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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 ProjectNEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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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 LightingNEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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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 Overvie w 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 126NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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

### 9:02 a.m. 2 

### MS. SULLIVAN: Good morning, 3 

### everybody. 4 

### (Chorus of good mornings.) 5 

### So welcome to the Department of 6 

### Energy's meeting for the Framework Document on 7 

### Energy Conservation Standards for ER and BR 8 

### and Small Diameter Incandes cent Lamps. 9 

### I'm Meg Sullivan with the 10 

### Department of Energy and I'm here with my 11 

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

### And they'll be presenting information about 13 

### how we're going to

-- the methodologies for 14 

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

### forward to hearing all of your comments, 16 

### questions and seeing your exciting 17 

### demonstrations. And if you want to comment 18 

### feel free to speak today or give us a written 19 

### submission before the end of the comment 20 

### period. 21 

### And with that, I'll turn it ov er to 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### -- Oh, John, do you want to speak? John. 1 

### FACILITATOR BROOKMAN: John 2 

### Cymbalsky. 3 

### MR. CYMBALSKY: Hi, John Cymbalsky. 4 

### I am the Appliance Standard Team Supervisor 5 

### and I just want to welcome everybody to the 6 

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

### all these lighting products are going to

-- 8 

### And if you have a little air conditioner in 9 

### here, too, it would help me. 10 

### (Off the record comments.) 11 

### FACILITATOR BROOKMAN: Okay. Well, 12 

### it's our tradition to do introductions. So 13 

### we'll start on this si de of the room and say 14 

### your name and organizational affiliation. 15 

### MR. HOWLEY: Joe Howley. I'm 16 

### Manager of Industry Relations for General 17 

### Electric and I also chair the NEMA Lighting 18 

### Division. 19 

### MR. COOK: Keith Cook with Philips 20 

### Lighting. 21 

### MR. HAKKARAINEN: I'm Pekka 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### Hakkarainen with Lutron Electronics and Vice 1 

### Chair of the Lighting Division at NEMA. 2 

### MR. NEUMANN: Justin Neumann with 3 

### NEMA, National Electrical Manufacturers 4 

### Association. 5 

### MR. VEDDER: Brian Vedder with 6 

### Philips Lighting. 7 

### MR. KUNDU: Bijit Kundu at Energy 8 

### Solutions here on behalf of Pacific Gas and 9 

### Electric. 10 

### MS. MAUER: Joanna Mauer, Appliance 11 

### Standards Awareness Project. 12 

### MR. BALLO: Tim Ballo, 13 

### Earthjustice. 14 

### MR. GREEN: John Green with Cooper 15 

### Lighting and I'm also Vice Chair of NEMA 16 

### Ballast Section. 17 

### MS. HORNER: Pam Horner with Osram 18 

### Sylvania and I chair the Lamp Section at NEMA. 19 

### MR. STAS: Eric Stas, DOE. 20 

### MR. CYMBALSKY: John Cymbalsky, 21


### DOE. 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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

### FACILITATOR BROOKMAN: Please. 2 

### MR. HARTLEY: Matthew Hartley, 3 

### Navigant Consulting. 4 

### FACILITATOR BROOKMAN: These won't 5 

### show up on the record. 6 

### MR. HARTLEY: Matt Hartley, 7 

### Navigant Consulting. 8 

### MS. GUPTA: Mimi Gupta, Navigant 9 

### Consulting. 10 

### MS. LEHR: Ali Lehr, Navigant 11 

### Consulting. 12 

### FACILITATOR BROOKMAN: Jeff, do you 13 

### want to introduce yourself? 14 

### MR. HARRIS: Jeff Harris, Alliance 15 

### to Save Energy. 16 

### MS. DEBUTTS: Lucy Debutts, DOE. 17 

### FACILITATOR BROOKMAN: Thank you. 18 

### Would you introduce yourself please? 19 

### MS. PASSE: My name is Ivy Passe. 20 

### FACILITATOR BROOKMAN: Thank you. 21 

### Okay. I think all of you have a 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### copy of the agenda as well as the PowerPoint 1 

### slides that will be the focal point for 2 

### discussion today and a copy of the proposed 3 

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

### briefly and then we'll jump right straight 5 

### into the content of the day. 6 

### Following this agenda review, there 7 

### is an opportunity for opening remarks, an 8 

### opening for anybody who wishes to do so to 9 

### make brief summary comments about issues that 10 

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

### have a review of the regulatory history and a 12 

### rulemaking overview and then moving to market 13 

### technology assessment and screening analysis, 14 

### engineering and product price determination. 15 

### We'll take a break midmorning. 16 

### Following that, energy use , life

- cycle cost 17 

### analysis and payback period analysis, 18 

### shipments analysis, national impacts analysis, 19 

### and then other NOPR analyses. At the end of 20 

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

### yet another opportunity for individuals to 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### comment and raise issues that may not have 1 

### been raised sufficiently during the course of 2 

### the meeting today. 3 

### Our intention as reflected in the 4 

### agenda is to finish today right about noon. 5 

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

### see how efficiently we can do this. Oka y. 7 

### I'm Doug Brookman by the way from 8 

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

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

### written some of what I think are norms or 11 

### common courtesy. Please speak one at a time 12 

### if you would. 13 

### Please say your name for the 14 

### record. You don't need to say your 15 

### organizational affiliation. All of you 16 

### registered when you entered the building today 17 

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


### your name. 19 

### I'm going to be calling people as 20 

### best I can by name. I wish to enc ourage 21 

### follow

- on comments. Sometimes it's very 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### helpful for the Department to get the back and 1 

### forth between different perspectives and 2 

### contiguous in the record itself. 3 

### Please keep the focus here. If you 4 

### could turn your machines on silent mode and if 5


### yo u need to have a sidebar conversation with 6 

### someone that's going to last for more than 7 

### about ten seconds you can take it out of the 8 

### room. We'll understand this part of the 9


### process. 10 

### If you could be concise, please 11 

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

### And we want to provide time for everybody to 13 

### do that today. 14 

### So that's what I would ask for. 15 

### Questions or comments here before we get into 16 

### the content? 17 

### Do you want to do this first slide, 18 

### Meg? The purpose of the public meeting. 19 

### MS. GUPTA: I could do that. 20 

### FACILITATOR BROOKMAN: You could do 21 

### that one, Mimi. Okay. And then after that 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### we'll -- 1 

### MS. GUPTA: All right. Good 2 

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

### public meeting is going to be presenting the 4 

### framework document that was made available on 5 

### the web. And the framework document basically 6 

### presents the procedural and analytical 7 

### approaches that DOE plans on taking in 8 

### conducting this rulemaking on incandescent 9 

### reflector lamps, specifically the ER, BR and 10 

### small diameters that are exempt from current 11 

### standards. 12 

### At this public meeting, DOE will be 13 

### seeking comment from interested parties on a 14 

### variety of issues and discussing the next 15 

### steps of the rulemaking. And DOE welcomes 16 

### comments on all aspects of the framework 17 

### document. I'll be queuing up or the 18 

### presenters will be queuing up a couple of 19 

### specific issues for comment. And feel free to 20 

### make any verbal or written comments. Thank 21


### you. 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### FACILITATOR BROOKMAN: As I 1 

### promised, now is an opportunity for anybody 2 

### that wants to make brief remarks here at the 3 

### outset, key issues, a summary of things you 4 

### wish to raise. And whoever would like to 5 

### start with that. 6 

### MR. NEUMANN: Yes, sure. On behalf 7 

### of NEMA and our member companies, we just 8 

### appreciate this opportunity to be here and 9 

### offer our resources and what we can do to help 10 

### out in this continual process. And I look 11 

### forward to working with DOE on this matter. 12 

### FACILITATOR BROOKMAN: Okay. Thank 13 

### you, Justin. Please say your name when you 14 

### speak. 15 

### MR. NEUMANN: I'm sorry. My 16 

### apologies. 17 

### FACILITATOR BROOKMAN: Not at all. 18 

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

### Other comments here at the outset? 20 

### (No verbal response.) 21 

### None? Nothing additional? No? 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### (No verbal response.) 1 

### Then let's go straight into the 2 

### content. Mimi. 3 

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

### off with a brief background of these products 5 

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

### Energy Policy Act of 1992 established energy 7 

### conservation standards for incandescent 8 

### reflector lamps excluding ER and BR bulb 9 

### shapes and lamps with diameters of 2.75 inches 10 

### or less. 11 

### Then the Energy Independence and 12 

### Security Act of 2007 expanded the definition 13 

### of incandescent reflector lamps to include 14 

### smaller diameter lamps, namely the ones with 15 

### diameters between 2.25 inches and 2.75 inches 16 

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

### also exempted several lamps from standards and 18 

### these are the lamps rated 50 watts or less 19 

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

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

### and the R20 of 45 watts or less. And these 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### are the subject of this rulemaking. 1 

### In July of 2009, DOE issued a final 2 

### rule amending existing standards for 3 

### incandescent reflector lamps. In an early 4 

### stage of that rulemaking, in the ANOPR, DOE 5 

### had preliminarily determined that it didn't 6 

### have authority to set standards for these 7 

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

### it concluded that based on a reexamination of 9 

### its authority DOE would conduct a separate 10 

### rulemaking to assess energy conservation 11 

### standards for these currently e xempt products. 12 

### FACILITATOR BROOKMAN: Meg 13 

### Sullivan. 14 

### MS. SULLIVAN: Yes, Meg Sullivan. 15 

### That comment period is going to be extended by 16 

### the way until July

-- This one. Yes. Two or 17 

### three weeks until July 8th. 18 

### (Off the record conversation.) 19 

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

### or three extra weeks on the comment period. 21 

### So July 1st or July 8th. Yes. 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### FACILITATOR BROOKMAN: And that 1 

### will be posted on your website or

-- Yes. 2 

### Okay. Good. Thank you. 3 

### MS. GUPTA: And then lastly the 4 

### Federal Register Notice for this framework 5 

### document and public meeting was published on 6 

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

### All right. In the framework 8 

### document, DOE determined that it has the 9 

### authority to regulate these exempt IRL and it 10 

### provides a detailed description of the 11 

### analytical approaches and tools and models 12 

### that DOE plans to use to evaluate the 13 

### standards for incandescent reflector lamps. 14 

### Because DOE believes that much of the analysis 15 

### conducted for the July 2009 final rule is 16 

### relevant to these typ es of lamps, DOE is 17 

### attempting to do this rulemaking on an 18 

### accelerated schedule, namely going from 19 

### framework documents straight to the notice of 20 

### proposed rulemaking. And DOE plans to publish 21 

### a final rule for this rulemaking by December 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### 2011. 1 

### Just as a little bit more 2 

### background as many of you know, the Energy 3 

### Policy Act of 1992 and a Test Procedure Final 4 

### Rule in 1997 established test procedures for 5 

### incandescent reflector lamps by incorporating 6 

### several ANSI and IESNA standards. And then 7 

### DOE adopted that test procedure or adopted 8 

### amendments to that test procedure updating 9 

### several of those industry standards in 2009. 10 

### DOE welcomes comment on whether any 11 

### further amendments are necessary to the 12 

### incandescent reflector lamp test procedure. 13 

### FACILITATOR BROOKMAN: The comment 14 

### box, it's an explicit request for comment 15 

### should anyone wish to do so. 16


### Pam Horner. 17 

### MS. HORNER: Pam Horner on behalf 18 

### of the NEMA Lamp Section in this case. 19 

### Basically, we agree with the DOE in terms of 20 

### the test procedures. We do want to insert a 21 

### comment here which you always hear from us 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### which is that it's okay since lumens per watt 1 

### is the metric. But we do not agree that 2 

### lumens per watt is the correct metric for this 3 

### product. So we want to make certain that that 4 

### is once again on the record. 5 

### FACILITATOR BROOKMAN: Thank you. 6 

### Yes, Pekka. 7 

### MR. HAKKARAINEN: I'm wondering if 8 

### it's appropriate to make a comment on an 9 

### earlier part of the framework document where 10 

### the rulemaking procedure is described. 11 

### FACILITATOR BROOKMAN: Go ahead. 12 

### Let's do it now. 13 

### MR. HAKKARAINEN: So I'm concerned 14 

### that in the process or the rulemaking process 15 

### there is no explicit assessment of consumer 16 

### impact analysis. And the reason why I'm 17 

### saying that is because after the introduction 18 

### of compact fluorescent lamps in the market 19 

### there were several lessons that we learned 20 

### from that experience and we have now been

-- 21 

### NEMA had a task force for I think about a year 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### studying consumer dissatisfiers that have 1 

### resulted in particular from the 2 

### incompatibility of compact fluorescent lamps 3 

### and dimmer controls. 4 

### And therefore my main concern that 5 

### I want to express here is that the consumer 6 

### impact should be evaluated in this rulemaking. 7 

### And in our final

-- And in our written 8 

### comments, I will describe the dissatifiers 9 

### that the NEMA task force has identified. 10 

### And I just wanted to make a 11 

### reference to a comment in the framework 12 

### document in Section 2.3.2.1 in the context of 13



### -- in a different context that discusses I 14 

### guess it discusses the different spectrum 15 

### lamps. There's a statement that says the 16 

### statute prohibits DOE from prescribing a 17 

### standard if such standard is likely to result 18 

### in the unavailability of performance 19 

### characteristics or features for a covered 20 

### product line or product type. 21 

### So I would just like DOE to take 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### thi s incompatibility of the replacement lamps 1 

### with dimmer controls into account as part of 2 

### the consumer impact analysis and, in 3 

### particular, also look at whether this will 4 

### result in fewer permanently installed lighting 5 

### fixtures being installed in homes to be 6



### r eplaced by plug

- in type devices, plug

- in 7 

### table and floor lamps and what the energy 8 

### impact of that is going to be. 9 

### Certainly as far as we can from a 10 

### NEMA perspective, we will be very willing to 11 

### help DOE in this analysis. Thank you. 12 

### FACILITATOR BROOKMAN: What will 13 

### you submit will be NEMA's reflections. 14


### MR. HAKKARAINEN: Correct. 15 

### FACILITATOR BROOKMAN: On this 16 

### point. 17


### MR. HAKKARAINEN: Correct. 18 

### FACILITATOR BROOKMAN: Okay. 19 

### MR. CYMBALSKY: This is John 20 

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

### talking about the consumer utility of the 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### product as opposed to the economic impact to 1 

### the consumer. 2 

### MR. HAKKARAINEN: That's correct. 3 

### MR. CYMBALSKY: That distinction. 4


### MR. HAKKARAINEN: Yes. 5 

### MR. CYMBALSKY: Thank you. 6 

### FACILITATOR BROOKMAN: Yes, thank 7


### you. 8 

### Other comments at this juncture? 9 

### (No verbal response.) 10 

### MS. GUPTA: And just as a last 11 

### procedural related slide, EISA 2007 requires 12 

### that DOE assess the standby mode and off mode 13 

### energy use of its regulated products. And as 14 

### concluded in t he July 2009 final rule, DOE 15 

### does not believe standby mode and off

- mode are 16 

### applicable modes of operation to incandescent 17 

### reflector lamps and, therefore, is not 18 

### incorporating those modes of energy use in its 19 

### energy conservation standards. 20 

### And DOE welcomes comments on those 21 

### conclusions. 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### FACILITATOR BROOKMAN: Pam. 1


### MS. HORNER: Pam Horner. NEMA 2 

### agrees with DOE. 3 

### FACILITATOR BROOKMAN: Let me say 4 

### for the record that the Department loves it 5 

### when the stakeholders agree with its 6 

### conclusions. 7


### PARTICIPANT : You can make that 8


### comment. 9 

### FACILITATOR BROOKMAN: So it's 10 

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

### well as addition thoughts. 12 

### MS. HORNER: Exactly. 13 

### FACILITATOR BROOKMAN: Okay. 14 

### MS. GUPTA: All right. So this 15 

### slide here maps out the different analyses DOE 16 

### conducts in the notice of proposed rulemaking 17 

### stage. Today we'll be discussing mostly the 18 

### top portion of the analyses which include the 19 

### market and tech and screening analysis which 20 

### develop product classes and design options 21 

### that feed into the engineering analysis and 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### product price determination which develops a 1 

### cost efficiency relationship which is then fed 2 

### into the life

- cycle cost and national impact 3 

### analysis that are used to assess consumer 4 

### impacts. 5 

### There are also several NOPR 6 

### analyses that DOE conducts including a life

7 

### cycle cost subgroup analysis and manufacturer 8 

### impact analysis, utility, employment, 9 

### environmental assessments, and a regulatory 10 

### impact analysis. And we'll go through each 11 

### one of these today. 12 

### So for the market and techn ology 13 

### assessment, DOE characterizes the exempt IRL 14 

### market and industry, establishes product 15 

### classes and identifies technology options to 16 

### improve efficacy of incandescent reflector 17 

### lamps. Then in the screening analysis, DOE 18 

### takes these technology options a nd screens 19 

### several of them out based on four screening 20 

### criteria. 21 

### Here I would just like to highlight 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### an issue for comment from the framework 1 

### document in which DOE invites interested 2 

### parties to submit data relevant to the market 3 

### assessment in the form of a written comment. 4 

### This includes historical shipments of exempted 5 

### incandescent reflector lamps by lamp type, 6 

### lamp wattage and market sector. 7 

### Later today, my colleague, Ali 8 

### Lehr, will be discussing the national impact 9 

### analysis where we'll discuss several of the 10 

### assumptions that DOE has used in the past to 11 

### characterize this market. So we'll also be 12 

### requesting comment on those assumptions. 13


### FACILITATOR BROOKMAN: Comments 14 

### here? Pam. 15 

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

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

### written comments due in July, we will not have 18 

### massive and copious amounts of data that we 19 

### will submit with the comments. But we wanted 20 

### to assure DOE that throughout NEMA Business 21 

### Information Systems which we fondly call NEMA 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### BIS we would like to extend a cooperative 1 

### attitude and we'd like to help with the 2 

### historic data that you seek. 3 

### FACILITATOR BROOKMAN: Thank you. 4 

### Yes. Keith. 5 

### MR. COOK: Keith Cook. Did I miss 6 

### Item 3? 7 

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

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

### MS. HORNER: If you look ahead 10 

### you'll see it's after four. 11 

### FACILITATOR BROOKMAN: Other 12 

### comments related to data submissions? 13 

### (No verbal comments.) 14 

### Okay. 15 

### MS. GUPTA: So one main task in the 16 

### market and technology assessment is to 17 

### establish product classes and DOE generally 18 

### establishes a separate energy conservation 19 

### standard for each product class. DOE divides 20 

### these product classes by the type of energy 21 

### used, the capacity of the product, or any 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### other performance related features such as one 1 

### rel ated to utility that would justify a 2 

### separate standard level. 3 

### In the July 2009 final rule, DOE 4 

### established a product class structure for the 5 

### incandescent reflector lamps that were 6 

### addressed in that rule and it divided product 7 

### classes by spectrum, diameter and voltage. In 8 

### consideration of the seeming technological 9 

### similarity between the products regulated in 10 

### July and those under consideration right now, 11 

### DOE is considering using the same product 12 

### class structure for the exempt IRL products 13 

### and welcomes comment on whether these are 14 

### appropriate criteria to use. 15


### FACILITATOR BROOKMAN: Pam. 16 

### MS. HORNER: Pam Horner. Regarding 17 

### two of the three categories, NEMA agrees with 18 

### DOE and that would be the diameter and the 19 

### spectrum. However, we would like to repeat 20



### o urselves regarding the voltage issue. We 21 

### strongly disagree with the establishment of 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### two voltage categories, the option of dimming 1 

### an incandescent reflector lamp to achieve 2 

### longer life and what we mean by that is 3 

### operating 130 volt lamps on 120 circuits i n 4


### many cases. 5 

### That reduced efficacy is always 6 

### available regardless of the rate of voltage. 7 

### We don't believe that the Department of Energy 8 

### should limit the utility for users that really 9 

### require 130 volt lamps. 10 

### And our main point here which we 11 

### will als o express in our written comments is 12 

### that all incandescent reflector lamps should 13 

### be tested at their voltage rating and be 14 

### subject to the same standards. This is what 15 

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

### tested at 130 volts for its performance 17 

### cha racteristics and the same for 120. 18 

### We believe that the effort to 19 

### justify two voltage categories is erroneous. 20 

### And in practical 130 volt lamps the filament 21 

### is designed for 130 volt application. It 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### tends, yes, to have a slightly reduced 1 

### efficacy compared to the 120 volt design, but 2 

### it's insignificant. 3 

### And bottom line rather than reading 4 

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

### lamps are used on 120 volt circuits in order 6 

### to extend life. That is true. Efficacy goes 7 

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

### and therefore the energy consumption. Thank 9


### you. 10 

### FACILITATOR BROOKMAN: Okay. Thank 11


### you. 12 

### Other comments on the structure of 13 

### the product classes? 14 

### (No verbal response.) 15 

### Okay. 16 

### MS. GUPTA: All right. Another 17 

### goal of the market and technology assessment 18 

### is to identify several technology options to 19 

### improve the efficacy of incandescent reflector 20 

### lamps and here on this slide you can see 21 

### several of the technology options that were 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### identified in the July 2009 final rule. Some 1 

### to note are the use of tungsten

- halogen 2 

### capsules, improved reflectors, halogen 3 

### infrared coatings. And DOE welcomes comment 4 

### on whether the technology options listed on 5 

### the previous slide are applicable to the lamps 6 

### under consideration in this rulemaking or if 7 

### any should b e added. 8 

### FACILITATOR BROOKMAN: Maybe if you 9 

### go back to the previous slide. Comments? 10


### Pam. 11


### MS. HORNER: Pam Horner. NEMA 12 

### agrees that the list is comprehensive and we 13 

### also believe it is complete. 14 

### FACILITATOR BROOKMAN: Additional 15 

### thoughts and comme nts? 16 

### (No verbal response.) 17 

### Okay. 18 

### MS. GUPTA: Then in the screening 19 

### analysis, technology options are screened 20 

### using the following criteria: technological 21 

### feasibility; practicability to manufacturer 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### install and service; adverse impacts on 1 

### product utility or availability to customers; 2 

### and adverse impacts on health and safety. 3 

### Again in the July 2009 final rule, 4 

### DOE screened out several technology options 5 

### listed here on this slide and plans to screen 6 

### out the same ones for this rulemaking and 7 

### requests comment on that screening analysis. 8


### FACILITATOR BROOKMAN: Pam. 9 

### MS. HORNER: Pam Horner. We agree 10 

### that the correct technologies have been 11 

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

### discussion on trihedral corner reflectors and 13 

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

### we agree that the correct ones have been 15 

### screened out. We agree with DOE. 16 

### MS. GUPTA: There's a description 17 

### in the TSD. 18 

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

### about those every day. 20 

### FACILITATOR BROOKMAN: Other 21 

### comments on the results of the screening 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### analysis? 1 

### (No verbal response.) 2 

### Okay. 3 

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

### be discussing the engineering analysis and the 5 

### product price determination. So the purpose 6 

### of these two analyses is basically to 7 

### establish a cost efficacy relationship for 8 

### these exempt IRL. 9 

### In the engineering analysis, we 10 

### also established the efficacy levels for 11 

### analysis. These outputs of the engineering 12 

### and product price determination are inputs 13 

### into the life

- cycle cost and national impact 14 

### analysis. 15 

### And the slide depicts a general 16 

### methodology that DOE took in the July 2009 17 

### final or July 2009 rulemaking and intends to 18 

### take again for this rulemaking in which the 19 

### first step of the engineering analysis is to 20 

### choose the representative product classe s from 21 

### the full eight product classes discussed 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### earlier. 1 

### Then for each of the representative 2 

### product classes DOE will define a baseline 3 

### model from which it will assess changes due to 4 

### more stringent standards. Then DOE will 5 

### develop efficacy levels that r ange from the 6 

### baseline to the maximum technologically 7 

### feasible level. DOE will then identify higher 8 

### efficacy substitutes from a database of 9 

### commercially available lamps and also when 10 

### necessary by developing model lamps. And 11 

### finally DOE will scale the results from the 12 

### representative product classes to the product 13 

### classes not directly analyzed. 14 

### So for the baseline models, DOE 15 

### analyzed commercially available products and 16 

### found that the 65 watt BR30 and the 45 watt 17 

### R20 lamps were the highest number of model s 18 

### sold and therefore DOE has preliminarily 19 

### chosen these two as the baseline lamps for 20 

### analysis. DOE is also choosing the standard 21 

### spectrum and 120 volt versions of these lamps. 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### To develop efficacy levels in the 1 

### July 2009 rule, DOE observed natural divis ions 2 

### that corresponded to more efficacious 3 

### commercially available technologies found in 4



### PAR

- shaped lamps. Based on much of the 5 

### discussion in the July 2009 rulemaking, DOE 6 

### believes that there's no clear utility 7 

### difference between PAR, ER, BR and R

- shaped 8 

### l amps. It's DOE's understanding that there's 9 

### already a significant amount of market 10 

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

### why it's unaware of a clear utility 12 

### difference. 13 

### In considering that assumption, DOE 14 

### intends to use the same efficacy levels as 15 

### established in the July 2009 final rule. And 16 

### you see here the efficacy levels established 17 

### for the large diameter standard spectrum 120 18 

### volt lamps. At the bottom of the slide you 19 

### see the 65 watt BR30 baseline which is a non

20 

### halogen incandescent technology. EL1 21 

### represents a halogen level. This is a new 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### level that was not analyzed in the July 2009 1 

### final rule, but rather was the baseline of 2 

### that rulemaking. Then EL2 through EL6 3 

### represent higher efficacy halogen, halogen 4 

### infrared options. 5 

### After establish ing efficacy levels, 6 

### DOE will then choose higher efficacy lamp 7 

### substitutes that will attempt to achieve the 8 

### same lumen output by increasing efficacy and 9 

### using reduce wattage lamps. In general, DOE 10 

### used commercially available lamps when 11 

### possible when creating their initial list of 12 

### replacement lamps. But when commercially 13 

### available lamps were not available in the 14 

### wattages or the efficacies that were required 15 

### by the efficacy level, DOE developed model 16 

### lamps to fill in the technology gaps based on 17 

### technologic al literature and relationships 18 

### between lamp lumen output, wattage and 19 

### lifetime. 20 

### For the 65 watt BR30 baseline, DOE 21 

### noted that the lumen output was very similar 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### to the 50 watt PAR lamp it analyzed in the 1 

### July 2009 final rule. And therefore the 2 

### replaceme nt lamp analysis is nearly identical 3 

### to the analysis in the July 2009 final rule. 4 

### For the 45 watt R20 baseline, 5 

### however, DOE had to develop a replacement lamp 6 

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

### earlier, DOE analyzed commercially available 8 

### prod ucts and tried to use those commercially 9 

### available products wherever possible. 10 

### However, one thing to note here is 11 

### as you can see all of the higher efficacy 12 

### options have a wattage of 40 watts here and 13 

### that's primarily due to the limitations of the 14


### scope of coverage on this product. The 15 

### definition of incandescent reflector lamp is 16 

### limited to only those lamps greater than or 17 

### equal to 40 watts. As you move to higher 18 

### efficacy, though a reduction in wattage may 19 

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



### on ly limited to 40 watts. So therefore as you 21 

### can see, EL6 has a significantly higher lumen 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### output than the baseline. 1 

### And finally as a last step to the 2 

### engineering analysis, DOE scales the efficacy 3 

### levels established for the two representative 4 

### product classes to the product classes not 5 

### directly analyzed. DOE intends to use the 6 

### same scaling factors established in the July 7 

### 2009 final rule, namely, a 15 percent 8 

### reduction for modified spectrum lamps and a 15 9 

### percent increase for high voltage lamps. 10 

### And now we will open the floor for 11 

### comments on the engineering analysis. 12


### FACILITATOR BROOKMAN: Joe. 13 

### MR. HOWLEY: Joe Howley. Well, 14 

### this is a big one. The engineering analysis 15 

### and the assumptions - we view this part as 16 

### critical to this rulemaking. To go dow n 17 

### through, there are certain questions presented 18 

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

### We'll have more extensive written comments. 20 

### With regard to the representative 21 

### product classes, we already had mentioned that 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### we agree with those except for the use of the 1 

### 120 volt and 130 volt product classes which 2 

### Pam referred to before. With regard to the 3 

### baseline lamps, we do agree that these 4 

### baseline lamps represent the highest volume 5 

### lamps of those types. So we believe those are 6 

### the correct baseline lamps to use. 7 

### When looking at the tables, 8 

### specifically we are trying to match up table 9 

### 2.4 with table 2.6, we were unable to match 10 

### the equations with the lumen per watt values 11 

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

### table 2.6 and you did the calculation b ased on 13 

### that equation, it does not calculate to 17 14 

### lumens per watt which is what is shown for EL5 15 

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

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

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

### not the same. The values that are calculated 19 

### are much higher than what the equation or 20 

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

### than what the equations would calculate. 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### MS. GUPTA: Right. I can maybe 1 

### provide a little bit of background on that. 2 

### In the July 2009 final rule, DOE received 3 

### comments that the rated lamp efficacies did 4 

### not always correctly correlate to the 5 

### compliance, the value submitted for 6 

### compliance, due to the reporting procedure. 7 

### And so those efficacy levels were reduced from 8 

### the rated efficacies in catalogs. So we 9 

### applied those same reductions. Does that? 10 

### MR. HOWLEY: Okay. 11 

### PARTICIPANT: This one is higher. 12 

### MS. GUPTA: So the rated values in 13 

### the lamp replacement table should be higher 14 

### than the equation values. 15 

### MR. HOWLEY: They are. Okay. 16 

### Well, thank you for that explanation of why 17 

### they don't match. 18 

### FACILITATOR BROOKMAN: Is that okay 19 

### from that correct? 20 

### MR. HOWLEY: I understand the 21 

### rationale. But I think from a pure analysis 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### standpoint, just from a pure engineering 1 

### standpoint that they should match from a pure 2 

### engineering standpoint, I understand why you 3 

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

### have to say about that. 5 

### FACILITATOR BROOKMAN: Okay. 6 

### MR. HOWLEY: It is what it is. 7 

### And a couple other topics before I 8 

### get into the large topic here. You had 9 

### mentioned about a 15 percent efficiency change 10 

### for modified spectrum. We would agree with 11 

### that same type of percentage for these 12 

### products. Although we understand why you're 13 

### applying the 15 percent for the 130 volt, 14 

### again we go back to the fact that should you 15 

### even be doing this at all. But we understand 16 

### your logic behind that percentage. 17 

### And just a comment. In viewing 18 

### your last chart about comparison of R20 lamps 19 

### with lamps with significantly higher lumen 20 

### output, generally the industry looks at 21 

### products with the same utility as being about 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### plus or minus 10 percent in lumen output. 1 

### Therefore, we would not view a product that 2 

### had twice the light output as having the same 3 

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

### well. For instance, pretty much anything 5 

### above EL2 would not be viewed as having the 6 

### same utility. EL1 and EL2 would. You could 7 

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

### get into EL3 to EL6, especially EL6 with 9 

### almost twice the light output, that would not 10 

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

### think that would be fair comparison to say a 12 

### consumer would be just as happy with the lamp 13 

### with twice as much light as half as much 14 

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

### get the same light output. It wouldn't 16


### pro vide the same utility. 17 

### Okay. Now we move into an area 18 

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

### aids as well, some more demonstrations here to 20 

### explain that the one assumption that DOE makes 21 

### that there is no clear utility difference 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### between BR, R and PAR lamps and therefore 1 

### using PAR lamps as the direct replacements. 2 

### We believe this assumption is inaccurate and 3 

### the reason these lamps exist. If indeed that 4 

### statement was true, we would argue these 5 

### different lamp types would not exist. If they 6 

### had exactly the same utility or even similar 7 

### utility, there would be no reason for all of 8 

### our companies to make these various lamp 9 

### types. 10 

### The reason these various lamp types 11 

### exist is there is a clear and marked utility 12 

### difference between these types and that 13 

### beca use of this you really need to analyze R 14 

### lamps within R lamps, ER lamps within ER 15 

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

### from an efficiency standpoint. You probably 17 

### could analyze them together. 18 

### You would have to have a different 19 

### diameter analysis as you're suggesting. But 20 

### you clearly wouldn't want to analyze the same 21 

### as PAR lamps. PAR lamps because of their 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### nature have a much better reflector technology 1 

### and therefore we can get more efficiency out 2 

### of this, significantly more efficiency out of 3



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

### if we use the same halogen capsule or halogen 5 

### IR capsule inside both of these technologies, 6 

### we would still get significantly more 7 

### efficiency out of a PAR lamp. Treating them 8 

### the same would essentially be eliminating the 9 

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

### ER lamp technology. 11 

### Also we would say that this 12 

### analysis, the analysis for PAR lamps, was done 13 

### primarily for commercial products and indeed 14 

### they're heavily used in retail establishments. 15 

### And so the commercial analysis, commercial 16 

### operating hours, commercial price points made 17



### sense. 18 

### However, the R lamp is primarily 19 

### used by residences. That would be 70, 75 20 

### percent of these products are used in 21 

### residential applications. That means they 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### should be ana lyzed based on residential 1 

### operating hours. They should be analyzed on 2 

### residential price points. And that is a 3 

### completely different analysis than the 4 

### analysis done for PAR lamps which is primarily 5 

### based on a commercial analysis. And so many 6 

### different re asons. 7 

### As we'd like to demonstrate, the 8 

### spots in the flood distributions of reflector 9 

### lamps and especially lighting distribution of 10 

### an ER lamp is very different than the spot and 11 

### flood distribution of a PAR lamp. So we can 12 

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

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

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

### actually like to demonstrate this versus just 16 

### saying that they're different. A picture is 17 

### worth a thousand words. Or seeing is 18 

### believing. So we thought we would show this. 19 

### Is that appropriate for you now? 20


### FACILITATOR BROOKMAN: Yes. Just I 21 

### want to make sure that your show and tell is 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### fully captured in the record. Do you want to 1 

### use this thing here? 2 

### (Off the record comments.) 3


### MR. HOWLEY: I guess I would first 4 

### like to start out with just the basic 5 

### difference between a reflector lamp and 6 

### elliptical reflector lamp. You've heard R 7 

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

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

### lighting person you would not know what the 10 

### difference was. 11 

### Perhaps just to on paper to 12 

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

### to capture in the record. ER stands for 14 

### elliptical reflector and if you look at an 15 

### ellipse, an ellipse has two focal points. And 16 

### the way an elliptical reflector works is the 17 

### filament of the lamp is placed at the focal 18 

### point, the first focal point. And the 19 

### reflector is quite a bit larger than a regular 20 

### R lamp and that is because all the light beams 21 

### that reflect off the reflector then are re

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### ref lected through the second focal point of 1 

### the ellipse so that you have a situation where 2 

### you can direct a lot of the light from this 3 

### product straight through a relatively small 4 

### opening or a deep down light or a down light 5 

### with a small opening. 6 

### And that was why this product was 7 

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

### in such fixtures that may have a very deep 9 

### recess or it may have a very small opening at 10 

### the bottom of the recess. And these fixtures 11 

### still exist today as they were installed 12 

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

### replacement lamps are still used for energy 14 

### efficient purposes. If indeed you were to 15 

### replace it with a different type of lamp, a 16 

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

### out of that fixture. 18 

### Pekka is going to demonstrate. 19 

### This is the beam pattern and this would be a 20 

### reflector flood. And maybe you could move 21 

### that a little bit closer. Pekka, move that a 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### little bit closer to the screen if it will 1 

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

### lights off. Great. 3


### FACILITAT OR BROOKMAN: Thank you. 4 

### MR. HOWLEY: So that's a reflector 5 

### flood trying to go through a small opening. 6 

### Now you can remove that and that's just

-- If 7 

### you could see the distribution of that lamp. 8 

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

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

### a very broad distribution on a reflector lamp. 11 

### It provides a very smooth distribution. 12 

### Homeowners like to use these over the kitchen 13 

### counter tops because it provides even 14 

### distribution across a very wide surface. 15 

### Okay. 16 

### The elliptical reflector lamp looks 17 

### like it has similar, a little tighter beam 18 

### pattern when you just show it straight when 19 

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

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

### you get

-- and we may have to do this like 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### this. I'll turn this on as well. So about 1 

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

### get still a pretty distribution of light out 3 

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

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

### that is blocked. 6 

### FACILITATOR BROOKMAN: The problem 7 

### is the bottom one is still on. 8 

### MR. HOWLEY: Oh. That's the 9 

### problem. 10 

### (Laughter.) 11 

### Why is there so much light on this 12


### screen? 13 

### (Off the record comments.) 14 

### But you can see there's very little 15 

### light coming out of if you just put a standard 16 

### flood light in there. 17


### FACILITATOR BROOKMAN: So restate 18 

### your conclusion. 19 

### MR. HOWLEY: Well, the conclusion 20 

### is that the elliptical reflector lamp is used 21 

### for very specific fixture types to get maximum 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### light out of the fixture, where the reflect or 1 

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

### used for maximum distribution of light across 3 

### the surface. 4 

### Now to contrast the reflector lamp 5 

### types that have been used and developed for 6 

### many years are the PAR lamps. The PAR lamps 7 

### were developed more to get maximum light punch 8 

### or maximum candle power on an object and this 9 

### is primarily where you want to highlight an 10 

### object either in your home or in retail. This 11 

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

### the retail environment we typically like to 13


### ge t the maximum punch on an object that 14 

### they're trying to sell. 15 

### Generally, the rule of thumb is to 16 

### get three times the light on the object than 17 

### the ambient light. So the object is to focus 18 

### the light dramatically in one area. If we 19 

### show the

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

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

### If we were to put that in a fixture with a 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### narrow opening, we would get something like 1 

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

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

### distribution. 4 

### The difference with the ER lamps is 5 

### you get light out of it plus you get your 6 

### distribution across a wider area. And that is 7 

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

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

### regular reflector flood and it wa s designed 10 

### for energy efficiency purposes so that in the 11 

### center area you have about the same light 12 

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

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

### was eliminated by the 1992 Energy Policy Act. 15 

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

### course, there were further exemptions in the 17 

### 2007 EISA law. 18 

### Now with the PAR lamps we could 19 

### also show the difference of two spots. These 20 

### are flood designs and we could also compare 21 

### and contrast two spots. You can get a 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### reflector lamp in a spot and you can get a PAR 1 

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

### want to concentrate the light. 3 

### But again saying "Is the reflector 4 

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

### can again demonstrate these two. And that's 6 

### about as good as you can get with a reflector 7 

### lamp spot. We can make the beam a little 8 

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

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

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

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



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

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

### lamps are used primarily for retail accent 15 

### lighting. 16 

### So they truly do provide two 17 

### different utilities. ER lamps provide a 18 

### different utility as well. The efficiencies 19 

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

### efficiencies of PAR lamps are much higher. So 21 

### if you were to set the efficiency level so 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### that PAR lamps could meet them, you would 1 

### essentially eliminate entirely R lamps from 2 

### the market and ER lamps from the market. And 3 

### there's no way to produce that same utility 4 

### out of a PAR lamp in terms of light 5 

### distribution. 6 

### (Off the record comment.) 7 

### One last thing about the utility of 8 

### dimmability and we're going to demonstrate 9 

### dimming an incandescent lamp. You could see 10 

### we could go down to about one percent dimming. 11 

### We could go down to a point where we could 12 

### barely see the light output. If you were 13 

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

### with dimming, incandescent you can do a very 15 

### smooth -- It dims very smoothly and it dims 16 

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

### If you would try to do the same 18 

### with compact fluorescent, we do have dimmable 19 

### compact fluorescent designs right now. First 20 

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

### replacement to the incandescent lamps. But 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### you see that these aren't just flood. These 1 

### are super floods. The light is going all the 2 

### way to that wall over there and over there as 3 

### well as hitting here. But they're extremely 4 

### broad. 5 

### Fluorescent technology lends itself 6 

### to extremely broad distributions of light, not 7 

### even as much on your kitchen counter. You 8 

### have as many lumens coming out, but it really 9 

### is going a lot of different directions. So 10 

### that's the first slight drawback. 11 

### The other drawback is dimming. So 12 

### can you take that all the way down? What 13 

### happens when you take it

-- It will drop out 14 

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

### closer so you can see the effect. Okay. 16 

### MR. CYMBALSKY: How low are you 17 

### going on that one? Is that 20 percent? 18 

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

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


### MR. HOWLEY: Yes. 21 

### MS. HORNER: Yeah, it would go down 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### to 20 percent. 1 

### MR. HOWLEY: About 20 percent and 2 

### some dimmer I notice will drop the lamp out if 3 

### you get too far. This dimmer is holding in 4 

### there o kay. Oh, it just dropped out. 5 

### (Off the record comments.) 6 

### MR. HAKKARAINEN: This is Pekka 7 

### Hakkarainen. The dropout is one of the 8 

### consumer dissatifiers that the NEMA task force 9 

### has identified. 10 

### FACILITATOR BROOKMAN: Okay. 11 

### MR. HOWLEY: And that comp letes our 12 

### demonstration. Thank you. 13 

### FACILITATOR BROOKMAN: Okay. So 14 

### are there questions from anybody following 15 

### that demonstration? 16 

### Yes, Keith, do you want to follow 17 

### on there? 18


### MR. COOK: No. 19 

### FACILITATOR BROOKMAN: You're just 20 

### putting the screen up. Okay. 21


### MR. COOK: Yes. 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### FACILITATOR BROOKMAN: So then 1 

### maybe you could, Joe, then restate the 2 

### implication of all of this for the record just 3 

### to clarify it. 4 

### MR. HOWLEY: Well, in summary and 5 

### for the record, reflector lamps and elliptical 6 

### reflector lamps offer a different utility to 7 

### consumers than PAR lamps, PAR30 lamps or PAR38 8 

### lamps. PAR lamps, their main advantage and 9 

### utility is highlighting objects. Reflector 10 

### lamps, their main utility is providing a nice 11 

### soft wash of light and also that's fully 12 

### dimmable down to very low levels. And 13 

### elliptical reflector lamps are also a unique 14 

### design designed to provide unique utility in 15 

### deep down lights or down lights with narrow 16 

### openings and still maintaining a relatively 17 

### wide light distribution pattern in fro nt of 18 

### the lamp. 19 

### FACILITATOR BROOKMAN: Okay. Thank 20


### you. 21 

### Yes. Tim Ballo. 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### MR. BALLO: Tim Ballo with 1 

### Earthjustice. Just one follow

- up question on 2 

### this. For the problem of the R shaped lamp 3 

### that would be installed in a deeply recessed 4 

### fixture, if the standard as I think it would 5 

### be likely to happen would result in a 6 

### significant increase in lumen output for that 7 

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

### light that escapes that fixture? 9 

### MR. HOWLEY: Well, if there was 10 

### more lumens available there would be more 11 

### light that comes out of the fixture. But 12 

### because it's simple optics you would still 13 

### have a great deal of those extra lumens caught 14 

### or trapped inside the fixture. So the 15 

### increase in lumens would be partially captured 16 

### by the fixture itself and partially exit the 17 

### fixture. 18 

### You would get still better utility 19 

### if, for instance, you designed a standard 20 

### where you were required to increase the 21 

### efficiency of a reflector lamp or a BR lamp in 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### and of itself or an ER lamp in and of itself, 1 

### for instance, requiring halogen technology in 2 

### that product. And you set the standard based 3 

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

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

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

### make this technology more efficient. That's 7



### no t what we're saying. 8 

### What we're saying is that you 9 

### shouldn't base the capability of the 10 

### efficiency gain on PAR lamps. You need to base 11 

### the capability of the efficiency gain using a 12 

### reflector shape, not using a PAR lamp shape. 13 

### That's our main point. 14



### FA CILITATOR BROOKMAN: Pam, do you 15


### want? Pam Horner. 16 

### MS. HORNER: Pam Horner. I think 17 

### Joe's last statement was the perfect summary. 18 

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

### two outcomes of this rulemaking. One outcome 20 

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

### for example, those for PAR lamps such that the 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### entire category that encompasses the PAR shape 1 

### is gone because the reflector system and the 2 

### distribution of light that comes out of that 3 

### BR shape cannot achieve the efficacy levels of 4 

### the PAR lamp. 5 

### The other outcome that is possible 6



### -- so we're talking philosophy here

-- is that 7 

### the BR shapes today could be made more 8 

### efficient by incorporating the same types of 9 

### technologies that are incorporated into the 10 

### PAR lamp rule. But I think you can see 11 

### clearly from the demonstration or maybe not 12 

### clearly from the demonstration but from the 13 

### numbers in any case that a BR shape reflector 14 

### is not physically capable of achieving the 15 

### efficacy levels of PAR lamps. That's point 16



### one. 17 

### So the other outcome could be that 18 

### what we have in that shape category could be 19 

### made more efficacious. But the warning is 20 

### that the efficacy levels would have to be 21 

### because of physics lower than those set for 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### the PAR lamps. So you can see that this is a 1 

### crossing point here. Wha t is the intent? And 2 

### the demonstration to me clearly shows if you 3 

### were watching the smoothness of beam that a 4 

### flood in PAR parlance is not the same thing as 5 

### a flood in BR parlance. Thereby, they have 6 

### two different utilities. 7 

### FACILITATOR BROOKMAN: Than k you. 8 

### So other comments on this series of 9 

### issues involving the demonstration? Jeff 10 

### Harris? 11 

### MR. HOWLEY: Jeff Harris, Alliance 12 

### to Save Energy. 13 

### FACILITATOR BROOKMAN: Hey, Jeff, 14 

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

### comments from industry. Is it John? 16


### MR. GREEN: Yes. 17 

### FACILITATOR BROOKMAN: Let's hear 18 

### all from industry and then we'll hear from 19 

### others. 20 

### Go ahead, John. 21 

### MR. GREEN: Thank you. John Green. 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### I'm with Cooper Lighting. We manufacture 1 

### luminaires and not lamps. But we also 2 

### manufacture those luminaires for a wide 3 

### variety of sources including reflector lamps, 4 

### metal halide, fluorescent, regular 5 

### incandescent. We employ a large number of 6 

### optical engineers to deliver light in the most 7 

### efficient way we can to work surfaces in area s 8 

### that do need those lights, that do need the 9 

### light. And a lot of these require reflectors 10 

### or refractive materials and fixtures. 11 

### In the cases where we use reflector 12 

### lamps to meet customer requirements, we have 13 

### to rely on the optics in that lamp to deliv er 14 

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

### reinforce Joe's explanation of the utility and 16 

### as a luminaires manufacturer we rely on 17 

### various lamp types to deliver various types of 18 

### utility lighting. 19 

### FACILITATOR BROOKMAN: Right. 20 

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

### for our customers. And the customers are 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### demanding that. So if we don't have that 1 

### variety of lamp available to us it would 2 

### really limit the type of luminaire we can 3 

### deliver to the customer. 4 

### FACILITATOR BROOKMAN: Many 5 

### different functions. 6


### MR. GREEN: Yes. 7 

### FACILITATOR BROOKMAN: Many 8 

### different kinds of utility accompanying those 9 

### different functions. 10 

### MR. GREEN: Exactly. Thank you. 11 

### FACILITATOR BROOKMAN: Jeff Harris. 12 

### MR. HARRIS: Thank you. Jeff 13 

### Harris, Alliance to Save Energy. I apologize 14 

### if this might be something that is in the 15 

### documentation already that I missed. But 16 

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

### about the higher light output I guess I have a 18 

### twofold question and that is if the market 19 

### decides to deliver equivalent output with 20 

### higher efficacy, lower wattage, how does that 21 

### lower wattage range or how would that affect 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### the efficacy of those lamps? Would they still 1 

### be the same efficacy using these technologies 2 

### or would they be lowered? 3 

### I guess the second question

-- You 4 

### might want to comment on both of them

-- is 5 

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

### lighting system losses if instead of a lower 7 

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

### dimmed to maintain that level of output. 9


### FACILITATOR BROOKMAN: Joe. 10 

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

### completely understand your question. I guess 12 

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

### standard is set specifically on R lamps or ER 14 

### lamps or both, it would increase the 15 

### efficiency. So the wattage would go down

. 16 

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

### same light output might be generated from a 60 18 

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

### It would be some lower wattage with the 20 

### halogen technology or some type of halogen 21 

### technology producing the same light output as 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### the lamps we have today but at lower wattage. 1 

### So it would be more efficient R lamp products 2 

### that would maintain the same utility and same 3 

### light distribution. 4 

### The second part of that question

-- 5 

### I'm not sure if I answered your question 6



### co rrectly and perhaps if I haven't you can 7 

### rephrase. 8 

### MR. HARRIS: I guess I was just 9 

### looking at the limitation of the 40 watt. 10 

### MR. HOWLEY: Oh that. 11 

### MR. HARRIS: And the range DOE 12 

### considered and for these lamps. 13 

### MR. HOWLEY: Okay. I didn't 14 

### understan d that. 15 

### MR. HARRIS: If instead the market 16 

### were to use these technologies would this 17 

### level of efficacy be achievable at lower 18 

### wattage and the same lumen output? 19 

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

### wattage. That technology has limited in terms 21 

### of how low you can go with the wattage. 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### FACILITATOR BROOKMAN: Keith. 1 

### MR. COOK: Keith Cook. Maybe what 2 

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

### curves. The problem is you go down in lower 4 

### wattages the efficiency also goes down. It's 5 

### very consistent. All of the classes showed 6 

### the same phenomena. 7 

### MR. HOWLEY: Also I understand from 8 

### our engineers there's technical limitations to 9 

### how low you can take

-- You can still use 10 

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

### can take that technology. There's limit ations 12 

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

### issues at real low wattages. 14 

### FACILITATOR BROOKMAN: Okay. Yes, 15 

### Tim. 16 

### MR. BALLO: Tim Ballo, 17 

### Earthjustice. If the Department sets a 18 

### standard at one of the higher energy levels, 19 

### it strikes me there's a potential for 20 

### manufacturers to come out with something less 21 

### than a 40 watt bulb that would be outside of 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### the scope of the standard. So I don't 1 

### understand. I guess I recall that the 40 watt 2 

### is a minimum wattage in the statute. But if 3 

### the Department de termines that that is likely 4 

### to happen that you could be potentially 5 

### creating a loophole for lamps less than 40 6 

### watts. I would encourage the Department to 7 

### explore standards for lamps that are less than 8 

### 40 watts or just extending the efficiency 9 

### equations down below 40 watts finding that 10 

### there's potential energy savings there. 11 

### FACILITATOR BROOKMAN: Okay. 12


### Joe. 13 

### MR. HOWLEY: I guess just to 14 

### comment on that. I would argue or suggest 15 

### that that would not be a loophole. If 16 

### manufacturers indeed created real ly low 17 

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

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

### significant energy savings. 20 

### FACILITATOR BROOKMAN: So a lot 21 

### said on this subject. Anything final before 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### we move on? 1 

### MS. GUPTA: Well, can I just ask 2 

### one question related to the different bulb 3 

### shapes? So combining what you said about ER 4 

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

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

### being suggested is taking this product class 7 

### structure and creating even further divis ions? 8 

### Having maybe another set of divisions that 9 

### groups BR together and ER and R together? Is 10 

### that what is being suggested? 11 

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

### that you need to separate

-- You need to 13 

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

### separate ER from R from BR in terms of the 15 

### efficiency. 16 

### MS. GUPTA: Okay. 17 

### MR. HOWLEY: The efficiency is very 18 

### similar in terms of what you can get from 19 

### these types of lamps. 20 

### MS. GUPTA: The three of them. 21 

### MR. HOWLEY: What we're suggesting 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### is that when you did your analysis and you 1 

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

### were clearly using curves from the PAR lamp 3 

### standard. So it was obvious that this was 4 

### based on the PAR lamp technology. And what 5 

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

### apply a PAR lamp technology efficiency to R 7 

### lamps. 8 

### MS. GUPTA: Okay. 9 

### MR. HOWLEY: You need to

-- Your EL 10 

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

### using R lamp technology and the curves have to 12 

### be based on R lamp or ER lamp technology. 13 

### Within this technology you could use the same 14 

### curve for the same similar diameter. 15 

### FACILITATOR BROOKMAN: Keith. 16 

### MR. COOK: Keith Cook. How about 17 

### if in our written comments we provide some 18 

### recommended product classes? 19 

### MS. GUPTA: That would be great. 20


### FACILITATOR BRO OKMAN: Okay. Good. 21 

### Yes, Ali. 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### MS. LEHR: I was just wondering if 1 

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

### lamp. Is there an average percent difference 3 

### in efficiency? You know, if you were looking 4 

### at these

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

### is there a certain percent reduction that you 6 

### would suggest using? 7 

### FACILITATOR BROOKMAN: Brian. 8 

### MR. VEDDER: Brian Vedder. Yes, 9 

### there are somewhere between 15 to 20 percent 10 

### less from the published catalog values. For 11 

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

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

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

### So there's a pretty significant difference 15 

### between the two. 16 

### FACILITATOR BROOKMAN: Did you

-- 17 

### Did I hear correctly? Did you say as a 18 

### deviation from th e published values? 19


### MR. VEDDER: No. 20 

### FACILITATOR BROOKMAN: Or is it the 21 

### published values? 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### MR. VEDDER: Using the published 1 

### values. 2 

### FACILITATOR BROOKMAN: Thank you. 3 

### Okay. 4 

### MR. HOWLEY: What Brian was saying 5 

### is that there's about approximately a 20

-- 6 

### And those are going to have different life 7 

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

### rating or you normalize them on a same life 9 

### rating, it appears to be approximately a 20 10 

### percent reduction in efficiency when you go to 11 

### the R lamp or ER lamp efficiency versus what 12 

### is possible with PAR lamp efficiency. 13 

### In other words, when you use the 14 

### same technology internally and you measure 15 

### lumens, you are going to get about 20 percent 16 

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

### of a reflector lamp. There are limitations to 18 

### how efficient this reflector is versus how 19 

### efficient we can make a PAR lamp reflector. 20 

### We simply can do a better job with reflector 21 

### technology with PAR lamps than we can with 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### blown glass where we silverize the interior of 1 

### blown glass. 2


### FACILITATOR BROOKMAN: Pam. 3 

### MS. HORNER: Pam Horner. And lest 4 

### the next comment I predict would come up is, 5 

### well, if the PAR shape is that much more 6 

### efficient why wouldn't we simply abandon the 7 

### BR. That was the point of the demonstration. 8


### FACILITATO R BROOKMAN: Right. 9 

### MS. HORNER: So maybe we are 10 

### zeroing in on with more clarity the point of 11 

### the demonstration which is there still remains 12 

### particularly in residential application how 13 

### utility for broad distribution filament lamp 14 

### technology which is capable of being achieved 15 

### with BR shape and is very different in 16 

### character with a PAR shape. 17 

### FACILITATOR BROOKMAN: John. 18 

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

### important for me to clarify that my statement 20 

### was based on the fact that we foresaw the 21 

### elimination of a ll the other reflector lamps 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### other than the PAR lamp and that was our 1 

### concern as a luminaire manufacturer. So I may 2 

### not have made that clear in my first 3


### statement. 4 

### FACILITATOR BROOKMAN: Thank you. 5 

### MR. GREEN: Thank you. 6 

### FACILITATOR BROOKMAN: Okay. So I 7 

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

### Yes. Okay. 9 

### MS. GUPTA: All right. And lastly, 10 

### I'll discuss the product price determination. 11 

### For this rulemaking, DOE plans on taking a 12 

### very similar approach to that which was taken 13 

### in the July 2009 final rule where prices were 14 

### developed by discounting blue book or 15 

### manufacturer list prices to develop high 16 

### range, medium range and low range and user 17 

### retail prices. And if a higher efficacy 18 

### replacement lamp analyzed in the engineering 19 

### analysis was not com mercially available, DOE 20 

### applied the incremental price difference 21 

### associated with that technology to develop a 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### price for that lamp replacement. 1 

### In addition, DOE applied weighted 2 

### average sales tax data by region based on 3 

### local data from sales tax clearinghouse. And 4 

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

### product price determination. 6 

### FACILITATOR BROOKMAN: Brian. 7 

### MR. VEDDER: Brian Vedder. NEMA 8 

### strongly recommends the use of the lowest 9 

### average retail price when doing the analysis 10 

### since consumers are buying this product 11 

### primarily based on the lowest price point. 12 

### This represents also the highest volume sales 13 

### channel. As we mentioned before, the roughly 14 

### 70 to 75 percent of the market that uses the 15 

### BR lamp is a consumer product. And this also 16 

### ackn owledged by the DOE in the framework 17 

### document section 2.9.3. Thank you. 18 

### FACILITATOR BROOKMAN: Thank you. 19 

### MR. HOWLEY: This is Joe Howley. 20 

### This would vary again from the PAR lamp 21 

### analysis where the median price was picked as 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### that lamp is primarily commercial lamp with a 1 

### lot of different price points. And it made 2 

### sense to use a median price. 3 

### With the reflector lamp, it's 4 

### primarily a consumer lamp and consumers 5 

### typically buy it at big box stores and other 6 

### mass merchandisers who are known for their lo w 7 

### pricing strategies and this is where the 8 

### majority of these types of products are 9 

### purchased. So it makes more sense to use a 10 

### typical price that a mass merchant sold to a 11 

### consumer which tends to be a low price point 12 

### because of their buying power. 13 

### MR. CYMBALSKY: This is John 14 

### Cymbalsky. Would you have data on how those 15 

### sales are portioned out between big box stores 16 

### and other retailers? Is that part of the NEMA 17 

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

### would help us verify the position you have on 19 

### the p rice end. 20 

### MR. HOWLEY: We have some of that 21 

### data, not quite to that detail. Although we 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### may -- individual companies may have more data 1 

### on customer sales. NEMA would have to do a 2 

### special survey to get down to that level. We 3 

### have a survey now, our statistical program, 4 

### where we show incandescent lamps sold through 5 

### various retail channels. But we'd have to 6 

### break that down to the reflector lamp level. 7


### FACILITATOR BROOKMAN: Pam. 8 

### MS. HORNER: Pam Horner. I think 9 

### one very appropriate place to help you i s in 10 

### the individual manufacturer interviews. Are 11 

### you going to be doing those? 12 

### MS. GUPTA: Yes, we will be. 13 

### MS. HORNER: Because in those 14 

### interviews we're always happy to share the 15 

### price points and such for our own companies 16 

### and I think it works out quite well in that 17 

### particular venue. So that might be the place. 18 

### MR. VEDDER: Okay. Thank you. 19 

### FACILITATOR BROOKMAN: Okay. 20 

### Thanks. 21 

### MS. GUPTA: All right. Now I'll 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### turn it over

-- Is it time for a break, Doug? 1 

### FACILITATOR BROOKMAN: Okay. 2 

### Fiftee n minute break now sounds good. It's 3 

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

### sure you wear your badge inside the building. 5 

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

### ground floor. Dunkin Donuts is there. And if 7 

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

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

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

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

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

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

### (Whereupon, a short recess was 14 

### taken.) 15 

### FACILITATOR BROOKMAN: On the 16 

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

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

### energy use and life

- cycle cost and payback 19 

### period analysis. Matt Hartley. 20 

### MR. HARTLEY: Thank you. My name 21 

### is Matt Hartley. I'll be speaking with you 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### about the energy use, the LCC and payback 1 

### period. 2 

### The Department uses the energy use 3 

### analysis to estimate energy consumption of 4 

### baseline and higher

- efficacy lamps. This 5 

### energy consumption is used in the life

- cycle 6 

### cost, payback period and national impact 7 

### analysis. 8 

### To calculate energy usage, we take 9 

### the operating hours of the lamp times the lamp 10 

### wattage. These operating hours come from DOE 11 

### surveys including the Lighting Market 12 

### Characterization, Commercial Building Energy 13 

### Consumption Survey and the Residential Energy 14 

### Consumption Survey. These surveys allow DOE 15 

### to account for variation in annual operating 16 

### hours by building type and lighting 17 

### application across census divisions and large 18 

### states. The table here shows the average 19 

### operating hours for the commercial and 20 

### residential sectors that were determined for 21 

### the July 2009 final rule. 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### At this time, DOE would welcome any 1 

### comments on the methodology for determining 2


### energy usage. 3 

### FACILITATOR BROOKMAN: Brian. 4


### MR. VEDDER: A little out of order. 5 

### Brian Vedder. We strongly recommend that DOE 6 

### uses the residential hours with respect to the 7 

### ER, BR and PAR type lamps. 8 

### FACILITATOR BROOKMAN: Thank you. 9 

### Yes, Pekka. 10 

### MR. HAKKARAINEN: Pekka 11 

### Hakkarainen. I would also like to note that 12 

### the use of lighting controls can have a 13 

### significant effect on energy use even in 14 

### residential applications. There is a little 15 

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

### residential applications. 17 

### Just for your information, NEMA has 18


### starte d working on a better residential 19 

### lighting control energy study to develop such 20 

### data, but I would like to certainly suggest 21 

### that DOE take into account the use of lighting 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### controls for these lamps. We estimate that 1 

### there are about 15 to 20 percent of the 2



### r esidential reflector lamps, for example, 3 

### operated by dimmers. And this represents 4 

### something like 70 million lamps in the 5 

### sockets. 6 

### And one final note is that we have, 7 

### NEMA has, been working with some of the NGOs 8 

### such as Jeff Harris who was here earlier i n 9 

### this room to develop residential energy code 10 

### requirements that acknowledge the use of 11 

### lighting controls in those applications, codes 12 

### such as the International Energy Conservation 13 

### Code or Title 24 of the California Code of 14 

### Regulations. And NEMA will, of course, be 15 

### happy to work with DOE to determine how this 16 

### could be done. 17 

### Thank you. 18 

### FACILITATOR BROOKMAN: Would there 19 

### be a comment confirming the use of the hours 20 

### listed here for commercial and residential? 21 

### No need to comment on that? 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### Joe. 1 

### MR. HOWLEY: We agree with the 2 

### hours presented for commercial and 3 

### residential. We would just suggest using the 4 

### residential hours as the primary basis for 5 

### analysis. 6 

### FACILITATOR BROOKMAN: Right. 7 

### Gotcha. Okay. 8 

### Yes please. Pekka. 9 

### MR. HAKKARAINEN: Pekka 10 

### Hak karainen. Just to be clear, the hours that 11 

### are shown here are the typical average hours 12 

### in residential. If lighting controls are 13 

### used, controls such as vacancy sensors or 14 

### timer switches or dimmers for that matter, the 15 

### effective hours are reduced when that is done. 16 

### So some percentage of these lamps

-- we 17 

### estimate 15 to 20 percent

-- would merit the 18 

### consideration of lighting controls. 19 

### FACILITATOR BROOKMAN: Okay. Thank 20


### you. 21 

### MS. GUPTA: Doug, can I ask a 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### question? 1 

### FACILITATOR BROOKMAN: Sure. Mimi. 2 

### MS. GUPTA: Mimi Gupta. Pekka, you 3 

### mentioned that you are aware of a couple of 4 

### residential studies. In your written 5 

### comments, could you just make note of those? 6 

### That would be very helpful. 7 

### MR. HAKKARAINEN: Okay. We'll 8 

### include them in the written c omments. Thank 9


### you. 10 

### FACILITATOR BROOKMAN: Thank you. 11


### So Matt. 12 

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

### discuss the life

- cycle cost and payback period 14 

### analysis. So the life

- cycle cost and payback 15 

### period is used to assess the impacts on a 16 

### consumer due to en ergy conservation standards. 17 

### It's conducted from the consumer's perspective 18 

### and shows the cost of owning and operating the 19 

### lamp over its lifetime. 20 

### As indicated in the diagram below, 21 

### the LCC considers two components - The first 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### cost, which is purchase price and 1 

### installation, and the operating cost 2 

### discounted to present value. When 3 

### appropriate, DOE calculates a residual value 4 

### for the remaining useful life of a lamp at the 5 

### end of the analysis period. 6 

### This allows DOE to calculate the 7 

### total life

- cycle cost for each standard level 8 

### considered. Results are then expressed as LCC 9 

### savings or the baseline LCC minus the 10 

### standards

- level LCC. A payback period is also 11 

### calculated and reported. 12 

### So I'll now discuss some key inputs 13 

### and the methodology used to calculate the LCC 14 

### and payback period, which is very similar to 15 

### what was done in the July 2009 final rule. 16 

### So, as mentioned previously, the life

- cycle 17 

### cost is derived from total installed price and 18 

### the total operating cost discounted to present 19 

### value. 20 

### The total installed price is made 21 

### up of purchase price, which includes product 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### price and sales tax, and the installation 1 

### cost. DOE could potentially use different 2 

### prices for the commercial and residential 3 

### sector as was discussed earlier. 4 

### Second, the total operat ing cost is 5 

### made up of the electricity consumption, as 6 

### explained in the energy use analysis 7 

### previously, and the electricity cost. Then 8 

### DOE uses a discount rate to calculate the 9 

### present value of any cash flows over the 10 

### analysis period. The discount rate i s 11 

### calculated separately for the residential and 12 

### commercial sector and the analysis period is 13 

### the lamp service life in years and is 14 

### determined by dividing the lamp's total life 15 

### time in hours by the annual operating hours 16 

### derived in the energy use analysis. 17 

### For installation costs, as we 18 

### mentioned previously, installation costs are a 19 

### component of the total installed cost. As was 20 

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

### calculate an installation cost for the 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### commercial sector, but assumes no installati on 1 

### cost for the residential sector. Installation 2 

### cost is the product of the average labor cost 3 

### and time needed to install the lamp. 4 

### DOE proposes to use “RS Means 5 

### Electrical Cost Data of 2007” and data from 6 

### the US Bureau of Labor Statistics, as was done 7 

### in the July 2009 final rule, to estimate 8 

### installation costs. These estimate an average 9 

### labor time of approximately four minutes and 10 

### average labor rate of $16.55. 11 

### This slide is not in your deck. It 12 

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

### receive some comment. 14 

### DOE plans to consider different 15 

### purchasing events in the life

- cycle cost and 16 

### payback period analysis. The two events 17 

### considered are new construction or renovation 18 

### and lamp replacement. As you saw in the 19 

### engineering analysis, several higher

- efficacy 20 

### replacements have a higher lumen output than 21 

### the baseline. 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### DOE is considering that the spacing 1 

### of fixtures can be altered during new 2 

### construction and renovation to include fewer 3 

### lamps and maintain the same total lumen 4 

### output. As such, DOE is c onsidering 5 

### normalizing total lumens for the new 6 

### construction and renovation event. DOE does 7 

### not plan to normalize lumens for the lamp 8 

### replacement event because consumers cannot 9 

### alter the existing lamp fixtures. 10 

### DOE welcomes comment on this 11 

### proposal. 12



### F ACILITATOR BROOKMAN: Joe. 13 

### MR. HOWLEY: Okay. Interesting 14 

### proposal. This is Joe Howley. The issue with 15 

### this, it's interesting because your new 16 

### construction/renovation concept is that you 17 

### would be able to space these fixtures further 18 

### apart simply because the PAR lamps would have 19 

### more lumens. 20 

### The fallacy of this concept is that 21 

### PAR lamps have a much tighter beam 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### distribution associated with them than R 1 

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

### able to space the fixtures further apart 3 

### because of the much broader distribution. But 4 

### indeed even though you were getting more light 5 

### out of PAR lamp you would not

-- In fact, 6 

### you'd probably have to space them closer. 7 

### If you passed a regulation that was 8 

### so high that you knew that R lamps were going 9 

### away and you only had PAR lamps left, you 10 

### would actually have to space the fixtures 11 

### closer rather than further apart because the 12 

### beam distribution is so tight on them. To get 13 

### a uniform distribution of light below, you 14 

### would have to move in. You would definitely 15



### n ot be able to space them further apart in a 16 

### new construction scenario. And it has to do 17 

### with the optics of the utility of the 18 

### products. It could only be done 19 

### theoretically, but in actuality you wouldn't 20 

### be able to get the proper beam distribution. 21


### MR. HARTLEY: Thank you. 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### FACILITATOR BROOKMAN: Other? Yes, 1


### Lane. 2 

### MR. BURT: Lane Burt, NRDC. It 3 

### seems like DOE is kind of wrangling with a lot 4 

### of questions about the sophistication of the 5 

### consumer and this is another one. The 6 

### sophistication of the cons umer to tell between 7 

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

### the Department is having to deal with. And we 9 

### certainly support trying to make the model 10 

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

### going to be 100 percent. Disregard the 12 

### differences , it's not going to be zero 13 

### percent. They all take into account the 14 

### differences. 15 

### But to the extent that the 16 

### Department can look for outside data sources, 17 

### talk to some renovation contractors and try to 18 

### get a percentage of how many folks actually do 19 

### a lighting redesign when they do a renovation. 20 

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

### the Department to look for outside data 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### sources for this tough decision that is going 1 

### to have to be made over and over again. 2 

### MR. HOWLEY: And, Lane, to that 3 

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

### residential or commercial lighting designers, 5 

### and I think they would validate the point that 6 

### I raised. 7 

### FACILITATOR BROOKMAN: Okay. Thank 8


### you. 9 

### I thought I saw somebody else. 10 

### Yes, Lane. 11 

### MR. BURT: One other poin t. Lane 12 

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

### now also going to be finding the decision an R 14 

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

### There are CFL reflector lamps. There are 16 

### other types of lamps. So that needs to factor 17 

### in especially if the co nsideration is on how 18 

### broad the beam is and where the lights are 19 

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

### different direction altogether. 21


### FACILITATOR BROOKMAN: Pam. 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### MS. HORNER: Pam Horner. Are we on 1 

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


### MS . MAUER: This is a new item. 3 

### MS. HORNER: So this is item X. 4 

### Thank you. 5 

### FACILITATOR BROOKMAN: And since 6 

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

### sure to give everybody a chance to look at 8 

### this and comment as they wish. Anything else? 9 

### If nothing else, okay. 10 

### (No verbal comment.) 11 

### MR. HARTLEY: Okay. To calculate 12 

### operating costs, we must multiply energy 13 

### consumption by energy prices. DOE calculates 14 

### average electricity prices for 13 geographic 15 

### areas by examining electric utility data. 16 

### This data is available from the Energy 17 

### Information Administration's Form EIA

- 861 18 

### which allows DOE to calculate the current 19 

### electricity price in each geographic region 20 

### for the residential and commercial sectors. 21 

### DOE then uses this current 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### electricity price to project electricity 1 

### prices using the Annual Energy Outlook. DOE 2 

### applies the trend seen in the Annual Energy 3 

### Outlook to the current price to project future 4 

### electricity prices. 5 

### Once all the cash flows are 6 

### determined, DOE uses a discount rate to 7 

### calculate the present value of expenses over 8 

### the analysis period. Discount rates are based 9 

### on the interest or finance cost to purchase 10 

### and operate products. This finance cost can 11 

### either be the cost of the debt or the 12 

### opportunity cost of equity used to purchase 13 

### and operate lamps. 14 

### The discount rate, like many other 15 

### components of the life

- cycle cost and payback 16 

### period analysis, uses a methodology similar to 17 

### what was done in the July 2009 final rule. 18 

### DOE welcomes comment on all aspects of the 19 

### life

- cycle cost and payback period analyses. 20 

### FACILITATOR BROOKMAN: Yes. Keith. 21 

### MR. COOK: Keith Cook. NEMA would 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### like to caution the DOE on the three year 1 

### rebuttable presumption that you have got 2 

### included in the information. And the problem 3 

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

### product is only two years then the three year 5 

### rebuttable presumption no longer makes any 6



### sense. 7 

### So therefore we'd recommend they 8 

### either use a two year payback as the 9 

### rebuttable presumption or the life of the 10 

### product, one or the other. 11


### FACIL ITATOR BROOKMAN: Okay. 12


### Joe. 13 

### MR. HOWLEY: And just to add 14 

### agreement to the electricity pricing analysis, 15 

### we would agree that that is an acceptable way 16 

### to determine electricity prices. 17 

### FACILITATOR BROOKMAN: And I just 18 

### want to clarify. Keith, you were speaking on 19 

### behalf of NEMA just a moment ago? 20


### MR. COOK: Yes. 21


### FACILITATOR BROOKMAN: You were. 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### Yes. Thank you. Okay. 1 

### So then other comments on this 2 

### inquiry, this comment box 10? These issues 3 

### related to LCC and payback period analysis? 4 

### (No verbal comment.) 5 

### Okay. 6 

### MR. HARTLEY: All right. At this 7 

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

### about shipments and the national impact 9 

### analysis. 10 

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

### going to be talking about shipments and the 12 

### national impact analysis. 13 

### So the purpose of the shipments 14 

### analysis is to estimate the shipments of 15 

### exempted lamps and the product mix of the 16 

### stock over the entire analysis period. This 17 

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

### case absent any standards for the exempted 19 

### lamps, and the standards case. 20 

### The NIA uses the shipment and stock 21 

### estimates to determine national energy savings 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### and net present value at various standard 1 

### levels. It's important to note that the 2 

### rulemaking only calculates energy savings for 3 

### consumers of exempted lamps. 4 

### To calculate installed stock and 5 

### shipment forecasts, DOE plans to use the same 6 

### methodology as the July 2009 Lamps Rule. In 7 

### that rule, DOE used historical shipments and 8 

### the average service lifetime to calculate 9 

### installed stock. DOE then appl ied growth in 10 

### floor space and assumptions regarding emerging 11 

### technologies to forecast the stock over the 12 

### analysis period. 13 

### For this rule, DOE plans to use the 14 

### latest versions of RECS and CBECS to determine 15 

### the anticipated growth in the number of IRL 16 

### socke ts in the residential and commercial 17 

### sectors. After forecasting the installed 18 

### stock, DOE then calculated the shipments 19 

### required to meet that stock, which would 20 

### include shipments due to both new construction 21 

### and lamp replacement events. 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### As I mentioned, DOE plans to use 1 

### historical shipments to calculate the 2 

### installed stock. NEMA submitted shipments as 3 

### part of the July 2009 Lamps Rule that were 4 

### disaggregated by halogen and non

- halogen lamp 5 

### shipments. As part of that rule, DOE applied 6 

### several assumptions to further characterize 7 

### the market. DOE plans to use the same 8 

### assumptions in this rule and they are 9 

### summarized here on this slide. Based on 10 

### manufacturer interviews, DOE assumes that the 11 

### NEMA shipments represent 70 percent of all 12



### non - halogen IRL shipments. 13 

### EISA 2007 set standards applicable 14 

### to some IRL, yet exempted others which are now 15 

### the subject of this rulemaking. DOE assumes 16 

### that the exempted lamps represent 60 percent 17 

### of all non

- halogen IRL shipments in 2005. And 18 

### last, DOE believes that 33 percent of non

19 

### halogen IRL go to the commercial sector, where 20 

### 67 percent go to the residential sector. 21 

### DOE requests comment on these 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### assumptions and also on the market share of 1 

### the 65 watt and 45 watt baseline lamps that 2 

### were selected in the engineering analysi s. 3


### FACILITATOR BROOKMAN: Pam Horner. 4 

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

### organized today. This is really

-- 6 

### MR. HOWLEY: This is Joe Howley. 7 

### Question as to if your IRL analysis was based 8 

### on all reflector lamps or was it simply based 9 

### on the exem pted reflector lamps? 10 

### MS. LEHR: You mean the analysis 11 

### for -- 12 

### MR. HOWLEY: Yeah. These 13 

### percentages that you're showing up here, was 14 

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

### based on only the exempted reflector lamps? 16 

### MS. LEHR: Just the exempt ed. 17 

### Well, I guess the non

- halogen IRL probably 18 

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

-- 19 

### FACILITATOR BROOKMAN: Mimi. 20 

### MS. GUPTA: Yes, Mimi Gupta, 21 

### Navigant Consulting. So NEMA submitted data 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### from 2001 to 2005 and it was disaggregated by 1 

### R incandescent and PAR incandescent. 2 

### MR. HOWLEY: Okay. 3 

### MS. GUPTA: Which was a little 4 

### confusing to us because it was our 5 

### understanding that most PARs were regulated at 6 

### a high enough efficacy already to be halogen. 7 

### So we took all of those incandescents, the R 8 

### incand escent plus the PAR incandescent, and we 9 

### tried to estimate what portion of those 10 

### remained exempt when EISA added new coverage. 11 

### So EISA took some of those incandescents and 12 

### made them halogen. And what portion remained 13 

### exempt and that's what that 60 percen t 14 

### represents. That's 60 percent of the R 15 

### incandescent plus PAR incandescent are the 16 

### exempted lamps. 17 

### MR. HOWLEY: Okay. So we may want 18 

### to reanalyze that data to see if those 19 

### percentages are still valid or accurate. 20 

### FACILITATOR BROOKMAN: You think 21 

### the market shifted or you think that 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### something's happened there? 1 

### MR. HOWLEY: Well, it could be that 2 

### the reflector lamp market which is really what 3 

### we're talking about regulating here is more 4 

### heavily residential even than the 67 percent 5 

### suggests. But that may be something that we 6 

### want to look at a little further within our 7 

### own groups. It's certainly heavily 8 

### residential at least 67 percent and maybe 9 

### higher. 10 

### FACILITATOR BROOKMAN: And you can 11 

### see also the Department requests information 12 

### on market shares of 65 watt and 45 watt. 13 

### MR. HOWLEY: Again, that's 14 

### information that we could work with our NEMA 15 

### statistical department to perhaps develop a 16 

### special survey. If you require specific data, 17 

### it might be beneficial perhaps working with 18 

### Navigant or DOE to get al l of the questions on 19 

### the table where data is needed and then we 20 

### could talk to the NEMA statistical department 21 

### about collecting a special survey to provide 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### that data of where the market is today. 1 

### FACILITATOR BROOKMAN: Just do one 2


### survey. 3 

### MR. HOWLEY: One survey on all the 4 

### questions that have to do with market share. 5 

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

### FACILITATOR BROOKMAN: Okay. 7 

### MR. HOWLEY: I always feel it's 8 

### better to work with accurate, current data 9 

### than projected data. It always s eems to be 10 

### better. 11 

### FACILITATOR BROOKMAN: The 12 

### Department likes that. They really do. 13 

### MR. HOWLEY: The only other comment 14 

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

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

### sure, to project out over 30 years for ene rgy 17 

### savings. It still seems to us that this is 18 

### not a practice that can lead to any kind of 19 

### accurate energy savings assumptions over 30 20


### years. 21 

### In particular, this product line I 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### believe is subject to another rulemaking 1 

### sometime in the future, perhaps by 2020. And 2 

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

### that date right or not. We could check the 4 

### rulemaking process to see when another 5 

### rulemaking is scheduled. At the very least, 6 

### there is talk within the National Energy 7 

### building debated right now of r equiring 8 

### another rulemaking on these types of products. 9 

### So it's our belief that another 10 

### rulemaking will occur one way or another on 11 

### these products, probably in the next ten 12 

### years. And given that that next rulemaking is 13 

### likely to have a significant impac t on these 14 

### products, it would only seem prudent to 15 

### estimate energy savings over the next ten 16 

### years because this rulemaking is likely to 17 

### generate energy savings of ten years or at 18 

### least to the next rulemaking. 19 

### If you're to project energy savings 20 

### over 30 y ears and then do another rulemaking 21 

### and project another 30 years energy savings, 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### you're really double or triple counting the 1 

### energy savings from each of these rulemakings. 2 

### That would be our estimate. It would seem 3 

### that you should project energy savings u p 4 

### until you expect the next rulemaking and the 5 

### next rulemaking could project energy savings 6 

### from that rulemaking. 7 

### Given the fact that you don't know 8 

### what the next rulemaking will be, it really is 9 

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

### occur beyond when the next rulemaking occurs. 11


### FACILITATOR BROOKMAN: Pam Horner. 12 

### MS. HORNER: My data showed that a 13 

### 2015 DOE rulemaking will set new standards for 14 

### all reflector lamps effective 2018. 15 

### FACILITATOR BROOKMAN: Okay. 16 

### Other comments on several important 17 

### assumptions here? And other comments on these 18 

### assumptions? 19 

### (No verbal response.) 20 

### Okay. 21 

### MS. LEHR: To account for the 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### market penetration of other relating 1 

### technologies in the IRL market, DOE plans to 2 

### model two base case scenarios similar to those 3



### mo deled in the July 2009 Lamps Rule. The 4 

### first is the existing technology scenario, 5 

### which forecasts the market penetration of 6 

### technologies that are currently available and 7 

### have reached maturation in terms of price and 8 

### efficacy, such as reflector CFLs. 9 

### The second is an emerging 10 

### technologies, which forecast both the 11 

### penetration of mature technologies and those 12 

### that are still undergoing significant changes 13 

### in price and efficacy. This would include 14 

### reflector CFLs, LEDs and ceramic metal 15 

### halides. 16 

### To establish the market penetration 17 

### forecast, DOE estimated the price and 18 

### performance of the alternative technologies 19 

### over the analysis period. DOE then calculated 20 

### the payback period of each alternative 21 

### compared to IRL. And last DOE used a 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### relationship between payback period and market 1 

### penetration to determine the forecasts. 2 

### So this graph illustrates how the 3 

### existing and emerging technology scenarios 4 

### might affect shipments. For the emerging 5 

### technology base case, there is initial decline 6 

### in shipments followed by a slight increase. 7 

### In this scenario, there is a large 8 

### increase in the market penetration of other 9 

### technologies, primarily LEDs, at the beginning 10 

### of the forecasted period lasting until about 11 

### 2020. After that point, the market 12 

### penetration remains fairly co nstant. 13 

### We see an increase in shipments 14 

### later in the analysis period due to overall 15 

### growth in the IRL market. In the July 2009 16 

### Lamps Rule, some stakeholders commented that 17 

### this increase was unlikely and DOE requests 18 

### comments now on how to model the existing and 19 

### emerging technology scenarios and also what 20 

### the most likely scenario is. 21 

### MS. HORNER: If only we knew. 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### MR. HOWLEY: This is Joe Howley 1 

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

### us that this technology would continue to grow 3 

### at those types of rates given everything that 4 

### we know is happening with residential building 5 

### codes, commercial building codes, 6 

### technologies. 7 

### The technologies coming into this 8 

### market we expect over the next ten years LED 9 

### technology to come into this market. We 10 

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

### further developed and less expensive in ten 12 

### years. Compact fluorescent lamp technology to 13 

### improve, perhaps the ability to improve. 14 

### And those products all have 15 

### extremely long lives. And as they get into 16 

### the marketplace or required by building codes, 17 

### it will have the effect of shrinking the 18 

### available market for these products. And we 19 

### think that will greatly moderate any growth 20 

### beyond 2020. But also we bring back our point 21 

### that it's extremely hard to guess and it's 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### really just a guess what's going to happen in 1 

### this marketplace beyond 2020 given the rapid 2 

### change we expect to happen with lighting 3 

### technology over the next decade. 4 

### FACILITATOR BROOKMAN: Yes, Pekka. 5 

### MR. HAKKARAINEN: Pekka 6 

### Hakkarainen. I just have a couple of 7 

### questions to Ali regarding this graph so I 8 

### understand what it says. First, the vertical 9 

### axis shipment, is that units? Is that what 10 

### it's intended to be? 11


### MS. LEHR: Yes. 12 

### MR. HAKKARAINEN: Okay. And, 13 

### secondly, the two base case forecast lines , 14 

### are they alternate scenarios or do they exist 15 

### at the same time? 16 

### MS. LEHR: They're alternate 17 

### scenarios. 18 

### MR. HAKKARAINEN: Alternate 19 

### scenarios. Okay. Thank you. 20 

### FACILITATOR BROOKMAN: I would just 21 

### reflect back too. The Department has 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### requested your comments on how these scenarios 1 

### might work or what would be a more plausible 2 

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

### thought process on that, I think that would be 4 

### helpful. 5 

### MR. HOWLEY: This is Joe Howley 6 

### again. I think the emerging technologies is 7 

### probably more likely to happen especially the 8 

### downward trend to 2020. Any analysis beyond 9 

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

### I can say. 11 

### But if you take our advice or 12 

### suggestion to look at energy savings or model 13 

### this just to the next rulemaking, I think you 14 

### can get a much more

-- much closer to reality 15 

### and maybe you have to do both. I would 16 

### suggest doing one, saying we believe this to 17 

### be a fairly accurate assessment. Projecting 18 

### beyond this you might even note is really 19 

### difficult to do because of the pending 20 

### expected new rulemaking in 2018 and not 21 

### knowing exactly where that standard will set 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### efficiency levels and what products will 1 

### remain after that standard. 2 

### If you have to do a 30 year 3 

### analysis, it just has to be caveated I think 4 

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

### this analysis may or may not be." 6 

### FACILITATOR BROOKMAN: Final 7


### comments? 8 

### (No verbal comments.) 9 

### MS. LEHR: So DOE is also 10 

### considering other shipment scenarios for this 11 

### rulemaking. DOE is considering modeling the 12 

### i mpact of the July 2009 Lamps Rule. As those 13 

### standards take effect in 2012, there may be an 14 

### increase in the shipments of exempt IRL if 15 

### consumers subject to those standards choose to 16 

### purchase the cheapest lamp available. 17 

### DOE is also considering modeling a 18 

### migration to lower wattage lamps that are 19 

### outside the scope of coverage of this 20 

### rulemaking. A 40 watt lamp that is compliant 21 

### with standards will likely be more expensive 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### and have a higher lumen output than a 38 or 39 1 

### watt lamp that is not subject to stan dards. 2 

### DOE requests comments on both of 3 

### these scenarios as well as any other scenario 4 

### that stakeholders believe is likely to occur. 5


### FACILITATOR BROOKMAN: Joe. 6 

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

### believe there will be an impact based on the 8 

### 2009 Lamps R ule. There will be some impact. 9 

### However, the reflector lamp market that's low 10 

### cost isn't likely to increase that much. 11 

### There will be some impact. 12 

### But the PAR lamp market, the 13 

### retailers using these, use these because 14 

### they're more sophisticated and they recognize 15 

### the cost of energy and they recognize the 16 

### overall operating cost of a lighting system 17 

### especially if they have thousands of these in 18 

### stores that may be located throughout the 19 

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

### stick with the halogen PAR lamps (1) because 21 

### they have a different functionality. They 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### want the highlighting. They need that 1 

### highlighting to sell merchandise. So because 2 

### they need that to be highlighted and they 3 

### can't get that highlighting utility from a 4 

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

### switch. 6 

### Also they will be able to analyze a 7 

### positive economic payback for them with these 8 

### more efficient sources. And when DOE did 9 

### their economic analysis, they modeled a more 10 

### efficient payback considering cost of product 11 

### plus energy savings from using these higher 12 

### efficiency technologies. 13 

### Since this is primarily a 14 

### residential lamp that we're talking about 15 

### here, they're already using the lower cost 16 

### lamp. And only a smaller percentage of them, 17 

### a third or less, use the halogen PAR lamps 18 

### today. Those third or less using halogen 19 

### PARs, I suppose there is some risk of 20 

### migration to a lower cost lamp on the consumer 21 

### level. 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### This will be offset by perhaps a 1 

### migration to lower wattage lamps. Because if 2 

### there is a migration to lower wattage lamps, 3 

### of course that will produce national energy 4 

### savings. So that may offset any migration 5 

### from PAR lamps to reflector lamps. 6 

### I guess we would agree that it 7 

### would be interesting to do both of these 8 

### analyses to see if perhaps they offset or wha t 9 

### the net effect of both of them might be. 10 

### FACILITATOR BROOKMAN: Okay. 11 

### Tim. 12 

### MR. BALLO: Tim Ballo, 13 

### Earthjustice. Just on the notion that a 14 

### migration down a few watts would produce 15 

### national energy savings. If consumers have to 16 

### increase the number o f fixtures to compensate 17 

### for reduction in lumen output, that would seem 18 

### to cancel out those energy savings. 19 

### MR. HOWLEY: It would very 20 

### unlikely. These are mostly used in down 21 

### lights. It would be very unlikely that a 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### consumer would hire a contractor to put more 1 

### holes in their ceiling and add more down 2 

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

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

### down lights. 5


### FACILITATOR BROOKMAN: Lane. 6 

### MR. BURT: This is Lane Burt. I 7 

### would just note that consumers have access to 8 

### many plug

- in fixtures and that they can shift 9 

### to whatever lighting source they like. We are 10 

### concerned about both of these impacts and both 11 

### of these effects and we encourage the 12 

### Department to look for as much data as they 13 

### can from sources outside this room to try to 14 

### quantify and account for the analysis. 15


### FACILITATOR BROOKMAN: You can see 16 

### the two elements listed in the comment box. 17 

### So any additional comments on those two? 18 

### (No verbal response.) 19 

### MS. LEHR: Okay. Well, this brings 20 

### us to the end of the shipment analysis. And 21 

### so DOE requests comments on this general 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### methodology, specifically on the historical 1 

### shipment data and the assumptions presented to 2 

### develop shipment forecasts, the market 3 

### penetration of existing and emerging 4 

### technologies and the shipment scenarios under 5 

### consideration as well as any other comments on 6 

### the shipments analysis. I know we've covered 7 

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

### that remains left to be said. 9 

### FACILITATOR BROOKMAN: Nothing 10 

### additional? We've covere d it? 11 

### (No verbal comments.) 12 

### MS. LEHR: Okay. DOE is planning 13 

### to use the same inputs and methodology as the 14 

### July 2009 Lamps Rule to calculate national 15 

### energy savings and net present value. The 16 

### inputs for both are summarized on this slide. 17 

### For nation al energy savings the 18 

### inputs are installed stock, unit annual energy 19 

### consumption which have already been discussed 20 

### in previous slides, electricity site to source 21 

### conversion factors which are calculated using 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### the Annual Energy Outlook, HVAC interaction 1 

### for which DOE plans to use 6.25 percent in the 2 

### commercial sector, does not plan to model in 3 

### the residential sector, the rebound rate for 4 

### which DOE plans to use one percent in 5 

### commercial and 8.5 percent in residential. 6 

### For net present value, some of the inputs are 7 

### shipments per unit installed cost, electricity 8 

### prices and also two different discount rates 9 

### as indicated by OMB guidelines. 10 

### And so DOE welcomes comments on its 11 

### decision to use the same inputs and 12 

### methodology as the July 2009 Lamps Rule as 13 

### well as any other comments on the national 14 

### impact analysis. 15


### FACILITATOR BROOKMAN: Pam. 16 

### MS. HORNER: This is Pam Horner. 17 

### The only comment, what we would like to 18 

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

### shorter, more realistic projection to 2018 or 20 

### 2020 rather than to 2043. 21 

### FACILITATOR BROOKMAN: Yes. Tim. 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### MR. BALLO: Tim Ballo. I just had 1 

### a question. Sorry if you explained this. Why 2 

### was the HVAC impact not modeled in the 3 

### residential sector or not expected to be? 4 

### MS. LEHR: In the Lamps Rule, we 5



### assu med that the effects on HVAC would be 6 

### negligible in the residential sector. And so 7 

### we chose not to include that effect there. 8


### FACILITATOR BROOKMAN: Lane. 9 

### MR. BURT: Lane Burt. Is it 10 

### possible to get a quick narrative just to 11 

### refresh my memory on the rebound effect in the 12 

### residential sector? 13 

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

### rebound rate in general is you know you can 15 

### calculate energy savings for a consumer using 16 

### a more efficient product than another. But 17 

### when they're actually using that more 18 

### effi cient product it's possible that their 19 

### behavior might change. They might decide that 20 

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

### not a big deal to turn it off when they don't 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### need and it might be left on a little bit 1 

### longer. And so the actual operating hours 2 

### increase and you don't realize all the energy 3 

### savings you might think you would. DOE 4 

### believed this would be more pronounced in the 5 

### residential sector than the commercial. 6 

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

### the concept. I'm just wondering what fe d into 8 

### the development of 8.5 percent compared to

-- 9 

### I mean DOE has used five percent. DOE has 10 

### used other numbers. 11 

### MS. LEHR: Sure. There was a 12 

### summary of four different reports that was 13 

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

### took the average of the range of values that 15 

### was reported for each sector. 16 

### FACILITATOR BROOKMAN: Those 17


### sources were? 18 

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

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

### for the July 2009 Lamps Rule. 21 

### FACILITATOR BROOKMAN: Other 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### comments on this series of issues? 1 

### MR. HOWLEY: This is Joe. Just one 2 

### more thing that occurred to me on the 3 

### residential sector rebound rate is that if 4 

### more efficient products were put in these down 5 

### lights that perhaps previously were on dimmers 6 

### and these products are no longer dimmable you 7 

### would be getting energy savings from the 8 

### dimmable products that were perhaps operated 9 

### in a dim mode certain times. 10 

### And you wouldn't get those same 11 

### energy savings from, say, a compact 12 

### fluorescent lamp that either would not be 13 

### dimmable or the energy savings would be 14 

### greatly reduced because those products only 15 

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

### only dim down a couple of watts even though 17 

### the light output is going down. Whereas if 18 

### you dim an incandescent lamp that's 65 w atts, 19 

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

### time you dim it. 21 

### So the dimmer factor that Pekka has 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### mentioned a few times, 15 to 20 percent of 1 

### these sockets being dimmable, to the extent 2 

### that they move to more energy efficient 3 

### products it might also have an impact on this 4 

### rebound rate. Just a thought. 5 

### MS. LEHR: Thanks. 6


### FACILITATOR BROOKMAN: No 7 

### additional comments? 8 

### (No verbal response.) 9 

### I want to call your attention to 10 

### item 12 there one more time. DOE welcomes 11 

### comments on the decision to use the same 12 

### inputs and methodologies as the July 2009 13 

### final rule. Any additional thoughts on that? 14 

### (No verbal response.) 15 

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

### the home stretch. Now I'll just briefly 17 

### discuss some of the other NOPR analyses that 18 

### DOE plans on doing. 19 

### One of them is the manufacturer 20 

### impact analysis where the purpose is to 21 

### identify the impacts of energy conservation 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### standards on manufacturers and DOE conducts 1 

### that in three phases, the first in which DOE 2 

### creates an industry profile to characteriz e 3 

### the industry and identify key issues in 4 

### manufacturing. In phase two, DOE prepares an 5 

### industry cash flow model called the GRIM or 6 

### Government Regulatory Impact Model that takes 7 

### into account any investment and revenue 8 

### changes that the industry might experience and 9 

### an interview questionnaire to guide interviews 10 

### with manufacturers. And in phase three, DOE 11 

### interviews manufacturers, assesses impacts of 12 

### standards, both quantitatively and 13 

### qualitatively, looking at impacts on 14 

### competition, manufacturing capacity, 15 

### employment and regulatory burden. 16 

### MR. BURT: Before we jump off 17 

### manufacturing impact analysis, I just want to 18 

### make a point that we made in July especially 19 

### in the context of the emerging technologies 20 

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

### that's i n flux. There are a lot of new 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### technologies. There's a lot of new products. 1 

### It's a little interesting to project 2 

### manufacturer impact just looking at one 3 

### particular division of a large company which 4 

### may also make the replacement product should 5 

### technology shift from one product to another. 6 

### So we would strongly suggest the 7 

### Department look at the bigger picture versus 8 

### throwing out large impact numbers that may not 9 

### reflect reality as the technology changes. 10 

### FACILITATOR BROOKMAN: Thank you. 11 

### Pekka. 12


### MR. HAKKARAINEN: Pekka 13 

### Hakkarainen. An additional comment. Now I'm 14 

### not representing NEMA because I haven't 15 

### checked with my colleagues here on this 16 

### comment. It seems to me that this is a 17 

### systems issue as well. This is not just a 18 

### lamp issue. 19 

### John Green spoke earlier about the 20 

### impact on luminaries and I certainly said a 21 

### couple of things about lighting controls. So 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### I would suggest that you consider also 1 

### interviewing other manufacturers in the 2 

### industry, not just the lamp companies. Thank 3


### you. 4


### FACILITATOR BROOKMAN: Thank you. 5 

### MS. GUPTA: Okay. And the final 6 

### content slide. On this slide we list several 7 

### NOPR analyses that DOE will be conducting. 8 

### This includes the life

- cycle subgroup analysis 9 

### where DOE analyzes life

- cycle cost impacts on 10 

### various national consumer subgroups, the 11 

### utility impact analysis and environmental 12 

### impact analysis where DOE uses NEMS to assess 13 

### the impacts on generation capacity and the 14 

### airborne pollutant emissions, the employment 15 

### impact analysis which is different than the 16 

### employment impact analysis that's conducted in 17 

### the manufacturing impact analysis. That's a 18 

### direct employment impact analysis. This is an 19 

### indirect employment impact analysis. And then 20 

### finally the regulatory impact analysis that 21 

### looks at the impacts of nonregulator y 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### alternatives. 1 

### So the following few slides have 2 

### many items for comment on the analyses that 3 

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

### through each one of these, but we welcome any 5 

### comments on those analyses both in written and 6 

### verbal form. 7


### FACILITA TOR BROOKMAN: Pam Horner. 8


### MS. HORNER: Pam Horner. NEMA 9 

### agrees with item 13. 10 

### FACILITATOR BROOKMAN: Low income 11 

### and senior citizens. 12 

### MS. HORNER: And for the remainder 13 

### either have no comment at this time or will 14 

### provide written comments on the balan ce. 15 

### Particularly on the environmental, we have 16 

### some expertise in that area and we have not 17 

### consulted with those experts yet. So we will 18 

### provide them written. 19 

### FACILITATOR BROOKMAN: Thank you. 20 

### Additional comments from anyone 21 

### else? You can see seven comment boxes looking 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### ahead to the NOPR phase. 1 

### (No verbal comments.) 2 

### No additional comments at this 3 

### time. Lane. 4 

### MR. BURT: Just a comment that my 5 

### point earlier also implies to the employment 6 

### analysis if you're looking at single divisions 7 

### of companies. 8 

### FACILITATOR BROOKMAN: Okay. 9 

### MS. GUPTA: Do you want to close 10 

### up? 11 

### FACILITATOR BROOKMAN: We should 12 

### provide an opportunity for final comment as we 13 

### promised at the outset. An opportunity for 14 

### any person to raise additional issues, issues 15 

### tha t did not get adequate coverage, that sort 16 

### of thing now in the closing stages of this 17 

### meeting. Yes. 18 

### MR. BALLO: Tim Ballo. I just had 19 

### a follow

- up question on the presentation that 20 

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

### I'm sorry if this is a dum b question. But it 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### seems to me that the focus of the light from a 1 

### lamp would be the product of both the shape of 2 

### the reflector and whatever change it goes 3 

### through in the lens of the bulb. Is there 4 

### some potential for altering the lens in such a 5 

### way that you can sort of compensate for the 6 

### way the reflector alters the lamp or does that 7



### -- Does messing with the lens reduce the 8 

### efficacy sort of inherently? 9


### FACILITATOR BROOKMAN: Joe. 10 

### MR. HOWLEY: Well, the technologies 11 

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

### more difficult, to get that light to spread 13 

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

### natural inclination, the reflector, is to 15 

### focus the beams in a very tight column. And 16 

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

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

### efficiency losses when you're trying to again 19 

### refocus the beam in a direction it doesn't 20 

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

### a reflector lamp with a soft distribution. 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### It's much harder to produce a PAR lamp with 1 

### that kind of soft distribution. 2


### FACILITATOR BROOKMAN: Pam. 3 

### MS. HORNER: Pam Horner and Brian 4 

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

### halogen product group for Philips. It's 6 

### actually a good question. 7 

### In our particular case, our company 8 

### provides -- I think th e widest we've been able 9 

### to get

-- I think to date probably the widest 10 

### beam on a PAR which is about 50 degrees and 11 

### you have to do things as you suggest to the 12 

### lensing to do that. You either have to frost 13 

### it which slightly decreases efficacy or change 14 

### the, as we call it, lenticular structure of 15 

### the little globs of glass. 16 

### FACILITATOR BROOKMAN: The 17 

### prismatics. 18 

### MS. HORNER: Yes, the prismatics 19 

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

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

### as we've been able to get it. 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### And if you take a BR

-- If I'm 1 

### remembering correctly, I think the 2 

### distribution on a flood is about 90 degrees or 3 

### so. There's a significant

-- Even though you 4 

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

### it to the same broad distribution of a BR

. 6 

### FACILITATOR BROOKMAN: So in my 7 

### kitchen I'll talk with you later. 8 

### (Laughter.) 9 

### MS. HORNER: Well, if you're 10 

### interested I do have a kitchen example which 11 

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

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


### Horner. 14 

### I have a kitchen with six down 15 

### lights and this isn't the voice of

-- I mean I 16 

### am a sophisticated lighting user, but forget 17 

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

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

### we decided to put in 50 watt halogen PARs in 20 

### the widest flood possible. And as it happens 21 

### there's a return as happens in many kitchens 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### on like a peninsula which is where my husband 1 

### does his crossword puzzles. 2 

### Well, this is significant in that 3 

### the light distribution which is not uncommon 4 

### from a BR reached not only from the stove to 5 

### the sink to the crossword puzzle but was 6 

### evenly distributed across the kitchen. We put 7 

### in the PAR lamps and the light beam fell short 8 

### of the peninsula. So we actually had to add 9 

### two fixtures and we didn't add down li ghts. 10 

### We were very energy conscious and added some 11 

### very low wattage pendants. But it happened to 12 

### be exactly the same wattage addition that we 13 

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

### do have them on dimmers, Pekka. 15 

### (Laughter.) 16 

### But the issue is that distribution 17 

### matters and probably even if you weren't a 18 

### sophisticated lighting user. You would 19 

### recognize that you could no longer see your 20 

### crossword puzzle and that you would have to do 21 

### something about it. 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### FACILITATOR BROOKMAN: So we've 1 

### learned a lot during the course of this 2 

### meeting. Opportunity for final comments. 3


### Lane. 4 

### MR. BURT: This may have been said 5 

### earlier. I missed the opening. But I would 6 

### like to thank the Department for following 7 

### through on the promise they made to Congress 8 

### and having this rulemaking and also addressing 9 

### one of the major concerns of the advocates and 10 

### this could potentially be a significant 11 

### loophole. So we all very much appreciate the 12 

### Department acting. 13 

### FACILITATOR BROOKMAN: Thank you. 14


### Joe. 15 

### MR. HOWLEY: My final comment is 16 

### we'd also like to thank the Department for 17 

### having this separate rulemaking on reflector 18 

### lamps because we believe it does require a 19 

### separate rulemaking and should not be grouped 20 

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

### different product, different application, 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### different utility. 1 

### And we would again suggest that you 2 

### look within this technology to see how far we 3 

### can improve the efficiency within a reflector 4 

### or ER technology in a separate rulemaking like 5 

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

### we are having a separate rulemaking on this 7 

### and not having the rulemaking grouped together 8 

### with the PAR lamp rulemaking. Thank you. 9 

### FACILITATOR BROOKMAN: Is it Bijit? 10 

### MR. KUNDU: Bijit Kundu, Energy 11 

### Solutions on behalf of PG&E. In gene ral to 12 

### echo some comments that were made earlier, we 13 

### support DOE's decision to expedite this 14 

### process and address these exempted products 15 

### and we thank the Department for doing that. 16 

### And we would also suggest or we 17 

### also support the decision of making use i n 18 

### general of the existing methodologies, data 19 

### and key assumptions which have already been 20 

### vetted through previous rulemakings. And we 21 

### would suggest or Pacific Gas & Electric would 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### suggest major modifications to the analysis be 1 

### revisited during the next rulemaking process 2 

### if major modifications are needed. 3 

### FACILITATOR BROOKMAN: Thank you. 4 

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

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

### you because this has been very, very 7 

### constructive and a lot of good information has 8 

### come forward very efficiently, very nicely 9 

### done and I especially appreciate everybody 10 

### coming so organized. That was very well done. 11 

### I'll turn it back to Meg Sullivan 12 

### for closing remarks. 13 

### MS. SULLIVAN: Well, thank you all 14 

### again for coming and commenting on this 15 

### rulemaking. We very much appreciate it and 16 

### look forward to your written comments. And 17 

### just a reminder to include the docket number 18 

### and RIN number when you send those in. And 19 

### the comment period is going to be extended to 20 

### the beginning of July and there will be a 21 

### notice about that hopefully soon. So thank 22NEAL R. GROSS COURT REPORTERS AND TRANSCRIBERS 1323 RHODE ISLAND AVE., N.W. (202) 234

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### you. 1 

### MR. BURT: One other note. Maybe 2 

### DOE should consider mandatory show

- and

- tell 3 

### sessions for the next

-- and all future 4 

### rulemaking hearings. 5 

### FACILITATOR BROOKMAN: I'd like to 6 

### see it myself. 7 

### MR. BURT: I enjoyed it. 8 

### FACILITATOR BROOKMAN: Thanks to 9 

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

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

### above

- entitled matter was closed.) 12
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