector 

5 lamp spot the same as a PAR lamp spot?" We 

6 can again demonstrate these two. And that's 

7 about as good as you can get with a reflector 

8 lamp spot. We can make the beam a little 

9 tighter, but we can't make it nearly as tight 

10 as we can make a PAR lamp and that is about 

11 the extent of how tight the beam can get. And 

12 then here is a spot of a PAR lamp where you 

13 can see much more of the light is focused in a 

14 very small area here. And that's why PAR 

15 lamps are used primarily for retail accent 

16 lighting.

17 So they truly do provide two 

18 different utilities. ER lamps provide a 

19 different utility as well. The efficiencies 

20 of ER lamps and R lamps are very similar. The 

21 efficiencies of PAR lamps are much higher. So 

22 if you were to set the efficiency level so 
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1 that PAR lamps could meet them, you would 

2 essentially eliminate entirely R lamps from 

3 the market and ER lamps from the market. And 

4 there's no way to produce that same utility 

5 out of a PAR lamp in terms of light 

6 distribution.

7 (Off the record comment.)

8 One last thing about the utility of 

9 dimmability and we're going to demonstrate 

10 dimming an incandescent lamp. You could see 

11 we could go down to about one percent dimming. 

12 We could go down to a point where we could 

13 barely see the light output. If you were 

14 trying to create a mood or an effect in a home 

15 with dimming, incandescent you can do a very 

16 smooth -- It dims very smoothly and it dims 

17 very deeply. You can go to very low levels.

18 If you would try to do the same 

19 with compact fluorescent, we do have dimmable 

20 compact fluorescent designs right now. First 

21 of all, you'll notice this is sold as a 

22 replacement to the incandescent lamps. But 
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1 you see that these aren't just flood. These 

2 are super floods. The light is going all the 

3 way to that wall over there and over there as 

4 well as hitting here. But they're extremely 

5 broad.

6 Fluorescent technology lends itself 

7 to extremely broad distributions of light, not 

8 even as much on your kitchen counter. You 

9 have as many lumens coming out, but it really 

10 is going a lot of different directions. So 

11 that's the first slight drawback.

12 The other drawback is dimming. So 

13 can you take that all the way down? What 

14 happens when you take it -- It will drop out 

15 right now. Okay. You might have to move that 

16 closer so you can see the effect. Okay.

17 MR. CYMBALSKY: How low are you 

18 going on that one? Is that 20 percent?

19 MR. HOWLEY: Yes. About 20, Pam?

20 MS. HORNER: What is it? My lamp?

21 MR. HOWLEY: Yes.

22 MS. HORNER: Yeah, it would go down 
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1 to 20 percent.

2 MR. HOWLEY: About 20 percent and 

3 some dimmer I notice will drop the lamp out if 

4 you get too far. This dimmer is holding in 

5 there okay. Oh, it just dropped out.

6 (Off the record comments.)

7 MR. HAKKARAINEN: This is Pekka 

8 Hakkarainen. The dropout is one of the 

9 consumer dissatifiers that the NEMA task force 

10 has identified.

11 FACILITATOR BROOKMAN: Okay.

12 MR. HOWLEY: And that completes our 

13 demonstration. Thank you.

14 FACILITATOR BROOKMAN: Okay. So 

15 are there questions from anybody following 

16 that demonstration?

17 Yes, Keith, do you want to follow 

18 on there?

19 MR. COOK: No.

20 FACILITATOR BROOKMAN: You're just 

21 putting the screen up. Okay.

22 MR. COOK: Yes.
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1 FACILITATOR BROOKMAN: So then 

2 maybe you could, Joe, then restate the 

3 implication of all of this for the record just 

4 to clarify it.

5 MR. HOWLEY: Well, in summary and 

6 for the record, reflector lamps and elliptical 

7 reflector lamps offer a different utility to 

8 consumers than PAR lamps, PAR30 lamps or PAR38 

9 lamps. PAR lamps, their main advantage and 

10 utility is highlighting objects. Reflector 

11 lamps, their main utility is providing a nice 

12 soft wash of light and also that's fully

13 dimmable down to very low levels. And 

14 elliptical reflector lamps are also a unique 

15 design designed to provide unique utility in 

16 deep down lights or down lights with narrow 

17 openings and still maintaining a relatively 

18 wide light distribution pattern in front of 

19 the lamp.

20 FACILITATOR BROOKMAN: Okay. Thank 

21 you.

22 Yes. Tim Ballo.
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1 MR. BALLO: Tim Ballo with 

2 Earthjustice. Just one follow-up question on 

3 this. For the problem of the R shaped lamp 

4 that would be installed in a deeply recessed 

5 fixture, if the standard as I think it would 

6 be likely to happen would result in a 

7 significant increase in lumen output for that 

8 lamp, what would that do to the amount of the 

9 light that escapes that fixture?

10 MR. HOWLEY: Well, if there was 

11 more lumens available there would be more 

12 light that comes out of the fixture. But 

13 because it's simple optics you would still 

14 have a great deal of those extra lumens caught 

15 or trapped inside the fixture. So the 

16 increase in lumens would be partially captured 

17 by the fixture itself and partially exit the 

18 fixture.

19 You would get still better utility 

20 if, for instance, you designed a standard 

21 where you were required to increase the 

22 efficiency of a reflector lamp or a BR lamp in 
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1 and of itself or an ER lamp in and of itself, 

2 for instance, requiring halogen technology in 

3 that product. And you set the standard based 

4 on what's capable, the efficiency that's 

5 capable. And in fact that's a halogen lamp 

6 right there and a halogen R lamp. So you can 

7 make this technology more efficient. That's 

8 not what we're saying.

9 What we're saying is that you 

10 shouldn't base the capability of the 

11 efficiency gain on PAR lamps. You need to base 

12 the capability of the efficiency gain using a 

13 reflector shape, not using a PAR lamp shape. 

14 That's our main point.

15 FACILITATOR BROOKMAN: Pam, do you 

16 want? Pam Horner.

17 MS. HORNER: Pam Horner. I think 

18 Joe's last statement was the perfect summary. 

19 Let me put it another way if I may. I can see 

20 two outcomes of this rulemaking. One outcome 

21 would be that the levels are set so high, say, 

22 for example, those for PAR lamps such that the 
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1 entire category that encompasses the PAR shape 

2 is gone because the reflector system and the 

3 distribution of light that comes out of that 

4 BR shape cannot achieve the efficacy levels of 

5 the PAR lamp.

6 The other outcome that is possible 

7 -- so we're talking philosophy here -- is that 

8 the BR shapes today could be made more 

9 efficient by incorporating the same types of 

10 technologies that are incorporated into the 

11 PAR lamp rule. But I think you can see 

12 clearly from the demonstration or maybe not 

13 clearly from the demonstration but from the 

14 numbers in any case that a BR shape reflector 

15 is not physically capable of achieving the 

16 efficacy levels of PAR lamps. That's point 

17 one.

18 So the other outcome could be that 

19 what we have in that shape category could be 

20 made more efficacious. But the warning is 

21 that the efficacy levels would have to be 

22 because of physics lower than those set for 
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1 the PAR lamps. So you can see that this is a 

2 crossing point here. What is the intent? And 

3 the demonstration to me clearly shows if you 

4 were watching the smoothness of beam that a 

5 flood in PAR parlance is not the same thing as 

6 a flood in BR parlance. Thereby, they have 

7 two different utilities.

8 FACILITATOR BROOKMAN: Thank you.

9 So other comments on this series of 

10 issues involving the demonstration? Jeff 

11 Harris?

12 MR. HOWLEY: Jeff Harris, Alliance 

13 to Save Energy.

14 FACILITATOR BROOKMAN: Hey, Jeff, 

15 let me hear from John first. Let's hear other 

16 comments from industry. Is it John?

17 MR. GREEN: Yes.

18 FACILITATOR BROOKMAN: Let's hear 

19 all from industry and then we'll hear from 

20 others.

21 Go ahead, John.

22 MR. GREEN: Thank you. John Green. 
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1 I'm with Cooper Lighting. We manufacture 

2 luminaires and not lamps. But we also 

3 manufacture those luminaires for a wide 

4 variety of sources including reflector lamps, 

5 metal halide, fluorescent, regular 

6 incandescent. We employ a large number of 

7 optical engineers to deliver light in the most 

8 efficient way we can to work surfaces in areas 

9 that do need those lights, that do need the 

10 light. And a lot of these require reflectors 

11 or refractive materials and fixtures.

12 In the cases where we use reflector 

13 lamps to meet customer requirements, we have 

14 to rely on the optics in that lamp to deliver 

15 light where we need it. So I'd like to 

16 reinforce Joe's explanation of the utility and 

17 as a luminaires manufacturer we rely on 

18 various lamp types to deliver various types of 

19 utility lighting.

20 FACILITATOR BROOKMAN: Right.

21 MR. GREEN: I'll put it that way 

22 for our customers. And the customers are 
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1 demanding that. So if we don't have that 

2 variety of lamp available to us it would 

3 really limit the type of luminaire we can 

4 deliver to the customer.

5 FACILITATOR BROOKMAN: Many 

6 different functions.

7 MR. GREEN: Yes. 

8 FACILITATOR BROOKMAN: Many 

9 different kinds of utility accompanying those 

10 different functions.

11 MR. GREEN: Exactly. Thank you.

12 FACILITATOR BROOKMAN: Jeff Harris.

13 MR. HARRIS: Thank you. Jeff 

14 Harris, Alliance to Save Energy. I apologize 

15 if this might be something that is in the 

16 documentation already that I missed. But 

17 picking up on the comment, Joe, that you made 

18 about the higher light output I guess I have a 

19 twofold question and that is if the market 

20 decides to deliver equivalent output with 

21 higher efficacy, lower wattage, how does that 

22 lower wattage range or how would that affect 
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1 the efficacy of those lamps? Would they still 

2 be the same efficacy using these technologies 

3 or would they be lowered?

4 I guess the second question -- You 

5 might want to comment on both of them -- is 

6 whether there's a way to think about the added 

7 lighting system losses if instead of a lower 

8 output lamp a dimmer is used and it is in fact 

9 dimmed to maintain that level of output.

10 FACILITATOR BROOKMAN: Joe.

11 MR. HOWLEY: Jeff, I'm not sure I 

12 completely understand your question. I guess 

13 I'll try to answer it in this way. If a new 

14 standard is set specifically on R lamps or ER 

15 lamps or both, it would increase the 

16 efficiency. So the wattage would go down. 

17 For instance, instead of a 65 watt BR30, the 

18 same light output might be generated from a 60 

19 watt or a 55 watt. I'm not sure what wattage. 

20 It would be some lower wattage with the 

21 halogen technology or some type of halogen 

22 technology producing the same light output as 
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1 the lamps we have today but at lower wattage. 

2 So it would be more efficient R lamp products 

3 that would maintain the same utility and same 

4 light distribution.

5 The second part of that question --

6 I'm not sure if I answered your question 

7 correctly and perhaps if I haven't you can 

8 rephrase.

9 MR. HARRIS: I guess I was just 

10 looking at the limitation of the 40 watt.

11 MR. HOWLEY: Oh that.

12 MR. HARRIS: And the range DOE 

13 considered and for these lamps.

14 MR. HOWLEY: Okay. I didn't 

15 understand that.

16 MR. HARRIS: If instead the market 

17 were to use these technologies would this 

18 level of efficacy be achievable at lower 

19 wattage and the same lumen output?

20 MR. HOWLEY: Oh, I see. Even lower 

21 wattage. That technology has limited in terms 

22 of how low you can go with the wattage.
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1 FACILITATOR BROOKMAN: Keith.

2 MR. COOK: Keith Cook. Maybe what 

3 we ought to do is go back and look at those 

4 curves. The problem is you go down in lower 

5 wattages the efficiency also goes down. It's 

6 very consistent. All of the classes showed 

7 the same phenomena.

8 MR. HOWLEY: Also I understand from 

9 our engineers there's technical limitations to 

10 how low you can take -- You can still use 

11 those EL5/EL6 kind of levels and how low you 

12 can take that technology. There's limitations 

13 of how low you can go. You run into technical 

14 issues at real low wattages.

15 FACILITATOR BROOKMAN: Okay. Yes, 

16 Tim.

17 MR. BALLO: Tim Ballo, 

18 Earthjustice. If the Department sets a 

19 standard at one of the higher energy levels, 

20 it strikes me there's a potential for 

21 manufacturers to come out with something less 

22 than a 40 watt bulb that would be outside of 
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1 the scope of the standard. So I don't 

2 understand. I guess I recall that the 40 watt 

3 is a minimum wattage in the statute. But if 

4 the Department determines that that is likely 

5 to happen that you could be potentially 

6 creating a loophole for lamps less than 40 

7 watts. I would encourage the Department to 

8 explore standards for lamps that are less than 

9 40 watts or just extending the efficiency 

10 equations down below 40 watts finding that 

11 there's potential energy savings there.

12 FACILITATOR BROOKMAN: Okay.

13 Joe.

14 MR. HOWLEY: I guess just to 

15 comment on that. I would argue or suggest 

16 that that would not be a loophole. If 

17 manufacturers indeed created really low 

18 wattage lamps, isn't that the point? And if 

19 they're used in great numbers, you'd have 

20 significant energy savings.

21 FACILITATOR BROOKMAN: So a lot 

22 said on this subject. Anything final before 
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1 we move on?

2 MS. GUPTA: Well, can I just ask 

3 one question related to the different bulb 

4 shapes? So combining what you said about ER 

5 and R lamps, Joe, and what Pam said about BR 

6 versus PAR lamps, it sounds as though what's 

7 being suggested is taking this product class 

8 structure and creating even further divisions? 

9 Having maybe another set of divisions that 

10 groups BR together and ER and R together? Is 

11 that what is being suggested?

12 MR. HOWLEY: No, I don't believe 

13 that you need to separate -- You need to 

14 separate the diameter, but you don't need to 

15 separate ER from R from BR in terms of the 

16 efficiency.

17 MS. GUPTA: Okay.

18 MR. HOWLEY: The efficiency is very 

19 similar in terms of what you can get from 

20 these types of lamps.

21 MS. GUPTA: The three of them.

22 MR. HOWLEY: What we're suggesting 
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1 is that when you did your analysis and you 

2 were projecting your EL2, 3, 4, 5 and 6, you 

3 were clearly using curves from the PAR lamp 

4 standard. So it was obvious that this was 

5 based on the PAR lamp technology. And what 

6 we're saying is that's inappropriate to try to 

7 apply a PAR lamp technology efficiency to R 

8 lamps.

9 MS. GUPTA: Okay.

10 MR. HOWLEY: You need to -- Your EL 

11 2, 3, 4, 5, and 6 have to be what is capable 

12 using R lamp technology and the curves have to 

13 be based on R lamp or ER lamp technology. 

14 Within this technology you could use the same 

15 curve for the same similar diameter.

16 FACILITATOR BROOKMAN: Keith.

17 MR. COOK: Keith Cook. How about 

18 if in our written comments we provide some 

19 recommended product classes?

20 MS. GUPTA: That would be great.

21 FACILITATOR BROOKMAN: Okay. Good. 

22 Yes, Ali.
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1 MS. LEHR: I was just wondering if 

2 you had a halogen ER/R lamp and a halogen PAR 

3 lamp. Is there an average percent difference 

4 in efficiency? You know, if you were looking 

5 at these -- If our ELs are based on PAR lamps, 

6 is there a certain percent reduction that you 

7 would suggest using?

8 FACILITATOR BROOKMAN: Brian.

9 MR. VEDDER: Brian Vedder. Yes, 

10 there are somewhere between 15 to 20 percent 

11 less from the published catalog values. For 

12 instance, if you look at a 40 PAR 30, then 

13 that has about 720 lumens in an IRC lamp, an 

14 IR lamp. And an IRC BR has about 610 lumens. 

15 So there's a pretty significant difference 

16 between the two.

17 FACILITATOR BROOKMAN: Did you --

18 Did I hear correctly? Did you say as a 

19 deviation from the published values?

20 MR. VEDDER: No.

21 FACILITATOR BROOKMAN: Or is it the 

22 published values?
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1 MR. VEDDER: Using the published 

2 values.

3 FACILITATOR BROOKMAN: Thank you. 

4 Okay.

5 MR. HOWLEY: What Brian was saying 

6 is that there's about approximately a 20 --

7 And those are going to have different life 

8 ratings as well. If you look at the same life 

9 rating or you normalize them on a same life 

10 rating, it appears to be approximately a 20 

11 percent reduction in efficiency when you go to 

12 the R lamp or ER lamp efficiency versus what 

13 is possible with PAR lamp efficiency.

14 In other words, when you use the 

15 same technology internally and you measure 

16 lumens, you are going to get about 20 percent 

17 more lumens out of a PAR lamp than you are out 

18 of a reflector lamp. There are limitations to 

19 how efficient this reflector is versus how 

20 efficient we can make a PAR lamp reflector. 

21 We simply can do a better job with reflector 

22 technology with PAR lamps than we can with 
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1 blown glass where we silverize the interior of 

2 blown glass.

3 FACILITATOR BROOKMAN: Pam.

4 MS. HORNER: Pam Horner. And lest 

5 the next comment I predict would come up is, 

6 well, if the PAR shape is that much more 

7 efficient why wouldn't we simply abandon the 

8 BR. That was the point of the demonstration.

9 FACILITATOR BROOKMAN: Right.

10 MS. HORNER: So maybe we are 

11 zeroing in on with more clarity the point of 

12 the demonstration which is there still remains 

13 particularly in residential application how 

14 utility for broad distribution filament lamp 

15 technology which is capable of being achieved 

16 with BR shape and is very different in 

17 character with a PAR shape.

18 FACILITATOR BROOKMAN: John.

19 MR. GREEN: Yes, I think it's 

20 important for me to clarify that my statement 

21 was based on the fact that we foresaw the 

22 elimination of all the other reflector lamps 
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1 other than the PAR lamp and that was our 

2 concern as a luminaire manufacturer. So I may 

3 not have made that clear in my first 

4 statement.

5 FACILITATOR BROOKMAN: Thank you.

6 MR. GREEN: Thank you.

7 FACILITATOR BROOKMAN: Okay. So I 

8 think we're ready to move on then. Are we? 

9 Yes. Okay.

10 MS. GUPTA: All right. And lastly, 

11 I'll discuss the product price determination. 

12 For this rulemaking, DOE plans on taking a 

13 very similar approach to that which was taken 

14 in the July 2009 final rule where prices were 

15 developed by discounting blue book or 

16 manufacturer list prices to develop high 

17 range, medium range and low range and user 

18 retail prices. And if a higher efficacy 

19 replacement lamp analyzed in the engineering 

20 analysis was not commercially available, DOE 

21 applied the incremental price difference 

22 associated with that technology to develop a 
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1 price for that lamp replacement.

2 In addition, DOE applied weighted 

3 average sales tax data by region based on 

4 local data from sales tax clearinghouse. And 

5 I'd like to open the floor for comment on the 

6 product price determination.

7 FACILITATOR BROOKMAN: Brian.

8 MR. VEDDER: Brian Vedder. NEMA 

9 strongly recommends the use of the lowest 

10 average retail price when doing the analysis 

11 since consumers are buying this product 

12 primarily based on the lowest price point. 

13 This represents also the highest volume sales 

14 channel. As we mentioned before, the roughly 

15 70 to 75 percent of the market that uses the 

16 BR lamp is a consumer product. And this also 

17 acknowledged by the DOE in the framework 

18 document section 2.9.3. Thank you.

19 FACILITATOR BROOKMAN: Thank you.

20 MR. HOWLEY: This is Joe Howley. 

21 This would vary again from the PAR lamp 

22 analysis where the median price was picked as 
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1 that lamp is primarily commercial lamp with a 

2 lot of different price points. And it made 

3 sense to use a median price.

4 With the reflector lamp, it's 

5 primarily a consumer lamp and consumers 

6 typically buy it at big box stores and other 

7 mass merchandisers who are known for their low 

8 pricing strategies and this is where the 

9 majority of these types of products are 

10 purchased. So it makes more sense to use a 

11 typical price that a mass merchant sold to a 

12 consumer which tends to be a low price point 

13 because of their buying power.

14 MR. CYMBALSKY: This is John 

15 Cymbalsky. Would you have data on how those 

16 sales are portioned out between big box stores 

17 and other retailers? Is that part of the NEMA 

18 data that you'll be providing? I think it 

19 would help us verify the position you have on 

20 the price end.

21 MR. HOWLEY: We have some of that 

22 data, not quite to that detail. Although we 
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1 may -- individual companies may have more data 

2 on customer sales. NEMA would have to do a 

3 special survey to get down to that level. We 

4 have a survey now, our statistical program, 

5 where we show incandescent lamps sold through 

6 various retail channels. But we'd have to 

7 break that down to the reflector lamp level.

8 FACILITATOR BROOKMAN: Pam.

9 MS. HORNER: Pam Horner. I think 

10 one very appropriate place to help you is in 

11 the individual manufacturer interviews. Are 

12 you going to be doing those?

13 MS. GUPTA: Yes, we will be.

14 MS. HORNER: Because in those 

15 interviews we're always happy to share the 

16 price points and such for our own companies 

17 and I think it works out quite well in that 

18 particular venue. So that might be the place.

19 MR. VEDDER: Okay. Thank you.

20 FACILITATOR BROOKMAN: Okay. 

21 Thanks.

22 MS. GUPTA: All right. Now I'll 
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1 turn it over -- Is it time for a break, Doug?

2 FACILITATOR BROOKMAN: Okay. 

3 Fifteen minute break now sounds good. It's 

4 10:15 a.m. We'll resume at 10:30 a.m. Make 

5 sure you wear your badge inside the building. 

6 There's a coffee shop all the way down to the 

7 ground floor. Dunkin Donuts is there. And if 

8 you're going to go to the other cafeteria, you 

9 need to go quickly because it's a haul and to 

10 get back here in 15 minutes. We'll resume at 

11 10:30 a.m. And thanks. We've really covered 

12 a lot of ground already. We'll proceed with 

13 this at 10:30 a.m. Off the record.

14 (Whereupon, a short recess was 

15 taken.)

16 FACILITATOR BROOKMAN: On the 

17 record. So let's start back up. Please take 

18 your seats. Next we're going to hear about 

19 energy use and life-cycle cost and payback 

20 period analysis. Matt Hartley.

21 MR. HARTLEY: Thank you. My name 

22 is Matt Hartley. I'll be speaking with you 
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1 about the energy use, the LCC and payback 

2 period.

3 The Department uses the energy use 

4 analysis to estimate energy consumption of 

5 baseline and higher-efficacy lamps. This 

6 energy consumption is used in the life-cycle 

7 cost, payback period and national impact 

8 analysis.

9 To calculate energy usage, we take 

10 the operating hours of the lamp times the lamp 

11 wattage. These operating hours come from DOE 

12 surveys including the Lighting Market 

13 Characterization, Commercial Building Energy 

14 Consumption Survey and the Residential Energy 

15 Consumption Survey. These surveys allow DOE 

16 to account for variation in annual operating 

17 hours by building type and lighting 

18 application across census divisions and large 

19 states. The table here shows the average 

20 operating hours for the commercial and 

21 residential sectors that were determined for 

22 the July 2009 final rule.
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1 At this time, DOE would welcome any 

2 comments on the methodology for determining 

3 energy usage.

4 FACILITATOR BROOKMAN: Brian.

5 MR. VEDDER: A little out of order. 

6 Brian Vedder. We strongly recommend that DOE 

7 uses the residential hours with respect to the 

8 ER, BR and PAR type lamps.

9 FACILITATOR BROOKMAN: Thank you.

10 Yes, Pekka.

11 MR. HAKKARAINEN: Pekka 

12 Hakkarainen. I would also like to note that 

13 the use of lighting controls can have a 

14 significant effect on energy use even in 

15 residential applications. There is a little 

16 bit of data available, not a whole lot, on 

17 residential applications.

18 Just for your information, NEMA has 

19 started working on a better residential 

20 lighting control energy study to develop such 

21 data, but I would like to certainly suggest 

22 that DOE take into account the use of lighting 
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1 controls for these lamps. We estimate that 

2 there are about 15 to 20 percent of the 

3 residential reflector lamps, for example, 

4 operated by dimmers. And this represents 

5 something like 70 million lamps in the 

6 sockets.

7 And one final note is that we have, 

8 NEMA has, been working with some of the NGOs 

9 such as Jeff Harris who was here earlier in 

10 this room to develop residential energy code 

11 requirements that acknowledge the use of 

12 lighting controls in those applications, codes 

13 such as the International Energy Conservation 

14 Code or Title 24 of the California Code of 

15 Regulations. And NEMA will, of course, be 

16 happy to work with DOE to determine how this 

17 could be done.

18 Thank you.

19 FACILITATOR BROOKMAN: Would there 

20 be a comment confirming the use of the hours 

21 listed here for commercial and residential? 

22 No need to comment on that?
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1 Joe.

2 MR. HOWLEY: We agree with the 

3 hours presented for commercial and 

4 residential. We would just suggest using the 

5 residential hours as the primary basis for 

6 analysis.

7 FACILITATOR BROOKMAN: Right. 

8 Gotcha. Okay.

9 Yes please. Pekka.

10 MR. HAKKARAINEN: Pekka 

11 Hakkarainen. Just to be clear, the hours that 

12 are shown here are the typical average hours 

13 in residential. If lighting controls are 

14 used, controls such as vacancy sensors or 

15 timer switches or dimmers for that matter, the 

16 effective hours are reduced when that is done. 

17 So some percentage of these lamps -- we 

18 estimate 15 to 20 percent -- would merit the 

19 consideration of lighting controls.

20 FACILITATOR BROOKMAN: Okay. Thank 

21 you.

22 MS. GUPTA: Doug, can I ask a 
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1 question?

2 FACILITATOR BROOKMAN: Sure. Mimi.

3 MS. GUPTA: Mimi Gupta. Pekka, you 

4 mentioned that you are aware of a couple of 

5 residential studies. In your written 

6 comments, could you just make note of those? 

7 That would be very helpful.

8 MR. HAKKARAINEN: Okay. We'll 

9 include them in the written comments. Thank 

10 you.

11 FACILITATOR BROOKMAN: Thank you.

12 So Matt.

13 MR. HARTLEY: Okay. So now I'll 

14 discuss the life-cycle cost and payback period 

15 analysis. So the life-cycle cost and payback 

16 period is used to assess the impacts on a 

17 consumer due to energy conservation standards. 

18 It's conducted from the consumer's perspective 

19 and shows the cost of owning and operating the 

20 lamp over its lifetime.

21 As indicated in the diagram below, 

22 the LCC considers two components - The first 
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1 cost, which is purchase price and 

2 installation, and the operating cost 

3 discounted to present value. When 

4 appropriate, DOE calculates a residual value 

5 for the remaining useful life of a lamp at the 

6 end of the analysis period. 

7 This allows DOE to calculate the 

8 total life-cycle cost for each standard level 

9 considered. Results are then expressed as LCC 

10 savings or the baseline LCC minus the 

11 standards-level LCC. A payback period is also 

12 calculated and reported.

13 So I'll now discuss some key inputs 

14 and the methodology used to calculate the LCC 

15 and payback period, which is very similar to 

16 what was done in the July 2009 final rule. 

17 So, as mentioned previously, the life-cycle 

18 cost is derived from total installed price and 

19 the total operating cost discounted to present 

20 value.

21 The total installed price is made 

22 up of purchase price, which includes product 
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1 price and sales tax, and the installation 

2 cost. DOE could potentially use different 

3 prices for the commercial and residential 

4 sector as was discussed earlier.

5 Second, the total operating cost is 

6 made up of the electricity consumption, as 

7 explained in the energy use analysis 

8 previously, and the electricity cost. Then 

9 DOE uses a discount rate to calculate the 

10 present value of any cash flows over the 

11 analysis period. The discount rate is 

12 calculated separately for the residential and 

13 commercial sector and the analysis period is 

14 the lamp service life in years and is 

15 determined by dividing the lamp's total life 

16 time in hours by the annual operating hours 

17 derived in the energy use analysis.

18 For installation costs, as we 

19 mentioned previously, installation costs are a 

20 component of the total installed cost. As was 

21 done in the July 2009 final rule, DOE plans to 

22 calculate an installation cost for the 
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1 commercial sector, but assumes no installation 

2 cost for the residential sector. Installation 

3 cost is the product of the average labor cost 

4 and time needed to install the lamp.

5 DOE proposes to use “RS Means 

6 Electrical Cost Data of 2007” and data from 

7 the US Bureau of Labor Statistics, as was done 

8 in the July 2009 final rule, to estimate 

9 installation costs. These estimate an average 

10 labor time of approximately four minutes and 

11 average labor rate of $16.55.

12 This slide is not in your deck. It 

13 was added at the last minute. But we want to 

14 receive some comment.

15 DOE plans to consider different 

16 purchasing events in the life-cycle cost and 

17 payback period analysis. The two events 

18 considered are new construction or renovation 

19 and lamp replacement. As you saw in the 

20 engineering analysis, several higher-efficacy 

21 replacements have a higher lumen output than 

22 the baseline.
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1 DOE is considering that the spacing 

2 of fixtures can be altered during new 

3 construction and renovation to include fewer 

4 lamps and maintain the same total lumen 

5 output. As such, DOE is considering 

6 normalizing total lumens for the new 

7 construction and renovation event. DOE does 

8 not plan to normalize lumens for the lamp 

9 replacement event because consumers cannot 

10 alter the existing lamp fixtures.

11 DOE welcomes comment on this 

12 proposal.

13 FACILITATOR BROOKMAN: Joe.

14 MR. HOWLEY: Okay. Interesting 

15 proposal. This is Joe Howley. The issue with 

16 this, it's interesting because your new 

17 construction/renovation concept is that you 

18 would be able to space these fixtures further 

19 apart simply because the PAR lamps would have 

20 more lumens.

21 The fallacy of this concept is that 

22 PAR lamps have a much tighter beam 
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1 distribution associated with them than R 

2 lamps. So in fact with R lamps you would be 

3 able to space the fixtures further apart 

4 because of the much broader distribution. But 

5 indeed even though you were getting more light 

6 out of PAR lamp you would not -- In fact, 

7 you'd probably have to space them closer.

8 If you passed a regulation that was 

9 so high that you knew that R lamps were going 

10 away and you only had PAR lamps left, you 

11 would actually have to space the fixtures 

12 closer rather than further apart because the 

13 beam distribution is so tight on them. To get 

14 a uniform distribution of light below, you 

15 would have to move in. You would definitely 

16 not be able to space them further apart in a 

17 new construction scenario. And it has to do 

18 with the optics of the utility of the 

19 products. It could only be done 

20 theoretically, but in actuality you wouldn't 

21 be able to get the proper beam distribution.

22 MR. HARTLEY: Thank you.
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1 FACILITATOR BROOKMAN: Other? Yes, 

2 Lane.

3 MR. BURT: Lane Burt, NRDC. It 

4 seems like DOE is kind of wrangling with a lot 

5 of questions about the sophistication of the 

6 consumer and this is another one. The 

7 sophistication of the consumer to tell between 

8 an R lamp and a PAR lamp is another issue that 

9 the Department is having to deal with. And we 

10 certainly support trying to make the model 

11 reflect reality as much as possible. It's not 

12 going to be 100 percent. Disregard the 

13 differences, it's not going to be zero 

14 percent. They all take into account the 

15 differences.

16 But to the extent that the 

17 Department can look for outside data sources, 

18 talk to some renovation contractors and try to 

19 get a percentage of how many folks actually do 

20 a lighting redesign when they do a renovation. 

21 That would be helpful. And I'd just encourage 

22 the Department to look for outside data 
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1 sources for this tough decision that is going 

2 to have to be made over and over again.

3 MR. HOWLEY: And, Lane, to that 

4 point, I’d talk to some lighting designers, 

5 residential or commercial lighting designers, 

6 and I think they would validate the point that 

7 I raised.

8 FACILITATOR BROOKMAN: Okay. Thank 

9 you.

10 I thought I saw somebody else. 

11 Yes, Lane.

12 MR. BURT: One other point. Lane 

13 Burt again. It's just that the consumer is 

14 now also going to be finding the decision an R 

15 and PAR when they're doing a light design. 

16 There are CFL reflector lamps. There are 

17 other types of lamps. So that needs to factor 

18 in especially if the consideration is on how 

19 broad the beam is and where the lights are 

20 going to be spaced. They may decide to go a 

21 different direction altogether.

22 FACILITATOR BROOKMAN: Pam.
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1 MS. HORNER: Pam Horner. Are we on 

2 item 10? It doesn't have an item number.

3 MS. MAUER: This is a new item. 

4 MS. HORNER: So this is item X. 

5 Thank you.

6 FACILITATOR BROOKMAN: And since 

7 this is not in your slide deck, I want to make 

8 sure to give everybody a chance to look at 

9 this and comment as they wish. Anything else? 

10 If nothing else, okay.

11 (No verbal comment.)

12 MR. HARTLEY: Okay. To calculate 

13 operating costs, we must multiply energy 

14 consumption by energy prices. DOE calculates 

15 average electricity prices for 13 geographic 

16 areas by examining electric utility data. 

17 This data is available from the Energy 

18 Information Administration's Form EIA-861 

19 which allows DOE to calculate the current 

20 electricity price in each geographic region 

21 for the residential and commercial sectors.

22 DOE then uses this current 
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1 electricity price to project electricity 

2 prices using the Annual Energy Outlook. DOE 

3 applies the trend seen in the Annual Energy 

4 Outlook to the current price to project future 

5 electricity prices.

6 Once all the cash flows are 

7 determined, DOE uses a discount rate to 

8 calculate the present value of expenses over 

9 the analysis period. Discount rates are based 

10 on the interest or finance cost to purchase 

11 and operate products. This finance cost can 

12 either be the cost of the debt or the 

13 opportunity cost of equity used to purchase 

14 and operate lamps.

15 The discount rate, like many other 

16 components of the life-cycle cost and payback 

17 period analysis, uses a methodology similar to 

18 what was done in the July 2009 final rule. 

19 DOE welcomes comment on all aspects of the 

20 life-cycle cost and payback period analyses.

21 FACILITATOR BROOKMAN: Yes. Keith.

22 MR. COOK: Keith Cook. NEMA would 
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1 like to caution the DOE on the three year 

2 rebuttable presumption that you have got 

3 included in the information. And the problem 

4 we've got with it is if the life of the 

5 product is only two years then the three year 

6 rebuttable presumption no longer makes any 

7 sense.

8 So therefore we'd recommend they 

9 either use a two year payback as the 

10 rebuttable presumption or the life of the 

11 product, one or the other.

12 FACILITATOR BROOKMAN: Okay.

13 Joe.

14 MR. HOWLEY: And just to add 

15 agreement to the electricity pricing analysis, 

16 we would agree that that is an acceptable way 

17 to determine electricity prices.

18 FACILITATOR BROOKMAN: And I just 

19 want to clarify. Keith, you were speaking on 

20 behalf of NEMA just a moment ago?

21 MR. COOK: Yes.

22 FACILITATOR BROOKMAN: You were. 
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1 Yes. Thank you. Okay.

2 So then other comments on this 

3 inquiry, this comment box 10? These issues 

4 related to LCC and payback period analysis?

5 (No verbal comment.)

6 Okay.

7 MR. HARTLEY: All right. At this 

8 time I'll pass it off to Ali who will speak 

9 about shipments and the national impact 

10 analysis.

11 MS. LEHR: My name is Ali. I'm 

12 going to be talking about shipments and the 

13 national impact analysis.

14 So the purpose of the shipments 

15 analysis is to estimate the shipments of 

16 exempted lamps and the product mix of the 

17 stock over the entire analysis period. This 

18 is done for both the base case, which is the 

19 case absent any standards for the exempted 

20 lamps, and the standards case.

21 The NIA uses the shipment and stock 

22 estimates to determine national energy savings 
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90

1 and net present value at various standard 

2 levels. It's important to note that the 

3 rulemaking only calculates energy savings for 

4 consumers of exempted lamps.

5 To calculate installed stock and 

6 shipment forecasts, DOE plans to use the same 

7 methodology as the July 2009 Lamps Rule. In 

8 that rule, DOE used historical shipments and 

9 the average service lifetime to calculate 

10 installed stock. DOE then applied growth in 

11 floor space and assumptions regarding emerging 

12 technologies to forecast the stock over the 

13 analysis period.

14 For this rule, DOE plans to use the 

15 latest versions of RECS and CBECS to determine 

16 the anticipated growth in the number of IRL 

17 sockets in the residential and commercial 

18 sectors. After forecasting the installed 

19 stock, DOE then calculated the shipments 

20 required to meet that stock, which would 

21 include shipments due to both new construction 

22 and lamp replacement events.
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1 As I mentioned, DOE plans to use 

2 historical shipments to calculate the 

3 installed stock. NEMA submitted shipments as 

4 part of the July 2009 Lamps Rule that were 

5 disaggregated by halogen and non-halogen lamp 

6 shipments. As part of that rule, DOE applied 

7 several assumptions to further characterize 

8 the market. DOE plans to use the same 

9 assumptions in this rule and they are 

10 summarized here on this slide. Based on 

11 manufacturer interviews, DOE assumes that the 

12 NEMA shipments represent 70 percent of all 

13 non-halogen IRL shipments.

14 EISA 2007 set standards applicable 

15 to some IRL, yet exempted others which are now 

16 the subject of this rulemaking. DOE assumes 

17 that the exempted lamps represent 60 percent 

18 of all non-halogen IRL shipments in 2005. And 

19 last, DOE believes that 33 percent of non20 halogen IRL go to the commercial sector, where 

21 67 percent go to the residential sector.

22 DOE requests comment on these 
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1 assumptions and also on the market share of 

2 the 65 watt and 45 watt baseline lamps that 

3 were selected in the engineering analysis.

4 FACILITATOR BROOKMAN: Pam Horner. 

5 Okay. Joe. Sorry. You all are so well 

6 organized today. This is really --

7 MR. HOWLEY: This is Joe Howley. 

8 Question as to if your IRL analysis was based 

9 on all reflector lamps or was it simply based 

10 on the exempted reflector lamps?

11 MS. LEHR: You mean the analysis 

12 for --

13 MR. HOWLEY: Yeah. These 

14 percentages that you're showing up here, was 

15 it based on both types of lamps or was it just 

16 based on only the exempted reflector lamps?

17 MS. LEHR: Just the exempted. 

18 Well, I guess the non-halogen IRL probably 

19 would -- Well, I guess it would be --

20 FACILITATOR BROOKMAN: Mimi.

21 MS. GUPTA: Yes, Mimi Gupta, 

22 Navigant Consulting. So NEMA submitted data 
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1 from 2001 to 2005 and it was disaggregated by 

2 R incandescent and PAR incandescent.

3 MR. HOWLEY: Okay.

4 MS. GUPTA: Which was a little 

5 confusing to us because it was our 

6 understanding that most PARs were regulated at 

7 a high enough efficacy already to be halogen. 

8 So we took all of those incandescents, the R 

9 incandescent plus the PAR incandescent, and we 

10 tried to estimate what portion of those 

11 remained exempt when EISA added new coverage. 

12 So EISA took some of those incandescents and 

13 made them halogen. And what portion remained 

14 exempt and that's what that 60 percent 

15 represents. That's 60 percent of the R 

16 incandescent plus PAR incandescent are the 

17 exempted lamps.

18 MR. HOWLEY: Okay. So we may want 

19 to reanalyze that data to see if those 

20 percentages are still valid or accurate.

21 FACILITATOR BROOKMAN: You think 

22 the market shifted or you think that 
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1 something's happened there?

2 MR. HOWLEY: Well, it could be that 

3 the reflector lamp market which is really what 

4 we're talking about regulating here is more 

5 heavily residential even than the 67 percent 

6 suggests. But that may be something that we 

7 want to look at a little further within our 

8 own groups. It's certainly heavily 

9 residential at least 67 percent and maybe 

10 higher.

11 FACILITATOR BROOKMAN: And you can 

12 see also the Department requests information 

13 on market shares of 65 watt and 45 watt.

14 MR. HOWLEY: Again, that's 

15 information that we could work with our NEMA 

16 statistical department to perhaps develop a 

17 special survey. If you require specific data, 

18 it might be beneficial perhaps working with 

19 Navigant or DOE to get all of the questions on 

20 the table where data is needed and then we 

21 could talk to the NEMA statistical department 

22 about collecting a special survey to provide 
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1 that data of where the market is today.

2 FACILITATOR BROOKMAN: Just do one 

3 survey.

4 MR. HOWLEY: One survey on all the 

5 questions that have to do with market share. 

6 We would be willing to work with you on those.

7 FACILITATOR BROOKMAN: Okay.

8 MR. HOWLEY: I always feel it's 

9 better to work with accurate, current data 

10 than projected data. It always seems to be 

11 better.

12 FACILITATOR BROOKMAN: The 

13 Department likes that. They really do.

14 MR. HOWLEY: The only other comment 

15 and this is just a general comment on DOE's 

16 method or maybe it's a requirement, I'm not 

17 sure, to project out over 30 years for energy 

18 savings. It still seems to us that this is 

19 not a practice that can lead to any kind of 

20 accurate energy savings assumptions over 30 

21 years.

22 In particular, this product line I 
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1 believe is subject to another rulemaking 

2 sometime in the future, perhaps by 2020. And 

3 we can look exactly. I don't know if I have 

4 that date right or not. We could check the 

5 rulemaking process to see when another 

6 rulemaking is scheduled. At the very least, 

7 there is talk within the National Energy 

8 building debated right now of requiring 

9 another rulemaking on these types of products.

10 So it's our belief that another 

11 rulemaking will occur one way or another on 

12 these products, probably in the next ten 

13 years. And given that that next rulemaking is 

14 likely to have a significant impact on these 

15 products, it would only seem prudent to 

16 estimate energy savings over the next ten 

17 years because this rulemaking is likely to 

18 generate energy savings of ten years or at 

19 least to the next rulemaking.

20 If you're to project energy savings 

21 over 30 years and then do another rulemaking 

22 and project another 30 years energy savings, 
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1 you're really double or triple counting the 

2 energy savings from each of these rulemakings. 

3 That would be our estimate. It would seem 

4 that you should project energy savings up 

5 until you expect the next rulemaking and the 

6 next rulemaking could project energy savings 

7 from that rulemaking.

8 Given the fact that you don't know 

9 what the next rulemaking will be, it really is 

10 just a guess, a wild guess, as to what may 

11 occur beyond when the next rulemaking occurs.

12 FACILITATOR BROOKMAN: Pam Horner.

13 MS. HORNER: My data showed that a 

14 2015 DOE rulemaking will set new standards for 

15 all reflector lamps effective 2018.

16 FACILITATOR BROOKMAN: Okay.

17 Other comments on several important

18 assumptions here? And other comments on these 

19 assumptions?

20 (No verbal response.)

21 Okay.

22 MS. LEHR: To account for the 
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1 market penetration of other relating 

2 technologies in the IRL market, DOE plans to 

3 model two base case scenarios similar to those 

4 modeled in the July 2009 Lamps Rule. The 

5 first is the existing technology scenario, 

6 which forecasts the market penetration of 

7 technologies that are currently available and 

8 have reached maturation in terms of price and 

9 efficacy, such as reflector CFLs.

10 The second is an emerging 

11 technologies, which forecast both the 

12 penetration of mature technologies and those 

13 that are still undergoing significant changes 

14 in price and efficacy. This would include 

15 reflector CFLs, LEDs and ceramic metal 

16 halides.

17 To establish the market penetration 

18 forecast, DOE estimated the price and 

19 performance of the alternative technologies 

20 over the analysis period. DOE then calculated 

21 the payback period of each alternative 

22 compared to IRL. And last DOE used a 
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1 relationship between payback period and market 

2 penetration to determine the forecasts.

3 So this graph illustrates how the 

4 existing and emerging technology scenarios 

5 might affect shipments. For the emerging 

6 technology base case, there is initial decline 

7 in shipments followed by a slight increase.

8 In this scenario, there is a large 

9 increase in the market penetration of other 

10 technologies, primarily LEDs, at the beginning 

11 of the forecasted period lasting until about 

12 2020. After that point, the market 

13 penetration remains fairly constant.

14 We see an increase in shipments 

15 later in the analysis period due to overall 

16 growth in the IRL market. In the July 2009 

17 Lamps Rule, some stakeholders commented that 

18 this increase was unlikely and DOE requests 

19 comments now on how to model the existing and 

20 emerging technology scenarios and also what 

21 the most likely scenario is.

22 MS. HORNER: If only we knew.
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1 MR. HOWLEY: This is Joe Howley 

2 again. Yeah, it just doesn't seem logical to 

3 us that this technology would continue to grow 

4 at those types of rates given everything that 

5 we know is happening with residential building 

6 codes, commercial building codes, 

7 technologies.

8 The technologies coming into this 

9 market we expect over the next ten years LED 

10 technology to come into this market. We 

11 expect -- in fact it's here today, but it will 

12 further developed and less expensive in ten 

13 years. Compact fluorescent lamp technology to 

14 improve, perhaps the ability to improve.

15 And those products all have 

16 extremely long lives. And as they get into 

17 the marketplace or required by building codes, 

18 it will have the effect of shrinking the 

19 available market for these products. And we 

20 think that will greatly moderate any growth 

21 beyond 2020. But also we bring back our point 

22 that it's extremely hard to guess and it's 
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1 really just a guess what's going to happen in 

2 this marketplace beyond 2020 given the rapid 

3 change we expect to happen with lighting 

4 technology over the next decade.

5 FACILITATOR BROOKMAN: Yes, Pekka.

6 MR. HAKKARAINEN: Pekka 

7 Hakkarainen. I just have a couple of 

8 questions to Ali regarding this graph so I 

9 understand what it says. First, the vertical 

10 axis shipment, is that units? Is that what 

11 it's intended to be?

12 MS. LEHR: Yes.

13 MR. HAKKARAINEN: Okay. And, 

14 secondly, the two base case forecast lines, 

15 are they alternate scenarios or do they exist 

16 at the same time?

17 MS. LEHR: They're alternate 

18 scenarios.

19 MR. HAKKARAINEN: Alternate 

20 scenarios. Okay. Thank you.

21 FACILITATOR BROOKMAN: I would just 

22 reflect back too. The Department has 
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1 requested your comments on how these scenarios 

2 might work or what would be a more plausible 

3 scenario? So if there's anybody that has a 

4 thought process on that, I think that would be 

5 helpful.

6 MR. HOWLEY: This is Joe Howley 

7 again. I think the emerging technologies is 

8 probably more likely to happen especially the 

9 downward trend to 2020. Any analysis beyond 

10 2020, 2025 is really speculative. That's all 

11 I can say.

12 But if you take our advice or 

13 suggestion to look at energy savings or model 

14 this just to the next rulemaking, I think you 

15 can get a much more -- much closer to reality 

16 and maybe you have to do both. I would 

17 suggest doing one, saying we believe this to 

18 be a fairly accurate assessment. Projecting 

19 beyond this you might even note is really 

20 difficult to do because of the pending 

21 expected new rulemaking in 2018 and not 

22 knowing exactly where that standard will set 
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1 efficiency levels and what products will 

2 remain after that standard.

3 If you have to do a 30 year 

4 analysis, it just has to be caveated I think 

5 with a lot of "We have no idea how accurate 

6 this analysis may or may not be."

7 FACILITATOR BROOKMAN: Final 

8 comments?

9 (No verbal comments.)

10 MS. LEHR: So DOE is also 

11 considering other shipment scenarios for this 

12 rulemaking. DOE is considering modeling the 

13 impact of the July 2009 Lamps Rule. As those 

14 standards take effect in 2012, there may be an 

15 increase in the shipments of exempt IRL if 

16 consumers subject to those standards choose to 

17 purchase the cheapest lamp available.

18 DOE is also considering modeling a

19 migration to lower wattage lamps that are 

20 outside the scope of coverage of this 

21 rulemaking. A 40 watt lamp that is compliant 

22 with standards will likely be more expensive 
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1 and have a higher lumen output than a 38 or 39 

2 watt lamp that is not subject to standards.

3 DOE requests comments on both of 

4 these scenarios as well as any other scenario 

5 that stakeholders believe is likely to occur.

6 FACILITATOR BROOKMAN: Joe.

7 MR. HOWLEY: It's Joe again. We 

8 believe there will be an impact based on the 

9 2009 Lamps Rule. There will be some impact. 

10 However, the reflector lamp market that's low 

11 cost isn't likely to increase that much. 

12 There will be some impact.

13 But the PAR lamp market, the 

14 retailers using these, use these because 

15 they're more sophisticated and they recognize 

16 the cost of energy and they recognize the 

17 overall operating cost of a lighting system 

18 especially if they have thousands of these in 

19 stores that may be located throughout the 

20 United States. So they're much more likely to 

21 stick with the halogen PAR lamps (1) because 

22 they have a different functionality. They 
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1 want the highlighting. They need that 

2 highlighting to sell merchandise. So because 

3 they need that to be highlighted and they 

4 can't get that highlighting utility from a 

5 reflector lamp we don't expect many of them to 

6 switch.

7 Also they will be able to analyze a 

8 positive economic payback for them with these 

9 more efficient sources. And when DOE did 

10 their economic analysis, they modeled a more 

11 efficient payback considering cost of product 

12 plus energy savings from using these higher 

13 efficiency technologies.

14 Since this is primarily a 

15 residential lamp that we're talking about 

16 here, they're already using the lower cost 

17 lamp. And only a smaller percentage of them, 

18 a third or less, use the halogen PAR lamps 

19 today. Those third or less using halogen 

20 PARs, I suppose there is some risk of 

21 migration to a lower cost lamp on the consumer 

22 level.
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1 This will be offset by perhaps a 

2 migration to lower wattage lamps. Because if 

3 there is a migration to lower wattage lamps, 

4 of course that will produce national energy 

5 savings. So that may offset any migration 

6 from PAR lamps to reflector lamps.

7 I guess we would agree that it 

8 would be interesting to do both of these 

9 analyses to see if perhaps they offset or what 

10 the net effect of both of them might be.

11 FACILITATOR BROOKMAN: Okay.

12 Tim.

13 MR. BALLO: Tim Ballo, 

14 Earthjustice. Just on the notion that a 

15 migration down a few watts would produce 

16 national energy savings. If consumers have to 

17 increase the number of fixtures to compensate 

18 for reduction in lumen output, that would seem 

19 to cancel out those energy savings.

20 MR. HOWLEY: It would very 

21 unlikely. These are mostly used in down 

22 lights. It would be very unlikely that a 
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1 consumer would hire a contractor to put more 

2 holes in their ceiling and add more down 

3 lights. That's a very expensive thing to do. 

4 So I wouldn't expect them to be adding more 

5 down lights.

6 FACILITATOR BROOKMAN: Lane.

7 MR. BURT: This is Lane Burt. I 

8 would just note that consumers have access to 

9 many plug-in fixtures and that they can shift 

10 to whatever lighting source they like. We are 

11 concerned about both of these impacts and both 

12 of these effects and we encourage the 

13 Department to look for as much data as they 

14 can from sources outside this room to try to 

15 quantify and account for the analysis.

16 FACILITATOR BROOKMAN: You can see 

17 the two elements listed in the comment box. 

18 So any additional comments on those two?

19 (No verbal response.)

20 MS. LEHR: Okay. Well, this brings 

21 us to the end of the shipment analysis. And 

22 so DOE requests comments on this general 
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1 methodology, specifically on the historical 

2 shipment data and the assumptions presented to 

3 develop shipment forecasts, the market 

4 penetration of existing and emerging 

5 technologies and the shipment scenarios under 

6 consideration as well as any other comments on 

7 the shipments analysis. I know we've covered 

8 a lot already, but if there's anything else 

9 that remains left to be said.

10 FACILITATOR BROOKMAN: Nothing 

11 additional? We've covered it?

12 (No verbal comments.)

13 MS. LEHR: Okay. DOE is planning 

14 to use the same inputs and methodology as the 

15 July 2009 Lamps Rule to calculate national 

16 energy savings and net present value. The 

17 inputs for both are summarized on this slide.

18 For national energy savings the 

19 inputs are installed stock, unit annual energy 

20 consumption which have already been discussed 

21 in previous slides, electricity site to source 

22 conversion factors which are calculated using 
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1 the Annual Energy Outlook, HVAC interaction 

2 for which DOE plans to use 6.25 percent in the 

3 commercial sector, does not plan to model in 

4 the residential sector, the rebound rate for 

5 which DOE plans to use one percent in 

6 commercial and 8.5 percent in residential. 

7 For net present value, some of the inputs are 

8 shipments per unit installed cost, electricity 

9 prices and also two different discount rates 

10 as indicated by OMB guidelines.

11 And so DOE welcomes comments on its 

12 decision to use the same inputs and 

13 methodology as the July 2009 Lamps Rule as 

14 well as any other comments on the national 

15 impact analysis.

16 FACILITATOR BROOKMAN: Pam.

17 MS. HORNER: This is Pam Horner. 

18 The only comment, what we would like to 

19 reiterate, is that we urge the DOE to use a 

20 shorter, more realistic projection to 2018 or 

21 2020 rather than to 2043.

22 FACILITATOR BROOKMAN: Yes. Tim.
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1 MR. BALLO: Tim Ballo. I just had 

2 a question. Sorry if you explained this. Why 

3 was the HVAC impact not modeled in the 

4 residential sector or not expected to be?

5 MS. LEHR: In the Lamps Rule, we 

6 assumed that the effects on HVAC would be 

7 negligible in the residential sector. And so 

8 we chose not to include that effect there.

9 FACILITATOR BROOKMAN: Lane.

10 MR. BURT: Lane Burt. Is it 

11 possible to get a quick narrative just to 

12 refresh my memory on the rebound effect in the 

13 residential sector?

14 MS. LEHR: Sure. Well, I guess the 

15 rebound rate in general is you know you can 

16 calculate energy savings for a consumer using 

17 a more efficient product than another. But 

18 when they're actually using that more 

19 efficient product it's possible that their 

20 behavior might change. They might decide that 

21 now that they have a more efficient lamp it's 

22 not a big deal to turn it off when they don't 
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1 need and it might be left on a little bit 

2 longer. And so the actual operating hours 

3 increase and you don't realize all the energy 

4 savings you might think you would. DOE 

5 believed this would be more pronounced in the 

6 residential sector than the commercial.

7 MR. BURT: Yes, I'm familiar with 

8 the concept. I'm just wondering what fed into 

9 the development of 8.5 percent compared to --

10 I mean DOE has used five percent. DOE has 

11 used other numbers.

12 MS. LEHR: Sure. There was a 

13 summary of four different reports that was 

14 looked at in the July 2009 Lamps Rule. And we 

15 took the average of the range of values that 

16 was reported for each sector.

17 FACILITATOR BROOKMAN: Those 

18 sources were?

19 MS. LEHR: I don't have them handy, 

20 but I could look them up. They're in the TSD 

21 for the July 2009 Lamps Rule.

22 FACILITATOR BROOKMAN: Other 
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1 comments on this series of issues?

2 MR. HOWLEY: This is Joe. Just one 

3 more thing that occurred to me on the 

4 residential sector rebound rate is that if 

5 more efficient products were put in these down 

6 lights that perhaps previously were on dimmers 

7 and these products are no longer dimmable you 

8 would be getting energy savings from the 

9 dimmable products that were perhaps operated 

10 in a dim mode certain times. 

11 And you wouldn't get those same 

12 energy savings from, say, a compact 

13 fluorescent lamp that either would not be

14 dimmable or the energy savings would be 

15 greatly reduced because those products only 

16 are at 13 watts. So if you dim them, they 

17 only dim down a couple of watts even though 

18 the light output is going down. Whereas if 

19 you dim an incandescent lamp that's 65 watts, 

20 you might be saving 20, 30, 40 watts every 

21 time you dim it.

22 So the dimmer factor that Pekka has 
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1 mentioned a few times, 15 to 20 percent of 

2 these sockets being dimmable, to the extent 

3 that they move to more energy efficient 

4 products it might also have an impact on this 

5 rebound rate. Just a thought.

6 MS. LEHR: Thanks.

7 FACILITATOR BROOKMAN: No 

8 additional comments? 

9 (No verbal response.)

10 I want to call your attention to 

11 item 12 there one more time. DOE welcomes 

12 comments on the decision to use the same 

13 inputs and methodologies as the July 2009 

14 final rule. Any additional thoughts on that?

15 (No verbal response.)

16 MS. GUPTA: All right. We're in 

17 the home stretch. Now I'll just briefly 

18 discuss some of the other NOPR analyses that 

19 DOE plans on doing.

20 One of them is the manufacturer 

21 impact analysis where the purpose is to 

22 identify the impacts of energy conservation 
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1 standards on manufacturers and DOE conducts 

2 that in three phases, the first in which DOE 

3 creates an industry profile to characterize 

4 the industry and identify key issues in 

5 manufacturing. In phase two, DOE prepares an 

6 industry cash flow model called the GRIM or 

7 Government Regulatory Impact Model that takes 

8 into account any investment and revenue 

9 changes that the industry might experience and 

10 an interview questionnaire to guide interviews 

11 with manufacturers. And in phase three, DOE 

12 interviews manufacturers, assesses impacts of 

13 standards, both quantitatively and 

14 qualitatively, looking at impacts on 

15 competition, manufacturing capacity, 

16 employment and regulatory burden.

17 MR. BURT: Before we jump off 

18 manufacturing impact analysis, I just want to 

19 make a point that we made in July especially 

20 in the context of the emerging technologies 

21 slide that you put up there. This is a market 

22 that's in flux. There are a lot of new 
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1 technologies. There's a lot of new products. 

2 It's a little interesting to project 

3 manufacturer impact just looking at one 

4 particular division of a large company which 

5 may also make the replacement product should 

6 technology shift from one product to another.

7 So we would strongly suggest the 

8 Department look at the bigger picture versus 

9 throwing out large impact numbers that may not 

10 reflect reality as the technology changes.

11 FACILITATOR BROOKMAN: Thank you.

12 Pekka.

13 MR. HAKKARAINEN: Pekka 

14 Hakkarainen. An additional comment. Now I'm 

15 not representing NEMA because I haven't 

16 checked with my colleagues here on this 

17 comment. It seems to me that this is a 

18 systems issue as well. This is not just a 

19 lamp issue.

20 John Green spoke earlier about the 

21 impact on luminaries and I certainly said a 

22 couple of things about lighting controls. So 
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1 I would suggest that you consider also 

2 interviewing other manufacturers in the 

3 industry, not just the lamp companies. Thank 

4 you.

5 FACILITATOR BROOKMAN: Thank you.

6 MS. GUPTA: Okay. And the final 

7 content slide. On this slide we list several 

8 NOPR analyses that DOE will be conducting. 

9 This includes the life-cycle subgroup analysis 

10 where DOE analyzes life-cycle cost impacts on 

11 various national consumer subgroups, the 

12 utility impact analysis and environmental 

13 impact analysis where DOE uses NEMS to assess 

14 the impacts on generation capacity and the 

15 airborne pollutant emissions, the employment 

16 impact analysis which is different than the 

17 employment impact analysis that's conducted in 

18 the manufacturing impact analysis. That's a 

19 direct employment impact analysis. This is an 

20 indirect employment impact analysis. And then 

21 finally the regulatory impact analysis that 

22 looks at the impacts of nonregulatory 
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1 alternatives.

2 So the following few slides have 

3 many items for comment on the analyses that 

4 I've quickly gone over. I'm not going to go 

5 through each one of these, but we welcome any 

6 comments on those analyses both in written and 

7 verbal form.

8 FACILITATOR BROOKMAN: Pam Horner.

9 MS. HORNER: Pam Horner. NEMA 

10 agrees with item 13.

11 FACILITATOR BROOKMAN: Low income 

12 and senior citizens.

13 MS. HORNER: And for the remainder 

14 either have no comment at this time or will 

15 provide written comments on the balance. 

16 Particularly on the environmental, we have 

17 some expertise in that area and we have not 

18 consulted with those experts yet. So we will 

19 provide them written.

20 FACILITATOR BROOKMAN: Thank you.

21 Additional comments from anyone 

22 else? You can see seven comment boxes looking 
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1 ahead to the NOPR phase.

2 (No verbal comments.)

3 No additional comments at this 

4 time. Lane.

5 MR. BURT: Just a comment that my 

6 point earlier also implies to the employment 

7 analysis if you're looking at single divisions 

8 of companies.

9 FACILITATOR BROOKMAN: Okay.

10 MS. GUPTA: Do you want to close 

11 up?

12 FACILITATOR BROOKMAN: We should 

13 provide an opportunity for final comment as we 

14 promised at the outset. An opportunity for 

15 any person to raise additional issues, issues 

16 that did not get adequate coverage, that sort 

17 of thing now in the closing stages of this 

18 meeting. Yes.

19 MR. BALLO: Tim Ballo. I just had 

20 a follow-up question on the presentation that 

21 we had earlier from NEMA. It seems to me and 

22 I'm sorry if this is a dumb question. But it 
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1 seems to me that the focus of the light from a 

2 lamp would be the product of both the shape of 

3 the reflector and whatever change it goes 

4 through in the lens of the bulb. Is there 

5 some potential for altering the lens in such a 

6 way that you can sort of compensate for the 

7 way the reflector alters the lamp or does that 

8 -- Does messing with the lens reduce the 

9 efficacy sort of inherently?

10 FACILITATOR BROOKMAN: Joe.

11 MR. HOWLEY: Well, the technologies 

12 play off each other, but it is difficult, much 

13 more difficult, to get that light to spread 

14 out of a PAR lamp because the PAR lamp's 

15 natural inclination, the reflector, is to 

16 focus the beams in a very tight column. And 

17 then you're taking that tight focus and you're 

18 trying to unfocus it again. And, yes, there's 

19 efficiency losses when you're trying to again 

20 refocus the beam in a direction it doesn't 

21 want to go into. So it's much easier to make 

22 a reflector lamp with a soft distribution. 
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1 It's much harder to produce a PAR lamp with 

2 that kind of soft distribution.

3 FACILITATOR BROOKMAN: Pam.

4 MS. HORNER: Pam Horner and Brian 

5 may want to step in here since he is in the 

6 halogen product group for Philips. It's 

7 actually a good question.

8 In our particular case, our company 

9 provides -- I think the widest we've been able 

10 to get -- I think to date probably the widest 

11 beam on a PAR which is about 50 degrees and 

12 you have to do things as you suggest to the 

13 lensing to do that. You either have to frost 

14 it which slightly decreases efficacy or change 

15 the, as we call it, lenticular structure of 

16 the little globs of glass.

17 FACILITATOR BROOKMAN: The 

18 prismatics.

19 MS. HORNER: Yes, the prismatics 

20 are going on there. So I don't think it's a 

21 bad question at all. But that's about as wide 

22 as we've been able to get it.
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1 And if you take a BR -- If I'm 

2 remembering correctly, I think the 

3 distribution on a flood is about 90 degrees or 

4 so. There's a significant -- Even though you 

5 can get it a little wider, you just can't get 

6 it to the same broad distribution of a BR. 

7 FACILITATOR BROOKMAN: So in my 

8 kitchen I'll talk with you later.

9 (Laughter.)

10 MS. HORNER: Well, if you're 

11 interested I do have a kitchen example which 

12 is for real. I don't know if anyone's 

13 interested in this or not. Again, this is Pam 

14 Horner.

15 I have a kitchen with six down 

16 lights and this isn't the voice of -- I mean I 

17 am a sophisticated lighting user, but forget 

18 that. I also watch my bank account. So we 

19 have six down lights and we had 65 BR30s. And 

20 we decided to put in 50 watt halogen PARs in 

21 the widest flood possible. And as it happens 

22 there's a return as happens in many kitchens 
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1 on like a peninsula which is where my husband 

2 does his crossword puzzles.

3 Well, this is significant in that 

4 the light distribution which is not uncommon 

5 from a BR reached not only from the stove to 

6 the sink to the crossword puzzle but was 

7 evenly distributed across the kitchen. We put 

8 in the PAR lamps and the light beam fell short 

9 of the peninsula. So we actually had to add 

10 two fixtures and we didn't add down lights. 

11 We were very energy conscious and added some 

12 very low wattage pendants. But it happened to 

13 be exactly the same wattage addition that we 

14 had saved by putting in the 50 watts. And we 

15 do have them on dimmers, Pekka.

16 (Laughter.)

17 But the issue is that distribution 

18 matters and probably even if you weren't a 

19 sophisticated lighting user. You would 

20 recognize that you could no longer see your 

21 crossword puzzle and that you would have to do 

22 something about it.
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1 FACILITATOR BROOKMAN: So we've 

2 learned a lot during the course of this 

3 meeting. Opportunity for final comments.

4 Lane.

5 MR. BURT: This may have been said 

6 earlier. I missed the opening. But I would 

7 like to thank the Department for following 

8 through on the promise they made to Congress 

9 and having this rulemaking and also addressing 

10 one of the major concerns of the advocates and 

11 this could potentially be a significant 

12 loophole. So we all very much appreciate the 

13 Department acting.

14 FACILITATOR BROOKMAN: Thank you.

15 Joe.

16 MR. HOWLEY: My final comment is 

17 we'd also like to thank the Department for 

18 having this separate rulemaking on reflector 

19 lamps because we believe it does require a 

20 separate rulemaking and should not be grouped 

21 together with the PAR lamp rulemaking. It's a 

22 different product, different application, 
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1 different utility.

2 And we would again suggest that you 

3 look within this technology to see how far we 

4 can improve the efficiency within a reflector 

5 or ER technology in a separate rulemaking like 

6 we're having. And we appreciate the fact that 

7 we are having a separate rulemaking on this 

8 and not having the rulemaking grouped together 

9 with the PAR lamp rulemaking. Thank you.

10 FACILITATOR BROOKMAN: Is it Bijit?

11 MR. KUNDU: Bijit Kundu, Energy 

12 Solutions on behalf of PG&E. In general to 

13 echo some comments that were made earlier, we 

14 support DOE's decision to expedite this 

15 process and address these exempted products 

16 and we thank the Department for doing that.

17 And we would also suggest or we 

18 also support the decision of making use in 

19 general of the existing methodologies, data 

20 and key assumptions which have already been 

21 vetted through previous rulemakings. And we 

22 would suggest or Pacific Gas & Electric would 
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1 suggest major modifications to the analysis be 

2 revisited during the next rulemaking process 

3 if major modifications are needed.

4 FACILITATOR BROOKMAN: Thank you. 

5 So I think that's all of the comments that I'm 

6 seeing now. For my part, I just thank all of 

7 you because this has been very, very 

8 constructive and a lot of good information has 

9 come forward very efficiently, very nicely 

10 done and I especially appreciate everybody 

11 coming so organized. That was very well done.

12 I'll turn it back to Meg Sullivan 

13 for closing remarks.

14 MS. SULLIVAN: Well, thank you all 

15 again for coming and commenting on this 

16 rulemaking. We very much appreciate it and 

17 look forward to your written comments. And 

18 just a reminder to include the docket number 

19 and RIN number when you send those in. And 

20 the comment period is going to be extended to 

21 the beginning of July and there will be a 

22 notice about that hopefully soon. So thank 
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1 you.

2 MR. BURT: One other note. Maybe 

3 DOE should consider mandatory show-and-tell 

4 sessions for the next -- and all future 

5 rulemaking hearings.

6 FACILITATOR BROOKMAN: I'd like to

7 see it myself.

8 MR. BURT: I enjoyed it.

9 FACILITATOR BROOKMAN: Thanks to 

10 all of you. Safe travels. Off the record.

11 (Whereupon, at 11:22 a.m., the 

12 above-entitled matter was closed.)

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