UNITED STATES OF AMERICA

DEPARTMENT OF ENERGY

**PUBLIC MEETING ON**  **TEST PROCEDURE NOTICE OF PROPOSED RULEMAKING FOR LIGHT** 

**- EMITTING**  **DIODE LAMPS**

U.S. Department of Energy 1000 Independence Ave., SW Washington, D.C. 20585

Room 8 E

- 089 Review Center

Thur s day May 3 , 2012

**Facilitator:**

Doug Brookman Public Solutions Baltimore, MDExecutive Court Reporters (301) 565

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**- Person**  **Participants Identified:** 

Ralph Tuttle

CREE Durham, North Carolina

M . “Chips” Chipalkatti Osram Sylvania Danvers, Massachusetts

Dave Szombatfalvy GE Lighting Cleveland, Ohio

John Green Cooper Lighting Peachtree City, Georgia

Keith Cook Philips Lighting Washington, D.C.

Jennifer Burns Philips Lighting Washington, D.C.

Alex Boesenberg National Electrical Manufacturers A ssociation (NEMA) Washington, D.C.

Pekka Hakkarainen Lutron Electronics Coopersburg, Pennsylvania

Pam Horner Osram Sylvania Danvers, Massachusetts

Austin Gelder ICF International Washington, D.C.

Adam Christensen Appliance Standards Awareness Project (ASAP) Washington, D.C.Executive Court Reporters (301) 565

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Mark Duffy GE Lighting Cleveland, Ohio

Julia Farber

UL Washington, D.C.

Kate Jensen Steptoe and Johnson Washington, D.C.

**Webinar Participants:**

Alex Truong Bulbrite Industries, Inc. Moonachie, New Jersey

Juan Menen dez

SCE Irwindale, California

Brent Fike

USCG New London, Connecticut

Carl Bloomfield Intertek Arlington Heights, Illinois

Ronald Daubach Osram Sylvania Beverly, Massachusetts

James Cyre Philips Salina, Kansas

Tanya Hernandez ICF International Durham , North CarolinaExecutive Court Reporters (301) 565

- 0064 4 Jeungmo Kang Samsung Electronics Yong

- in, South Korea

Dan Chwastyk Navigant Washington, D.C.

Cameron Miller

NIST Gaithersburg, Maryland

Michael Myer

PNNL Lexington, Massachusetts

Scott Travis

UL Westerville, Ohio

Jennifer Amann

ACE EE Washington, D.C.

Joel Jacobson Feit Electric Company, Inc. Pico Rivera, California

Michael McGaraghan Energy Solutions Oakland, California

Re b ecca Rainer Cooper Lighting Vicksburg, Mississippi

Sandeep Sood Litetronics International Alsip, Illinois

Jackie Swiernik Intertek Cortland, New YorkExecutive Court Reporters (301) 565

- 0064 5 Daniel Rogers ICF International Westfield, New Jersey

Timothy Rasinski

NVLAP Gaithersburg, Maryland

Randall Higa

SCE Irwindale, California

David Lis Northeast Energy Efficiency Partnerships (NEEP) Lexington , Massachusetts

Howard Kosowsky Power and Lighting Systems Miami, Florida

Morgan Pixley Regency Lighting Chatsworth, California

Teren Abear

SCE Irwindale, California

Patricia Sandoval Feit Electric Company, Inc. Pico Rivera, California

Christopher Wol d

CLASP Washington, D.C.

Greg Murphy MaxLite West Caldwell, New Jersey

Rui Li

Lumentra Toronto, CanadaExecutive Court Reporters (301) 565

- 0064 6 Pierrette LeBlanc Natural Resources Canada Ottawa, Canada

Jason Tuenge

PNNL Portland, Oregon

Luke Mason

Ecova Durango, Colorado

Joe Zamore Ledsour ce Wellington, Florida

Eugene So Maxlite West Caldwell, New Jersey

Steve Walczak Sternberg Lighting Roselle, Illinois

Henry Shen Turolight Inc. Toronto, Canada

Jeff Davis Intertek Cortland, New York

Robert Lingard

PNNL Portland, Oregon

**Participants from DOE:** 

Lucy deButts DOE Lighting Project Manager Washington, D.C.Executive Court Reporters (301) 565

- 0064 7 Jim Brodrick

DOE Solid State Lighting Washington, D.C.

Betsy Kohl General Counsel’s Office Washington, D.C.

**Participants from Consultants:**

Mansi Thakkar Navigant Washington, D .C.

Matthew Walker Navigant Washington , D.C.

Aris Marantan Navigant Washington , D.C.

Rachel Dickenson Navigant Washington, D.C.Executive Court Reporters (301) 565

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**AGENDA**

**ITEM PAGE** 

Welcome, Doug Brookman 5

Welcome for DOE, Ms. deButts 5

Introdu ctions 6

Agenda Review , Doug Brookman 7

Meeting overview, Ms. deButts 9

Rulemaking Process and Scope, Ms. deButts 1 5

Test Procedures for Input Power, Lumen Output, and CCT, Ms. Thakkar 2 0

Test Procedure for Rated Lifeti me Ms. Thakkar 55

Closing Remarks , Ms. deButts 118Executive Court Reporters (301) 565

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

MR. BROOKMAN: Good morning every one and 2

w elcome . This is the U.S. Department of Energy’s 3

public meeting on the Test Procedure, Notice of 4

Proposed Rulemaking , for Light

- Emitting Diode Lamps. 5

Today is Thursday

, May 3rd , here at the 6

Department of Energy in Washington, D.C. My name is 7

Doug Brookman from Public Solutions in Baltimore. So 8

g lad to see you this morning. W e’re going to start 9

o ff th is morning wi th welcoming remarks from Lucy 10

deButts. 11

**Welcoming Remarks** 12

MS. DEBUTTS: Good morning, every one

. My 13

name is Lucy deButts , and I represent DOE as a 14

lighting team project manager. And today our primary 15

focus is to present the LED test procedure NOPR, and 16

open the dialogue between the industry and DOE in 17

developing this rulemaking. We are looking forward to 18

your input and your cooperation in developing this 19

rule. 20

And at this point, I’d like to turn it back 21

to Doug Brookman, our experienced facilitator, f or 22

some ground rules and going over the agenda. 23

MR. BROOKMAN: Thank you. And we’ll do 24

introductions first, though, as our tradition. Please 25Executive Court Reporters (301) 565

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say your name and organizational affiliation. You can 1

also get used to turning on these microphones, and 2

getti ng them fairly close. 3

**Introductions** 4

MR. TUTTLE: Thank you. My name is Ralph 5

Tuttle. I am with CREE in Durham, North Carolina. 6

MR. BROOKMAN: Thank you. 7

MR. CHIPALKATTI: Good morning. I am Chips 8

Chipalkatti from Osram Sylvania in Danvers, 9

Mass achusetts. 10

MR. SZOMBATFALVY: Hi everyone. This is 11

Dave Szombatfalvy from GE Lighting located in 12

Cleveland, Ohio. 13

MR. GREEN: John Green with Cooper Lighting 14

in Georgia. 15

MR. COOK: Keith Cook with Philips Lighting, 16

here in D.C. 17

MR. BROOKMAN: I li ke that people are saying 18

where they’re from. I like that part. You’re next. 19

MS. BURNS: Jennifer Burns, Philips 20

Lighting, here in D.C. 21

MR. BOESENBERG: Alex Boesenberg, National 22

Electrical Manufacturers Association, D.C. 23

MR. HAKKARAINEN : Pekka Ha kkarainen with 24

Lutron Electronics, Coopersburg, Pennsylvania, also 25Executive Court Reporters (301) 565

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chairing the NEMA Lighting Systems Division this year. 1

MS. HORNER: Pam Horner with Osram Sylvania 2

out of Danvers, Massachusetts. 3

MR. GELDER: Austin Gelder with ICF 4

International out o f Washington, D.C. 5

MR. CHRISTENSEN : Adam Christensen with 6

Appliance Standards Awareness Project here in D.C. 7

MR. DUFFY: Mark Duffy with GE Lighting out 8

of Cleveland, Ohio. 9

MS. THAKKAR: This is Mansi Thakkar with 10

Navigant Consulting out of D.C. 11

M R. WALKER: Matthew Walker with Navigant, 12

D.C. 13

MR. MARANTAN: Aris Marantan, Navigant, D.C. 14

MR. BROOKMAN: Okay. Thanks to all of you. 15

Everybody get a chance

– one person did not get a 16

chance to introduce himself. 17

MR. BRODRICK : Jim Brodrick , DOE, Solid 18

State Lighting. 19

MR. BROOKMAN: We were just talking about 20

you, Jim. All of you received a packet of information 21

as you came into the room, and hopefully handed a 22

business card to Brenda Edwards

. 23

**Agenda Review** 24

MR. BROOKMAN: Included in the pac ket was 25Executive Court Reporters (301) 565

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the agenda, which I’m going to run through very 1

quickly. Immediately following this agenda review and 2

a brief overview from Lucy, there’s an opportunity to 3

make opening statements, to raise issues that are 4

important to you at this stage in the rul emaking 5

procedure. 6

Following th at , we wi ll dive straight into 7

the content. You can see it listed there

-- test 8

procedure for input power, lumen output, and 9

correlated color temperature

, CCT

. 10

We’ll take a b rea k mid

- morning, round about 11

10:15 or so, following the break , test procedure for 12

rated lifetime and then questions and closing remarks. 13

At the end of the day, close to noonish perhaps today, 14

there’s yet another opportunity to make comments that 15

are important to you. So there are a lot of 16

oppo rtunity, not only to comment on the detailed 17

PowerPoint slides that you all have, but at the end of 18

the day as well, so let’s make sure you get said what 19

you came here to say. 20

I’d ask for your consideration

. P lease , if 21

you would, speak one at a time. Please, every time 22

you speak, say your name for the record

. There will 23

be a complete transcript of this meeting posted on the 24

DOE website

. I’m going to be cu e ing individuals by 25Executive Court Reporters (301) 565

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name as best I can. I a lso wish to encourage follow 1

on comments

. S ometimes the back and forth between 2

individuals is very help ful to the Department as they 3

try and interpret what you’re saying

. 4

If you can keep the focus here. Please t urn 5

your cell phones on silent

. And l imit sidebar 6

conversations. You all have gotten used to using 7

these microphones now. They work better than they 8

used to in the past. And i f you can be concise, share 9

the air time, then that will be beneficial. That’ll 10

be good for all of us. 11

Q uestions or comments here at the outset 12

before I turn it ba ck to Lucy? I see none. Lucy. 13

**Overview** 14

MS. DEBUTTS: All right, so Doug already 15

went over the agenda. Going to the webinar situation. 16

So today’s public meeting is being broadcast over the 17

internet and those stakeholders that cannot attend in 18

person can listen in and follow the slides as we go 19

along. The webinar’s participants, unfortunately, 20

will not be able to talk to us due to the sound system 21

limitations. The microphones are better but the 22

system is not necessarily working all the time, 23

unfortu nately. However, they can use the chat or 24

questions feature on the webinar software to patch in 25Executive Court Reporters (301) 565

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their questions or remarks, and the webinar 1

facilitator will be reviewing them with the help of 2

the Navigant consultant, and if there are any 3

questions that we want to address, we will definitely 4

read them and address them in the room. 5

All those questions are going to be made 6

part of the transcript today and will be published on 7

the DOE website and be made part of the docket. We 8

will try to address all of the questions that we 9

receive today, time permitting, and so please don’t be 10

shy, and provide us with your input as much as 11

possible. 12

We understand that the complicating 13

technology of solid state lighting so we are looking 14

for you to assist us in developing this rulemaking. 15

And last, but not least, just like I said, 16

the transcript is going to be made available as soon 17

as we get it back and we’ll post it on the web. 18

However the presentation and the Notice itself are 19

already on the web on DOE website, and is readily 20

available to everyone. 21

So, as I stated earlier, the purpose s of 22

this lighting meeting is to present the LED lamps test 23

procedure and begin the conversation with the 24

industry. Mansi Thakkar with Navigant Consulting will 25Executive Court Reporters (301) 565

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help DOE in presenting part of the test procedure. We 1

will discuss the rulemaking itself and the information 2

collection for the next step of the rulemaking. And 3

we’re very interested in all of your remarks, not 4

necessarily just those that will be addressed during 5

the presentat ion. Obviously, there are other issues 6

and please help us in discussing everything that you 7

feel that should be addressed. 8

If you disagree with DOE’s approach, we 9

would really appreciate the alternative solutions that 10

you may provide to us. 11

So as fo r the issue boxes, you will see 12

issue boxes like these throughout the presentations. 13

These boxes highlight specific issues that would like 14

to be addressed. The item number s in these boxes are 15

not necessarily in numerical order throughout the 16

present ation , however, we arranged them in a way that 17

is useful for the presentation itself. So what I mean 18

is you may see the item number 20 discussed before the 19

item number 11, for example. It’s not because we 20

don’t know how to count, it’s just to help us to 21

prese nt. 22

As far as the deadline for comment period 23

submission, we have it due on June 25, 2012. So we 24

will appreciate all your written comments to be 25Executive Court Reporters (301) 565

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submit ted by that date. And at this time, I would 1

like to invite opening remarks. 2

MR. BROOKMAN: Thank you. We wish to invite 3

opening statements from anybody that wishes to do so. 4

Would you like to introduce yourself? Please, hit the 5

microphone, turn it on, say your name and 6

organizational affiliation. 7

MS. JENSEN: I’m Kate Jensen with Steptoe 8

and Jo hnson, representing Acuity Brands Lighting. 9

MR. BROOKMAN: Thank you. Okay. So let’s 10

start with opening remarks, b rief summary statement s 11

about issues that matter to you. Yes, please, Ralph. 12

**Opening Remarks** 13

MR. TUTTLE: In order to follow the rule s, I 14

have to introduce myself again, apparently. I’m Ralph 15

Tuttle. CREE just wants to thank the Department of 16

Energy for the opportunity to work with you all on 17

this rulemaking. We have a long history of working 18

with the Department of Energy and also wo rking with 19

our associates in the lighting industry and I think we 20

can pretty quickly come to agreement on how to 21

proceed. 22

Other than that, I will hold any comments 23

until we go through each of the issues individually. 24

Jim Brodrick , it’s good to see you again. 25Executive Court Reporters (301) 565

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MR. BRODRICK : Thanks. 1

MR. BROOKMAN: Thank you. Alex. We expect 2

it, and we like it. Go ahead. 3

MR. BOESENBERG: I’m Alex Boesenberg with 4

the National Electrical Manufacturers Association. 5

Many of my members are present today. Of course, w e 6

thank the Department and the meeting room facilitators 7

here and everybody for this opportunity. As is often 8

the case, our comments are still developing, so today 9

we, whereas in some later stages of rulemaking, we 10

might be able to rattle off a list to yo u, now it’s 11

more of an open idea session. But of course, we will 12

finalize our comments and get those submitted. 13

The issue of lumen maintenance is one of 14

concern to us, and we will discuss that when we get to 15

that point in the discussion and slides today

. 16

I have already briefly discussed with Lucy, 17

and I will follow up with the Department

, a concern we 18

have for solid state lighting as it relates to 19

actually yesterday’s external power supplies [EPS] 20

rulemaking. Lighting is historically its own animal, 21

a nd basically want to keep it that way for several 22

reasons. And I’ll send you some more information on 23

that and look forward to future discussions. 24

And lastly, as it states in the NOPR, this 25Executive Court Reporters (301) 565

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ruling is for the DOE to help the FTC with their 1

labeling progra m, and obviously we agree with that and 2

think it’s a good idea, because we’re the ones who 3

have to

– my members are the ones who have to follow 4

the labeling guidance and satisfy the FTC, and so that 5

makes sense. We would caution the Department against, 6

by force of habit, instituting a performance standards 7

rulemaking for LED lamps immediately following this 8

test procedures rule, because solid state is an 9

emerging technology. It’s not ready to be regulated 10

yet. We’ve said that many times in the past, and 11

that’s still the sentiment. I think if you

– well, no 12

one wants to read the EPS NOPR if they don’t have to. 13

It’s several hundred pages, but if you were to keyword 14

search it, you’ll find they make mention of the fact 15

that they had no actual solid state li ghting power 16

supply data to cite because they couldn’t find any 17

products at the time they did their testing. I think 18

that shows the Department has already tried, in 19

effect, and ran up against the issue of there just 20

aren’t that many products available and not a lot of 21

mature product line, definitely, because products are 22

changing every several months. And that illustrates, 23

that’s one point that illustrates the issue, my 24

statement that we’re not ready to regulate the 25Executive Court Reporters (301) 565

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performance of those products just yet. 1

If the Department is concerned about poor 2

performance and protecting consumers from 3

opportunistic products, NEMA has undertaken a standard 4

and has published a standard for minimum performance 5

requirements, and if that issue is a concern of the 6

Departmen t, we’re happy to share that standard with 7

you and have a discussion about it and what our intent 8

and goals of that standard are. Thank you. 9

MR. BROOKMAN: Thank you. Additional 10

comments here at the outset? Nothing additional. 11

Okay, so then let’s tur n to the content. Yes. Mansi. 12

MS. DEBUTTS: Not her yet. You’re still 13

going to hear me for a couple of seconds. All right, 14

so at this point, I’d like to go over the rulemaking 15

process and the scope of this rulemaking. 16

**Rulemaking Process and S cope**  17

MS. DEBUTTS: As far as the next steps for 18

the LED lamps test procedure rulemaking go, we are at 19

the NOPR stage, as we all know, and the NOPR published 20

in the Federal Register on April 9, 2012. As I 21

already stated, today’s of course, the public meeting. 22

As I stated, the comment period will end on June 25, 23

2012, after which DOE will review and consider all the 24

comments that we receive. And currently, we plan to 25Executive Court Reporters (301) 565

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publish the final rule for the test procedure by 1

November of this year. 2

The scope of this rul emaking. So this 3

rulemaking is applicable to LED lamps that fall within 4

DOE’s proposed definition of LED lamp. This 5

definition will be found in 10CFR430.2, and it is 6

based on the term integrated LED lamp as defined by 7

the ANSI standard, RP

- 16

- 2010. The LED source is a 8

lighting producing component within the LED lamp. LED 9

lamp is intended to connect directly to the brain 10

circuit through a corresponding ANSI circuit, and 11

these integrated lamps comprise of LED source, which 12

could be LED component or LED mo dule. LED driver and 13

ANSI standard base and other optical, thermal, 14

mechanical or electrical components such as phosphor 15

layers, insulation materials, fasteners to hold 16

components within the lamp together, and electrical 17

wiring. 18

So at this time, I would like to ask for 19

your comments on both, proposed scope and the 20

definition of LED lamp. 21

MR. BROOKMAN: Pekka. 22

MR. HAKKARAINEN : Pekka Hakkarainen . Just 23

on the previous slide you said that the final rule 24

will be published in November. When would be the 25Executive Court Reporters (301) 565

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effective date? Immediately or at some future time? 1

MS. DEBUTTS: It’s going to be

– well, the 2

effective date is going to be the publication date, 3

and the compliance date is going to be some time away. 4

MR. HAKKARAINEN : Normally, I think we are 5

used to having a three year period before effective 6

date is set. 7

MS. DEBUTTS: With the compliance date 8

you’re talking about. 9

MR. HAKKARAINEN : Yes, with the compliance. 10

MS. DEBUTTS: Right. 11

MR. HAKKARAINEN : So it’s three years? 12

MS. DEBUTTS: Mansi, can you help me on this 13

one? I don’t have the

-- 14

MS. THAKKAR: This is Mansi Thakkar. So the 15

compliance date will actually be dependent on when FTC 16

adopts this rule, so after DOE makes this rule final, 17

FTC will have to adopt this rule and state that 18

s takeholders have to use this test procedure to test 19

LED lamps. 20

MR. BROOKMAN: And do you anticipate some 21

timeframe? Is it typically going to be a couple of 22

years? Would it be quicker? Do you know? 23

MS. THAKKAR: I don’t know what FTC’s 24

timeline would be, but

– 25Executive Court Reporters (301) 565

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MR. HAKKARAINEN : So how is the effective 1

date going to be determined, then. Is there a process 2

for determining that? 3

MS. THAKKAR: Well, when FTC

– when DOE 4

comes out with the test procedure, FTC has to use it 5

for the labeling requirement s. They need to adopt 6

that test procedure. So we, even though we don’t know 7

the timeframe right now, I guess it’s not going to be 8

immediate. So I can follow up and see, you know, 9

cooperate with FTC and see what their plan is. 10

Unfortunately, I cannot an swer that question right now 11

about the timeframe. But they’re going to be some 12

time between the issuance and the adoption. 13

MS. KOHL: Lucy, this is Betsy Kohl from GC. 14

I just want to add, the FTC would have to do a 15

rulemaking to adopt that, so there’s going to be 16

further process, so there’ll be some time. 17

MR. BROOKMAN: Okay. Keith. 18

MR. COOK: Keith Cook with Philips. I’m a 19

little concerned about the scope. I thought that the 20

purpose of this rulemaking was in support of the FTC. 21

The FTC labeling right now is dedicated to consumer, 22

which is a much narrower marker than the RP

- 16 23

definition of integrated LED lamps. Does this mean 24

that the scope is beyond what the FTC labeling 25Executive Court Reporters (301) 565

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requirements. 1

MR. WALKER: Matthew Walker, Navigant. The 2

idea is that this test procedure scope is established 3

broadly to match what’s in the ANSI RP

- 16, but then 4

later, when FTC would adopt this test method, they 5

would establish a

– their own scope of applicability 6

for their own labeling requirements. So rather than 7

DOE an ticipate what FTC would need for their scope, 8

the idea is to let FTC make that determination when 9

they adopt the test method. 10

MR. BROOKMAN: Matthew, do you anticipate 11

that FTC is going to focus on consumer products, or do 12

you know what they’re thinking? 13

MR. WALKER: I mean I probably shouldn’t 14

speculate on what they would be able to do, but I 15

would say that you could look at what FTC’s current 16

definition of general service LED lamp is to have an 17

idea of where they stand at this point in time. 18

MR. BRO OKMAN: So the question is on the 19

scope and definition of LED lamps. Comments? 20

Additional comments on that? Nothing additional. 21

Okay. 22

MS. DEBUTTS: Well, without further ado, 23

Mansi Thakkar with Navigant will start on the test 24

procedure part. 25Executive Court Reporters (301) 565

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1

**Test Procedure**  **for Determining Input Power,** 2

**Lumen Output and CCT** 3

MS. THAKKAR: Thanks, Lucy. Good morning, 4

everyone. I’m Mansi Thakkar from Navigant, and I will 5

be presenting the next two sections that discuss the 6

test procedure for determining input powe r, lumen 7

output and CCT, as well as the test procedure for 8

determining the rated lifetime of LED lamps. 9

Starting with the test procedure for 10

determining lumen output, input power and CCT, DOE 11

proposes that LM

- 79 should be adopted, but has 12

included some m odifications or additional information 13

to clarify the test conditions and setup. DOE 14

reviewed available industry standards and spoke with 15

several industry experts and determined that LM

- 79 was 16

the method being used by industry. It is also the 17

method refe renced by Energy Star in the integral LED 18

lamp specification for testing LED lamps for Energy 19

Star qualification. 20

FTC light bulb labeling rule also recommends 21

to us e LM

- 79 for representations on the lighting facts 22

label. 23

Finally, LM

- 79 is the standard required by 24

DOE’s lighting facts program for voluntary 25Executive Court Reporters (301) 565

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participation in the program. 1

Based on this review, DOE determined that 2

LM

- 79 was the best approach to determine input power, 3

lumen output, and CCT. 4

LM

- 79 specifies the test setup, test 5

condition s, measurement instruments, as well as the 6

method of taking measurements for LED lamps. Of these 7

specifications, the items listed on this slide have 8

been adopted exactly as specified. 9

MR. BROOKMAN: Slow down a little bit. 10

MS. THAKKAR: Okay. Sorry. DOE now 11

requests comment on the proposed incorporation of LM

12

79 to determine lumen output, input power, and CCT, 13

and specifically these conditions that are being 14

adopted exactly as specified. 15

MR. BROOKMAN: You can see issue box 2, and 16

you can see the v arious elements that they’d like to 17

receive comment on. Alex, is that you? Next? No? 18

Pekka. 19

MR. HAKKARAINEN : Generally speaking, I 20

think that the industry is in agreement with this. 21

MR. BROOKMAN: Okay. Thank you. Do we a 22

have any more specific comments? Nothing additional. 23

Okay. 24

MR. WALKER: This is Matthew Walker, 25Executive Court Reporters (301) 565

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Navigant. We did have another comment from the 1

webinar that refers back to the first issue. The 2

question was, “ what lamp types and bases are included 3

within the definition of integral LED lamp, examples 4

being PAR, R, medi um , mogul, candelabra, pin bases?” 5

I think our response is the definition in RP

- 16 would 6

include all types of bases and I guess I’d refer back 7

to the point that I made earlier that FTC would 8

redefine the scope of their labeling rule at the time 9

of adoption of this test method. 10

MR. BROOKMAN: Can you say who wrote us from 11

the web? We wanted to identify who sends in the 12

questions. 13

MR. WALKER: Michael McGaraghan

. 14

MR. BROOKMAN: Great. Thank you. So we’re 15

going to try, as Lucy said, to include comments and 16

questions from those joining us via the internet. So 17

you may proceed. 18

MS. THAKKAR: Any other comments on issue 2? 19

So the first topic for discussion is air movement. As 20

mentioned on the previous slid e, the air movement 21

requirement is being adopted without any modification 22

from LM

- 79, which states that the air flow during 23

testing LED lamp should be such that the normal 24

convective air flow induced by the lamp is not 25Executive Court Reporters (301) 565

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affected. While this requirement is proposed in the 1

NOPR, DOE considered whether additional specifications 2

should be provided to determine air movement. For 3

example, IES LM

- 9

- 2009, which is the standard for 4

determining the electrical and photometric 5

characteristics for fluorescent lamps, pr ovides a test 6

to determine that the environment is draft

- free. It 7

requires a single ply tissue paper to be held in place 8

of the lamp to observe, usually, that the environment 9

is indeed draft

- free. 10

DOE requests comment about whether the LM

- 79 11

specificati on is sufficient or whether more 12

information should be provided to determine the air 13

movement. 14

MR. BROOKMAN: Keith. 15

MR. COOK: This is case of let’s not over

16

specify. We don’t have to. This test, as silly as it 17

sounds, has been an accepted industry practice 18

forever, and it’s well understood. I’d say let’s just 19

continue with it. 20

MR. BROOKMAN: Okay. Thank you. Do we have 21

additional comments? Chip? 22

MR. CHIPALKATTI: This is Chip Chipalkatti. 23

Yeah, the air flow, I agree with Keith on this, not 24

over

- specify because there might be cases where 25Executive Court Reporters (301) 565

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there’s active cooling fans, and that can affect the 1

whole air flow situation. 2

MR. BROOKMAN: Okay. 3

MR. WALKER: Matthew Walker, Navigant. Just 4

to be clear, your over

- specify

– don’t over

- specify, 5

stay with LM

- 79 specifications? Don’t add LM

- 9 6

specifications? 7

MR. COOK: Yeah, the issue is whether air 8

movements should be specified in more detail, and I’m 9

saying no. 10

MR. WALKER: Okay. Just clarifying. 11

MR. BROOKMAN: Okay. Thank you, Keith. 12

MS. THAKKAR: Okay. Thank you. Moving on 13

to lamp orientation. DOE is not proposing LM

- 79 14

specification for lamp orientation. DOE understands 15

that while the light emission process of an LED source 16

is not affected by the orientation of the lamp, the 17

thermal conditions for the LED sources could be 18

affected by orientation, which in turn would affect 19

the light output. Given this impact of orientation on 20

thermal effects within the lamp, DOE’s view is that it 21

is important to test the lamps in specific 22

orientation s. However, LM

- 79 does not specify an 23

orientation, and instead states that the lamp should 24

be tested in the orientation recommended by the 25Executive Court Reporters (301) 565

- 0064 29

manufacturer for the intended use of the lamp. 1

DOE is not proposing this requirement 2

because on reviewing manufact urer catalogs, DOE has 3

learned that the operating orientation is usually not 4

specified by the manufacturer. Therefore, DOE is 5

proposing that an equal number of lamps should be 6

operated in the base up, base down, and horizontal 7

orientations. 8

In issue 4 , DOE requests comment on the 9

proposed lamp orientation requirements. 10

MR. SZOMBATFALVY: This is David from GE. 11

We believe that testing base up and base down would be 12

enough with respect to understanding what the lamp’s 13

capabilities are, because in betw een you’re going to 14

get

– you’re not going to gain any value by testing 15

the horizontal position. And in addition, you’re 16

going to have additional uncertainty in the 17

measurement values between the goniometer and the 18

sphere in the horizontal position. 19

MR. BROOKMAN: Okay. Thank you. Keith. 20

MR. COOK: Keith Cook. Yeah, I agree with 21

that. I think we may be confusing technologies here. 22

HID is absolutely dependent upon the orientation, but 23

not so much with the solid state lighting. And so I 24

think we’re again over

- specifying if we go to three 25Executive Court Reporters (301) 565

- 0064 30

position testing. 1

MR. BROOKMAN: Thank you. Additional 2

comments? Okay. 3

MS. THAKKAR: Okay. The next topic is the 4

electrical settings requirement, and there are two 5

issues to discuss here. The first issue i s input 6

characteristics. DOE proposes that the LED lamp 7

should be operated at the rated voltage during 8

testing, as specified in LM

- 79. Further, for lamps 9

with multiple operating voltages, DOE proposes that 10

the lamp should be tested at 120 volts, if it is rated 11

for 120 volts, or at the highest rated voltage. 12

120 volts was selected because it is the 13

most common operating voltage of available lamps , and 14

especially if the lamps that are in FTC current 15

labeling scope. For LED lamps, DOE proposes that the 16

lamp should be operated at the maximum input power as 17

specified in LM

- 79. 18

The second issue for discussion under 19

electrical settings is lamps with multiple modes of 20

operation. LM

- 79 specifies that if a lamp has 21

multiple modes of operation, such as vari able CCT, it 22

should be tested at the different modes. In its 23

research of manufacturer catalogs, DOE did not come 24

across any lamps that functioned at multiple modes of 25Executive Court Reporters (301) 565

- 0064 31

CCT, and requests more information about these 1

products. 2

In issue 5, DOE requests comm ent on the 3

voltage and dimming requirements as well as the 4

availability of lamps that operate at multiple modes 5

of operation. 6

MR. BROOKMAN: Chip. 7

MR. CHIPALKATTI: Chip Chipalkatti. I’m 8

curious, when you say multiple modes, do you mean 9

variable CCT a s a mode, or do you mean every CCT that 10

it’s possible to go to? 11

MS. THAKKAR: I think the way LM

- 79 12

specifies it, it’s a lamp that’s intended to work at 13

two or maybe more different CCTs. 14

MR. BROOKMAN: So multiple modes means 15

different CCTs? 16

MS. THAK KAR: Yes. 17

MR. BROOKMAN: Keith. 18

MR. COOK: Keith Cook. Yeah, I think when 19

LM

- 79 was written, the intent was just to leave 20

flexibility there. We know that technically, it’s 21

very feasible to do this, the trouble is trying to 22

identify a market need tha t creates the product. But 23

all we’re doing is leaving the flexibility for future 24

development, and so that’s, I think, the sole intent 25Executive Court Reporters (301) 565

- 0064 32

behind it. 1

MS. THAKKAR: So I have a follow up question 2

to that. For those lamps in the future, would you 3

recommend th at it’s tested at each CCT that it can 4

operate on? 5

MR. COOK: Again, it depends upon the 6

intent. What you’re trying to accomplish with the 7

test. Typically, there is a difference in efficacy as 8

you go to different CCTs, so if you chose the worst 9

efficac y, if that’s what you’re looking for, you don’t 10

have to run the one test, you wouldn’t have to run 11

multiple. 12

MS. THAKKAR: Okay. 13

MR. BROOKMAN: Mark, do you want to comment 14

here? 15

MR. DUFFY: Yeah, this is Mark Duffy of GE. 16

There is a very distinct possibility that this would 17

be a continuously variable CCT. So to say something 18

like I want to test them all, would be an impossible 19

thing. 20

MS. THAKKAR: Right. 21

MR. BROOKMAN: Chip, you want to add on? 22

MR. CHIPALKATTI: Yeah, that was exactly the 23

r eason for my question. Because it’s foreseeable that 24

there’ll be lamps at variable CCTs, continuously 25Executive Court Reporters (301) 565

- 0064 33

variable, variable CRIs, variable lumen outputs and so 1

on. You couldn’t possibly test every one of them. 2

MR. BROOKMAN: So what should DOE do here? 3

MR. CHIPALKATTI: I think I like the idea of 4

looking for the most extreme of these conditions as 5

the baseline, so the idea of the lowest efficacy might 6

be

– 7

MR. BROOKMAN: Should they specify it as the 8

lowest efficacy, or should they say something else? 9

MR. COOK: This is probably something we 10

need to take off line. There’s a lot of different 11

permutations. Testing at the worst possible efficacy 12

for a setting that no one would ever use anyway, 13

that’s not fair. So we’ll have to discuss it and come 14

back

. 15

MR. BROOKMAN: Okay. Thank you. We did 16

gain some clarity there, I thought. That was good. 17

Are there other issues here in the issue box that you 18

wish to cue? 19

MS. THAKKAR: That was the main one, but if 20

there are any other comments on the voltage or dimming 21

requirements? 22

MR. BROOKMAN: I’m just scanning through 23

here. I guess they all roll towards that same point. 24

Okay. So then, with no objection, then, we’ll move 25Executive Court Reporters (301) 565

- 0064 34

on. Yes. 1

MS. THAKKAR: Okay. The next topic is lamp 2

seasoning. This is also an area where DOE is not 3

proposing LM

- 79 specification. LM

- 79 does not require 4

the lamp to be seasoned prior to stabilizing the lamp 5

and recording measurements. However, industry has 6

observed a hump during the first 1000 hours of 7

operation of LED source as shown in this graph on the 8

right. If the lamp is not seasoned prior to 9

measurements, then depending on the time required for 10

lamp stabilization, it is possible that the lumen 11

output determined through testing, may be higher than 12

the actual lumen output of the lamp. 13

Therefore , DOE proposes that the lamp should 14

be seasoned for 1000 hours prior to stabilization and 15

lumen output measurement. DOE requests comment as 16

well as any available data on seasoning the LED lamp 17

for 1000 hours before measuring lumen output. 18

MR. BROOKMAN: Ralph. 19

MR. TUTTLE: Thank you. Ralph Tuttle with 20

CREE. When we initially developed LM

- 79, we discussed 21

this ad nauseum. The reality is that the graph that’s 22

shown on the right is a CREE LED

– I provided that 23

information to Er ic. Not all LEDs exhibit this 24

increase in lumen output during the first 1000 hours 25Executive Court Reporters (301) 565

- 0064 35

of operation. I was also the chairman of the TM

- 21 1

committee, and during the development of TM

- 21, we had 2

the opportunity to look at the LED behavior of 3

products from all the major LED manufacturers. While 4

in fact, there were some that exhibited this 5

characteristic, there were also a lot of LEDs that in 6

the first few hundred hours, dropped significantly. 7

As a result, I would strongly recommend that we not 8

include seasonin g in the testing of these products. 9

MR. BROOKMAN: In any form? 10

MR. TUTTLE: In any form, that is correct. 11

Basically, you take the product out of the box and you 12

put it into your goniometer and you perform the 13

measurement. 14

MR. BROOKMAN: You do the t est. Okay. 15

Other comments or recommendations for the Department 16

with respect to seasoning? Keith? 17

MR. COOK: I’ve been biting my tongue, but

– 18

a thousand hours may not be enough in some cases, 19

that’s a problem, because if you look at the data that 20

the Pacific Northwest National Laboratories has 21

published on the L price testing, it actually was 3000 22

hours that it went up. 23

MR. BROOKMAN: Which then caused that lamp 24

to be, quote, “seasoned”? 25Executive Court Reporters (301) 565

- 0064 36

MR. COOK: It then leveled off. But it 1

increased for 3000 h ours, so, you know, where do you 2

draw the line? Let’s just draw it at point zero. 3

MR. BROOKMAN: Okay. So you agree with 4

Ralph? 5

MR. COOK: Yes. 6

MR. BOESENBERG: This is Alex Boesenberg, 7

NEMA. This is one of those points where I would 8

submit that t his is the hazard of a regulation that 9

restricts innovation. LED designs, formulas, are 10

changing every day and so next month’s LED might never 11

have a seasoning, or after that, one that burns in 12

after several thousand hours. And remember that, you 13

know, t he way we usually figure 1000 hours is three 14

hours a day, that’s a year. Seasoning for a year 15

before we can test it? Let’s not do that. 16

MR. BROOKMAN: Okay. Yes, please. Adam. 17

MR. CHRISTENSEN : This is Adam with ASAP. 18

Just more of a curiosity ques tion than anything. Is 19

there a technical hypothesis about why light increases 20

in the beginning, or decreases in some cases? 21

MR. BROOKMAN: Ralph? 22

MR. TUTTLE: It really depends on a lot of 23

factors in the construction of the LED, both the chip 24

as well as the lamp itself. Typically, the behavior 25Executive Court Reporters (301) 565

- 0064 37

that you can see in this graph is due to the fact that 1

during the construction of the LED chip and the growth 2

of the multi

- quantum layers, not all of the dopant 3

atoms that are incorporated in the crystal structu re 4

occupy an electrically active site. Rather than being 5

in a substitutional site in the lattice, they might be 6

in an interstitial site. As you start to operate the 7

LED it heats up, and those atoms will then move in the 8

crystal to a substitutional site, become electrically 9

active, and you will get an increase in the lumen 10

output of the chip itself. 11

Conversely, when you’re talking about sudden 12

reductions in light output, oftentimes that’s due to 13

the encapsulants that are used, and changes that occur 14

in t hose encapsulants as they’re first heated up. 15

So it really depends from one manufacturer 16

to the next on how they construct both the component 17

itself, as well as how they process the chip. Sorry, 18

that’s kind of a

– 19

MR. BROOKMAN: That’s cool. That’s a brief 20

primer. 21

MR. CHRISTENSEN : That was perfect. Thanks. 22

MR. BROOKMAN: Okay. Thank you. I like 23

that. So final comments on seasoning? Okay. And 24

NEMA will submit detailed comments on this point. 25Executive Court Reporters (301) 565

- 0064 38

MR. BOESENBERG: We’ll do our best on that 1

one. 2

MR. BROOKMAN: Thank you. I’m sure you 3

will. Okay. 4

MS. THAKKAR: Okay. Moving on to lamp 5

stabilization. This is an area where DOE is adopting 6

the specification in LM

- 79, but has added 7

clarification on how lamp stabilization should be 8

determined. So LM

- 79 specifies that the lamp should 9

be stabilized until the variation of at least three 10

readings of input power and lumen output over a period 11

of 13 minutes, taken 15 minutes apart, is less than 12

point five percent. 13

DOE proposes to adopt this specifi cation and 14

further includes the equation listed on this slide to 15

clarify how the variation should be calculated. That 16

is, the variation should be calculated as the 17

difference between the maximum and the minimum values 18

of lumen output or input power, divid ed by the 19

respective minimum value. 20

In issue 7, DOE requests comment on the 21

proposed clarification for calculating the variation 22

to determine lamp stability. 23

MR. BROOKMAN: Keith. 24

MR. COOK: Generally speaking, I think this 25Executive Court Reporters (301) 565

- 0064 39

is just good practice. W e would agree with this 1

approach. 2

MR. BROOKMAN: Yes, Mark. 3

MR. DUFFY: Yeah, Mark Duffy of GE Lighting. 4

Just a small matter. The equation should be expressed 5

as a percent. 6

MS. THAKKAR: Right. Okay. 7

MR. BROOKMAN: Thank you. That’s useful. 8

Additional comments on lamp stabilization? Okay. 9

MS. THAKKAR: The next topic is measuring 10

the lumen output of the LED lamp. LM

- 79 specifies 11

that a sphere

- spectroradiometer, a sphere

- photometer, 12

or a goniophotometer should be used to measure the 13

lume n output of the lamp. 14

DOE proposes to adopt this specification and 15

requests comment on it. In particular, DOE is 16

interested to receive comment as well as available 17

data about how the lumen output from each of these 18

measurements compare. 19

MR. BROOKMAN : Yes. 20

MR. SZOMBATFALVY: This is David from GE. 21

From our experience we show that between the 22

goniometer and the sphere measurement, we can get like 23

a two percent difference. What’s more important is 24

when we look at the overall average from making 25Executive Court Reporters (301) 565

- 0064 40

mea surements at one site, at one location. There’s an 1

inherent bias, because when you look at round robin 2

measurements for NVLAP and different labs, like the GE 3

facility, we can see like a three percent difference. 4

So it’s important that we understand what those 5

percentages are and incorporate that in this 6

measurement method. 7

MR. BROOKMAN: Between the different 8

systems? 9

MR. SZOMBATFALVY: Yes, I mean, within the 10

lab you can expect, between a goniometer and a sphere 11

approximately a two percent difference in measure 12

results. Whereas, if you go outside between labs, 13

let’s say NVLAP and another location, you can expect 14

approximately a three percent difference. 15

MR. BROOKMAN: Okay. 16

MR. COOK: Actually, NVLAP has published a 17

variation of four percent. 18

MR. SZOMBATFALVY: Four percent? 19

MR. COOK: Yes. 20

MR. BROOKMAN: Yes, I’m sorry, Mark, go 21

ahead. 22

MR. DUFFY: Just one further comment on that 23

regard. Between labs could become very important if 24

you’re thinking about future rulemakings, because that 25Executive Court Reporters (301) 565

- 0064 41

actually represents a bias and not a random variation. 1

The lab that you choose to measure your samples in 2

will only be one lab, it will not be all of the labs. 3

MR. BROOKMAN: Okay. 4

MR. DUFFY: Okay. So as you consider any 5

rulemakings in the future , or deciding how you’re 6

going to place values on the lighting facts label, 7

that needs to be taken into account if you’re making 8

measurements of small quantities of lamps. 9

MR. BROOKMAN: Got you. Do you have any 10

additional? 11

MS. THAKKAR: I have a foll ow up question to 12

the four percent across NVLAP labs. Is that when you 13

compare the same two systems, the sphere

14

spectroradiometer across two different labs, or is

– 15

MR. COOK: It’s not specific to 16

spectroradiometers or goniophotometers, it is a 17

publishe d NVLAP percentage statistic, based on round 18

robin testing from a variety of labs. They all test 19

the same piece of gear, you can get up to four percent 20

difference, and they all did it right. They satisfied 21

every requirement possible. It’s simply, it’s 22

s tatistics. There will be up to a four percent 23

variation

– 24

MR. BROOKMAN: And they didn’t specify these 25Executive Court Reporters (301) 565

- 0064 42

different systems? 1

MR. COOK: Pardon? 2

MR. BROOKMAN: They did not specify these 3

different systems? 4

MR. COOK: No, it’s independent of lumen 5

meas urement, it’s just a lab variation that NVLAP has 6

empirically determined. 7

MR. BROOKMAN: Okay. I see some heads 8

nodding around the room. 9

MS. THAKKAR: Thank you. 10

MR. BROOKMAN: Okay. Yes, Adam. 11

MR. CHRISTENSEN : This is Adam from ASAP. 12

This is a little bit more of a mash

- up between issue 13

4, back in the orientation issue and then this one. 14

The gentleman from GE, sorry, I forget your

– Dave. 15

You mentioned before the orientation could be an issue 16

when using different types of light measurement. 17

MR. SZOMBATFALVY: That’s correct. 18

Specifically when you do a goniometer measurement, the 19

mirror in the way makes that measurement

– when it’s 20

in the horizontal position you can get inaccurate 21

measurements. It’s a difficult measurement. 22

MR. CHRISTENS EN : It’s just inherent in the 23

tool that you use? 24

MR. SZOMBATFALVY: To the best of my 25Executive Court Reporters (301) 565

- 0064 43

understanding, what my guy told me was it’s inherent 1

in the tool in the way the measurement is made. 2

PARTICIPANT: Right, it’s in the test 3

equipment. It’s not in th e device being measured. 4

MR. BROOKMAN: Thank you. Are we ready to 5

move on? Yes. 6

MS. THAKKAR: Okay. Moving on to 7

measurements for directional lamps. DOE proposes that 8

the total lamp lumen output should be measured rather 9

than the beam lumens, whic h are also known as the 10

zonal lumens. This is because other directional lamp 11

technologies, such as incandescent reflector lamps, or 12

IRLs, report total lumens on FTC’s lighting facts 13

label. If directional LED lamps report anything other 14

than total lumens, these lamps cannot be compared to 15

other directional lamp technologies on the basis of 16

FTC’s label. 17

DOE requests comment on its proposal to 18

measure total lumens for directional lamps. 19

MR. BOESENBERG: This is an ongoing 20

discussion inside of industry. Lamp directionality 21

and where you

– what you measure where, is a very 22

broad question. It’s definitely being pursued in 23

various standards bodies and testing bodies, but we 24

don’t have a good answer yet. 25Executive Court Reporters (301) 565

- 0064 44

MR. COOK: Well, the other thing we need to 1

unders tand too is what is the purpose of the test, or 2

what are you trying to accomplish? I mean if you’re 3

looking for uniformity, that’s one thing. If you’re 4

looking for total efficacy, that’s something else. 5

This is a very broad one. It all depends on what 6

you’re trying to measure. 7

MR. BROOKMAN: So we first heard from Alex, 8

and then we heard from Keith. Now we’re going to hear 9

from Pam. 10

MS. HORNER: Yes, I’d like to point out 11

another reason, less you think we don’t have our act 12

together. It is complex at another level, and that is 13

that the Department of Energy has rulemakings on other 14

technologies, where reflector lamps reside. And a 15

determination, shall we say, on this can affect those 16

other technology performance standards, believe me. 17

MR. BROOKMA N: Okay. 18

MS. HORNER: So we need to have an internal 19

discussion on this. 20

MR. BROOKMAN: Okay. And you’ll do that and 21

get comments back in time. 22

MR. BOESENBERG: I said we’d do our best. 23

MR. BROOKMAN: Are there additional comments 24

on this point and divergence. I should note for the 25Executive Court Reporters (301) 565

- 0064 45

record, when Mansi raised this issue, there was a lot 1

of chuckling going on in the room. So that’s what 2

that’s all about. Okay. So we’re going to proceed. 3

MS. THAKKAR: Okay. 4

MR. BROOKMAN: Apparently we hav e a question 5

from the web. Yes. Matthew. 6

MR. WALKER: Okay, so we have a few 7

questions from the web. Start with one

– 8

MR. BROOKMAN: From? 9

MR. WALKER: From Joel Jacobson. “ This 10

would increase the time to measure initial lumens of 11

every LED lamp. It is not worth it. ” This is at 8 : 37 12

am , so it’s in reference to the seasoning discussion. 13

Then we have one from Cameron Miller, two 14

points. “ From NVLAP PT and NIST Map Testing, the 15

differences between all laboratories is within 16

standard deviation of plus or minus three percent. 17

The second point is how tight are you going to define 18

a sphere? Is a hemisphere acceptable? ” 19

That might be a good thing for the room to 20

discuss as to whether a hemisphere could be an 21

acceptable requirement for the LM

- 79 testing. 22

MR. BROOKMAN: What is a hemisphere? 23

MR. WALKER: Usually, the sphere testing for 24

light output is a complete round ball, and then a 25Executive Court Reporters (301) 565

- 0064 46

hemisphere would be half of that, and I imagine it 1

might be a cheaper device. Less expensive device. 2

MR. BRO OKMAN: ... clarify what that was, 3

okay. Could we get comment on that? 4

MR. COOK: Maybe Ralph can answer this, but 5

I don’t remember that being accepted in LM

- 79. 6

MR. BROOKMAN: Ralph? 7

MR. TUTTLE: Yeah, this is Ralph Tuttle. It 8

is not an acceptable p ractice. There’s too much error 9

incorporated in trying to do any measurements with 10

hemispheres. If the

– it really depends on the light 11

pattern coming out of the product that’s being tested, 12

so we do not recommend that the hemisphere be used for 13

that. 14

MR. BROOKMAN: Prior to Ralph, we heard from 15

Keith. Thank you. Thanks to both of you. Do you 16

have a follow on? 17

MS. THAKKAR: No. 18

MR. BROOKMAN: No follow on on that. Yes. 19

MR. WALKER: I still have a couple more. 20

Again, another Cameron Miller. “ NVLAP has not 21

published the plus or minus four percent total 22

encompassing data yet. ” Context for that might be a 23

little bit lost since we’ve moved on a little bit. 24

MR. BROOKMAN: Alex? 25Executive Court Reporters (301) 565

- 0064 47

MR. BOESENBERG: I saw four published 1

somewhere. I’ll find it. 2

MR. WALKER: Okay. And we have Tim Rasinski 3

at NVLAP

. “ We can allow DOE to review our proficiency 4

testing data here at NIST, but cannot supply copy of 5

the reports. The reports are only intended for lab 6

use and have not been reviewed for release to the 7

g eneral public. ” 8

So then, earlier, Cameron Miller made the 9

comment, “ I feel the hump is probably insignificant in 10

the rating process ”

– again referring back to 11

seasoning. “ I do feel that the 1000 hours should be 12

included because this would eliminate bad products 13

that TM

- 21 prediction might falsely predict good 14

performance. ” Okay. 15

So there’s an idea that TM

- 12 data could be 16

used to project, I guess project

– I’ll just read as 17

it says. “ TM

- 21 should be used to project the data, 18

but using the 1000 hour s of seasoning would validate 19

the application of TM

- 21. ” So that was a Cameron 20

Miller comment. Sorry I didn’t state that to begin 21

with. 22

Another Cameron Miller. “ LM

- 79 2008 is 23

being updated and the new version will be available, 24

probably in the fall. ” 25Executive Court Reporters (301) 565

- 0064 48

Cameron Miller, “ the hemisphere will be 1

accepted in the new version of LM

- 79. ” 2

Alex Truong. “ LM

- 79 requires a type C 3

goniophotometer, so horizontal lamp positioning does 4

not apply. ” 5

And that brings us to the end of the current 6

webinar comments. 7

MR . BROOKMAN: Okay. That’s good. And 8

Ralph, you want to comment on

– not that last thing. 9

MR. TUTTLE: This is Ralph, I’m sorry. The 10

update to LM

- 79 is still in the development stages, 11

and has not been screened or approved by IES. So 12

while Cameron n otes that that is one of the topics of 13

discussion, it has not been ratified at this point, as 14

is the use of a type A goniometer, which is also being 15

discussed. 16

MR. BROOKMAN: Okay. Thank you. And of 17

course, the Department’s wanting to make these 18

meetin gs accessible via the internet, so thanks to 19

those that are joining us via the internet. That 20

works well for a lot of folks. Additional comments on 21

this segment before we move on? Okay. 22

MS. THAKKAR: Moving on to the sampling 23

plan. DOE proposes tha t at least 21 lamps should be 24

tested to determine the input power, lumen output and 25Executive Court Reporters (301) 565

- 0064 49

CCT. The lamps should be selected first with a 1

minimum of three lamps are picked per month for seven 2

months of production out of a 12 month period. These 3

months are not r equired to be consecutive over the 12 4

month period. If production occurs less than seven 5

months of the year, three or more lamps should be 6

selected evenly for each month of production. If more 7

than 21 lamps are tested, the sample size should be a 8

multipl e of three so that an equal number of lamps are 9

tested in each orientation. 10

DOE requests comment on the proposed sample 11

size requirements for testing these lamps. 12

MR. BROOKMAN: Sampling. Always an issue. 13

MR. BOESENBERG: Alex Boesenberg, NEMA. W e 14

are working on the response to this. Obviously, 21 is 15

traditional in the lighting rulemakings. However, in 16

the case of solid state there is somewhat of a 17

precedent Energy Star. They test ten. So there’s 18

some discussion we have to have, and then there ’s some 19

consideration the Department needs to make about, you 20

know, if somebody got there before you, and we’ve 21

already been doing our testing to that, is it 22

reasonable to continue that. But there’s a lot of ins 23

and outs, and we will provide more written comment. 24

MR. BROOKMAN: Okay. Thank you. Dave. 25Executive Court Reporters (301) 565

- 0064 50

Mark. 1

MR. DUFFY: That’s all right. Mark Duffy of 2

GE. The fourth bullet on your slide about equal 3

number of lamps in each orientation, if you take our 4

suggestion of not using horizontal, then you prob ably 5

don’t need to worry about that particular aspect. 6

MR. BROOKMAN: Okay. Yes, Adam. 7

MR. CHRISTENSEN : This is Adam from ASAP. 8

So just besides traditional sampling in industry, is 9

there other justification for why 21 that DOE is 10

investigating? 11

MS . THAKKAR: It was based on what’s 12

traditionally used for other lighting sources, but it 13

was also based on picking a number that was a multiple 14

of three that wasn’t too small

– because of the 15

orientation requirements, yes. 16

MR. CHRISTENSEN : Traditionally we’ve had to 17

do this for fluorescent lamps for a long time now. 18

MR. BROOKMAN: Okay. Alex. 19

MR. BOESENBERG: Alex Boesenberg, NEMA. 20

Just another comment. We

– it might be worth for ASAP 21

to look at our comments to the HID lamps rulemaking. 22

For insta nce, 21 was thrown out there too because, 23

again, it’s traditional. But when you’re talking 24

about a 2500 watt lamp, it’s awfully expensive to run 25Executive Court Reporters (301) 565

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21 of them for a year. Or two or three years, ten 1

years until failure. So that’s an issue that opened 2

up the 21 isn’t perfect discussion. And then also, 3

specific to solid state, as I made mention in my 4

opening remarks, it is an emerging technology. We are 5

trying to get

– consumers are clamoring for it. We’re 6

trying to get it to market quickly, and the larger the 7

samples, the longer the test times, the more it is we 8

tell people we have a product, we just can’t sell it 9

to them. So it’s a consideration. 10

MR. BROOKMAN: Thank you. Keith. 11

MR. COOK: I guess one question I’ve got is 12

what are you going to do wit h these 21 samples? Are 13

you just going to run a CCT test, or CRI, or are you 14

going to do a lumen maintenance test also? 15

MS. THAKKAR: So I can answer that. We are 16

just going to test it for input power, lumen output, 17

and CCT, which are the metrics in FT C’s lighting facts 18

label. 19

MR. COOK: Okay. 20

MR. BROOKMAN: Are you finished, Keith? 21

Pekka. 22

MR. HAKKARAINEN : Yes, one other thing that 23

comes to mind in this is that the seven months of 24

production, it’ll be very important to carefully draft 25Executive Court Reporters (301) 565

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the lang uage here in this rule, because my 1

understanding is that to comply with the FTC labeling 2

requirements, provisional labeling can be used with 3

new lamps to introduce them to the market before the 4

seven months worth of production. Depending on how 5

this rule is written, that could mess up the current 6

system and therefore new lamps would not be able to 7

get to the market at the right time. So it’s very 8

important how this is written. 9

MR. BROOKMAN: Thank you. Ralph. 10

MR. TUTTLE: This is Ralph Tuttle. And 11

P ekka, that is exactly what I was going to comment on, 12

is the fact that

– you know, if I’m Ralph’s light bulb 13

company, making some products, I want to get them on 14

to the market as quickly as possible, and conform to 15

FTC requirements. I want to measure my s amples and be 16

able to put that label on the product immediately, 17

rather than waiting for any period of time to do so. 18

So I agree with you completely, Pekka. 19

MR. BROOKMAN: Please, yes, Mark. 20

MR. DUFFY: Just to add to the agreement. I 21

would like to s uggest that DOE consider, for the 22

initial labeling, that they just take 21 samples, and 23

then if future rules, the next second year comes 24

along, then you take this kind of thing into account, 25Executive Court Reporters (301) 565

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but initially you should be able to label on the basis 1

of your fi rst production. 2

MR. BROOKMAN: Okay. Keith. 3

MR. COOK: Keith Cook. Yeah, to pick up on 4

what Mark’s saying. This is where I was originally 5

headed. Is the ironic thing about this whole testing 6

throughout a year is the fact that we haven’t had a 7

desig n stay in production more than a year. Period. 8

This technology is changing so fast. The LED 9

efficiency is going up so quickly, that we redesign 10

every fricking product, every year. And so by the 11

time we run this testing, it doesn’t mean anything any 12

mor e, because we’re on to the next product. 13

MR. BROOKMAN: Interesting. Okay. Thank 14

you. Yes, Chip. 15

MR. CHIPALKATTI: Chip Chipalkatti, Osram. 16

I have the same concern. As constant change in the 17

technology and new products coming in, so some of 18

thes e long term tests are meaningless by the time the 19

product is ready to be launched. 20

MR. BROOKMAN: What should be done about 21

this? Alex. 22

MR. BOESENBERG: Well, I don’t know if I 23

have an answer to that question of what should be 24

done, but this is an ill ustration of the emerging 25Executive Court Reporters (301) 565

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nature of these products, and regulations tend to be 1

for mature products. These are not mature, that’s why 2

we’re having difficulties nailing this down. And so 3

the suggestion of just taking an initial sample may be 4

the best we ca n do until the technology quiets down. 5

MR. BROOKMAN: Okay. We have additional 6

comment or question from the internet? 7

MR. WALKER: Yes, we have an additional 8

comment from Julia Farber, appears to refer back to 9

the goniophotometer discussion. “ The iss ue with the 10

measurement of horizontally oriented lamps is based on 11

shadowing, because of the lamp’s poor mechanism. 12

Lamps are usually supported from above or below, and 13

the support structure can interfere with the light 14

measurement. ” 15

MR. BROOKMAN: Okay . Thank you. So, let’s 16

move on. 17

MS. THAKKAR: Okay. The final topic of 18

discussion in this section are the rounding 19

requirements. DOE proposes that the values over all 20

21 samples should be averaged and only the average 21

value should be rounded. For in put power, the average 22

value should be rounded to the nearest tenth digit, 23

for example, 12.5 watts. For lumen output and CCT, 24

the average value should be rounded to the nearest 25Executive Court Reporters (301) 565

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tens unit, such as 820 lumens, or 2750 Kelvin

. 1

For the estimated annual en ergy cost, which 2

is also a metric required for FTC’s lighting facts 3

label, DOE proposes that it should be calculated as 4

the product of the average input power, the 5

electricity cost rate, and the estimated average 6

annual use. This value should be rounded t o the 7

nearest cent, such as $7.23. 8

DOE requests comment on the proposed 9

calculation and rounding requirements. 10

MR. BROOKMAN: Pam. 11

MS. HORNER: This is Pam Horner who just had 12

the microphone put in front of her. If my colleagues 13

would help me reme mber, I believe the current FTC 14

rounding rule is five lumens. 15

PARTICIPANT: Correct. 16

MS. HORNER: Which we don’t like, by the 17

way. 18

MR. BROOKMAN: I see

– 19

MS. HORNER: And dare I say this is at least 20

better. And at least cents makes sense, not to round 21

to tenths of cents, so that’s a good thing. But I 22

would say this falls into the category of, we had 23

better think about this before we say anything further 24

as a collection of manufacturer comments. But you 25Executive Court Reporters (301) 565

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bring up some good questions, thank you. 1

MR. BROOKMAN: Mark, you want to comment 2

here? 3

MR. DUFFY: Yeah, I may make a comment. I 4

will be involved in the NEMA

– ultimately, in the NEMA 5

comment. But something that is apparently

– that I 6

would like to see DOE consider in their rounding 7

recommen dations here is what the resolution of the 8

measurement is. Because in many cases, the resolution 9

of the measurement far exceeds the rounding 10

specification, especially in the FTC case. 11

MR. BROOKMAN: Okay. Yes, Adam. 12

MR. CHRISTENSEN : I think I would also be 13

curious to see about the resolution of the test 14

measurement and have rounding based more on that than 15

– or have DOE consider that in their determination. 16

MR. BROOKMAN: Thank you. Yes, John. 17

MR. GREEN: Yes, John Green with Cooper. I 18

agree wi th the issues with rounding. I have to look 19

at estimated average use per day, that that’s a guess 20

to begin with, so rounding to, you know, a penny out 21

of $10.00 doesn’t seem to fit the model very well. 22

MR. BROOKMAN: Okay. Additional comments? 23

We’re g oing to hear back from NEMA on this one, I 24

guess. Additional comments at this point? Nothing 25Executive Court Reporters (301) 565

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additional

– oh, yes, Ralph. 1

MR. TUTTLE: Ralph Tuttle. I guess one 2

question that I have as I’m going over this is that 3

when it comes to Energy Star and EPA r equirements, 4

labs performing these measurements have to be approved 5

laboratories. And at this point in time, unless I 6

missed it, I don’t see anything in this document 7

regarding certification of the labs. So I’m just 8

wondering what the requirement will, i n fact, be. 9

MR. WALKER: This is Matthew Walker, 10

Navigant. You’re right. The LED NOPR as written so 11

far does not include a laboratory accreditation 12

requirement, and I guess this is an opportunity for 13

you and others to suggest that you would like to ha ve 14

that or not like to have that, and what specific 15

requirements you think would be the most useful for 16

LEDs. 17

MR. BROOKMAN: Ralph, please. 18

MR. TUTTLE: Thank you. Ralph Tuttle again. 19

I strongly urge the DOE to consider a requirement of 20

certification of laboratories that are performing 21

these tests. 22

MR. BROOKMAN: Okay. Thank you. Does NEMA 23

have a posture on this? On the question of 24

certification of testing laboratories? 25Executive Court Reporters (301) 565

- 0064 58

MR. BOESENBERG: We’ll have to discuss it 1

and reply back. 2

MR. BROOKMAN: Okay. Thanks, Alex. 3

Anything else? Matthew? 4

MR. WALKER: Yes, one other thing on the 5

measurement resolutions and values that we were 6

talking about earlier. I mean, to the extent possible 7

that NEMA is able to provide their own suggestions and 8

feedback based on their own experience with those 9

measurements, I think that would be very valuable. 10

MR. BROOKMAN: Okay. We’ve been 11

tremendously efficient, and we’ve gone through 25 12

slides in a record amount of time. 13

MR. BOESENBERG: Alex Boesenberg, to repl y 14

to that

– Yeah, let me slow you down a little bit 15

here. As we have stated, we are working on industry 16

guidance on the issue of measurements rounding and 17

reporting. And I look forward to delivering that as 18

soon as possible to the entire world, the Depar tment 19

included. 20

MR. BROOKMAN: Okay. Thanks for that. The 21

reason I’m asking the question is whether

– it’s now 22

ten after ten, whether we should take a break before 23

we proceed, or whether we should just press on. I 24

don’t know

– how long do you think the next element, 25Executive Court Reporters (301) 565

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test procedure for rated lifetime

– I see about 20

- odd 1

slides, so maybe we should take a break. Just a quick 2

break. 3

It’s now ten minutes after ten. We’ll 4

resume at 10:25, and many thanks for very, very 5

constructive, high quality comme nt here. We’ll see 6

you back here at 10:25. 7

W ear your visitor’s badge in the building

. 8

There are rest rooms on both ends of the hall. 9

There’s a coffee shop down on the ground floor in that 10

direction. Don’t leave the building. We ’ll see you 11

back here at 10:25. 12

(Whereupon, at 1 0 : 10 a.m., the meeting was 13

recessed for a 1 6 minute period.) 14

MR. BROOKMAN: Let’s resume. Please take 15

your seats. As I noted, we made really good progress 16

before the break this morning , and now we’re going to 17

proceed and hear about test procedures for rated 18

lifetime. And back to Mansi. 19

**Test Procedure for Determining the Rated Lifetime of** 20

**LED Lamps** 21

MS. THAKKAR: Thanks, Doug. So moving on to 22

the next section, we will now talk about the proposed 23

test procedure for dete rmining the rated lifetime of 24

LED lamps. The FTC lighting facts label also has a 25Executive Court Reporters (301) 565

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metric called “life” on the label which reports the 1

expected rated lifetime of the lamp in number of years 2

based on an estimated three hours per day of usage. 3

MR. WALKER: Mansi, I’m going to stop you 4

for a second. This is Matthew Walker, Navigant. A 5

couple of comments from the earlier section that came 6

in during the break. 7

MR. BROOKMAN: Yeah, let’s do those now 8

before we proceed. Please, yes. 9

MR. WALKER: So the fir st one is from Ronald 10

Daubach

. “ There’s a difference between laboratory 11

accreditation and certification of data. I think that 12

you want to consider laboratory accreditation, and not 13

a certification program. ” 14

MR. BROOKMAN: I see, so I’m going to

– I’m 15

g oing to receive comment also from the room. Ralph I 16

see you commenting, yes? 17

MR. TUTTLE: (off mic) 18

MR. BROOKMAN: That’s correct. And Chip? 19

MR. CHIPALKATTI: I agree with that. 20

MR. BROOKMAN: Okay. We have I think

– I 21

see several

– many of the manufacturers thumbs up, 22

heads nodding, so thanks for that comment. Yes. 23

MR. WALKER: So the next one is from Michael 24

McGaraghan

. “ How does the energy cost calculation 25Executive Court Reporters (301) 565

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come into this rounding issue? Energy cost is not one 1

of the metrics being proposed in this procedure, is 2

it? ” 3

MR. BROOKMAN: Alex? 4

MR. BOESENBERG: Alex Boesenberg, NEMA. No, 5

the energy cost is published by the Department and 6

they just actually published the latest 11.84 cents, I 7

think, this past week. 8

MR. BROOKMAN: Okay. 9

MR . WALKER: Okay. So this one again from 10

Ronald Daubach

. “ Accreditation procedure by which 11

authoritative third party gives formal recognition 12

that a body or person is competent to carry out 13

specific tasks. Certification is a procedure by which 14

a third pa rty gives written assurance ( certificate of 15

conformity ) that a product, process, or service 16

conforms to specified requirements. ” 17

MR. BROOKMAN: So that’s just amplification. 18

We’ve already covered that one. 19

MR. WALKER: Yes. 20

MR. BROOKMAN: Okay. Tha t’s all? Then 21

we’re moving on. Back to Mansi. 22

MS. THAKKAR: Okay. Because a standardized 23

test method does not currently exist to determine the 24

rated lifetime of LED lamps, DOE reviewed four 25Executive Court Reporters (301) 565

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approaches to determine rated lifetime, and analyzed 1

advantag es and disadvantages of each approach. 2

The first approach that was analyzed, which 3

is in column one on this slide, requires that the 4

lumen output of the LED lamp is measured until it 5

reaches 70 percent of initial lumen output, or L70. 6

The second appr oach, as required by Energy 7

Star for qualifying lamps for the Energy Star label, 8

and requires that LED lamps be tested for 6000 hours. 9

The lumen maintenance at 6000 hours should meet a 10

minimum value to make a rated lifetime claim of 25,000 11

hours. Qualifi cation for more than 25,000 hours 12

requires more than 6000 hours of testing, and 13

corresponding lumen maintenance requirements at those 14

hours. 15

The third approach that was considered, 16

which is column three on this slide, requires that 17

testing of the LED lam p for a minimum of 6000 hours 18

and projecting the time required to reach L70 lumen 19

maintenance based on our projection model. 20

Finally, the fourth approach, which is also 21

the approach proposed in this NOPR, requires that the 22

LED source, rather than the LED lamp, be tested for a 23

minimum of 6000 hours, according to IES LM

- 80, and the 24

lumen maintenance be projected to L70 using the method 25Executive Court Reporters (301) 565

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outlined in IES TM

- 21. However, the maximum rated 1

lifetime projection should not exceed 25,000 hours. 2

We will now discus s the advantages and 3

disadvantages of the four approaches. 4

MR. BROOKMAN: Before you do, let’s hear 5

from Mark. 6

MR. DUFFY: Yeah, I just want

– before we go 7

too much further down this road, I’d like to get some 8

clarification. Earlier you defined an LED source, and 9

I’m trying to understand whether we’re talking about 10

the package level, where LM

- 80 data may exist, or 11

whether you’re talking about arrays of packages where 12

the LM

- 80 data would only be that of the individual 13

packet? 14

MS. THAKKAR: So the int ent is that it 15

applies to those components that LM

- 80 applies to, and 16

LM

- 80 says that it’s for a modular package, or an 17

array. 18

MR. DUFFY: Thank you for that 19

clarification. 20

MR. BROOKMAN: Okay. Keith. 21

MR. COOK: I guess I’ve got to voice 22

concern. T he topic here is approaches considered to 23

determine rated lifetime. And yet your lifetime is 24

being predicated solely upon LM

- 79 data. That is very 25Executive Court Reporters (301) 565

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misleading because there’s a lot of other factors that 1

go into these devices, such as the drivers and the 2

m echanical aspects that are not being comprehended 3

with this testing. And so you’re telling everybody 4

that the device is good for X number of hours, based 5

solely upon the LEDs themselves. And I think that 6

that’s very, very, very misleading and may result in a 7

lot of disappointment by some of the people out in the 8

field. 9

MR. BROOKMAN: What would suggest the 10

Department do? 11

MR. COOK: The problem is right now this 12

technology is so new that we haven’t been able to 13

develop a good standard. And I understan d that that’s 14

a bad situation, but it’s reality, and there are 15

groups, for instance, there’s one that’s headed by 16

Fred Wel s h , that is trying to get their arms around 17

that very subject, and they’re trying to come up with 18

ways to test, to establish reliabili ty levels. But 19

we’re not there yet. 20

MR. BROOKMAN: Okay. Alex? 21

MR. BOESENBERG: Alex Boesenberg, NEMA. As 22

an analogy or a reference to the difficulty, Ralph and 23

others could comment on how long it took to write LM

24

79 and LM

- 80. The

– came up with a n idea and then it 25Executive Court Reporters (301) 565

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didn’t work aspect of solid state standards, and I can 1

speak from that

– from the experience of the NEMA 2

solid state lighting standards that I facilitated with 3

many of the people in this room. When we said, okay, 4

let’s do this method X

, Y and Z. By the time we had 5

finished discussing the wording of that paragraph a 6

few months later, it was no longer valid, because the 7

solid state system we had taken as the baseline, 8

didn’t exist any more. And so the challenge for 9

anything right now for rated lifetime is that the 10

assumptions and physical circuitry parameters and 11

things that go into it, have a habit of not sticking 12

around long enough for us to finish publishing the 13

document. 14

And if you figure on 1000 hours a year as 15

typical consumer mai ntenance, we’re talking about 16

people putting 25 years on packaging already, and for 17

now, the industry has left that up to individual 18

manufacturer discretion. 19

MR. BROOKMAN: Yeah. Ralph. 20

MR. TUTTLE: I would agree with Alex. Today 21

there is no known me thodology in the industry to 22

accurately determine the lifetime of a solid state 23

lighting product, whether it’s a luminaire or a 24

replacement bulb type of product. 25Executive Court Reporters (301) 565

- 0064 66

One thing that perhaps DOE may want to 1

consider is that instead of defining the lifetime o f 2

the product on the package, define instead lumen 3

maintenance of the source itself. And that is a 4

measure that there are standards or methodologies in 5

the industry that are very common today. But lifetime 6

is not something that we can accurately predict today. 7

MS. THAKKAR: I have a clarifying question 8

for that. So given that this is for FTC’s label, 9

would that lumen maintenance value then just be 10

reported against the life metric, or would you suggest 11

something else for life on the label? 12

MR. BROOKMA N: Back to Ralph. 13

MR. TUTTLE: Yeah, Ralph Tuttle again. I 14

would recommend that on the label that there be no 15

claims of life at this point in time, because the 16

reality is that there is no way that we can predict 17

that. Case in point, a lot of the studi es that were 18

done up at PN N L within the CALiPER program showed 19

very, very rapid lumen depreciation and actually non

20

functionality of some products in very short periods 21

of time, even though some of the best LEDs in the 22

world were being used in those produc ts. 23

So, you know, there are groups, as was 24

previously referred to, that are working on this

– 25Executive Court Reporters (301) 565

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trying to tackle this subject, but as of today, we 1

have no answer. 2

MR. BROOKMAN: Alex. 3

MR. BOESENBERG: Alex Boesenberg. And of 4

course we understand we’ re talking about something 5

that feeds into some other agency’s program. We have 6

our own ongoing discussions with the FTC about this 7

and other subjects, so I sympathize. I understand 8

that the DOE has a certain lack of control over the 9

final product, as it were. But we will comment as 10

best we can. 11

MR. BROOKMAN: Okay. Thank you. Okay. 12

MS. THAKKAR: Okay. Moving on. We would 13

like to discuss the advantages and disadvantages of 14

the four methods that we considered. The first 15

advantage of approach on e is that the LED lamp, rather 16

than the LED source is being tested. Additionally, 17

this method is not a projection of rated lifetime, so 18

the reported value of lifetime is what you actually 19

observe during testing. 20

However, this approach does have some 21

d isadvantages. The biggest one being that the time 22

required to test the LED lamp until it reaches L70 can 23

be extremely long. The lumen of the lamp takes 25,000 24

hours to reach 70 percent of initial light output, the 25Executive Court Reporters (301) 565

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time required for testing would be almos t three years. 1

Another disadvantage of this long testing time is that 2

because LED lamps and LEDs in general, are a rapidly 3

evolving technology, the product may be obsolete by 4

the time testing is completed. 5

(Laughter.) 6

MR. BROOKMAN: Ralph would like t o comment 7

at this point. Ralph. 8

MR. TUTTLE: This is Ralph Tuttle again, and 9

I have to respectfully disagree with that comment and 10

the chuckles that went around here. I mean, even 11

today, we are providing to the lighting community, 12

LEDs that we designed and put into production five 13

years ago, and they’re still being used today. 14

They’re still being

– in fact, that older product I’m 15

referring to was just within the last year that some 16

of our newer products finally surpassed it in the 17

volume of product tha t we were shipping. So while 18

everybody is absolutely right, that we’re all working 19

on improving the lumen maintenance of the product, the 20

efficacy of the product, just the overall robustness 21

of it, still today, there are a lot of LEDs that were 22

designed q uite some time ago that are still being 23

designed into products. 24

MR. BROOKMAN: Okay. Thanks for the 25Executive Court Reporters (301) 565

- 0064 69

clarification. 1

MS. THAKKAR: Actually, I have a 2

clarification question. When you say LEDs, do you 3

mean the LED package, or do you mean the LED lamp 4

it self. 5

MR. TUTTLE: I’m talking about both. 6

MS. THAKKAR: Both. 7

MR. TUTTLE: In some cases, but I am 8

specifically referring to the LED package itself. 9

MS. THAKKAR: Okay. Thank you. 10

MR. BROOKMAN: Yes, Chip. 11

MR. CHIPALKATTI: I think the poin t just 12

made highlights the additional fact of divergence 13

between the actual chip and the light source, and the 14

rapid change in the final product. And so it’s

– the 15

question of value, what product is being written about 16

here in this rule? And I think it’s the system. And 17

so the fundamental fact is that even though some LEDs 18

may be still being used, there’s a lot more 19

manufacturers of LEDs coming with new stuff, and so 20

there’s a constant change in that field anyway. 21

MR. BROOKMAN: This is a point Alex made 22

yesterday about

– thinking about this as a system. 23

Many of you weren’t

– some of you

– many of you were 24

here yesterday. Okay. So additional clarifications 25Executive Court Reporters (301) 565

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before we move on? The Department’s going to try and 1

have to figure out, try and do somethin g about this, 2

right? Unless they choose not to, so let’s hear 3

advantages and disadvantages. 4

MS. THAKKAR: Okay. Moving on to approach 5

two. The advantage of this approach is also that it 6

tests the LED lamp rather than the LED source. 7

Additionally, the lamp is tested for a minimum of 6000 8

hours only, and therefore this approach is not as time 9

consuming as approach one. A disadvantage of approach 10

two is that it does not take into account LED failure 11

mechanisms, other than lumen depreciation. And while 12

Energy Star does require a rapid cycle stress test for 13

testing failure, this method is not a proven source to 14

determine failure for LED lamps. 15

The advantages of approach three are very 16

similar to those of approach two. Approach three also 17

tests the lamp rather than the source, and requires 18

testing for a minimum of 6000 hours only, and is 19

therefore not as burdensome as approach one. However, 20

a key disadvantage of this approach is that a standard 21

method has not yet been developed to project LM

- 79 22

lumen ma intenance data to determine the lifetime of 23

the lamp. Additionally, it may not be feasible to 24

develop a method of projection in a timely manner for 25Executive Court Reporters (301) 565

- 0064 71

reporting life on the lighting facts label by FTC. 1

Finally, the advantages of the proposed 2

method, which is approach four, is that it uses 3

industry accepted standards, LM

- 80 and TM

- 21, to 4

project the lumen maintenance of the LED source. DOE 5

also proposes that the maximum rated lifetime that is 6

reported, should not exceed 25,000 hours. This is 7

important to i nsure that exceedingly large projections 8

of lifetime are not made exclusively on LED source 9

lumen maintenance data. It is also currently unknown 10

what the lifetime of some of the other components 11

within the lamp, such as the LED driver, might be. 12

25,000 h ours provides a conservative estimate of the 13

lamp’s overall lifetime. Finally, the proposed 14

approach would be less burdensome than testing the LED 15

lamp for 6000 hours because LM

- 80 data for the LED 16

source is often available from LED source 17

manufacturers. 18

The proposed approach does have some 19

disadvantages, though. The primary one being that it 20

projects LED source data, rather than LED lamp data. 21

Secondly, the proposed approach does not account for 22

other LED lamp failure mechanisms, such as LED driver 23

de gradation and failure, the effect of the 24

interactions between LED sources and between LED 25Executive Court Reporters (301) 565

- 0064 72

sources and other components. However, these failure 1

mechanisms cannot be accounted for currently because 2

standardized test methods to determine the impact of 3

these components have not yet been developed. As new 4

standards to determine the life of an LED driver and 5

other components are developed, this proposed test 6

procedure could be revised. 7

Therefore, DOE proposes approach four, 8

because it uses a standardized test and projection 9

method, and has minimal test burden. DOE now requests 10

comment on the four approaches presented as well as 11

the relative cost and benefits of each approach. 12

MR. BROOKMAN: Alex. 13

MR. BOESENBERG: Alex Boesenberg for NEMA. 14

As you may expe ct, we are still working on the 15

industry comment for this. Approaches number two and 16

number four are receiving the most discussion, but 17

actually favoring one over the other isn’t necessarily 18

– we’re not flipping a coin or anything, but it’s more 19

of a

– as you note, there are advantages and 20

disadvantages to each. So we’ll have more on that. 21

I do want to comment specifically on 25,000 22

hours, because the sentiment I have received and am 23

receiving still, is that we disagree with a cap which 24

is ultimately an arbitrary number. We sympathize

– I 25Executive Court Reporters (301) 565

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sympathize with the Department that 25 years sounds 1

like plenty long already, and yes there are many 2

outside factors, but it is not typical of test 3

procedures to put reporting, or cap requirements. 4

That is something t hat you arrive at based on your 5

testing. And ultimately, the marking of the package, 6

as we’ve noted several times today, is something 7

between the manufacturer and the FTC. So for those 8

reasons, fundamentally, I would submit that the 9

Department remove tha t cap and number one, we’re still 10

working on test procedures that will actually allow 11

you to arrive at a more scientifically based number, 12

but even so, it’s something for my manufacturers to 13

discuss with the FTC as far as what they put on there. 14

And also , it’s an internal decision. Some 15

companies do not want to put an outrageously large 16

number for lifetime, because they just

– they want to 17

be conservative. And others consider it a marketing 18

decision, and if we think we’ve got LM

- 80 and we can 19

say 40 yea rs, let’s do it. There’s lots of individual 20

decisions that some are market

- driven, so they’re 21

internal company decisions that’s part of the free 22

trade, and free open market between different 23

companies and their positions, and what they claim and 24

how they compete based on performance and other 25Executive Court Reporters (301) 565

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factors. So, lifetime is highly discussed. 1

MR. BROOKMAN: I have a follow on question 2

for Alex. Since you said

– you said you were 3

considering two and four, is it likely that if NEMA 4

arrives at something it will b e kind of bounded in 5

that framework, or is it possible that NEMA will come 6

back with something that DOE has not yet anticipated? 7

MR. BOESENBERG: I’m not sure because it’s 8

still early. And, of course our initial comments at 9

the start of this section, yo u can take as fairly 10

negative on the whole topic. So it’s just as likely 11

our response will be, leave it off the table for now. 12

MR. BROOKMAN: Okay. Pam. 13

MS. HORNER: I’m going to risk

– this is Pam 14

Horner. I’m going to risk philosophical couple of 15

s entences here. And I’m not meant to be flip. If you 16

take the point of view of the consumer, which to 17

Keith’s earlier point is probably what should be 18

considered, since this is in concert with the FTC, one 19

would have to assume that the consumer, try to be one 20

for a moment, talks about or thinks about what is the 21

meaning of life

– I’m not kidding. That’s what this 22

is about. So with the ordinary light bulb world, 23

there is an expectation of the consumer, and I see you 24

nodding here, that life does not mean l umen 25Executive Court Reporters (301) 565

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maintenance, it means it’s the end of the bulb as I 1

know it. It doesn’t work any more. 2

What we’re faced with is the reality that 3

the meaning of life, for the consumer, has no test 4

procedure that is agreed upon by the experts, which 5

points to premat ure, on this point, but it also opens 6

the possibility, and whether we incorporate it into 7

our comments or not, Alex, I think we should also be 8

very innovative and say that perhaps this is an 9

education opportunity. 10

One of the

– Alex mentioned that we we re 11

looking at approaches two and four, we were commenting 12

on them, and one could argue that one of the reasons 13

for that is both talk about lumen maintenance, which 14

is the reality of how we have characterized the 15

meaning of life for those who produce this p roduct. 16

And in that world, this may sound silly, but is there 17

an educational approach that we could take that starts 18

to say this is the way this operates, guys, and what 19

it means on the box when we say so many hours, it 20

means something different than you’ re used to. 21

So it doesn’t preclude the possibility of us 22

embarking upon something to educate the consumer, 23

rather than to try to drive home something that isn’t 24

ready. I hope I’m making sense. Thank you. 25Executive Court Reporters (301) 565

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MR. BROOKMAN: Yes, that was helpful. Tha nk 1

you. Alex. 2

MR. BOESENBERG: This is Alex Boesenberg. 3

Thank you, Pam. It’s worth me stating for the record 4

and reminding everybody, especially someone who comes 5

and reads the transcript and isn’t familiar with solid 6

state lighting, which is a lot of people, that LEDs 7

don’t just burn out and stop working. They just get 8

dimmer. That’s where lumen maintenance and L70 come 9

from. L70 is when it’s at 70 percent of what it once 10

was. And the point is the consumer definition of 11

lifetime that Pam spoke abo ut is, it doesn’t work any 12

more at all. But industry and transportation safety, 13

individuals, municipalities, everyone is grappling 14

with the fact that LEDs just get dimmer, and it’s a 15

huge deal for roadway lighting because municipalities 16

have a mandatory o bligation to put a certain number of 17

lumens on a road surface. They need to know when they 18

have to replace that LED because HID, it just stops 19

working. But the LEDs will last a long time past what 20

I guess

– I might get in trouble

– but call it their 21

usef ul life, in terms of producing enough lumens to 22

meet the safety standard. That’s something industry 23

is actively working on. 24

Unfortunately, Jim Brodrick left already. 25Executive Court Reporters (301) 565

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He could tell us about the Municipal Solid State 1

Street Lighting Consortium that he is helping run 2

where they are addressing that very issue. And they 3

are working with the Next Generation Lighting Industry 4

Alliance that Keith Cook is the chair of, which is 5

industry’s think tank for the MSSLC, and is helping 6

them grapple with that issue. Ultimately, there are

– 7

there’s no path forward on what to do to somehow 8

identify an LED as hit a point where you might want to 9

consider “replacement” I’ll call it, because it still 10

works. So do we make it turn off? Do we make a light 11

blink? Who knows? There’s all kinds of different 12

ways to solve it. And it’s a problem that has never 13

been an issue because other stuff just burns out. 14

MR. BROOKMAN: John, comment? 15

MR. GREEN: Yes, to support that, where LEDs 16

are used in commercial or maybe even indu strial 17

applications as well, they usually have light levels 18

that are specified by IES that

– so minimum light 19

levels to perform tasks, and those levels just don’t 20

exist in the normal consumer market for residential 21

applications. So it just supports the fa ct that 22

people expect the lifetime to mean it’s not going to 23

work any more, it’s not going to fall below a certain 24

level in my house. 25Executive Court Reporters (301) 565

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MR. BROOKMAN: Okay. Thank you. Comment 1

from the web? 2

MR. WALKER: Yeah, we do have one from the 3

webinar participant s. Cameron Miller, on the 25,000 4

hour cap, his comment is, “ the cap can be increased as 5

long as industry provides specific statistics to prove 6

their stated numbers. ” 7

MR. BROOKMAN: Okay. So do we have 8

additional comment on these four approaches? We’ve 9

heard from NEMA about what they plan to do, and any 10

other comments? Mark. 11

MR. DUFFY: This is Mark Duffy of GE. I 12

agree with all of these comments, they’ve been 13

terrific. 14

MR. BROOKMAN: Even the philosophical ones. 15

MR. DUFFY: Even the philosophica l ones, the 16

meaning of life, you know,

-- 17

MR. BROOKMAN: We might need to go to the 18

bar rather than lunch. 19

MR. DUFFY: Yeah, exactly. Recommendations 20

for lamp replacement and so forth is something that 21

DOE should be prepared for as a response that may 22

incorporate multiple methods, because in some cases 23

LM

- 80 data may be available, in some cases LM

- 80 data 24

may not be available, and if you’re in a situation 25Executive Court Reporters (301) 565

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where you’ve specified your preference for approach 1

four, you may be in a situation where all of a sudden 2

there’s products out there for whom LM

- 80 data isn’t 3

available and you need to have some way of 4

establishing what you’re going to put on

– or FTC 5

needs to establish what’ going to be put on their box. 6

MR. BROOKMAN: Yeah. Lucy, can you 7

describe, or can someone describe the nature of the 8

consultation with FTC at this point? Have you begun 9

that? Not yet. 10

MS. DEBUTTS: No, we haven’t, not yet. But 11

we actually, just like Alex stated, you know, we read 12

the documentation from the group that Jim Br odrick is 13

working with, and we are going to be taking this into 14

consideration, and we understand the issue is very 15

complex. So although a lot of your remarks probably 16

preempted the next slide we’re going to have. 17

MR. BROOKMAN: Okay. I’ll just make the 18

comment NEMA has been so involved in standard

- setting 19

activities for a long, long, time. You’re very 20

sophisticated at this stuff. If you’re going to come 21

forward with something that’s a lot different from 22

what they’re looking at, you’ve got to get

– you ’ve 23

got to do early consultations, so they’re looking at 24

some pathway that’s going to drive this train. 25Executive Court Reporters (301) 565

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MS. DEBUTTS: We will take care

– take a 1

look at all the comments and we’ll consider the 2

alternatives. That’s why I asked earlier, if you have 3

a prop osal please do so because we want to make sure 4

that what we’re doing is useful for everyone. 5

MR. BROOKMAN: Yeah. Pekka. 6

] MR. HAKKARAINEN : So this is Pekka 7

Hakkarainen . I’m now speaking as a representative of 8

a company that does not make these produ cts, but 9

nevertheless is involved in this lighting business, 10

and what is troubling to me listening to this 11

conversation, is that I don’t think that we are 12

possibly going to have a proposal by the 25 th of June 13

to offer that could be adopted. This is an are a that 14

I am concluding in my mind, that we are simply not 15

ready to do so. Is there some way that we can take 16

the reality of the situation into account and with 17

regard to the life rating, do it differently than 18

traditional rulemakings where we have a comme nt period 19

and then we sort of go into a waiting period, as 20

industry, and then the final rule comes out. Is there 21

some mechanism where we could do it differently? 22

MR. BROOKMAN: Interesting idea. Alex. 23

MR. BOESENBERG: Alex Boesenberg. I would 24

offer, in support of that, remember that ultimately 25Executive Court Reporters (301) 565

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we’re talking about consumer satisfaction and market 1

policing. There are mechanisms for reporting 2

complaints for products, et cetera. And the FTC has 3

their own enforcement procedures too. Specific to 4

this su pporting the FTC’s labeling, lifetime claims 5

could be left up to them specifically at this time. 6

MR. BROOKMAN: Thank you. Chip. 7

MR. CHIPALKATTI: Chip Chipalkatti, Osram 8

Sylvania. You just wanted to make a general comment 9

about all of this, not spec ific to the methodologies, 10

is the fact that it’s insistence of the FTC labeling 11

requirement and the key word is labeling. And a lot 12

of the challenges of putting a lot of information on 13

very small packages is a critical concern. It’s 14

expensive, but it’s o ften not legible because it’s so 15

hard to find the information on the package. So one 16

must take into account the impact on the actual 17

physical packaging. As we think about educating 18

consumers and so on, and what needs to go on the 19

label. 20

MR. BROOKMAN: Okay. Final comments on 21

this. Betsy? 22

MS. KOHL: This is really good to go back to 23

the question from Lutron

– this is Betsy from GC

– if 24

we receive additional information that we want to have 25Executive Court Reporters (301) 565

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another round of comment or be posted up, or have a 1

supplemen tal document of some kind, there are ways, 2

opportunities, for additional input. 3

MR. HAKKARAINEN : And I’m just now speaking 4

for myself, but I have a suspicion that others in the 5

room might agree that we would welcome that kind of an 6

approach. 7

MR. BROOK MAN: Thank you, Pekka. Appreciate 8

you raising it. Thank you, Betsy. Okay. So let’s 9

proceed then. 10

MS. THAKKAR: Okay. These are the test 11

procedures that are proposed in the NOPR, which is 12

approach four that we just discussed. DOE is 13

proposing a def inition for rated lifetime, as the time 14

when the lumen output of the LED source falls below 70 15

percent of initial light output. It is possible that 16

this definition may change if the proposed test 17

procedure to determine rated lifetime changes. 18

DOE requ ests comment on the proposed 19

definition of rated lifetime. 20

MR. BROOKMAN: Keith. 21

MR. COOK: Absolutely not. 22

MR. BROOKMAN: Maybe you’ve got to be more 23

specific than that. Come on. 24

MS. DEBUTTS: You don’t want to comment, or 25Executive Court Reporters (301) 565

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you don’t agree with th is. 1

MR. COOK: I don’t agree, that’s not the 2

definition. Pure and simple. There’s a lot more in 3

that lamp than just the LEDs. 4

MR. BROOKMAN: Do you want to

– Alex, do you 5

want to comment here? 6

MR. BOESENBERG: Alex Boesenberg. I didn’t 7

have anythi ng specific to comment, but I think to 8

build on Keith’s point, that this is one of those 9

issues where you’re talking about a component of a 10

larger product, and rated lifetime is really specific 11

to the product. It doesn’t matter if the LED will 12

last 100 ye ars, I’m pretty sure the rest of the system 13

won’t. So it’s

– I think the word is irrelevant. It 14

is irrelevant to this subject, the overall, you know, 15

the goal of this rule. 16

MR. BROOKMAN: Other comments here? Adam? 17

MR. CHRISTENSEN : I’m not sure th at I’d go 18

as far as saying irrelevant, but it’s a tricky problem 19

to solve for sure. I think it’s still early in our 20

process, and we’re a consensus building group for 21

those of you that don’t know ASAP, we have consumer 22

groups as well as utilities and envir onmental groups 23

on our board. So we’re still grappling with some of 24

this, but to the extent that kind of a systems 25Executive Court Reporters (301) 565

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approach could be taken and more included in the 1

analysis of a measure of lifetime, besides just lumen 2

maintenance, I think it would probabl y be helpful. 3

MR. BROOKMAN: Good. Thank you. 4

MR. CHRISTENSEN : But I can’t say anything 5

more specific at this time because I don’t have

– 6

MS. THAKKAR: Thank you. 7

MR. BROOKMAN: But you’re working on it. 8

MR. CHRISTENSEN : We’re working on i t. 9

MR. BROOKMAN: Yeah. Okay. That’s good. 10

Additional comments on lamp rated lifetime? Please go 11

ahead. Yes. 12

MS. FARBER: So just to clarify then, your 13

comment about

– 14

MR. BROOKMAN: Please say your name again. 15

MS. FARBER: I’m sorry, Julia F arber with 16

UL. Just to clarify. What you mean by the other 17

additional components in the lighting structure. 18

What’s their annual lifetime? Is there any easier wa y 19

to measure how long those products will last ? Just a 20

thought, maybe you’d want to build th e lifetime around 21

how long those would last. 22

MR. BOESENBERG: This is Alex Boesenberg. 23

Industry and other scientific groups are definitely 24

looking at that. Mean time between failures and all 25Executive Court Reporters (301) 565

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those other factors. It is proving to not be that 1

simple. 2

MS. FARBER: Oh, I’m sure. 3

MR. BOESENBERG: Of course, and certainly 4

UL, we have used your test methodologies as basis for 5

some of our systems approaches. The fact that UL 6

recognizes a luminaire as a system integral with the 7

ballast driver light source and everything else, 8

you’ve been very useful to us, thank you. 9

MS. FARBER: You’re quite welcome. 10

MR. BOESENBERG: But

– so the

– yeah, that 11

was one of the first things brought up years ago at 12

some of the earliest CALiPER and DOE’s SSL meetings, 13

as e veryone grappled with, well, what if the 14

transistor fails? So yes, it’s part of what’s being 15

discussed but turned out to be a lot harder than that. 16

MR. BROOKMAN: Thanks. Now let’s proceed. 17

MS. THAKKAR: Moving on to the steps to 18

determine the rated lifetime, as was just defined. 19

The first step is to project the rated lifetime is to 20

determine the in

- situ temperature of the LED source 21

when it operates within the lamp. This temperature 22

can be determined by performing an in

- situ temperature 23

measurement test, or ISTMT. The in

- situ temperature 24

is required to know the temperature at which lumen 25Executive Court Reporters (301) 565

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maintenance data should be used for projecting rated 1

lifetime. 2

Once the case temperature is known, the 3

second step is to obtain lumen maintenance data at 4

this temperature. This can be done in one of three 5

ways. The lumen maintenance data is either available 6

at the case temperature directly from the LED source 7

manufacturer. The second option is if the case 8

temperature falls between two other temperatures at 9

whi ch lumen maintenance data is available, then the 10

lumen maintenance data at the case temperature can be 11

interpolated in TM

- 21. Finally, if the lumen 12

maintenance data is not available from the source 13

manufacturer and cannot be interpolated, it must be 14

obtai ned by testing the LED source and measuring the 15

lumen maintenance at the in

- situ temperature. 16

The last step in determining the rated 17

lifetime is projecting the lumen maintenance data that 18

is obtained in step two. The method described in TM

19

21 should b e used to project lifetime, but the maximum 20

allowable value of the rated lifetime should not 21

exceed 25,000 hours. 22

We will now go into the details for each of 23

these steps. 24

MR. BROOKMAN: Yes, excuse me, before you

– 25Executive Court Reporters (301) 565

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Ralph. 1

MR. TUTTLE: Thank you. Ra lph Tuttle, with 2

CREE. I would like to make a recommendation. I think 3

that as an industry we concur that any attempt to 4

define rated lifetime, regardless of the methodology, 5

is useless at this point. And while I appreciate the 6

amount of work that’s gone into developing these step 7

by step methods, the reality is, once we go through 8

them, I think as an industry we’re going to say, you 9

know, that doesn’t work. So perhaps we might want to 10

bypass some of this at this point in time. 11

MR. BROOKMAN: I’m looki ng at Alex. Ralph 12

just made a representation on behalf of the industry. 13

Alex. 14

MR. BOESENBERG: I was debating whether or 15

not to make the same statement. I also appreciate, I 16

know it took a lot of time to put all this together, 17

and I can’t speak for th ose on the phone. There may 18

be someone who would like to review it. I do not have 19

any industry consensus, I haven’t even received hardly 20

any comments on these portions because we’re not 21

prepared to comment on it. So, we have no comment, by 22

and large. I can’t speak for everyone, but if she 23

goes over it pretty quick

-- 24

MR. BROOKMAN: As you look at these slides 25Executive Court Reporters (301) 565

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and the details in these slides, NEMA would, of 1

course, be commenting perhaps specifically or 2

generally on what’s in here as you review this 3

mat erial. But maybe we should just put the question 4

to those who are on line, whether they have any 5

specific comments about this. I guess what you’re 6

suggesting is that we not review all these slides, 7

correct? 8

MR. BOESENBERG: Proposing to the group to 9

co nsider that, and probably jump to slide 46 and talk 10

about sample size again. 11

MR. BROOKMAN: So I make this query to those 12

joining us on line, if you’d like this additional 13

review, then we can go through this, I presume. Mark. 14

MR. DUFFY: Yeah, I respe ctfully would like 15

to hear, regardless of the potential irrelevance, I’d 16

like to hear what the DOE is thinking about when they 17

put this proposal together, even if we are concerned 18

about the whole proposal. 19

MR. BROOKMAN: Are you suggesting

– I’m not 20

sure I understand what that means. That means you 21

want to go through these slides, or

– 22

MR. DUFFY: Yeah, that’s basically what I’m 23

saying, is please give the DOE an opportunity to tell 24

us what they were thinking so that when we develop our 25Executive Court Reporters (301) 565

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comments which w e need to make to this very proposal, 1

we know exactly what was in your minds. I think it 2

will help us as an industry to know that. 3

MS. DEBUTTS: It’s only six slides, you 4

know, and the people on the webinar would like to go 5

over them as well. So if you all don’t mind

– 6

MR. BROOKMAN: Well, let’s do it. 7

MR. CHRISTENSEN : I would like to as well. 8

MR. BROOKMAN: Adam would as well. So let’s 9

do it and Mansi’s doing a very efficient job with 10

this. So proceed. 11

MS. THAKKAR: Okay. So the first step as 12

DOE has proposed the test procedure currently, is to 13

determine the in

- situ temperature of the LED source. 14

DOE proposes that the UL standard 1993

- 2009 should be 15

used for setting up the test box, test conditions, 16

testing equipment, and instrumentation. Additionally, 17

a thermocouple should be attached to the LED source at 18

the temperature measurement point that is identified 19

by the LED source manufacturer by making a temporary 20

hole to insert the thermocouple as stated in Appendix 21

D in the Energy Star specif ication. 22

DOE requests comment on adopting the 23

relevant sections of UL standard 1993 and performing 24

the ISTMT, as well as the practicality of attaching 25Executive Court Reporters (301) 565

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the thermocouple temporarily to determine the in

- situ 1

temperature. 2

MR. BROOKMAN: Does it make sense for us to 3

go through all of them and receive comments at the 4

end, or should we do it section by section? I’m 5

unclear myself. 6

MR. DUFFY: I’d like to go section by 7

section, because I have a question. 8

MR. BROOKMAN: Okay. Mark, please. 9

MR. DUFFY: I’ll turn my microphone on. 10

This is Mark Duffy of GE. I have a question about UL 11

1993, and I guess we have UL in the room. The 12

question is, is the purpose of that set up to mimic 13

normal operating conditions, or is it to mimic some 14

sort of a stressed op erating condition within this 15

box, within this enclosed box? 16

MR. BROOKMAN: Can you answer this one, 17

Mansi. 18

MS. THAKKAR: So my understanding is that it 19

mimics normal conditions in terms of the ambient 20

temperature and humidity requirements for a lamp 21

t hat’s designated to be operated in normal conditions, 22

but it also provides specific stress tests for a lamp 23

that might be used say, in a wet location, or a humid 24

location. And for those conditions, it provides 25Executive Court Reporters (301) 565

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specific details on how to test a lamp in an 1

environment that’s simulates the humid conditions or 2

the wet conditions. 3

MR. DUFFY: So I guess my question is, if 4

you put it in a box to measure this temperature, are 5

you going to elevate the temperature artificially 6

above normal operating conditions? 7

MS. THAKKAR: I believe the test box is open 8

from the bottom end, and the UL standard actually 9

provides how to control the temperature for each 10

component, and what to do in case the temperature is 11

getting above what it should be. So they ask you to 12

edit out and make sure the temperature returns back to 13

normal. 14

MR. DUFFY: Okay. So, I guess I’ll get 15

right to the point here, if the UL test is intended to 16

determine whether or not a temperature maximum has 17

been exceeded, it might be a stress type of a test 18

that’s looking for whether, under these conditions, 19

extreme conditions, have they exceeded

– has the 20

safety temperature been exceeded. That would not be 21

the right kind of test to get at normal operating 22

conditions for determining lumen maintenance. That ’s 23

my concern. 24

MR. BROOKMAN: Okay. Julia, do you want to 25Executive Court Reporters (301) 565

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comment? 1

MS. FARBER: I am unfortunately not a 2

technical expert in this particular area, but we did 3

have our technical expert supposedly calling in, so if 4

I may ask if somebody who’s manning the laptop could 5

see if someone from UL has responded to any of these 6

thoughts. 7

MR. BROOKMAN: Sure, Matthew’s over there. 8

We’ll see if anybody has responded. 9

MS. FARBER: In the meantime, we could 10

definitely take these considerations and I could 11

fol low up with those for people who are interested in 12

that specific answer. 13

MR. BROOKMAN: Okay. Matthew, do you have 14

something from the web? 15

MR. WALKER: Yes, we did have one comment 16

from the web, I’m not sure of the affiliation . But it 17

comes from C arl Bloomf i eld. 18

MS. FARBER: Bloomfield. 19

MR. WALKER: Bloomfield. Okay. Well, the 20

comment is, “ as the use of UL 1993 is being specified, 21

please note that the standard allows an optional test 22

box for specific wattage products, ” and then in a 23

second stat ement from C arl Bloomfield, “ the 24

temperature test is usually to represent real life 25Executive Court Reporters (301) 565

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application. ” 1

MR. BROOKMAN: Okay. Thank you. So let’s 2

proceed then. 3

MS. THAKKAR: Are there any other comments. 4

MR. WALKER: We did just receive one more. 5

This o ne is from Joel Jacobson. “ Agree, the UL box is 6

a worst case scenario. ” 7

MR. BROOKMAN: Okay. Yes, Ralph, please. 8

Let us know. 9

MR. TUTTLE: I’m sorry. Yeah, that’s pretty 10

conflicting, you know, worst case would, to me, 11

indicate the worst possible op erating conditions that 12

the manufacturer of the product recommends that 13

product be used under. Whereas normal is

– yeah, 14

undefined at this point in time, to me. 15

MR. BROOKMAN: They might specify a 16

temperature range and you’d be at the worst end of 17

that range. Okay. So let’s proceed. 18

MS. THAKKAR: Okay. We will now discuss the 19

method for obtaining lumen maintenance data if it must 20

be determined by testing the LED source. DOE proposes 21

to adopt LM

- 80 for the test conditions, set up, 22

instrumentation, a nd measurement of lumen output of 23

LED sources. For the test conditions, DOE proposes 24

that the requirements specified in LM

- 80 should be 25Executive Court Reporters (301) 565

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adopted with some modification, Instead of testing 1

LED source at three case temperatures as specified in 2

LM

- 80, DOE p roposes that testing should be performed 3

only at the case temperature identified during the 4

ISTMT. Additionally, the drive current passing 5

through the LED source during testing should be equal 6

to or greater than the drive current passing through 7

the sourc e when it is operated within the lamp. 8

The second topic under test conditions is 9

air temperature and air

– sorry, go ahead. 10

MR. DUFFY: I may be your most frequent 11

interrupter through these, but I want to deal with 12

each one as I think of them. This ge ts back to the 13

clarification that I asked for before. If LM

- 80 data 14

is not available, and now you have a complete lamp 15

unit, is it incumbent upon the testing procedure to 16

tear that unit apart and test these sources according 17

to LM

- 80 at a temperature that represents this 18

institute temperature. Is that what you’re thinking? 19

MS. THAKKAR: Yeah, that was the intent. 20

But I had a clarification to your clarification. 21

MR. DUFFY: Okay. 22

MS. THAKKAR: Would you have to tear apart 23

the lamp to get the sourc e, or would the source be 24

available? 25Executive Court Reporters (301) 565

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MR. DUFFY: Usually you have to destroy the 1

product to get this piece out of the product for 2

testing in that manner. 3

MS. THAKKAR: I see. 4

MR. BROOKMAN: Yeah, go ahead, Ralph. 5

MR. TUTTLE: Another situation, and one of 6

the reasons LM

- 80 is written the way it is is that 7

it’s not feasible that source manufacturers test LEDs 8

at every conceivable temperature that it may be used 9

under. LEDs in replacement bulb products can run at 10

temperature s anywhere from 55 to 140 degrees 11

Centigrade and everywhere in between. One of the 12

reasons that we specify today, three, and ultimately 13

probably two

– and the LM

- 80 is currently going 14

through a revision

– the reason that we specify at 15

least two temperatures is to allow us to deter mine the 16

relative lumen maintenance at a temperature in between 17

the upper and lower. So the way this is written would 18

make it extremely difficult to comply to the 19

requirement. 20

MR. BROOKMAN: Okay. And can you offer how 21

it might be revised so that you m ight comply? 22

MR. TUTTLE: If in fact, DOE is intent on 23

using LM

- 80 and TM

- 21 as a methodology for determining 24

lumen maintenance of the light source, I would 25Executive Court Reporters (301) 565

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recommend that they simply follow all the 1

methodologies as defined in those documents, rather 2

tha n try and add something different to them. 3

MR. BROOKMAN: Okay. Thank you. Other 4

comments at this juncture? Okay. 5

MS. THAKKAR: So, the second topic under 6

test conditions is the air temperature and air 7

movement requirements. DOE proposes that the air 8

temperature around the LED source should be maintained 9

between the case temperature and five degrees Celsius 10

below the case temperature as specified in LM

- 80. 11

That is, if the case temperature is 70 degrees 12

Celsius, the air temperature should be betwe en 65 and 13

70 degrees Celsius. 14

For air movement, DOE proposes to adopt the 15

specification in LM

- 80 as well, which states that care 16

should be taken to minimize any drafts around the LED 17

source, but some air movement is necessary to avoid 18

thermal stratific ation. 19

DOE requests comment

– we already went 20

through the first part about testing at just the in

21

situ , so in the second part, DOE requests comment 22

about whether the measurement location point for 23

measuring air temperature around the LED source should 24

be specified, and whether the allowed air flow should 25Executive Court Reporters (301) 565

- 0064 97

also be further specified. 1

MR. BROOKMAN: Comments on those two 2

elements? Location and proximity, I guess. Ralph. 3

MR. TUTTLE: Well, I guess for lack of 4

anybody else, I’ll comment on it. We’ve no ted that 5

there’s somewhat of a

– some vagueness in the way the 6

LM

- 80 was originally written relative to minimizing 7

the air flow, and in fact that’s one of the topics 8

that’s been discussed in quite a bit of detail within 9

the working group that’s rewriting L M

- 80 at this point 10

in time. We anticipate the new document will be 11

completed before the end of this year, and in the new 12

document, it will define exactly how to monitor the 13

air flow through the system. 14

MR. BROOKMAN: Okay. Thank you. Other 15

comments as reflected in issue box 13? Okay. 16

MS. THAKKAR: I just have a clarification 17

there. Would it also include more detail on how to or 18

where to measure the air temperature? 19

MR. TUTTLE: It defines

– it gives 20

recommendations on best practices. 21

MS. THAK KAR: Okay. Thank you. 22

MR. BROOKMAN: Thanks, Ralph. Okay. 23

MS. THAKKAR: Further operating orientation 24

during testing. DOE proposes to adopt LM

- 80 which 25Executive Court Reporters (301) 565

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states that the LED source should be oriented as 1

specified by the source manufacturer, and s paced out 2

to allow air flow around each unit. While DOE 3

proposed three specific orientations for testing the 4

LED lamp, it is not doing so for testing the LED 5

source because the case temperature is being 6

controlled during testing. Therefore, the impact of 7

orientation on the thermal effects of the LED source 8

should be minimal when testing the LED source, thus 9

minimizing the effect of orientation on lumen output. 10

DOE requests comment on the proposed 11

approach of using manufacturer guidance for the 12

operating orientation. No comments. 13

MR. BROOKMAN: Comments? No comments on 14

this one? 15

MS. THAKKAR: Moving on to the external

– 16

MR. BROOKMAN: Here’s Ralph, good. 17

MR. TUTTLE: Yeah, let me comment on this. 18

During LM

- 80 testing, our experience is that 19

ori entation of the component itself in no way affects 20

lumen depreciation of that component. 21

MR. BROOKMAN: Okay. 22

MS. THAKKAR: Thank you. So moving on to 23

the external driver. DOE proposes that the external 24

driver used for testing should be as specifie d in LM

- 25Executive Court Reporters (301) 565

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80 as well, which requires that the driver should be 1

compliant with manufacturer’s guidance. DOE request 2

comment on whether this requirement is sufficient or 3

needs further clarification. 4

MR. BROOKMAN: Ralph, I’m looking at you. 5

MR. TUTTLE: I ’m sorry, I think we’re really 6

talking about two different things here. LEDs during 7

LM

- 80 testing are driven typically at constant current 8

with laboratory power supplies, which, relative to an 9

external driver that is used in a bulb product, we’re 10

talking two different things here. The requirements 11

as far as variation in output power are extremely 12

tight when it comes to LM

- 80 testing. And my 13

experience with drivers used in bulb products is that 14

they can’t come close to maintaining the accuracy that 15

a labo ratory power supply does. 16

MS. THAKKAR: Okay. Okay. 17

MR. BROOKMAN: Yes, Keith. 18

MR. COOK: Keith Cook. This is, I think, a 19

little bit confusing because the scope said it was 20

integrated lamp, which meant that the driver was 21

included in the device. Now you’re talking about an 22

external power supply. Which is it? 23

MS. THAKKAR: To clarify that point, so it 24

is an integrated lamp, but this is for when only the 25Executive Court Reporters (301) 565

- 0064 100

source within the lamp is being tested. So it might 1

not be tested with the integrated drive r and you need 2

another power supply to run the source. 3

MR. SZOMBATFALVY: This is David from GE. 4

MR. BROOKMAN: Yes, Dave, go ahead. 5

MR. SZOMBATFALVY: Yes, this is the point 6

that Mark had brought up about maybe having a dual 7

path, that if we don’t have LM

- 80 data, that we may 8

look at another one of those scenarios that you 9

proposed, like scenario two or something like that. 10

MR. BROOKMAN: Ralph, you wish to

– Chip. 11

Chip, please. 12

MR. CHIPALKATTI: Chip Chipalkatti. Again 13

this comes back to the question of is it the component 14

or the lamp that you are looking at, and maybe there’s 15

this emerging conversation that there might be two 16

dual parts for this, if the LM

- 80 data is not there. 17

MR. BROOKMAN: I see. 18

MR. CHIPALKATTI: But you’re effective ly 19

trying to certify or qualify a product, and yet you 20

are reaching inside to only one element of that 21

overall product to test it. 22

MR. BROOKMAN: Isn’t the product typically 23

an integral lamp? 24

MR. CHIPALKATTI: Yes. 25Executive Court Reporters (301) 565

- 0064 101

MR. BROOKMAN: Typically, right. 1

MR. CHIPALKATTI: And it goes back to what 2

Mark was saying earlier. You’re going to have to 3

tear this product apart to actually test this 4

component. 5

MR. BROOKMAN: Go ahead, Mark. 6

MR. DUFFY: Yeah, of course, I agree. But 7

the

– it’s just an overall comment

– 8

MR. CHIPALKATTI: (comment off mic) 9

MR. DUFFY: Yeah, I think it is. Just an 10

overall observation. This is an awful lot of effort 11

to get at an FTC label number. So at some point we 12

need to step back and ask ourselves, what should we 13

advise the FTC in regard to their label and have that 14

conversation at some point. 15

MR. BROOKMAN: I wish FTC were in the room 16

here. 17

MR. DUFFY: It would be helpful. 18

MS. DEBUTTS: We’ll definitely take your 19

comments and we’ll see what we can do in cooperation 20

with the agency. 21

MR. BROOKMAN: Thank you. Okay. So, this 22

is very helpful. I think this is very, very helpful 23

what we’re doing here. So keep going. 24

MS. THAKKAR: Okay. For measuring the lumen 25Executive Court Reporters (301) 565

- 0064 102

output of the LED source, LM

- 80 specifies that a 1

spect roradiometer should be used. Instead, DOE is 2

proposing that any of the three methods specified in 3

LM

- 79 for the LED lamp should be used to measure the 4

lumen output of the LED source as well. These three 5

methods are the sphere

- spectroradiometer, sphere

6

ph otometer, and goniophotometer. 7

DOE requests comment on whether any of these 8

three methods can be used to measure lumen output or 9

only the spectroradiometer should be used. 10

MR. BROOKMAN: Alex. 11

MR. BOESENBERG: I have grammatical comment. 12

Just to cla rify sentence two there. Is it the same 13

thing to say that DOE is proposing that either the 14

first, the second, or the third test device might be 15

used or may be used? 16

MS. THAKKAR: Yeah

– 17

MR. BOESENBERG: Because some could read 18

that to say you have to do it all three. I’m pretty 19

sure that’s not your intent, but I want to clarify 20

that. 21

MS. THAKKAR: That is right, the intent is 22

that any one of the three methods could be used. 23

MR. BROOKMAN: Thanks for that 24

clarification. This is like legislative la nguage 25Executive Court Reporters (301) 565

- 0064 103

here. 1

MR. WALKER: This is Matthew Walker from 2

Navigant. Could anyone speak to why LM

- 80 specifies 3

one of the measurement instruments as compared to LM

4

79 where all three are included? 5

MR. BROOKMAN: Ralph, please. 6

MR. TUTTLE: Yeah. In fact I was looking at 7

this. LM

- 80 requires not only testing of lumen output 8

of the LEDs, but also chromaticity, and in fact 9

forward voltage and all of the

– many of the 10

photometric and electrical characteristics of the 11

product under test. For example, you ca n’t use 12

goniophotometer to measure color. You need a G onio

13

spectroradiometer, which is a different tool 14

completely. So, however, if all you’re measuring is 15

lumen output, then a goniophotometer can be used for 16

that purpose. So, the instrument that was de fined in 17

LM

- 80 allows us to in fact, test all of the critical 18

parameters of the LEDs during the test procedure. 19

Does that make sense? Okay. So again, if all we’re 20

interested in is how much light is coming out of the 21

LED, it’s really a relative number ov er time, and 22

there’s a variety of different instruments that can be 23

used to perform that measurement. 24

MR. BROOKMAN: Okay. Either then. Yes. It 25Executive Court Reporters (301) 565

- 0064 104

specifies either for those three, correct? Yeah. 1

MR. BOESENBERG: Alex Boesenberg, again. As 2

was previo usly stated, particularly for those people 3

who like the approach that uses LM

- 80 because they’re 4

already undergoing that testing, logically there’s no 5

reason to specify other devices, and as was already 6

stated, just stick with LM

- 80 because that’s the 7

agre ed to industry standard. 8

MR. BROOKMAN: Got you. 9

MR. BOESENBERG: Options are nice, but in 10

this case, they just complicate things. 11

MR. BROOKMAN: Matthew. We have someone? 12

MR. WALKER: Yes, we have comment from 13

Timothy R asinski regarding issue 16. “ Labs are 14

accredited for standards as written. If accreditation 15

is involved, notations will have to be made in the 16

scope and could it confuse clients expecting LM

- 80 to 17

be run as specified .” I should point out, that Tim 18

R asinski is from NVLAP

. 19

MR. BR OOKMAN: Okay. Thanks to him, that’s 20

useful. Yes. Do we have any additional comments on 21

this stream before we move on. Okay. 22

MS. THAKKAR: Moving on to lumen maintenance 23

measurement. DOE proposes that the lumen maintenance 24

should be measured as sp ecified in LM

- 80 and TM

- 21. 25Executive Court Reporters (301) 565

- 0064 105

Additionally, DOE proposes to adopt some relevant 1

guidelines from the Energy Star guidance document for 2

measuring the lumen maintenance of LED sources. These 3

guidelines specify that the CCT of all the LED sources 4

being tested must be the same. Further, the guidance 5

document provides guidelines on testing three types of 6

sources that are listed at the bottom of this slide. 7

For LED lamps that contain both phosphor converted 8

white and single color LED packages, the LED array 9

unit s that are tested should incorporate both types of 10

LED packages. For LED lamps that contain LED arrays 11

with either a common phosphor layer over all dyes, or 12

individual phosphor layers over each dye, the LED 13

array units that are tested should be the larges t LED 14

array in the lamp and the average current through each 15

dye in the LED array should be equal to or greater 16

than the average current through each dye in the lamp. 17

Finally, for LED lamps that contain an LED 18

array that is an assembly of LED packages wi th their 19

own phosphor layer, the temperature at which testing 20

is done should corresponds to the in

- situ temperature 21

of the hottest package in the array. 22

DOE requests comment on adopting these 23

guidelines from the Energy Star guidance document for 24

measurin g lumen maintenance of the LED source. 25Executive Court Reporters (301) 565

- 0064 106

MR. BROOKMAN: Ralph, please. 1

MR. TUTTLE: Sorry. Item one, about 2

phosphor converted white and single color LED 3

packages, integrated together in a lamp, is something 4

that we, in particular are having discussions with EPA 5

on right now. What this is referring to are LED 6

sources, if you will, or bulb products, which 7

incorporate both white LEDs as well as red LEDs in 8

order to reach a certain chromaticity and CRI. 9

There’s a question as to whether or not the LM

- 80 dat a 10

from individual red LEDs plus LM

- 80 data from 11

individual white LEDs is acceptable, rather than 12

putting them both together on a board and performing 13

the LM

- 80 testing on the board itself. 14

At this point in time, it’s my understanding 15

that the EPA has a ccepted our proposal that both 16

individual LED data be used. So I think it’s 17

preliminary right now until we get better definition 18

from EPA on this. 19

MR. BROOKMAN: And you’re thinking that

– 20

oh, you anticipate that what EPA is specifying here, 21

that will e volve? 22

MR. TUTTLE: Yes, absolutely. 23

MR. BROOKMAN: Okay. Is that sufficient? 24

MS. THAKKAR: Yes. Could you also please 25Executive Court Reporters (301) 565

- 0064 107

provide more information on that in your written 1

comments? 2

MR. TUTTLE: Sure. Absolutely. 3

MS. THAKKAR: Thank you. 4

MR. B ROOKMAN: Okay. Yes, please. Dave. 5

MR. SZOMBATFALVY: Clarification. What 6

about lamps or replacement lamps that have phosphor 7

that’s external to the LEDs, in other words, around 8

the lamp itself, not over the LEDs. Remote phosphors. 9

Is that covered. 10

MR. TUTTLE: I’m wondering if that’s

– it’s 11

our understanding that’s covered in item two here, 12

which is LED arrays with either a common phosphor 13

layer overall. 14

MR. BROOKMAN: Okay. Thank you. That’s 15

helpful. That’s clarifying. 16

MS. THAKKAR: Okay. So moving on. The 17

final step in the three step process is to determine 18

the rated lifetime of the LED lamp, is to project the 19

lumen maintenance data that was obtained in the 20

previous step. DOE proposes that the rated lifetime 21

should be projected as spec ified in TM

- 21. If the 22

projected rated lifetime according to TM

- 21 is greater 23

than 25,000 hours, then the rated lifetime should be 24

25,000 hours. If the projected rated lifetime 25Executive Court Reporters (301) 565

- 0064 108

according to TM

- 21 is less than 25,000 hours, then the 1

rated lifetime is the projected value. Once the rated 2

lifetime is determined by this projection method, it 3

should be calculated in number of years based on three 4

hours per day of operation as required by FTC for the 5

lighting facts label. 6

DOE proposes that the rated lifetime should 7

be rounded to the nearest tenth of a year, for 8

example, 22.8 years, which is also a requirement for 9

FTC’s label. 10

MR. BROOKMAN: Alex. 11

MR. BOESENBERG: Alex Boesenberg, NEMA. 12

This is another issue we are discussing with FTC, 10.2 13

year lifetime really isn’t something that consumers 14

necessarily might embrace, but it’s an issue we are 15

working on. 16

MR. BROOKMAN: Mark. 17

MR. DUFFY: My previous comment about 18

resolution comes in really important at this point. 19

Especially since, in the consumer mar ket , they might 20

consider that 20.2 and 20.3 are really different 21

numbers in the consumer market. So I think we have to 22

think about

– something I installed 22 years ago, I 23

may have sold that home, it might have gone with the 24

appliances, so the LED is reall y outliving many of the 25Executive Court Reporters (301) 565

- 0064 109

things that we’re

– 1

MR. BROOKMAN: Probably outlives the drapes. 2

MR. DUFFY: It outlives the drapes for sure 3

in my house. 4

MR. BROOKMAN: Thank you. Ralph. 5

MR. TUTTLE: And then again, not to beat a 6

dead horse, but in fact I ES TM

- 21 does not project 7

rated lifetime. It projects lumen maintenance. 8

MR. BROOKMAN: Okay. 9

MS. THAKKAR: Okay. 10

MR. BROOKMAN: Yes, please, John. 11

MR. GREEN: John Green, sorry. The decimal 12

point might make a difference if the lifetime is 13

shor t. I mean, 1.2 years might make sense, but not 14

22.2 years. So maybe two significant digits is the 15

way to look at it, rather than tenths of a year or 16

something like that. 17

MR. BROOKMAN: Okay. Good. Thank you. 18

MS. THAKKAR: We already heard a lot o f 19

feedback on all these issues, but at this point, if 20

there are any final thoughts or more feedback on the 21

proposed test procedure? 22

MR. BROOKMAN: Take a quick peek at 19, 20 23

and 11, and see if there’s anything else you wish to 24

contribute at this point. Julia. 25Executive Court Reporters (301) 565

- 0064 110

MS. FARBER: We’ve got a clarification 1

question on UL 1993. It is that the temperature test 2

apparatus for 1993 is considered a representative 3

severe test of thermal performance, as the can itself 4

is very narrow in diameter and allows for very l ittle 5

heat dissipation. So it’s not an overlay worst case 6

environment, but it is intended to represent the most 7

challenging of foreseeable installation applications. 8

MR. BROOKMAN: A severe case. 9

MS. FARBER: Yes, so it’s supposed to allow 10

for a wors t case scenario installation, I guess, or 11

the most severe, not the worst case. 12

MR. BROOKMAN: To test for the safety of the 13

heat. 14

MS. FARBER: Exactly. 15

MR. BROOKMAN: Okay. 16

MS. FARBER: So that it’s safe in all 17

conditions. 18

MR. BROOKMAN: Pam, please. Thank you, 19

Julia. 20

MS. HORNER: This is Pam Horner with Osram 21

Sylvania. I just

– maybe I missed it, but could you 22

please just briefly summarize why a 25,000 hour cap? 23

Thank you. 24

MS. THAKKAR: So you’re asking why a cap or 25Executive Court Reporters (301) 565

- 0064 111

why the number 25, 000? Well, the cap was put in place 1

because there’s so many unknown variables right now, 2

like we don’t know the driver lifetime, the 3

interactions of the components, and also the proposed 4

test procedure is, like you said, not doing the 5

systems approach, bu t it’s only looking at the source 6

and determining the lumen maintenance of the source, 7

so 25,000 hours is basically put in place to provide a 8

conservative estimate and not have like a 50,000 or 9

100,000 years of lumen maintenance, which is just 10

based on sou rce, when you’re actually going to

– when 11

you put this on FTC’s label, it’s going to represent 12

the life of the lamp, so 25,000 hours was put as a 13

conservative estimate to not like give

– so that 14

you’re basically not disappointing the consumer if it 15

dies be fore then. 16

MR. BROOKMAN: Keith. 17

MR. COOK: Yeah, Keith Cook. But it’s

– 18

it’s still an arbitrary number. I mean, as far as you 19

know, the driver fails at 12,000 hours. So I think 20

that you’re better off with nothing, and base it upon 21

real testing of t he system, and that’s what we’ve got 22

to work on. 23

MR. BROOKMAN: Okay. Mark. 24

MR. DUFFY: So just for the record, on your 25Executive Court Reporters (301) 565

- 0064 112

issue 11, everything about that may be okay, but UL 1

standard 1993 should not be used to determine normal 2

operating temperature. 3

M R. BROOKMAN: Normal operating temperature. 4

MR. DUFFY: Correct, because that’s what 5

you’re going to be using to project your lumen 6

maintenance. 7

MR. BROOKMAN: Yes, because that’s what 8

Julia just brought to us. Okay. Got you. 9

MS. THAKKAR: I have a follow up question to 10

that. Would you have some thought on what could be 11

used to determine the in

- situ temperature, if not UL 12

1993? 13

MR. DUFFY: Well, I may be able to 14

speculate. I think it would be helpful if I work with 15

my NEMA compatriots to give you a NEMA response to 16

that. 17

MS. THAKKAR: Okay. Sure. 18

MR. DUFFY: Did you note that, Alex? 19

MR. BOESENBERG: Yes. 20

MR. BROOKMAN: Okay, so now we’re to sample 21

size requirements. 22

MS. THAKKAR: DOE proposes that the sample 23

size requirement for testing the LED source should be 24

as specified in TM

- 21, which is necessary for the 25Executive Court Reporters (301) 565

- 0064 113

projection method outlined in TM

- 21 to be valid. At 1

least ten units should be tested at a given case 2

temperature and drive current to project the lumen 3

maintenance data. 4

DOE r equests comment on the proposed sample 5

size requirements for testing the LED sources. 6

MR. BROOKMAN: We already touched on this a 7

little. Have we addressed this, or is there more to 8

be said? Alex. 9

MR. BOESENBERG: Alex Boesenberg. The 10

previous discu ssion was about lifetime lumen 11

maintenance testing. This is a different test, hence 12

the different

– ten appears here versus 21 on the 13

previous. But what

– 14

PARTICIPANT: The 21 was about lamps, LM

- 79. 15

This is LM

- 80. This is sources. 16

MR. BOESENBERG: Yeah. So I don’t know, I 17

would ask Ralph, what does TM

- 21 say for sample size? 18

MR. BROOKMAN: Ralph, please. 19

MR. TUTTLE: Actually TM

- 21 recommends a 20

minimum of 20 LEDs to be used during LM

- 80 testing to 21

allow projections of long term lumen maintena nce. We 22

did allow fewer units to be used, but then reduced the 23

maximum number of hours that could be projected with 24

the fewer units. But for a minimum of actually 35,000 25Executive Court Reporters (301) 565

- 0064 114

hours, we recommend 20 LEDs. 1

MR. BROOKMAN: Okay. Do we have additional 2

comments on this point? I see none. Okay. 3

MS. THAKKAR: Okay. The next topic is the 4

estimated burden to small businesses. DOE is required 5

to analyze the testing burden to small businesses once 6

this rulemaking is established. Do you have a 7

question? 8

MR. C OOK: Yeah, I do have a question. 9

MR. BROOKMAN: Keith, please. 10

MR. COOK: I’m sorry, Keith Cook. 11

Repeatedly, it seems like the question is whether or 12

not we should make changes to an already approved 13

standard, and I’m really concerned that if we fo llow 14

that path, it’s going to lead to a lot of confusion 15

out there, as to which test I’m running and which data 16

needs to be supplied to who. I think we need to be 17

consistent and stay with something that’s already been 18

approved. 19

MR. BROOKMAN: Okay. Tha nks for that 20

comment. Got it. Now to burden on small businesses. 21

MS. THAKKAR: So DOE is required to analyze 22

the testing burden to small businesses once this 23

rulemaking is established, and if it is adopted by FTC 24

for the lighting facts label. To deter mine this 25Executive Court Reporters (301) 565

- 0064 115

burden, DOE estimated the number of small businesses 1

that manufacture LED lamps in the United States, and 2

estimated the cost burden to these manufacturers. DOE 3

estimated that of the 32 manufacturers of LED lamps in 4

the US, about 17 manufacturers are small businesses. 5

Further, DOE estimated that these small manufacturers 6

produce about 17 basic models of LED lamps each. For 7

these 17 models, DOE estimates a one

- time setup cost 8

of $12,000 to build racks to test the LED lamp. The 9

cost to test these lamps will be approximately $68,000 10

for determining input power, lumen output, CCT, and 11

rated lifetime for the first year. The cost for 12

subsequent years should be less than $68,000 because 13

only new products or redesigned products would be 14

tested. 15

Fin ally, in its light bulb rulemaking, FTC 16

determined that the cost for changing package and 17

product labeling, as well as the cost for updating 18

retail catalogues would not impose a significant 19

burden on small entities. Because the values would 20

potentially ne ed updating, only for LED lamps, DOE 21

does not expect this to be a significant burden 22

either. 23

DOE requests comment on the estimated number 24

of small businesses impacted by this rulemaking, as 25Executive Court Reporters (301) 565

- 0064 116

well as the estimated costs and associated burden to 1

small busin esses by this rulemaking once it is adopted 2

by FTC. 3

MR. BROOKMAN: Mark. 4

MR. DUFFY: Yeah, this is Mark Duffy. Well, 5

I don’t work for one of those small manufacturers. 6

I’m a little concerned by the assumption that they 7

would want to setup an accredit ed laboratory to do 8

this. I suspect that most of those small 9

manufacturers are going to be sending their product 10

out for a third party test and receiving certification 11

of compliance or whatever, to use for their labels. 12

MR. BROOKMAN: Would that mean th e cost 13

would be higher? 14

MR. DUFFY: I don’t know. 15

MR. BROOKMAN: Keith. 16

MR. COOK: I guess I’m not sure where we’re 17

going with this particular question. If we show undue 18

burden to the small manufacturers, does that mean they 19

don’t have to comply wit h FTC requirements? 20

MR. BROOKMAN: No. 21

MR. COOK: Then this is an academic 22

question. I don’t understand why we’re even asking 23

it. 24

MR. BROOKMAN: John. Excuse me. Dave, go 25Executive Court Reporters (301) 565

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ahead. 1

MR. SZOMBATFALVY: Yeah, I’m not

– you had 2

mentioned that this

– th e cost was associated with the 3

test procedures for input power, lumen, and output

– 4

lumen output and CCT. But what about the cost if we 5

have to execute the test procedure for rated life. I 6

think that’s a significant cost to a manufacturer, 7

even like GE, if we need to do that. 8

MR. BROOKMAN: I guess

– go ahead. 9

MS. THAKKAR: To clarify, the $68,000 that’s 10

put there includes the rated lifetime as proposed as 11

well. The assumption there being that the in

- situ 12

temperature measurement test is performed by the 13

manufacturer, but LM

- 80 data is typically available, 14

so you may not have to test the source itself. 15

MR. BROOKMAN: Yes, go ahead, please. 16

MR. SZOMBATFALVY: Yes, I was going down the 17

path when we don’t have LM

- 80 data, so there is a 18

significant cos t if we don’t have the LM

- 80 data to do 19

that testing that’s proposed. 20

MR. BROOKMAN: Okay. Thanks, Dave. Yes, 21

Chip. 22

MR. CHIPALKATTI: Chip Chipalkatti. I’m 23

just asking about the number 17, the magic number 17. 24

I think that there’s evident and not s o evident small 25Executive Court Reporters (301) 565

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companies that are present today in this field. 1

Though I’m not working for a small company, I do have 2

contact with a lot of them, and I think that might be 3

an underestimate of how many small companies there 4

are. 5

MR. BROOKMAN: Underestim ate? 6

MR. CHIPALKATTI: Yes. 7

MR. BROOKMAN: Could you speculate? Twice 8

as many? Ten times as many? 9

MR. CHIPALKATTI: Twice, heading towards ten 10

times. 11

PARTICIPANT: Are you talking about just US 12

manufacturers? 13

MS. THAKKAR: Just the US? 14

MR. CH IPALKATTI: Yes, US. And that’s a 15

speculation, because a lot of these companies are 16

under the radar, if you will, what you call operating 17

in stealth mode, and so on, so trying to get into the 18

market. And I don’t know if that’s a concern at all, 19

but if th e underlying reason for this question is the 20

impact on innovation and new companies and all of 21

that, then that should be a matter for further study. 22

MR. BROOKMAN: Okay. I saw both Pekka and 23

Alex. I think Pekka was first. 24

MR. HAKKARAINEN : Pekka Hakk arainen . I 25Executive Court Reporters (301) 565

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wanted to ask our friend Julia, is it from UL, whether 1

this cost estimate is reasonable for third party 2

testing? 3

MR. BROOKMAN: Julia. 4

MS. FARBER: I’ll have to get back to you. 5

MR. BROOKMAN: Alex, please. 6

MR. BOESENBERG: Alex Boesen berg, NEMA. 7

Relative to the number of small businesses, I would 8

ask, since he’s not here I can’t ask him, did your 9

offices ask Jim Brodrick , because he is in direct 10

contact with hundreds of companies, some of which will 11

be small. 12

MR. BROOKMAN: Austin, did you have a 13

comment? 14

MR. GELDER: Yeah, Austin Gelder. ICF 15

International. I was wondering where the $12,000 16

estimate came for initial setup, because if you’re 17

talking about all of the measurement devices to 18

measure things such as CCT, lumens, power, plus all of 19

the racks, I could see one piece of equipment costing 20

$10,000 to set this up for some of these

– some of 21

these small manufacturers who maybe all they’re making 22

is they came out and they started making LED lamps. 23

They may not have the lab alre ady in place, so their 24

cost to set up a lab could be a huge multiple of that. 25Executive Court Reporters (301) 565

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MR. BROOKMAN: Would you

– could you provide 1

a range? What do you think to have it, to actually 2

set up a lab, the initial set up, what would it be? 3

MR. GELDER: Oh, you coul d easily get over 4

$100,000, between the facilities and all of the 5

additional equipment and the cost to have someone 6

trained to run that equipment, because

– in addition, 7

I’m pretty sure we’ve talked about getting accredited, 8

and that in and of itself ends up being a very 9

expensive process, both from the accreditation 10

standpoint, as well as getting the quality management 11

system in place from a labor perspective. 12

MR. BROOKMAN: I see. Ralph. 13

MR. TUTTLE: A type C goniometer, you’re 14

probably talking about $200,000. A one meter 15

integrating sphere with the associated equipment is 16

easily $ 100 ,000. So maybe building racks would cost 17

$12,000, but that’s about it. 18

MR. HAKKARAINEN : Pekka Hakkarainen . Am I 19

understanding correctly that small business is defin ed 20

as company that has fewer than 500 people, is that the 21

definition? 22

MS. THAKKAR: It’s

– for electric lamps, 23

it’s actually fewer than 1000 employees. Electric 24

lamp manufacturers. 25Executive Court Reporters (301) 565

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MR. BROOKMAN: Oh. Yesterday in the 1

appliance standard proceeding yes terday, I’m pretty 2

sure the slide said SBA says under 500. That’s my 3

recollection. 4

MS. KOHL: This is Betsy Kohl. It depends 5

on the industry. The SBA has a table of size 6

standards based on your industry code, and it’s up on 7

their website if you’re int erested in looking at it, 8

but that’s where we get them from. 9

MR. BROOKMAN: Thank you. The source. 10

Useful. Okay. So thank you. That was also 11

illuminating, that information there. Yes. Are there 12

other follow on questions that you have? 13

MS. THAKKA R: No. I was going to hand it 14

over to Lucy deButts for

– 15

MR. WALKER: We do have one more

– sorry, 16

this is Matthew Walker, Navigant. We do have one more 17

comment from the webinar, webinar participant. Joel 18

Jacobson, “ the number of models introduced i nto the 19

market are increasing rapidly, so cost estimates are 20

significantly underestimated. ” 21

MR. BROOKMAN: Okay. 22

MR. WALKER: Then we have, regarding set up 23

cost for testing, from Jacki Sw i ernik. 24

“ Goniophotometer, $200,000 minimum. Two meter 25Executive Court Reporters (301) 565

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integr ating sphere with accessories, $60,000 average. ” 1

And that’s all from the webinar. 2

MR. BROOKMAN: Thank you. So at the outset, 3

we promised you another opportunity to make comments 4

at the end of the meeting. We’ve arrived at the end 5

of these presentatio n slides and the discussion. 6

Any closing remarks before I turn it back to Lucy? 7

Nothing here in closing. Okay, back to Lucy. 8

**Closing Remarks** 9

MS. DEBUTTS: Well, I hope nobody minds that 10

I’m talking, sitting here and not standing there. 11

Okay. So I j ust wanted to thank everyone. This 12

actually was very good, productive, and helpful. And 13

to make sure that everybody understands how to reach 14

us, you know, and submit the written comments, the 15

slide represents all the information that you need to 16

have. S everal avenues are explained, you know. Of 17

course, we prefer the electronic method, as usual, 18

however if it’s not possible, postal service or 19

courier can be used. And Brenda Edwards, our public 20

meeting coordinator would be taken care of

– she’s 21

out there somewhere

– she will be taking care of the 22

comments and

– as they come in. We will address them 23

and review them and come back to you if we have 24

additional questions. So hopefully, it’s okay for us 25Executive Court Reporters (301) 565

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to seek some clarification. 1

A gain , comment period ends on June 25 th , but 2

to address the previous concerns, if the comments 3

that we receive state that DOE needs to give more 4

time to developing the test procedure as Betsy Kohl 5

stated, there are avenues of doing that as well. 6

So just want to thank everyone for coming 7

and see if any other questions are there in the room. 8

Back to Doug. 9

MR. BROOKMAN: Thanks to all of you. Safe 10

travels. 11

(Whereupon, (end time not specified) , the 12

meeting in the above captioned matter was adjourned.) 13

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25Executive Court Reporters (301) 565

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**REPORTER 'S CERTIFICATE** 

This is to certify that the attached proceedings

before:

**U.S. DEPARTMENT OF ENERGY**

In the Matter of:

**PUBLIC MEETING**  **ON TEST PROCEDURE NOTICE OF PROPOSED RULEMAKING FOR LIGHT** 

**- EMITTING**  **DIODE LAMPS**

Were held as herein appears an d that this is the

original transcript thereof for the file of the

Department, Commission, Board, Administrative Law Judge

or the Agency.

Further, I am neither counsel for or related to any

party to the above proceedings.



### Wendy Greene

Official Reporter

Dated: April 9, 2012