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 8E-089 Review Center

Thursday

May 3, 2012

Facilitator:

Doug Brookman

Public Solutions

Baltimore, MD
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In-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 Association (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.
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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 Menendez

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 Carolina
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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

ACEEE

Washington, D.C.

Joel Jacobson

Feit Electric Company, Inc.

Pico Rivera, California

Michael McGaraghan

Energy Solutions

Oakland, California

Rebecca Rainer

Cooper Lighting

Vicksburg, Mississippi

Sandeep Sood

Litetronics International

Alsip, Illinois 

Jackie Swiernik

Intertek

Cortland, New York
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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 Wold

CLASP

Washington, D.C.

Greg Murphy

MaxLite

West Caldwell, New Jersey

Rui Li

Lumentra

Toronto, Canada
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Pierrette LeBlanc

Natural Resources Canada

Ottawa, Canada

Jason Tuenge

PNNL

Portland, Oregon

Luke Mason

Ecova

Durango, Colorado

Joe Zamore

Ledsource

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.
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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.
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AGENDA

 ITEM PAGE

Welcome, Doug Brookman 5

Welcome for DOE, Ms. deButts 5

Introductions 6

Agenda Review, Doug Brookman 7

Meeting overview, Ms. deButts 9

Rulemaking Process and Scope, 

Ms. deButts 15

Test Procedures for Input Power, Lumen

Output, and CCT, Ms. Thakkar 20

Test Procedure for Rated Lifetime

Ms. Thakkar 55

Closing Remarks, Ms. deButts 118
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1 P R O C E E D I N G S

2 MR. BROOKMAN: Good morning everyone and 

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

4 public meeting on the Test Procedure, Notice of 

5 Proposed Rulemaking, for Light-Emitting Diode Lamps. 

6 Today is Thursday, May 3rd, here at the

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

8 Doug Brookman from Public Solutions in Baltimore. So 

9 glad to see you this morning. We’re going to start 

10 off this morning with welcoming remarks from Lucy 

11 deButts.

12 Welcoming Remarks

13 MS. DEBUTTS: Good morning, everyone. My 

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

15 lighting team project manager. And today our primary 

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

17 open the dialogue between the industry and DOE in 

18 developing this rulemaking. We are looking forward to 

19 your input and your cooperation in developing this 

20 rule.

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

22 to Doug Brookman, our experienced facilitator, for 

23 some ground rules and going over the agenda.

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

25 introductions first, though, as our tradition. Please 
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1 say your name and organizational affiliation. You can 

2 also get used to turning on these microphones, and 

3 getting them fairly close.

4 Introductions

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

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

7 MR. BROOKMAN: Thank you. 

8 MR. CHIPALKATTI: Good morning. I am Chips 

9 Chipalkatti from Osram Sylvania in Danvers, 

10 Massachusetts.

11 MR. SZOMBATFALVY: Hi everyone. This is 

12 Dave Szombatfalvy from GE Lighting located in 

13 Cleveland, Ohio.

14 MR. GREEN: John Green with Cooper Lighting 

15 in Georgia.

16 MR. COOK: Keith Cook with Philips Lighting, 

17 here in D.C.

18 MR. BROOKMAN: I like that people are saying 

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

20 MS. BURNS: Jennifer Burns, Philips 

21 Lighting, here in D.C.

22 MR. BOESENBERG: Alex Boesenberg, National 

23 Electrical Manufacturers Association, D.C.

24 MR. HAKKARAINEN: Pekka Hakkarainen with 

25 Lutron Electronics, Coopersburg, Pennsylvania, also 
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1 chairing the NEMA Lighting Systems Division this year.

2 MS. HORNER: Pam Horner with Osram Sylvania 

3 out of Danvers, Massachusetts.

4 MR. GELDER: Austin Gelder with ICF 

5 International out of Washington, D.C.

6 MR. CHRISTENSEN: Adam Christensen with 

7 Appliance Standards Awareness Project here in D.C.

8 MR. DUFFY: Mark Duffy with GE Lighting out 

9 of Cleveland, Ohio.

10 MS. THAKKAR: This is Mansi Thakkar with 

11 Navigant Consulting out of D.C.

12 MR. WALKER: Matthew Walker with Navigant, 

13 D.C.

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

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

16 Everybody get a chance – one person did not get a 

17 chance to introduce himself.

18 MR. BRODRICK: Jim Brodrick, DOE, Solid 

19 State Lighting.

20 MR. BROOKMAN: We were just talking about 

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

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

23 business card to Brenda Edwards. 

24 Agenda Review

25 MR. BROOKMAN: Included in the packet was 
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1 the agenda, which I’m going to run through very 

2 quickly. Immediately following this agenda review and 

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

4 make opening statements, to raise issues that are 

5 important to you at this stage in the rulemaking 

6 procedure. 

7 Following that, we will dive straight into 

8 the content. You can see it listed there -- test 

9 procedure for input power, lumen output, and 

10 correlated color temperature, CCT.

11 We’ll take a break mid-morning, round about 

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

13 rated lifetime and then questions and closing remarks. 

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

15 there’s yet another opportunity to make comments that 

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

17 opportunity, not only to comment on the detailed 

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

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

20 you came here to say. 

21 I’d ask for your consideration. Please, if 

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

23 you speak, say your name for the record. There will 

24 be a complete transcript of this meeting posted on the 

25 DOE website. I’m going to be cueing individuals by 
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1 name as best I can. I also wish to encourage follow 

2 on comments. Sometimes the back and forth between 

3 individuals is very helpful to the Department as they 

4 try and interpret what you’re saying.

5 If you can keep the focus here. Please turn 

6 your cell phones on silent. And limit sidebar 

7 conversations. You all have gotten used to using 

8 these microphones now. They work better than they 

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

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

11 be good for all of us. 

12 Questions or comments here at the outset 

13 before I turn it back to Lucy? I see none. Lucy. 

14 Overview

15 MS. DEBUTTS: All right, so Doug already 

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

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

18 internet and those stakeholders that cannot attend in 

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

20 along. The webinar’s participants, unfortunately, 

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

22 limitations. The microphones are better but the 

23 system is not necessarily working all the time, 

24 unfortunately. However, they can use the chat or 

25 questions feature on the webinar software to patch in 
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1 their questions or remarks, and the webinar 

2 facilitator will be reviewing them with the help of 

3 the Navigant consultant, and if there are any 

4 questions that we want to address, we will definitely 

5 read them and address them in the room.

6 All those questions are going to be made 

7 part of the transcript today and will be published on 

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

9 will try to address all of the questions that we 

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

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

12 possible.

13 We understand that the complicating 

14 technology of solid state lighting so we are looking 

15 for you to assist us in developing this rulemaking. 

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

17 the transcript is going to be made available as soon 

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

19 However the presentation and the Notice itself are

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

21 available to everyone.

22 So, as I stated earlier, the purposes of 

23 this lighting meeting is to present the LED lamps test 

24 procedure and begin the conversation with the 

25 industry. Mansi Thakkar with Navigant Consulting will 
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1 help DOE in presenting part of the test procedure. We 

2 will discuss the rulemaking itself and the information 

3 collection for the next step of the rulemaking. And 

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

5 necessarily just those that will be addressed during 

6 the presentation. Obviously, there are other issues 

7 and please help us in discussing everything that you 

8 feel that should be addressed.

9 If you disagree with DOE’s approach, we 

10 would really appreciate the alternative solutions that 

11 you may provide to us. 

12 So as for the issue boxes, you will see 

13 issue boxes like these throughout the presentations. 

14 These boxes highlight specific issues that would like 

15 to be addressed. The item numbers in these boxes are 

16 not necessarily in numerical order throughout the 

17 presentation, however, we arranged them in a way that 

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

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

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

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

22 present. 

23 As far as the deadline for comment period 

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

25 will appreciate all your written comments to be
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1 submitted by that date. And at this time, I would 

2 like to invite opening remarks.

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

4 opening statements from anybody that wishes to do so. 

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

6 microphone, turn it on, say your name and 

7 organizational affiliation.

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

9 and Johnson, representing Acuity Brands Lighting.

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

11 start with opening remarks, brief summary statements 

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

13 Opening Remarks

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

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

16 Tuttle. CREE just wants to thank the Department of 

17 Energy for the opportunity to work with you all on 

18 this rulemaking. We have a long history of working 

19 with the Department of Energy and also working with 

20 our associates in the lighting industry and I think we 

21 can pretty quickly come to agreement on how to 

22 proceed. 

23 Other than that, I will hold any comments 

24 until we go through each of the issues individually. 

25 Jim Brodrick, it’s good to see you again.
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1 MR. BRODRICK: Thanks.

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

3 it, and we like it. Go ahead.

4 MR. BOESENBERG: I’m Alex Boesenberg with 

5 the National Electrical Manufacturers Association. 

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

7 thank the Department and the meeting room facilitators 

8 here and everybody for this opportunity. As is often 

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

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

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

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

13 finalize our comments and get those submitted.

14 The issue of lumen maintenance is one of 

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

16 that point in the discussion and slides today.

17 I have already briefly discussed with Lucy, 

18 and I will follow up with the Department, a concern we 

19 have for solid state lighting as it relates to 

20 actually yesterday’s external power supplies [EPS] 

21 rulemaking. Lighting is historically its own animal, 

22 and basically want to keep it that way for several 

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

24 that and look forward to future discussions.

25 And lastly, as it states in the NOPR, this 
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1 ruling is for the DOE to help the FTC with their 

2 labeling program, and obviously we agree with that and 

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

4 have to – my members are the ones who have to follow 

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

6 makes sense. We would caution the Department against, 

7 by force of habit, instituting a performance standards 

8 rulemaking for LED lamps immediately following this 

9 test procedures rule, because solid state is an 

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

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

12 that’s still the sentiment. I think if you – well, no 

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

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

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

16 that they had no actual solid state lighting power 

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

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

19 that shows the Department has already tried, in 

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

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

22 mature product line, definitely, because products are 

23 changing every several months. And that illustrates, 

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

25 statement that we’re not ready to regulate the 
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1 performance of those products just yet.

2 If the Department is concerned about poor 

3 performance and protecting consumers from 

4 opportunistic products, NEMA has undertaken a standard 

5 and has published a standard for minimum performance 

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

7 Department, we’re happy to share that standard with 

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

9 and goals of that standard are. Thank you.

10 MR. BROOKMAN: Thank you. Additional 

11 comments here at the outset? Nothing additional. 

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

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

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

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

16 process and the scope of this rulemaking.

17 Rulemaking Process and Scope 

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

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

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

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

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

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

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

25 comments that we receive. And currently, we plan to 
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1 publish the final rule for the test procedure by 

2 November of this year.

3 The scope of this rulemaking. So this 

4 rulemaking is applicable to LED lamps that fall within 

5 DOE’s proposed definition of LED lamp. This 

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

7 based on the term integrated LED lamp as defined by 

8 the ANSI standard, RP-16-2010. The LED source is a 

9 lighting producing component within the LED lamp. LED 

10 lamp is intended to connect directly to the brain 

11 circuit through a corresponding ANSI circuit, and 

12 these integrated lamps comprise of LED source, which 

13 could be LED component or LED module. LED driver and 

14 ANSI standard base and other optical, thermal, 

15 mechanical or electrical components such as phosphor

16 layers, insulation materials, fasteners to hold 

17 components within the lamp together, and electrical 

18 wiring.

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

20 your comments on both, proposed scope and the 

21 definition of LED lamp.

22 MR. BROOKMAN: Pekka.

23 MR. HAKKARAINEN: Pekka Hakkarainen. Just 

24 on the previous slide you said that the final rule 

25 will be published in November. When would be the
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1 effective date? Immediately or at some future time?

2 MS. DEBUTTS: It’s going to be – well, the 

3 effective date is going to be the publication date, 

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

5 MR. HAKKARAINEN: Normally, I think we are 

6 used to having a three year period before effective 

7 date is set.

8 MS. DEBUTTS: With the compliance date 

9 you’re talking about.

10 MR. HAKKARAINEN: Yes, with the compliance.

11 MS. DEBUTTS: Right.

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

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

14 one? I don’t have the --

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

16 compliance date will actually be dependent on when FTC 

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

18 FTC will have to adopt this rule and state that 

19 stakeholders have to use this test procedure to test 

20 LED lamps.

21 MR. BROOKMAN: And do you anticipate some 

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

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

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

25 timeline would be, but –
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1 MR. HAKKARAINEN: So how is the effective 

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

3 for determining that?

4 MS. THAKKAR: Well, when FTC – when DOE 

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

6 for the labeling requirements. They need to adopt 

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

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

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

10 cooperate with FTC and see what their plan is. 

11 Unfortunately, I cannot answer that question right now 

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

13 time between the issuance and the adoption.

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

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

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

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

18 MR. BROOKMAN: Okay. Keith.

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

20 little concerned about the scope. I thought that the 

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

22 The FTC labeling right now is dedicated to consumer, 

23 which is a much narrower marker than the RP-16

24 definition of integrated LED lamps. Does this mean 

25 that the scope is beyond what the FTC labeling 
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1 requirements.

2 MR. WALKER: Matthew Walker, Navigant. The 

3 idea is that this test procedure scope is established 

4 broadly to match what’s in the ANSI RP-16, but then 

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

6 would establish a – their own scope of applicability 

7 for their own labeling requirements. So rather than 

8 DOE anticipate what FTC would need for their scope, 

9 the idea is to let FTC make that determination when 

10 they adopt the test method.

11 MR. BROOKMAN: Matthew, do you anticipate 

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

13 you know what they’re thinking?

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

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

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

17 definition of general service LED lamp is to have an 

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

19 MR. BROOKMAN: So the question is on the 

20 scope and definition of LED lamps. Comments? 

21 Additional comments on that? Nothing additional. 

22 Okay. 

23 MS. DEBUTTS: Well, without further ado, 

24 Mansi Thakkar with Navigant will start on the test 

25 procedure part.
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1

2 Test Procedure for Determining Input Power, 

3 Lumen Output and CCT

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

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

6 be presenting the next two sections that discuss the 

7 test procedure for determining input power, lumen 

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

9 determining the rated lifetime of LED lamps.

10 Starting with the test procedure for 

11 determining lumen output, input power and CCT, DOE 

12 proposes that LM-79 should be adopted, but has 

13 included some modifications or additional information 

14 to clarify the test conditions and setup. DOE 

15 reviewed available industry standards and spoke with 

16 several industry experts and determined that LM-79 was 

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

18 method referenced by Energy Star in the integral LED 

19 lamp specification for testing LED lamps for Energy 

20 Star qualification.

21 FTC light bulb labeling rule also recommends 

22 to use LM-79 for representations on the lighting facts 

23 label.

24 Finally, LM-79 is the standard required by 

25 DOE’s lighting facts program for voluntary 
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1 participation in the program. 

2 Based on this review, DOE determined that 

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

4 lumen output, and CCT.

5 LM-79 specifies the test setup, test 

6 conditions, measurement instruments, as well as the 

7 method of taking measurements for LED lamps. Of these 

8 specifications, the items listed on this slide have 

9 been adopted exactly as specified.

10 MR. BROOKMAN: Slow down a little bit.

11 MS. THAKKAR: Okay. Sorry. DOE now 

12 requests comment on the proposed incorporation of LM13 79 to determine lumen output, input power, and CCT, 

14 and specifically these conditions that are being 

15 adopted exactly as specified.

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

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

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

19 Pekka.

20 MR. HAKKARAINEN: Generally speaking, I 

21 think that the industry is in agreement with this.

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

23 have any more specific comments? Nothing additional. 

24 Okay. 

25 MR. WALKER: This is Matthew Walker, 
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1 Navigant. We did have another comment from the 

2 webinar that refers back to the first issue. The 

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

4 within the definition of integral LED lamp, examples 

5 being PAR, R, medium, mogul, candelabra, pin bases?” 

6 I think our response is the definition in RP-16 would 

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

8 to the point that I made earlier that FTC would 

9 redefine the scope of their labeling rule at the time 

10 of adoption of this test method.

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

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

13 questions.

14 MR. WALKER: Michael McGaraghan.

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

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

17 questions from those joining us via the internet. So 

18 you may proceed.

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

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

21 mentioned on the previous slide, the air movement 

22 requirement is being adopted without any modification 

23 from LM-79, which states that the air flow during 

24 testing LED lamp should be such that the normal 

25 convective air flow induced by the lamp is not 
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1 affected. While this requirement is proposed in the 

2 NOPR, DOE considered whether additional specifications 

3 should be provided to determine air movement. For 

4 example, IES LM-9-2009, which is the standard for 

5 determining the electrical and photometric 

6 characteristics for fluorescent lamps, provides a test 

7 to determine that the environment is draft-free. It 

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

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

10 is indeed draft-free.

11 DOE requests comment about whether the LM-79 

12 specification is sufficient or whether more 

13 information should be provided to determine the air 

14 movement.

15 MR. BROOKMAN: Keith.

16 MR. COOK: This is case of let’s not over17 specify. We don’t have to. This test, as silly as it 

18 sounds, has been an accepted industry practice 

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

20 continue with it.

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

22 additional comments? Chip?

23 MR. CHIPALKATTI: This is Chip Chipalkatti. 

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

25 over-specify because there might be cases where 
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1 there’s active cooling fans, and that can affect the 

2 whole air flow situation.

3 MR. BROOKMAN: Okay. 

4 MR. WALKER: Matthew Walker, Navigant. Just 

5 to be clear, your over-specify – don’t over-specify, 

6 stay with LM-79 specifications? Don’t add LM-9 

7 specifications?

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

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

10 saying no.

11 MR. WALKER: Okay. Just clarifying.

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

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

14 to lamp orientation. DOE is not proposing LM-79 

15 specification for lamp orientation. DOE understands 

16 that while the light emission process of an LED source 

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

18 thermal conditions for the LED sources could be 

19 affected by orientation, which in turn would affect 

20 the light output. Given this impact of orientation on 

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

22 is important to test the lamps in specific 

23 orientations. However, LM-79 does not specify an 

24 orientation, and instead states that the lamp should 

25 be tested in the orientation recommended by the 
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1 manufacturer for the intended use of the lamp.

2 DOE is not proposing this requirement 

3 because on reviewing manufacturer catalogs, DOE has 

4 learned that the operating orientation is usually not 

5 specified by the manufacturer. Therefore, DOE is 

6 proposing that an equal number of lamps should be 

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

8 orientations. 

9 In issue 4, DOE requests comment on the 

10 proposed lamp orientation requirements.

11 MR. SZOMBATFALVY: This is David from GE. 

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

13 enough with respect to understanding what the lamp’s 

14 capabilities are, because in between you’re going to 

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

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

17 going to have additional uncertainty in the 

18 measurement values between the goniometer and the 

19 sphere in the horizontal position.

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

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

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

23 HID is absolutely dependent upon the orientation, but 

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

25 think we’re again over-specifying if we go to three 
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1 position testing.

2 MR. BROOKMAN: Thank you. Additional 

3 comments? Okay. 

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

5 electrical settings requirement, and there are two 

6 issues to discuss here. The first issue is input 

7 characteristics. DOE proposes that the LED lamp 

8 should be operated at the rated voltage during 

9 testing, as specified in LM-79. Further, for lamps 

10 with multiple operating voltages, DOE proposes that 

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

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

13 120 volts was selected because it is the 

14 most common operating voltage of available lamps, and 

15 especially if the lamps that are in FTC current 

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

17 lamp should be operated at the maximum input power as 

18 specified in LM-79. 

19 The second issue for discussion under 

20 electrical settings is lamps with multiple modes of 

21 operation. LM-79 specifies that if a lamp has 

22 multiple modes of operation, such as variable CCT, it 

23 should be tested at the different modes. In its 

24 research of manufacturer catalogs, DOE did not come 

25 across any lamps that functioned at multiple modes of 
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1 CCT, and requests more information about these 

2 products.

3 In issue 5, DOE requests comment on the 

4 voltage and dimming requirements as well as the 

5 availability of lamps that operate at multiple modes 

6 of operation.

7 MR. BROOKMAN: Chip.

8 MR. CHIPALKATTI: Chip Chipalkatti. I’m 

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

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

11 it’s possible to go to?

12 MS. THAKKAR: I think the way LM-79 

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

14 two or maybe more different CCTs.

15 MR. BROOKMAN: So multiple modes means 

16 different CCTs?

17 MS. THAKKAR: Yes.

18 MR. BROOKMAN: Keith.

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

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

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

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

23 identify a market need that creates the product. But 

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

25 development, and so that’s, I think, the sole intent 
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1 behind it.

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

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

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

5 operate on?

6 MR. COOK: Again, it depends upon the 

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

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

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

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

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

12 multiple.

13 MS. THAKKAR: Okay. 

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

15 here?

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

17 There is a very distinct possibility that this would 

18 be a continuously variable CCT. So to say something 

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

20 thing.

21 MS. THAKKAR: Right.

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

23 MR. CHIPALKATTI: Yeah, that was exactly the 

24 reason for my question. Because it’s foreseeable that 

25 there’ll be lamps at variable CCTs, continuously 
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1 variable, variable CRIs, variable lumen outputs and so 

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

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

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

5 looking for the most extreme of these conditions as 

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

7 be –

8 MR. BROOKMAN: Should they specify it as the 

9 lowest efficacy, or should they say something else?

10 MR. COOK: This is probably something we 

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

12 permutations. Testing at the worst possible efficacy 

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

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

15 back.

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

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

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

19 wish to cue? 

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

21 there are any other comments on the voltage or dimming 

22 requirements?

23 MR. BROOKMAN: I’m just scanning through 

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

25 Okay. So then, with no objection, then, we’ll move 
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1 on. Yes.

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

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

4 proposing LM-79 specification. LM-79 does not require 

5 the lamp to be seasoned prior to stabilizing the lamp 

6 and recording measurements. However, industry has 

7 observed a hump during the first 1000 hours of 

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

9 right. If the lamp is not seasoned prior to 

10 measurements, then depending on the time required for 

11 lamp stabilization, it is possible that the lumen 

12 output determined through testing, may be higher than 

13 the actual lumen output of the lamp.

14 Therefore, DOE proposes that the lamp should 

15 be seasoned for 1000 hours prior to stabilization and 

16 lumen output measurement. DOE requests comment as 

17 well as any available data on seasoning the LED lamp 

18 for 1000 hours before measuring lumen output.

19 MR. BROOKMAN: Ralph.

20 MR. TUTTLE: Thank you. Ralph Tuttle with 

21 CREE. When we initially developed LM-79, we discussed 

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

23 shown on the right is a CREE LED – I provided that 

24 information to Eric. Not all LEDs exhibit this 

25 increase in lumen output during the first 1000 hours 
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1 of operation. I was also the chairman of the TM-21 

2 committee, and during the development of TM-21, we had 

3 the opportunity to look at the LED behavior of 

4 products from all the major LED manufacturers. While 

5 in fact, there were some that exhibited this 

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

7 the first few hundred hours, dropped significantly. 

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

9 include seasoning in the testing of these products.

10 MR. BROOKMAN: In any form?

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

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

13 put it into your goniometer and you perform the 

14 measurement.

15 MR. BROOKMAN: You do the test. Okay. 

16 Other comments or recommendations for the Department 

17 with respect to seasoning? Keith?

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

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

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

21 the Pacific Northwest National Laboratories has 

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

23 hours that it went up.

24 MR. BROOKMAN: Which then caused that lamp 

25 to be, quote, “seasoned”?
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1 MR. COOK: It then leveled off. But it 

2 increased for 3000 hours, so, you know, where do you 

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

4 MR. BROOKMAN: Okay. So you agree with 

5 Ralph?

6 MR. COOK: Yes.

7 MR. BOESENBERG: This is Alex Boesenberg, 

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

9 submit that this is the hazard of a regulation that 

10 restricts innovation. LED designs, formulas, are 

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

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

13 after several thousand hours. And remember that, you 

14 know, the way we usually figure 1000 hours is three 

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

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

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

18 MR. CHRISTENSEN: This is Adam with ASAP. 

19 Just more of a curiosity question than anything. Is 

20 there a technical hypothesis about why light increases 

21 in the beginning, or decreases in some cases?

22 MR. BROOKMAN: Ralph?

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

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

25 as well as the lamp itself. Typically, the behavior 
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1 that you can see in this graph is due to the fact that 

2 during the construction of the LED chip and the growth 

3 of the multi-quantum layers, not all of the dopant 

4 atoms that are incorporated in the crystal structure 

5 occupy an electrically active site. Rather than being 

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

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

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

9 crystal to a substitutional site, become electrically 

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

11 output of the chip itself.

12 Conversely, when you’re talking about sudden 

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

14 the encapsulants that are used, and changes that occur 

15 in those encapsulants as they’re first heated up.

16 So it really depends from one manufacturer 

17 to the next on how they construct both the component 

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

19 that’s kind of a –

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

21 primer.

22 MR. CHRISTENSEN: That was perfect. Thanks.

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

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

25 NEMA will submit detailed comments on this point.
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1 MR. BOESENBERG: We’ll do our best on that 

2 one.

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

4 will. Okay. 

5 MS. THAKKAR: Okay. Moving on to lamp 

6 stabilization. This is an area where DOE is adopting 

7 the specification in LM-79, but has added 

8 clarification on how lamp stabilization should be 

9 determined. So LM-79 specifies that the lamp should 

10 be stabilized until the variation of at least three 

11 readings of input power and lumen output over a period 

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

13 point five percent.

14 DOE proposes to adopt this specification and 

15 further includes the equation listed on this slide to 

16 clarify how the variation should be calculated. That 

17 is, the variation should be calculated as the 

18 difference between the maximum and the minimum values 

19 of lumen output or input power, divided by the 

20 respective minimum value. 

21 In issue 7, DOE requests comment on the 

22 proposed clarification for calculating the variation 

23 to determine lamp stability.

24 MR. BROOKMAN: Keith.

25 MR. COOK: Generally speaking, I think this 
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1 is just good practice. We would agree with this 

2 approach.

3 MR. BROOKMAN: Yes, Mark.

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

5 Just a small matter. The equation should be expressed 

6 as a percent.

7 MS. THAKKAR: Right. Okay.

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

9 Additional comments on lamp stabilization? Okay. 

10 MS. THAKKAR: The next topic is measuring 

11 the lumen output of the LED lamp. LM-79 specifies 

12 that a sphere-spectroradiometer, a sphere-photometer, 

13 or a goniophotometer should be used to measure the 

14 lumen output of the lamp. 

15 DOE proposes to adopt this specification and 

16 requests comment on it. In particular, DOE is 

17 interested to receive comment as well as available 

18 data about how the lumen output from each of these 

19 measurements compare.

20 MR. BROOKMAN: Yes.

21 MR. SZOMBATFALVY: This is David from GE. 

22 From our experience we show that between the 

23 goniometer and the sphere measurement, we can get like 

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

25 when we look at the overall average from making 
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1 measurements at one site, at one location. There’s an 

2 inherent bias, because when you look at round robin

3 measurements for NVLAP and different labs, like the GE 

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

5 So it’s important that we understand what those 

6 percentages are and incorporate that in this 

7 measurement method.

8 MR. BROOKMAN: Between the different 

9 systems?

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

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

12 approximately a two percent difference in measure 

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

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

15 approximately a three percent difference.

16 MR. BROOKMAN: Okay. 

17 MR. COOK: Actually, NVLAP has published a 

18 variation of four percent.

19 MR. SZOMBATFALVY: Four percent?

20 MR. COOK: Yes.

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

22 ahead.

23 MR. DUFFY: Just one further comment on that 

24 regard. Between labs could become very important if 

25 you’re thinking about future rulemakings, because that
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1 actually represents a bias and not a random variation. 

2 The lab that you choose to measure your samples in 

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

4 MR. BROOKMAN: Okay. 

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

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

7 going to place values on the lighting facts label, 

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

9 measurements of small quantities of lamps.

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

11 additional?

12 MS. THAKKAR: I have a follow up question to 

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

14 compare the same two systems, the sphere15 spectroradiometer across two different labs, or is –

16 MR. COOK: It’s not specific to 

17 spectroradiometers or goniophotometers, it is a 

18 published NVLAP percentage statistic, based on round 

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

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

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

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

23 statistics. There will be up to a four percent 

24 variation –

25 MR. BROOKMAN: And they didn’t specify these 
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1 different systems?

2 MR. COOK: Pardon?

3 MR. BROOKMAN: They did not specify these 

4 different systems?

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

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

7 empirically determined.

8 MR. BROOKMAN: Okay. I see some heads 

9 nodding around the room.

10 MS. THAKKAR: Thank you. 

11 MR. BROOKMAN: Okay. Yes, Adam.

12 MR. CHRISTENSEN: This is Adam from ASAP. 

13 This is a little bit more of a mash-up between issue 

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

15 The gentleman from GE, sorry, I forget your – Dave. 

16 You mentioned before the orientation could be an issue 

17 when using different types of light measurement.

18 MR. SZOMBATFALVY: That’s correct. 

19 Specifically when you do a goniometer measurement, the 

20 mirror in the way makes that measurement – when it’s 

21 in the horizontal position you can get inaccurate 

22 measurements. It’s a difficult measurement.

23 MR. CHRISTENSEN: It’s just inherent in the 

24 tool that you use?

25 MR. SZOMBATFALVY: To the best of my 
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1 understanding, what my guy told me was it’s inherent 

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

3 PARTICIPANT: Right, it’s in the test 

4 equipment. It’s not in the device being measured.

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

6 move on? Yes.

7 MS. THAKKAR: Okay. Moving on to 

8 measurements for directional lamps. DOE proposes that 

9 the total lamp lumen output should be measured rather 

10 than the beam lumens, which are also known as the 

11 zonal lumens. This is because other directional lamp 

12 technologies, such as incandescent reflector lamps, or 

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

14 label. If directional LED lamps report anything other 

15 than total lumens, these lamps cannot be compared to 

16 other directional lamp technologies on the basis of 

17 FTC’s label. 

18 DOE requests comment on its proposal to 

19 measure total lumens for directional lamps.

20 MR. BOESENBERG: This is an ongoing 

21 discussion inside of industry. Lamp directionality 

22 and where you – what you measure where, is a very 

23 broad question. It’s definitely being pursued in 

24 various standards bodies and testing bodies, but we 

25 don’t have a good answer yet.
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1 MR. COOK: Well, the other thing we need to 

2 understand too is what is the purpose of the test, or 

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

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

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

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

7 you’re trying to measure.

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

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

10 from Pam.

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

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

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

14 that the Department of Energy has rulemakings on other 

15 technologies, where reflector lamps reside. And a 

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

17 other technology performance standards, believe me.

18 MR. BROOKMAN: Okay. 

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

20 discussion on this.

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

22 get comments back in time.

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

24 MR. BROOKMAN: Are there additional comments 

25 on this point and divergence. I should note for the 
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1 record, when Mansi raised this issue, there was a lot 

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

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

4 MS. THAKKAR: Okay. 

5 MR. BROOKMAN: Apparently we have a question 

6 from the web. Yes. Matthew.

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

8 questions from the web. Start with one –

9 MR. BROOKMAN: From?

10 MR. WALKER: From Joel Jacobson. “This 

11 would increase the time to measure initial lumens of 

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

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

14 Then we have one from Cameron Miller, two 

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

16 differences between all laboratories is within 

17 standard deviation of plus or minus three percent. 

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

19 a sphere? Is a hemisphere acceptable?” 

20 That might be a good thing for the room to 

21 discuss as to whether a hemisphere could be an 

22 acceptable requirement for the LM-79 testing.

23 MR. BROOKMAN: What is a hemisphere?

24 MR. WALKER: Usually, the sphere testing for 

25 light output is a complete round ball, and then a 
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1 hemisphere would be half of that, and I imagine it 

2 might be a cheaper device. Less expensive device.

3 MR. BROOKMAN: ... clarify what that was, 

4 okay. Could we get comment on that?

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

6 I don’t remember that being accepted in LM-79.

7 MR. BROOKMAN: Ralph?

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

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

10 incorporated in trying to do any measurements with 

11 hemispheres. If the – it really depends on the light 

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

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

14 that.

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

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

17 have a follow on?

18 MS. THAKKAR: No.

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

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

21 Again, another Cameron Miller. “NVLAP has not 

22 published the plus or minus four percent total 

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

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

25 MR. BROOKMAN: Alex?
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1 MR. BOESENBERG: I saw four published 

2 somewhere. I’ll find it.

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

4 at NVLAP. “We can allow DOE to review our proficiency 

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

6 the reports. The reports are only intended for lab 

7 use and have not been reviewed for release to the 

8 general public.”

9 So then, earlier, Cameron Miller made the 

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

11 the rating process” – again referring back to 

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

13 included because this would eliminate bad products 

14 that TM-21 prediction might falsely predict good 

15 performance.” Okay. 

16 So there’s an idea that TM-12 data could be 

17 used to project, I guess project – I’ll just read as 

18 it says. “TM-21 should be used to project the data, 

19 but using the 1000 hours of seasoning would validate 

20 the application of TM-21.” So that was a Cameron 

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

22 with.

23 Another Cameron Miller. “LM-79 2008 is 

24 being updated and the new version will be available, 

25 probably in the fall.”
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1 Cameron Miller, “the hemisphere will be 

2 accepted in the new version of LM-79.”

3 Alex Truong. “LM-79 requires a type C 

4 goniophotometer, so horizontal lamp positioning does 

5 not apply.”

6 And that brings us to the end of the current 

7 webinar comments.

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

9 Ralph, you want to comment on – not that last thing. 

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

11 update to LM-79 is still in the development stages, 

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

13 while Cameron notes that that is one of the topics of 

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

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

16 discussed.

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

18 course, the Department’s wanting to make these 

19 meetings accessible via the internet, so thanks to 

20 those that are joining us via the internet. That 

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

22 this segment before we move on? Okay. 

23 MS. THAKKAR: Moving on to the sampling 

24 plan. DOE proposes that at least 21 lamps should be 

25 tested to determine the input power, lumen output and 
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1 CCT. The lamps should be selected first with a 

2 minimum of three lamps are picked per month for seven 

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

4 months are not required to be consecutive over the 12 

5 month period. If production occurs less than seven 

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

7 selected evenly for each month of production. If more 

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

9 multiple of three so that an equal number of lamps are 

10 tested in each orientation.

11 DOE requests comment on the proposed sample 

12 size requirements for testing these lamps.

13 MR. BROOKMAN: Sampling. Always an issue. 

14 MR. BOESENBERG: Alex Boesenberg, NEMA. We 

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

16 traditional in the lighting rulemakings. However, in 

17 the case of solid state there is somewhat of a 

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

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

20 consideration the Department needs to make about, you 

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

22 already been doing our testing to that, is it 

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

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

25 MR. BROOKMAN: Okay. Thank you. Dave. 
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1 Mark.

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

3 GE. The fourth bullet on your slide about equal 

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

5 suggestion of not using horizontal, then you probably 

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

7 MR. BROOKMAN: Okay. Yes, Adam.

8 MR. CHRISTENSEN: This is Adam from ASAP. 

9 So just besides traditional sampling in industry, is 

10 there other justification for why 21 that DOE is 

11 investigating?

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

13 traditionally used for other lighting sources, but it 

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

15 of three that wasn’t too small – because of the 

16 orientation requirements, yes.

17 MR. CHRISTENSEN: Traditionally we’ve had to 

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

19 MR. BROOKMAN: Okay. Alex.

20 MR. BOESENBERG: Alex Boesenberg, NEMA. 

21 Just another comment. We – it might be worth for ASAP 

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

23 For instance, 21 was thrown out there too because, 

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

25 about a 2500 watt lamp, it’s awfully expensive to run 
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1 21 of them for a year. Or two or three years, ten 

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

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

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

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

6 trying to get – consumers are clamoring for it. We’re 

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

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

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

10 to them. So it’s a consideration.

11 MR. BROOKMAN: Thank you. Keith.

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

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

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

15 going to do a lumen maintenance test also?

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

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

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

19 label.

20 MR. COOK: Okay. 

21 MR. BROOKMAN: Are you finished, Keith? 

22 Pekka.

23 MR. HAKKARAINEN: Yes, one other thing that 

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

25 production, it’ll be very important to carefully draft 
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1 the language here in this rule, because my 

2 understanding is that to comply with the FTC labeling 

3 requirements, provisional labeling can be used with 

4 new lamps to introduce them to the market before the 

5 seven months worth of production. Depending on how 

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

7 system and therefore new lamps would not be able to 

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

9 important how this is written.

10 MR. BROOKMAN: Thank you. Ralph.

11 MR. TUTTLE: This is Ralph Tuttle. And 

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

13 is the fact that – you know, if I’m Ralph’s light bulb 

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

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

16 FTC requirements. I want to measure my samples and be 

17 able to put that label on the product immediately, 

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

19 So I agree with you completely, Pekka.

20 MR. BROOKMAN: Please, yes, Mark.

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

22 would like to suggest that DOE consider, for the 

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

24 then if future rules, the next second year comes 

25 along, then you take this kind of thing into account, 
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1 but initially you should be able to label on the basis 

2 of your first production.

3 MR. BROOKMAN: Okay. Keith.

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

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

6 headed. Is the ironic thing about this whole testing 

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

8 design stay in production more than a year. Period. 

9 This technology is changing so fast. The LED 

10 efficiency is going up so quickly, that we redesign 

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

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

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

14 MR. BROOKMAN: Interesting. Okay. Thank 

15 you. Yes, Chip.

16 MR. CHIPALKATTI: Chip Chipalkatti, Osram. 

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

18 technology and new products coming in, so some of 

19 these long term tests are meaningless by the time the 

20 product is ready to be launched.

21 MR. BROOKMAN: What should be done about 

22 this? Alex.

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

24 have an answer to that question of what should be 

25 done, but this is an illustration of the emerging 
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1 nature of these products, and regulations tend to be 

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

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

4 the suggestion of just taking an initial sample may be 

5 the best we can do until the technology quiets down.

6 MR. BROOKMAN: Okay. We have additional 

7 comment or question from the internet?

8 MR. WALKER: Yes, we have an additional 

9 comment from Julia Farber, appears to refer back to 

10 the goniophotometer discussion. “The issue with the 

11 measurement of horizontally oriented lamps is based on 

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

13 Lamps are usually supported from above or below, and 

14 the support structure can interfere with the light 

15 measurement.”

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

17 move on.

18 MS. THAKKAR: Okay. The final topic of 

19 discussion in this section are the rounding 

20 requirements. DOE proposes that the values over all 

21 21 samples should be averaged and only the average 

22 value should be rounded. For input power, the average 

23 value should be rounded to the nearest tenth digit, 

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

25 the average value should be rounded to the nearest 
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1 tens unit, such as 820 lumens, or 2750 Kelvin. 

2 For the estimated annual energy cost, which 

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

4 label, DOE proposes that it should be calculated as 

5 the product of the average input power, the 

6 electricity cost rate, and the estimated average 

7 annual use. This value should be rounded to the 

8 nearest cent, such as $7.23. 

9 DOE requests comment on the proposed 

10 calculation and rounding requirements.

11 MR. BROOKMAN: Pam.

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

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

14 would help me remember, I believe the current FTC 

15 rounding rule is five lumens.

16 PARTICIPANT: Correct.

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

18 way.

19 MR. BROOKMAN: I see –

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

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

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

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

24 better think about this before we say anything further 

25 as a collection of manufacturer comments. But you 
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1 bring up some good questions, thank you.

2 MR. BROOKMAN: Mark, you want to comment 

3 here?

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

5 will be involved in the NEMA – ultimately, in the NEMA 

6 comment. But something that is apparently – that I 

7 would like to see DOE consider in their rounding 

8 recommendations here is what the resolution of the 

9 measurement is. Because in many cases, the resolution 

10 of the measurement far exceeds the rounding 

11 specification, especially in the FTC case.

12 MR. BROOKMAN: Okay. Yes, Adam.

13 MR. CHRISTENSEN: I think I would also be 

14 curious to see about the resolution of the test 

15 measurement and have rounding based more on that than 

16 – or have DOE consider that in their determination.

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

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

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

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

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

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

23 MR. BROOKMAN: Okay. Additional comments? 

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

25 guess. Additional comments at this point? Nothing 
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1 additional – oh, yes, Ralph.

2 MR. TUTTLE: Ralph Tuttle. I guess one 

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

4 when it comes to Energy Star and EPA requirements, 

5 labs performing these measurements have to be approved 

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

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

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

9 wondering what the requirement will, in fact, be.

10 MR. WALKER: This is Matthew Walker, 

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

12 far does not include a laboratory accreditation 

13 requirement, and I guess this is an opportunity for 

14 you and others to suggest that you would like to have 

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

16 requirements you think would be the most useful for 

17 LEDs.

18 MR. BROOKMAN: Ralph, please.

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

20 I strongly urge the DOE to consider a requirement of 

21 certification of laboratories that are performing 

22 these tests.

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

24 have a posture on this? On the question of 

25 certification of testing laboratories?
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1 MR. BOESENBERG: We’ll have to discuss it 

2 and reply back.

3 MR. BROOKMAN: Okay. Thanks, Alex. 

4 Anything else? Matthew?

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

6 measurement resolutions and values that we were 

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

8 that NEMA is able to provide their own suggestions and 

9 feedback based on their own experience with those 

10 measurements, I think that would be very valuable.

11 MR. BROOKMAN: Okay. We’ve been 

12 tremendously efficient, and we’ve gone through 25 

13 slides in a record amount of time.

14 MR. BOESENBERG: Alex Boesenberg, to reply 

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

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

17 guidance on the issue of measurements rounding and 

18 reporting. And I look forward to delivering that as 

19 soon as possible to the entire world, the Department 

20 included. 

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

22 reason I’m asking the question is whether – it’s now 

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

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

25 don’t know – how long do you think the next element, 
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1 test procedure for rated lifetime – I see about 20-odd 

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

3 break.

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

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

6 constructive, high quality comment here. We’ll see 

7 you back here at 10:25.

8 Wear your visitor’s badge in the building. 

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

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

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

12 back here at 10:25. 

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

14 recessed for a 16 minute period.)

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

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

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

18 proceed and hear about test procedures for rated 

19 lifetime. And back to Mansi.

20 Test Procedure for Determining the Rated Lifetime of 

21 LED Lamps

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

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

24 test procedure for determining the rated lifetime of 

25 LED lamps. The FTC lighting facts label also has a 
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1 metric called “life” on the label which reports the 

2 expected rated lifetime of the lamp in number of years 

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

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

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

6 couple of comments from the earlier section that came 

7 in during the break.

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

9 before we proceed. Please, yes.

10 MR. WALKER: So the first one is from Ronald 

11 Daubach. “There’s a difference between laboratory 

12 accreditation and certification of data. I think that 

13 you want to consider laboratory accreditation, and not 

14 a certification program.”

15 MR. BROOKMAN: I see, so I’m going to – I’m 

16 going to receive comment also from the room. Ralph I 

17 see you commenting, yes?

18 MR. TUTTLE: (off mic)

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

20 MR. CHIPALKATTI: I agree with that.

21 MR. BROOKMAN: Okay. We have I think – I 

22 see several – many of the manufacturers thumbs up, 

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

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

25 McGaraghan. “How does the energy cost calculation 
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1 come into this rounding issue? Energy cost is not one 

2 of the metrics being proposed in this procedure, is 

3 it?”

4 MR. BROOKMAN: Alex?

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

6 the energy cost is published by the Department and 

7 they just actually published the latest 11.84 cents, I 

8 think, this past week.

9 MR. BROOKMAN: Okay. 

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

11 Ronald Daubach. “Accreditation procedure by which 

12 authoritative third party gives formal recognition 

13 that a body or person is competent to carry out 

14 specific tasks. Certification is a procedure by which 

15 a third party gives written assurance (certificate of 

16 conformity) that a product, process, or service 

17 conforms to specified requirements.”

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

19 We’ve already covered that one.

20 MR. WALKER: Yes.

21 MR. BROOKMAN: Okay. That’s all? Then 

22 we’re moving on. Back to Mansi.

23 MS. THAKKAR: Okay. Because a standardized 

24 test method does not currently exist to determine the 

25 rated lifetime of LED lamps, DOE reviewed four 
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1 approaches to determine rated lifetime, and analyzed 

2 advantages and disadvantages of each approach.

3 The first approach that was analyzed, which 

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

5 lumen output of the LED lamp is measured until it 

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

7 The second approach, as required by Energy 

8 Star for qualifying lamps for the Energy Star label, 

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

10 The lumen maintenance at 6000 hours should meet a 

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

12 hours. Qualification for more than 25,000 hours 

13 requires more than 6000 hours of testing, and 

14 corresponding lumen maintenance requirements at those 

15 hours.

16 The third approach that was considered, 

17 which is column three on this slide, requires that 

18 testing of the LED lamp for a minimum of 6000 hours 

19 and projecting the time required to reach L70 lumen 

20 maintenance based on our projection model.

21 Finally, the fourth approach, which is also 

22 the approach proposed in this NOPR, requires that the 

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

24 minimum of 6000 hours, according to IES LM-80, and the 

25 lumen maintenance be projected to L70 using the method 
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1 outlined in IES TM-21. However, the maximum rated 

2 lifetime projection should not exceed 25,000 hours.

3 We will now discuss the advantages and 

4 disadvantages of the four approaches.

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

6 from Mark.

7 MR. DUFFY: Yeah, I just want – before we go 

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

9 clarification. Earlier you defined an LED source, and 

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

11 the package level, where LM-80 data may exist, or 

12 whether you’re talking about arrays of packages where 

13 the LM-80 data would only be that of the individual 

14 packet?

15 MS. THAKKAR: So the intent is that it 

16 applies to those components that LM-80 applies to, and 

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

18 array.

19 MR. DUFFY: Thank you for that 

20 clarification.

21 MR. BROOKMAN: Okay. Keith.

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

23 concern. The topic here is approaches considered to 

24 determine rated lifetime. And yet your lifetime is 

25 being predicated solely upon LM-79 data. That is very 
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1 misleading because there’s a lot of other factors that 

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

3 mechanical aspects that are not being comprehended 

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

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

6 solely upon the LEDs themselves. And I think that 

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

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

9 field.

10 MR. BROOKMAN: What would suggest the 

11 Department do?

12 MR. COOK: The problem is right now this 

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

14 develop a good standard. And I understand that that’s 

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

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

17 Fred Welsh, that is trying to get their arms around 

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

19 ways to test, to establish reliability levels. But 

20 we’re not there yet.

21 MR. BROOKMAN: Okay. Alex?

22 MR. BOESENBERG: Alex Boesenberg, NEMA. As 

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

24 others could comment on how long it took to write LM25 79 and LM-80. The – came up with an idea and then it 
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1 didn’t work aspect of solid state standards, and I can 

2 speak from that – from the experience of the NEMA 

3 solid state lighting standards that I facilitated with 

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

5 let’s do this method X, Y and Z. By the time we had 

6 finished discussing the wording of that paragraph a 

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

8 solid state system we had taken as the baseline, 

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

10 anything right now for rated lifetime is that the 

11 assumptions and physical circuitry parameters and 

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

13 around long enough for us to finish publishing the 

14 document.

15 And if you figure on 1000 hours a year as 

16 typical consumer maintenance, we’re talking about 

17 people putting 25 years on packaging already, and for 

18 now, the industry has left that up to individual 

19 manufacturer discretion.

20 MR. BROOKMAN: Yeah. Ralph.

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

22 there is no known methodology in the industry to 

23 accurately determine the lifetime of a solid state 

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

25 replacement bulb type of product. 
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1 One thing that perhaps DOE may want to 

2 consider is that instead of defining the lifetime of 

3 the product on the package, define instead lumen 

4 maintenance of the source itself. And that is a 

5 measure that there are standards or methodologies in 

6 the industry that are very common today. But lifetime 

7 is not something that we can accurately predict today.

8 MS. THAKKAR: I have a clarifying question 

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

10 would that lumen maintenance value then just be 

11 reported against the life metric, or would you suggest 

12 something else for life on the label?

13 MR. BROOKMAN: Back to Ralph.

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

15 would recommend that on the label that there be no 

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

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

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

19 done up at PNNL within the CALiPER program showed 

20 very, very rapid lumen depreciation and actually non21 functionality of some products in very short periods 

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

23 world were being used in those products. 

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

25 previously referred to, that are working on this –
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1 trying to tackle this subject, but as of today, we 

2 have no answer.

3 MR. BROOKMAN: Alex.

4 MR. BOESENBERG: Alex Boesenberg. And of 

5 course we understand we’re talking about something 

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

7 our own ongoing discussions with the FTC about this 

8 and other subjects, so I sympathize. I understand 

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

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

11 best we can.

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

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

14 like to discuss the advantages and disadvantages of 

15 the four methods that we considered. The first 

16 advantage of approach one is that the LED lamp, rather 

17 than the LED source is being tested. Additionally, 

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

19 the reported value of lifetime is what you actually 

20 observe during testing. 

21 However, this approach does have some 

22 disadvantages. The biggest one being that the time 

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

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

25 hours to reach 70 percent of initial light output, the 
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1 time required for testing would be almost three years. 

2 Another disadvantage of this long testing time is that 

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

4 evolving technology, the product may be obsolete by 

5 the time testing is completed.

6 (Laughter.)

7 MR. BROOKMAN: Ralph would like to comment 

8 at this point. Ralph.

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

10 I have to respectfully disagree with that comment and 

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

12 today, we are providing to the lighting community, 

13 LEDs that we designed and put into production five 

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

15 They’re still being – in fact, that older product I’m 

16 referring to was just within the last year that some 

17 of our newer products finally surpassed it in the 

18 volume of product that we were shipping. So while 

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

20 on improving the lumen maintenance of the product, the 

21 efficacy of the product, just the overall robustness 

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

23 designed quite some time ago that are still being 

24 designed into products.

25 MR. BROOKMAN: Okay. Thanks for the 
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1 clarification.

2 MS. THAKKAR: Actually, I have a 

3 clarification question. When you say LEDs, do you 

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

5 itself.

6 MR. TUTTLE: I’m talking about both.

7 MS. THAKKAR: Both.

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

9 specifically referring to the LED package itself.

10 MS. THAKKAR: Okay. Thank you. 

11 MR. BROOKMAN: Yes, Chip.

12 MR. CHIPALKATTI: I think the point just 

13 made highlights the additional fact of divergence 

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

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

16 question of value, what product is being written about 

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

18 so the fundamental fact is that even though some LEDs 

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

20 manufacturers of LEDs coming with new stuff, and so 

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

22 MR. BROOKMAN: This is a point Alex made 

23 yesterday about – thinking about this as a system. 

24 Many of you weren’t – some of you – many of you were 

25 here yesterday. Okay. So additional clarifications 
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1 before we move on? The Department’s going to try and 

2 have to figure out, try and do something about this, 

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

4 advantages and disadvantages.

5 MS. THAKKAR: Okay. Moving on to approach 

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

7 tests the LED lamp rather than the LED source. 

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

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

10 consuming as approach one. A disadvantage of approach 

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

12 mechanisms, other than lumen depreciation. And while 

13 Energy Star does require a rapid cycle stress test for 

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

15 determine failure for LED lamps.

16 The advantages of approach three are very 

17 similar to those of approach two. Approach three also 

18 tests the lamp rather than the source, and requires 

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

20 therefore not as burdensome as approach one. However, 

21 a key disadvantage of this approach is that a standard 

22 method has not yet been developed to project LM-79 

23 lumen maintenance data to determine the lifetime of 

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

25 develop a method of projection in a timely manner for 
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1 reporting life on the lighting facts label by FTC.

2 Finally, the advantages of the proposed 

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

4 industry accepted standards, LM-80 and TM-21, to 

5 project the lumen maintenance of the LED source. DOE 

6 also proposes that the maximum rated lifetime that is 

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

8 important to insure that exceedingly large projections 

9 of lifetime are not made exclusively on LED source 

10 lumen maintenance data. It is also currently unknown 

11 what the lifetime of some of the other components 

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

13 25,000 hours provides a conservative estimate of the 

14 lamp’s overall lifetime. Finally, the proposed 

15 approach would be less burdensome than testing the LED 

16 lamp for 6000 hours because LM-80 data for the LED 

17 source is often available from LED source 

18 manufacturers.

19 The proposed approach does have some 

20 disadvantages, though. The primary one being that it 

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

22 Secondly, the proposed approach does not account for 

23 other LED lamp failure mechanisms, such as LED driver 

24 degradation and failure, the effect of the 

25 interactions between LED sources and between LED 
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1 sources and other components. However, these failure 

2 mechanisms cannot be accounted for currently because 

3 standardized test methods to determine the impact of 

4 these components have not yet been developed. As new 

5 standards to determine the life of an LED driver and 

6 other components are developed, this proposed test 

7 procedure could be revised.

8 Therefore, DOE proposes approach four, 

9 because it uses a standardized test and projection 

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

11 comment on the four approaches presented as well as 

12 the relative cost and benefits of each approach.

13 MR. BROOKMAN: Alex.

14 MR. BOESENBERG: Alex Boesenberg for NEMA. 

15 As you may expect, we are still working on the 

16 industry comment for this. Approaches number two and 

17 number four are receiving the most discussion, but 

18 actually favoring one over the other isn’t necessarily 

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

20 of a – as you note, there are advantages and 

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

22 I do want to comment specifically on 25,000 

23 hours, because the sentiment I have received and am 

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

25 is ultimately an arbitrary number. We sympathize – I 
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1 sympathize with the Department that 25 years sounds 

2 like plenty long already, and yes there are many 

3 outside factors, but it is not typical of test 

4 procedures to put reporting, or cap requirements. 

5 That is something that you arrive at based on your 

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

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

8 between the manufacturer and the FTC. So for those 

9 reasons, fundamentally, I would submit that the 

10 Department remove that cap and number one, we’re still 

11 working on test procedures that will actually allow 

12 you to arrive at a more scientifically based number, 

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

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

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

16 companies do not want to put an outrageously large 

17 number for lifetime, because they just – they want to 

18 be conservative. And others consider it a marketing 

19 decision, and if we think we’ve got LM-80 and we can 

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

21 decisions that some are market-driven, so they’re 

22 internal company decisions that’s part of the free 

23 trade, and free open market between different 

24 companies and their positions, and what they claim and 

25 how they compete based on performance and other 
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1 factors. So, lifetime is highly discussed.

2 MR. BROOKMAN: I have a follow on question 

3 for Alex. Since you said – you said you were 

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

5 arrives at something it will be kind of bounded in 

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

7 back with something that DOE has not yet anticipated?

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

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

10 the start of this section, you can take as fairly 

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

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

13 MR. BROOKMAN: Okay. Pam.

14 MS. HORNER: I’m going to risk – this is Pam 

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

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

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

18 Keith’s earlier point is probably what should be 

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

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

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

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

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

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

25 nodding here, that life does not mean lumen 
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1 maintenance, it means it’s the end of the bulb as I 

2 know it. It doesn’t work any more.

3 What we’re faced with is the reality that 

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

5 procedure that is agreed upon by the experts, which 

6 points to premature, on this point, but it also opens 

7 the possibility, and whether we incorporate it into 

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

9 very innovative and say that perhaps this is an 

10 education opportunity. 

11 One of the – Alex mentioned that we were 

12 looking at approaches two and four, we were commenting 

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

14 for that is both talk about lumen maintenance, which 

15 is the reality of how we have characterized the 

16 meaning of life for those who produce this product. 

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

18 an educational approach that we could take that starts 

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

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

21 means something different than you’re used to. 

22 So it doesn’t preclude the possibility of us 

23 embarking upon something to educate the consumer, 

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

25 ready. I hope I’m making sense. Thank you. 
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1 MR. BROOKMAN: Yes, that was helpful. Thank 

2 you. Alex.

3 MR. BOESENBERG: This is Alex Boesenberg. 

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

5 and reminding everybody, especially someone who comes 

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

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

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

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

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

11 was. And the point is the consumer definition of 

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

13 more at all. But industry and transportation safety, 

14 individuals, municipalities, everyone is grappling 

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

16 huge deal for roadway lighting because municipalities 

17 have a mandatory obligation to put a certain number of 

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

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

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

21 I guess – I might get in trouble – but call it their 

22 useful life, in terms of producing enough lumens to 

23 meet the safety standard. That’s something industry 

24 is actively working on. 

25 Unfortunately, Jim Brodrick left already. 
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1 He could tell us about the Municipal Solid State 

2 Street Lighting Consortium that he is helping run 

3 where they are addressing that very issue. And they 

4 are working with the Next Generation Lighting Industry 

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

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

7 them grapple with that issue. Ultimately, there are –

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

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

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

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

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

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

14 been an issue because other stuff just burns out.

15 MR. BROOKMAN: John, comment?

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

17 are used in commercial or maybe even industrial 

18 applications as well, they usually have light levels 

19 that are specified by IES that – so minimum light 

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

21 exist in the normal consumer market for residential 

22 applications. So it just supports the fact that 

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

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

25 level in my house.
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1 MR. BROOKMAN: Okay. Thank you. Comment 

2 from the web?

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

4 webinar participants. Cameron Miller, on the 25,000 

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

6 long as industry provides specific statistics to prove 

7 their stated numbers.”

8 MR. BROOKMAN: Okay. So do we have 

9 additional comment on these four approaches? We’ve 

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

11 other comments? Mark.

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

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

14 terrific.

15 MR. BROOKMAN: Even the philosophical ones.

16 MR. DUFFY: Even the philosophical ones, the 

17 meaning of life, you know, --

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

19 bar rather than lunch.

20 MR. DUFFY: Yeah, exactly. Recommendations 

21 for lamp replacement and so forth is something that 

22 DOE should be prepared for as a response that may

23 incorporate multiple methods, because in some cases 

24 LM-80 data may be available, in some cases LM-80 data 

25 may not be available, and if you’re in a situation 
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1 where you’ve specified your preference for approach 

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

3 there’s products out there for whom LM-80 data isn’t 

4 available and you need to have some way of 

5 establishing what you’re going to put on – or FTC 

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

7 MR. BROOKMAN: Yeah. Lucy, can you 

8 describe, or can someone describe the nature of the 

9 consultation with FTC at this point? Have you begun 

10 that? Not yet.

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

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

13 the documentation from the group that Jim Brodrick is 

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

15 consideration, and we understand the issue is very 

16 complex. So although a lot of your remarks probably 

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

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

19 comment NEMA has been so involved in standard-setting 

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

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

22 forward with something that’s a lot different from 

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

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

25 some pathway that’s going to drive this train.
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1 MS. DEBUTTS: We will take care – take a 

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

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

4 a proposal please do so because we want to make sure 

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

6 MR. BROOKMAN: Yeah. Pekka.

7 ] MR. HAKKARAINEN: So this is Pekka 

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

9 a company that does not make these products, but 

10 nevertheless is involved in this lighting business, 

11 and what is troubling to me listening to this 

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

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

14 to offer that could be adopted. This is an area that 

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

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

17 the reality of the situation into account and with 

18 regard to the life rating, do it differently than 

19 traditional rulemakings where we have a comment period 

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

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

22 some mechanism where we could do it differently?

23 MR. BROOKMAN: Interesting idea. Alex.

24 MR. BOESENBERG: Alex Boesenberg. I would 

25 offer, in support of that, remember that ultimately 
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1 we’re talking about consumer satisfaction and market 

2 policing. There are mechanisms for reporting 

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

4 their own enforcement procedures too. Specific to 

5 this supporting the FTC’s labeling, lifetime claims 

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

7 MR. BROOKMAN: Thank you. Chip.

8 MR. CHIPALKATTI: Chip Chipalkatti, Osram 

9 Sylvania. You just wanted to make a general comment 

10 about all of this, not specific to the methodologies, 

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

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

13 of the challenges of putting a lot of information on 

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

15 expensive, but it’s often not legible because it’s so 

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

17 must take into account the impact on the actual 

18 physical packaging. As we think about educating 

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

20 label.

21 MR. BROOKMAN: Okay. Final comments on 

22 this. Betsy?

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

24 the question from Lutron – this is Betsy from GC – if 

25 we receive additional information that we want to have 
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1 another round of comment or be posted up, or have a 

2 supplemental document of some kind, there are ways, 

3 opportunities, for additional input.

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

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

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

7 approach.

8 MR. BROOKMAN: Thank you, Pekka. Appreciate 

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

10 proceed then.

11 MS. THAKKAR: Okay. These are the test 

12 procedures that are proposed in the NOPR, which is 

13 approach four that we just discussed. DOE is 

14 proposing a definition for rated lifetime, as the time 

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

16 percent of initial light output. It is possible that 

17 this definition may change if the proposed test 

18 procedure to determine rated lifetime changes. 

19 DOE requests comment on the proposed 

20 definition of rated lifetime.

21 MR. BROOKMAN: Keith.

22 MR. COOK: Absolutely not.

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

24 specific than that. Come on.

25 MS. DEBUTTS: You don’t want to comment, or 
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1 you don’t agree with this.

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

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

4 that lamp than just the LEDs.

5 MR. BROOKMAN: Do you want to – Alex, do you 

6 want to comment here?

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

8 have anything specific to comment, but I think to 

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

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

11 larger product, and rated lifetime is really specific 

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

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

14 won’t. So it’s – I think the word is irrelevant. It 

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

16 the goal of this rule.

17 MR. BROOKMAN: Other comments here? Adam?

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

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

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

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

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

23 groups as well as utilities and environmental groups 

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

25 this, but to the extent that kind of a systems 
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1 approach could be taken and more included in the 

2 analysis of a measure of lifetime, besides just lumen 

3 maintenance, I think it would probably be helpful.

4 MR. BROOKMAN: Good. Thank you. 

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

6 more specific at this time because I don’t have –

7 MS. THAKKAR: Thank you. 

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

9 MR. CHRISTENSEN: We’re working on it.

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

11 Additional comments on lamp rated lifetime? Please go 

12 ahead. Yes.

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

14 comment about –

15 MR. BROOKMAN: Please say your name again. 

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

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

18 additional components in the lighting structure. 

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

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

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

22 how long those would last.

23 MR. BOESENBERG: This is Alex Boesenberg. 

24 Industry and other scientific groups are definitely 

25 looking at that. Mean time between failures and all 
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1 those other factors. It is proving to not be that 

2 simple. 

3 MS. FARBER: Oh, I’m sure.

4 MR. BOESENBERG: Of course, and certainly 

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

6 some of our systems approaches. The fact that UL 

7 recognizes a luminaire as a system integral with the 

8 ballast driver light source and everything else, 

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

10 MS. FARBER: You’re quite welcome.

11 MR. BOESENBERG: But – so the – yeah, that 

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

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

14 as everyone grappled with, well, what if the 

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

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

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

18 MS. THAKKAR: Moving on to the steps to 

19 determine the rated lifetime, as was just defined. 

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

21 determine the in-situ temperature of the LED source 

22 when it operates within the lamp. This temperature 

23 can be determined by performing an in-situ temperature 

24 measurement test, or ISTMT. The in-situ temperature 

25 is required to know the temperature at which lumen 
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1 maintenance data should be used for projecting rated 

2 lifetime. 

3 Once the case temperature is known, the 

4 second step is to obtain lumen maintenance data at 

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

6 ways. The lumen maintenance data is either available 

7 at the case temperature directly from the LED source 

8 manufacturer. The second option is if the case 

9 temperature falls between two other temperatures at 

10 which lumen maintenance data is available, then the 

11 lumen maintenance data at the case temperature can be 

12 interpolated in TM-21. Finally, if the lumen 

13 maintenance data is not available from the source 

14 manufacturer and cannot be interpolated, it must be 

15 obtained by testing the LED source and measuring the 

16 lumen maintenance at the in-situ temperature. 

17 The last step in determining the rated 

18 lifetime is projecting the lumen maintenance data that 

19 is obtained in step two. The method described in TM20 21 should be used to project lifetime, but the maximum 

21 allowable value of the rated lifetime should not 

22 exceed 25,000 hours. 

23 We will now go into the details for each of 

24 these steps.

25 MR. BROOKMAN: Yes, excuse me, before you –
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1 Ralph.

2 MR. TUTTLE: Thank you. Ralph Tuttle, with 

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

4 that as an industry we concur that any attempt to 

5 define rated lifetime, regardless of the methodology, 

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

7 amount of work that’s gone into developing these step 

8 by step methods, the reality is, once we go through 

9 them, I think as an industry we’re going to say, you 

10 know, that doesn’t work. So perhaps we might want to 

11 bypass some of this at this point in time.

12 MR. BROOKMAN: I’m looking at Alex. Ralph 

13 just made a representation on behalf of the industry. 

14 Alex.

15 MR. BOESENBERG: I was debating whether or 

16 not to make the same statement. I also appreciate, I 

17 know it took a lot of time to put all this together, 

18 and I can’t speak for those on the phone. There may 

19 be someone who would like to review it. I do not have 

20 any industry consensus, I haven’t even received hardly 

21 any comments on these portions because we’re not 

22 prepared to comment on it. So, we have no comment, by 

23 and large. I can’t speak for everyone, but if she 

24 goes over it pretty quick --

25 MR. BROOKMAN: As you look at these slides 
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1 and the details in these slides, NEMA would, of 

2 course, be commenting perhaps specifically or 

3 generally on what’s in here as you review this 

4 material. But maybe we should just put the question 

5 to those who are on line, whether they have any 

6 specific comments about this. I guess what you’re 

7 suggesting is that we not review all these slides, 

8 correct?

9 MR. BOESENBERG: Proposing to the group to 

10 consider that, and probably jump to slide 46 and talk 

11 about sample size again.

12 MR. BROOKMAN: So I make this query to those 

13 joining us on line, if you’d like this additional 

14 review, then we can go through this, I presume. Mark.

15 MR. DUFFY: Yeah, I respectfully would like 

16 to hear, regardless of the potential irrelevance, I’d 

17 like to hear what the DOE is thinking about when they 

18 put this proposal together, even if we are concerned 

19 about the whole proposal.

20 MR. BROOKMAN: Are you suggesting – I’m not 

21 sure I understand what that means. That means you 

22 want to go through these slides, or –

23 MR. DUFFY: Yeah, that’s basically what I’m 

24 saying, is please give the DOE an opportunity to tell 

25 us what they were thinking so that when we develop our 
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1 comments which we need to make to this very proposal, 

2 we know exactly what was in your minds. I think it 

3 will help us as an industry to know that.

4 MS. DEBUTTS: It’s only six slides, you 

5 know, and the people on the webinar would like to go 

6 over them as well. So if you all don’t mind –

7 MR. BROOKMAN: Well, let’s do it.

8 MR. CHRISTENSEN: I would like to as well.

9 MR. BROOKMAN: Adam would as well. So let’s 

10 do it and Mansi’s doing a very efficient job with 

11 this. So proceed.

12 MS. THAKKAR: Okay. So the first step as 

13 DOE has proposed the test procedure currently, is to 

14 determine the in-situ temperature of the LED source. 

15 DOE proposes that the UL standard 1993-2009 should be 

16 used for setting up the test box, test conditions, 

17 testing equipment, and instrumentation. Additionally, 

18 a thermocouple should be attached to the LED source at 

19 the temperature measurement point that is identified 

20 by the LED source manufacturer by making a temporary 

21 hole to insert the thermocouple as stated in Appendix 

22 D in the Energy Star specification.

23 DOE requests comment on adopting the 

24 relevant sections of UL standard 1993 and performing 

25 the ISTMT, as well as the practicality of attaching 
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1 the thermocouple temporarily to determine the in-situ

2 temperature. 

3 MR. BROOKMAN: Does it make sense for us to 

4 go through all of them and receive comments at the 

5 end, or should we do it section by section? I’m 

6 unclear myself.

7 MR. DUFFY: I’d like to go section by 

8 section, because I have a question. 

9 MR. BROOKMAN: Okay. Mark, please.

10 MR. DUFFY: I’ll turn my microphone on. 

11 This is Mark Duffy of GE. I have a question about UL 

12 1993, and I guess we have UL in the room. The 

13 question is, is the purpose of that set up to mimic 

14 normal operating conditions, or is it to mimic some 

15 sort of a stressed operating condition within this 

16 box, within this enclosed box?

17 MR. BROOKMAN: Can you answer this one, 

18 Mansi.

19 MS. THAKKAR: So my understanding is that it 

20 mimics normal conditions in terms of the ambient 

21 temperature and humidity requirements for a lamp 

22 that’s designated to be operated in normal conditions, 

23 but it also provides specific stress tests for a lamp 

24 that might be used say, in a wet location, or a humid 

25 location. And for those conditions, it provides 
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1 specific details on how to test a lamp in an 

2 environment that’s simulates the humid conditions or 

3 the wet conditions.

4 MR. DUFFY: So I guess my question is, if 

5 you put it in a box to measure this temperature, are 

6 you going to elevate the temperature artificially 

7 above normal operating conditions?

8 MS. THAKKAR: I believe the test box is open 

9 from the bottom end, and the UL standard actually 

10 provides how to control the temperature for each 

11 component, and what to do in case the temperature is 

12 getting above what it should be. So they ask you to 

13 edit out and make sure the temperature returns back to 

14 normal.

15 MR. DUFFY: Okay. So, I guess I’ll get 

16 right to the point here, if the UL test is intended to 

17 determine whether or not a temperature maximum has 

18 been exceeded, it might be a stress type of a test

19 that’s looking for whether, under these conditions, 

20 extreme conditions, have they exceeded – has the 

21 safety temperature been exceeded. That would not be 

22 the right kind of test to get at normal operating 

23 conditions for determining lumen maintenance. That’s 

24 my concern.

25 MR. BROOKMAN: Okay. Julia, do you want to 
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1 comment? 

2 MS. FARBER: I am unfortunately not a 

3 technical expert in this particular area, but we did 

4 have our technical expert supposedly calling in, so if 

5 I may ask if somebody who’s manning the laptop could 

6 see if someone from UL has responded to any of these 

7 thoughts.

8 MR. BROOKMAN: Sure, Matthew’s over there. 

9 We’ll see if anybody has responded. 

10 MS. FARBER: In the meantime, we could 

11 definitely take these considerations and I could 

12 follow up with those for people who are interested in 

13 that specific answer.

14 MR. BROOKMAN: Okay. Matthew, do you have 

15 something from the web?

16 MR. WALKER: Yes, we did have one comment 

17 from the web, I’m not sure of the affiliation. But it 

18 comes from Carl Bloomfield. 

19 MS. FARBER: Bloomfield.

20 MR. WALKER: Bloomfield. Okay. Well, the 

21 comment is, “as the use of UL 1993 is being specified, 

22 please note that the standard allows an optional test 

23 box for specific wattage products,” and then in a 

24 second statement from Carl Bloomfield, “the 

25 temperature test is usually to represent real life 
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1 application.”

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

3 proceed then.

4 MS. THAKKAR: Are there any other comments.

5 MR. WALKER: We did just receive one more. 

6 This one is from Joel Jacobson. “Agree, the UL box is 

7 a worst case scenario.”

8 MR. BROOKMAN: Okay. Yes, Ralph, please. 

9 Let us know.

10 MR. TUTTLE: I’m sorry. Yeah, that’s pretty 

11 conflicting, you know, worst case would, to me, 

12 indicate the worst possible operating conditions that 

13 the manufacturer of the product recommends that 

14 product be used under. Whereas normal is – yeah, 

15 undefined at this point in time, to me.

16 MR. BROOKMAN: They might specify a 

17 temperature range and you’d be at the worst end of 

18 that range. Okay. So let’s proceed.

19 MS. THAKKAR: Okay. We will now discuss the 

20 method for obtaining lumen maintenance data if it must 

21 be determined by testing the LED source. DOE proposes 

22 to adopt LM-80 for the test conditions, set up, 

23 instrumentation, and measurement of lumen output of 

24 LED sources. For the test conditions, DOE proposes 

25 that the requirements specified in LM-80 should be 
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1 adopted with some modification, Instead of testing 

2 LED source at three case temperatures as specified in 

3 LM-80, DOE proposes that testing should be performed 

4 only at the case temperature identified during the 

5 ISTMT. Additionally, the drive current passing 

6 through the LED source during testing should be equal 

7 to or greater than the drive current passing through 

8 the source when it is operated within the lamp.

9 The second topic under test conditions is 

10 air temperature and air – sorry, go ahead.

11 MR. DUFFY: I may be your most frequent 

12 interrupter through these, but I want to deal with 

13 each one as I think of them. This gets back to the 

14 clarification that I asked for before. If LM-80 data 

15 is not available, and now you have a complete lamp 

16 unit, is it incumbent upon the testing procedure to 

17 tear that unit apart and test these sources according 

18 to LM-80 at a temperature that represents this 

19 institute temperature. Is that what you’re thinking?

20 MS. THAKKAR: Yeah, that was the intent. 

21 But I had a clarification to your clarification.

22 MR. DUFFY: Okay. 

23 MS. THAKKAR: Would you have to tear apart 

24 the lamp to get the source, or would the source be 

25 available?
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1 MR. DUFFY: Usually you have to destroy the 

2 product to get this piece out of the product for 

3 testing in that manner.

4 MS. THAKKAR: I see.

5 MR. BROOKMAN: Yeah, go ahead, Ralph.

6 MR. TUTTLE: Another situation, and one of 

7 the reasons LM-80 is written the way it is is that 

8 it’s not feasible that source manufacturers test LEDs 

9 at every conceivable temperature that it may be used 

10 under. LEDs in replacement bulb products can run at 

11 temperatures anywhere from 55 to 140 degrees 

12 Centigrade and everywhere in between. One of the 

13 reasons that we specify today, three, and ultimately 

14 probably two – and the LM-80 is currently going 

15 through a revision – the reason that we specify at 

16 least two temperatures is to allow us to determine the 

17 relative lumen maintenance at a temperature in between 

18 the upper and lower. So the way this is written would 

19 make it extremely difficult to comply to the 

20 requirement.

21 MR. BROOKMAN: Okay. And can you offer how 

22 it might be revised so that you might comply?

23 MR. TUTTLE: If in fact, DOE is intent on 

24 using LM-80 and TM-21 as a methodology for determining 

25 lumen maintenance of the light source, I would 
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1 recommend that they simply follow all the 

2 methodologies as defined in those documents, rather 

3 than try and add something different to them.

4 MR. BROOKMAN: Okay. Thank you. Other 

5 comments at this juncture? Okay. 

6 MS. THAKKAR: So, the second topic under 

7 test conditions is the air temperature and air 

8 movement requirements. DOE proposes that the air 

9 temperature around the LED source should be maintained 

10 between the case temperature and five degrees Celsius 

11 below the case temperature as specified in LM-80. 

12 That is, if the case temperature is 70 degrees 

13 Celsius, the air temperature should be between 65 and 

14 70 degrees Celsius. 

15 For air movement, DOE proposes to adopt the 

16 specification in LM-80 as well, which states that care 

17 should be taken to minimize any drafts around the LED 

18 source, but some air movement is necessary to avoid 

19 thermal stratification. 

20 DOE requests comment – we already went 

21 through the first part about testing at just the in22 situ, so in the second part, DOE requests comment 

23 about whether the measurement location point for 

24 measuring air temperature around the LED source should 

25 be specified, and whether the allowed air flow should 
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1 also be further specified.

2 MR. BROOKMAN: Comments on those two 

3 elements? Location and proximity, I guess. Ralph.

4 MR. TUTTLE: Well, I guess for lack of 

5 anybody else, I’ll comment on it. We’ve noted that 

6 there’s somewhat of a – some vagueness in the way the 

7 LM-80 was originally written relative to minimizing 

8 the air flow, and in fact that’s one of the topics 

9 that’s been discussed in quite a bit of detail within 

10 the working group that’s rewriting LM-80 at this point 

11 in time. We anticipate the new document will be 

12 completed before the end of this year, and in the new 

13 document, it will define exactly how to monitor the 

14 air flow through the system.

15 MR. BROOKMAN: Okay. Thank you. Other 

16 comments as reflected in issue box 13? Okay. 

17 MS. THAKKAR: I just have a clarification 

18 there. Would it also include more detail on how to or 

19 where to measure the air temperature?

20 MR. TUTTLE: It defines – it gives 

21 recommendations on best practices.

22 MS. THAKKAR: Okay. Thank you. 

23 MR. BROOKMAN: Thanks, Ralph. Okay. 

24 MS. THAKKAR: Further operating orientation 

25 during testing. DOE proposes to adopt LM-80 which 
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1 states that the LED source should be oriented as 

2 specified by the source manufacturer, and spaced out 

3 to allow air flow around each unit. While DOE 

4 proposed three specific orientations for testing the 

5 LED lamp, it is not doing so for testing the LED 

6 source because the case temperature is being 

7 controlled during testing. Therefore, the impact of

8 orientation on the thermal effects of the LED source 

9 should be minimal when testing the LED source, thus 

10 minimizing the effect of orientation on lumen output.

11 DOE requests comment on the proposed 

12 approach of using manufacturer guidance for the 

13 operating orientation. No comments.

14 MR. BROOKMAN: Comments? No comments on 

15 this one?

16 MS. THAKKAR: Moving on to the external –

17 MR. BROOKMAN: Here’s Ralph, good.

18 MR. TUTTLE: Yeah, let me comment on this. 

19 During LM-80 testing, our experience is that 

20 orientation of the component itself in no way affects 

21 lumen depreciation of that component.

22 MR. BROOKMAN: Okay. 

23 MS. THAKKAR: Thank you. So moving on to 

24 the external driver. DOE proposes that the external 

25 driver used for testing should be as specified in LM-
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1 80 as well, which requires that the driver should be 

2 compliant with manufacturer’s guidance. DOE request 

3 comment on whether this requirement is sufficient or 

4 needs further clarification.

5 MR. BROOKMAN: Ralph, I’m looking at you.

6 MR. TUTTLE: I’m sorry, I think we’re really 

7 talking about two different things here. LEDs during 

8 LM-80 testing are driven typically at constant current 

9 with laboratory power supplies, which, relative to an 

10 external driver that is used in a bulb product, we’re 

11 talking two different things here. The requirements 

12 as far as variation in output power are extremely 

13 tight when it comes to LM-80 testing. And my 

14 experience with drivers used in bulb products is that 

15 they can’t come close to maintaining the accuracy that 

16 a laboratory power supply does.

17 MS. THAKKAR: Okay. Okay.

18 MR. BROOKMAN: Yes, Keith.

19 MR. COOK: Keith Cook. This is, I think, a 

20 little bit confusing because the scope said it was 

21 integrated lamp, which meant that the driver was 

22 included in the device. Now you’re talking about an 

23 external power supply. Which is it?

24 MS. THAKKAR: To clarify that point, so it 

25 is an integrated lamp, but this is for when only the 
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1 source within the lamp is being tested. So it might 

2 not be tested with the integrated driver and you need 

3 another power supply to run the source.

4 MR. SZOMBATFALVY: This is David from GE. 

5 MR. BROOKMAN: Yes, Dave, go ahead.

6 MR. SZOMBATFALVY: Yes, this is the point 

7 that Mark had brought up about maybe having a dual 

8 path, that if we don’t have LM-80 data, that we may 

9 look at another one of those scenarios that you 

10 proposed, like scenario two or something like that.

11 MR. BROOKMAN: Ralph, you wish to – Chip. 

12 Chip, please.

13 MR. CHIPALKATTI: Chip Chipalkatti. Again 

14 this comes back to the question of is it the component 

15 or the lamp that you are looking at, and maybe there’s 

16 this emerging conversation that there might be two 

17 dual parts for this, if the LM-80 data is not there.

18 MR. BROOKMAN: I see.

19 MR. CHIPALKATTI: But you’re effectively 

20 trying to certify or qualify a product, and yet you 

21 are reaching inside to only one element of that 

22 overall product to test it.

23 MR. BROOKMAN: Isn’t the product typically 

24 an integral lamp?

25 MR. CHIPALKATTI: Yes.
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1 MR. BROOKMAN: Typically, right.

2 MR. CHIPALKATTI: And it goes back to what 

3 Mark was saying earlier. You’re going to have to 

4 tear this product apart to actually test this 

5 component.

6 MR. BROOKMAN: Go ahead, Mark.

7 MR. DUFFY: Yeah, of course, I agree. But 

8 the – it’s just an overall comment –

9 MR. CHIPALKATTI: (comment off mic)

10 MR. DUFFY: Yeah, I think it is. Just an 

11 overall observation. This is an awful lot of effort 

12 to get at an FTC label number. So at some point we 

13 need to step back and ask ourselves, what should we 

14 advise the FTC in regard to their label and have that 

15 conversation at some point.

16 MR. BROOKMAN: I wish FTC were in the room 

17 here.

18 MR. DUFFY: It would be helpful.

19 MS. DEBUTTS: We’ll definitely take your 

20 comments and we’ll see what we can do in cooperation

21 with the agency.

22 MR. BROOKMAN: Thank you. Okay. So, this 

23 is very helpful. I think this is very, very helpful 

24 what we’re doing here. So keep going.

25 MS. THAKKAR: Okay. For measuring the lumen 
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1 output of the LED source, LM-80 specifies that a 

2 spectroradiometer should be used. Instead, DOE is 

3 proposing that any of the three methods specified in 

4 LM-79 for the LED lamp should be used to measure the 

5 lumen output of the LED source as well. These three 

6 methods are the sphere-spectroradiometer, sphere7 photometer, and goniophotometer.

8 DOE requests comment on whether any of these 

9 three methods can be used to measure lumen output or 

10 only the spectroradiometer should be used.

11 MR. BROOKMAN: Alex.

12 MR. BOESENBERG: I have grammatical comment. 

13 Just to clarify sentence two there. Is it the same 

14 thing to say that DOE is proposing that either the 

15 first, the second, or the third test device might be 

16 used or may be used?

17 MS. THAKKAR: Yeah –

18 MR. BOESENBERG: Because some could read 

19 that to say you have to do it all three. I’m pretty 

20 sure that’s not your intent, but I want to clarify 

21 that.

22 MS. THAKKAR: That is right, the intent is 

23 that any one of the three methods could be used.

24 MR. BROOKMAN: Thanks for that 

25 clarification. This is like legislative language 
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1 here.

2 MR. WALKER: This is Matthew Walker from 

3 Navigant. Could anyone speak to why LM-80 specifies 

4 one of the measurement instruments as compared to LM5 79 where all three are included?

6 MR. BROOKMAN: Ralph, please.

7 MR. TUTTLE: Yeah. In fact I was looking at 

8 this. LM-80 requires not only testing of lumen output 

9 of the LEDs, but also chromaticity, and in fact 

10 forward voltage and all of the – many of the 

11 photometric and electrical characteristics of the 

12 product under test. For example, you can’t use 

13 goniophotometer to measure color. You need a Gonio14 spectroradiometer, which is a different tool 

15 completely. So, however, if all you’re measuring is 

16 lumen output, then a goniophotometer can be used for 

17 that purpose. So, the instrument that was defined in 

18 LM-80 allows us to in fact, test all of the critical 

19 parameters of the LEDs during the test procedure. 

20 Does that make sense? Okay. So again, if all we’re 

21 interested in is how much light is coming out of the 

22 LED, it’s really a relative number over time, and 

23 there’s a variety of different instruments that can be 

24 used to perform that measurement.

25 MR. BROOKMAN: Okay. Either then. Yes. It 
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1 specifies either for those three, correct? Yeah.

2 MR. BOESENBERG: Alex Boesenberg, again. As 

3 was previously stated, particularly for those people 

4 who like the approach that uses LM-80 because they’re 

5 already undergoing that testing, logically there’s no 

6 reason to specify other devices, and as was already 

7 stated, just stick with LM-80 because that’s the 

8 agreed to industry standard.

9 MR. BROOKMAN: Got you.

10 MR. BOESENBERG: Options are nice, but in 

11 this case, they just complicate things.

12 MR. BROOKMAN: Matthew. We have someone?

13 MR. WALKER: Yes, we have comment from 

14 Timothy Rasinski regarding issue 16. “Labs are 

15 accredited for standards as written. If accreditation 

16 is involved, notations will have to be made in the 

17 scope and could it confuse clients expecting LM-80 to 

18 be run as specified.” I should point out, that Tim 

19 Rasinski is from NVLAP.

20 MR. BROOKMAN: Okay. Thanks to him, that’s 

21 useful. Yes. Do we have any additional comments on 

22 this stream before we move on. Okay. 

23 MS. THAKKAR: Moving on to lumen maintenance 

24 measurement. DOE proposes that the lumen maintenance 

25 should be measured as specified in LM-80 and TM-21. 
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1 Additionally, DOE proposes to adopt some relevant 

2 guidelines from the Energy Star guidance document for 

3 measuring the lumen maintenance of LED sources. These 

4 guidelines specify that the CCT of all the LED sources 

5 being tested must be the same. Further, the guidance 

6 document provides guidelines on testing three types of 

7 sources that are listed at the bottom of this slide. 

8 For LED lamps that contain both phosphor converted 

9 white and single color LED packages, the LED array 

10 units that are tested should incorporate both types of 

11 LED packages. For LED lamps that contain LED arrays 

12 with either a common phosphor layer over all dyes, or 

13 individual phosphor layers over each dye, the LED 

14 array units that are tested should be the largest LED 

15 array in the lamp and the average current through each 

16 dye in the LED array should be equal to or greater 

17 than the average current through each dye in the lamp.

18 Finally, for LED lamps that contain an LED 

19 array that is an assembly of LED packages with their 

20 own phosphor layer, the temperature at which testing 

21 is done should corresponds to the in-situ temperature 

22 of the hottest package in the array.

23 DOE requests comment on adopting these 

24 guidelines from the Energy Star guidance document for 

25 measuring lumen maintenance of the LED source.
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1 MR. BROOKMAN: Ralph, please.

2 MR. TUTTLE: Sorry. Item one, about 

3 phosphor converted white and single color LED 

4 packages, integrated together in a lamp, is something 

5 that we, in particular are having discussions with EPA 

6 on right now. What this is referring to are LED 

7 sources, if you will, or bulb products, which 

8 incorporate both white LEDs as well as red LEDs in 

9 order to reach a certain chromaticity and CRI. 

10 There’s a question as to whether or not the LM-80 data 

11 from individual red LEDs plus LM-80 data from 

12 individual white LEDs is acceptable, rather than 

13 putting them both together on a board and performing 

14 the LM-80 testing on the board itself. 

15 At this point in time, it’s my understanding 

16 that the EPA has accepted our proposal that both 

17 individual LED data be used. So I think it’s 

18 preliminary right now until we get better definition 

19 from EPA on this.

20 MR. BROOKMAN: And you’re thinking that –

21 oh, you anticipate that what EPA is specifying here, 

22 that will evolve?

23 MR. TUTTLE: Yes, absolutely.

24 MR. BROOKMAN: Okay. Is that sufficient?

25 MS. THAKKAR: Yes. Could you also please 
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1 provide more information on that in your written 

2 comments?

3 MR. TUTTLE: Sure. Absolutely.

4 MS. THAKKAR: Thank you. 

5 MR. BROOKMAN: Okay. Yes, please. Dave.

6 MR. SZOMBATFALVY: Clarification. What 

7 about lamps or replacement lamps that have phosphor 

8 that’s external to the LEDs, in other words, around 

9 the lamp itself, not over the LEDs. Remote phosphors. 

10 Is that covered.

11 MR. TUTTLE: I’m wondering if that’s – it’s 

12 our understanding that’s covered in item two here, 

13 which is LED arrays with either a common phosphor 

14 layer overall.

15 MR. BROOKMAN: Okay. Thank you. That’s 

16 helpful. That’s clarifying.

17 MS. THAKKAR: Okay. So moving on. The 

18 final step in the three step process is to determine 

19 the rated lifetime of the LED lamp, is to project the 

20 lumen maintenance data that was obtained in the 

21 previous step. DOE proposes that the rated lifetime 

22 should be projected as specified in TM-21. If the 

23 projected rated lifetime according to TM-21 is greater 

24 than 25,000 hours, then the rated lifetime should be 

25 25,000 hours. If the projected rated lifetime 
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1 according to TM-21 is less than 25,000 hours, then the 

2 rated lifetime is the projected value. Once the rated 

3 lifetime is determined by this projection method, it 

4 should be calculated in number of years based on three 

5 hours per day of operation as required by FTC for the 

6 lighting facts label.

7 DOE proposes that the rated lifetime should 

8 be rounded to the nearest tenth of a year, for 

9 example, 22.8 years, which is also a requirement for 

10 FTC’s label. 

11 MR. BROOKMAN: Alex.

12 MR. BOESENBERG: Alex Boesenberg, NEMA. 

13 This is another issue we are discussing with FTC, 10.2 

14 year lifetime really isn’t something that consumers 

15 necessarily might embrace, but it’s an issue we are 

16 working on.

17 MR. BROOKMAN: Mark.

18 MR. DUFFY: My previous comment about 

19 resolution comes in really important at this point. 

20 Especially since, in the consumer market, they might 

21 consider that 20.2 and 20.3 are really different 

22 numbers in the consumer market. So I think we have to 

23 think about – something I installed 22 years ago, I 

24 may have sold that home, it might have gone with the 

25 appliances, so the LED is really outliving many of the 
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1 things that we’re –

2 MR. BROOKMAN: Probably outlives the drapes.

3 MR. DUFFY: It outlives the drapes for sure 

4 in my house.

5 MR. BROOKMAN: Thank you. Ralph.

6 MR. TUTTLE: And then again, not to beat a 

7 dead horse, but in fact IES TM-21 does not project 

8 rated lifetime. It projects lumen maintenance.

9 MR. BROOKMAN: Okay. 

10 MS. THAKKAR: Okay.

11 MR. BROOKMAN: Yes, please, John.

12 MR. GREEN: John Green, sorry. The decimal 

13 point might make a difference if the lifetime is 

14 short. I mean, 1.2 years might make sense, but not 

15 22.2 years. So maybe two significant digits is the 

16 way to look at it, rather than tenths of a year or 

17 something like that.

18 MR. BROOKMAN: Okay. Good. Thank you. 

19 MS. THAKKAR: We already heard a lot of 

20 feedback on all these issues, but at this point, if 

21 there are any final thoughts or more feedback on the 

22 proposed test procedure?

23 MR. BROOKMAN: Take a quick peek at 19, 20 

24 and 11, and see if there’s anything else you wish to 

25 contribute at this point. Julia. 
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1 MS. FARBER: We’ve got a clarification 

2 question on UL 1993. It is that the temperature test 

3 apparatus for 1993 is considered a representative 

4 severe test of thermal performance, as the can itself 

5 is very narrow in diameter and allows for very little 

6 heat dissipation. So it’s not an overlay worst case 

7 environment, but it is intended to represent the most 

8 challenging of foreseeable installation applications.

9 MR. BROOKMAN: A severe case. 

10 MS. FARBER: Yes, so it’s supposed to allow 

11 for a worst case scenario installation, I guess, or 

12 the most severe, not the worst case.

13 MR. BROOKMAN: To test for the safety of the 

14 heat. 

15 MS. FARBER: Exactly.

16 MR. BROOKMAN: Okay. 

17 MS. FARBER: So that it’s safe in all 

18 conditions.

19 MR. BROOKMAN: Pam, please. Thank you, 

20 Julia.

21 MS. HORNER: This is Pam Horner with Osram 

22 Sylvania. I just – maybe I missed it, but could you 

23 please just briefly summarize why a 25,000 hour cap? 

24 Thank you. 

25 MS. THAKKAR: So you’re asking why a cap or 
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1 why the number 25,000? Well, the cap was put in place 

2 because there’s so many unknown variables right now, 

3 like we don’t know the driver lifetime, the 

4 interactions of the components, and also the proposed 

5 test procedure is, like you said, not doing the 

6 systems approach, but it’s only looking at the source 

7 and determining the lumen maintenance of the source, 

8 so 25,000 hours is basically put in place to provide a 

9 conservative estimate and not have like a 50,000 or 

10 100,000 years of lumen maintenance, which is just 

11 based on source, when you’re actually going to – when 

12 you put this on FTC’s label, it’s going to represent 

13 the life of the lamp, so 25,000 hours was put as a 

14 conservative estimate to not like give – so that 

15 you’re basically not disappointing the consumer if it 

16 dies before then.

17 MR. BROOKMAN: Keith.

18 MR. COOK: Yeah, Keith Cook. But it’s –

19 it’s still an arbitrary number. I mean, as far as you 

20 know, the driver fails at 12,000 hours. So I think 

21 that you’re better off with nothing, and base it upon 

22 real testing of the system, and that’s what we’ve got 

23 to work on.

24 MR. BROOKMAN: Okay. Mark.

25 MR. DUFFY: So just for the record, on your 
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1 issue 11, everything about that may be okay, but UL 

2 standard 1993 should not be used to determine normal 

3 operating temperature.

4 MR. BROOKMAN: Normal operating temperature.

5 MR. DUFFY: Correct, because that’s what 

6 you’re going to be using to project your lumen 

7 maintenance.

8 MR. BROOKMAN: Yes, because that’s what 

9 Julia just brought to us. Okay. Got you.

10 MS. THAKKAR: I have a follow up question to 

11 that. Would you have some thought on what could be 

12 used to determine the in-situ temperature, if not UL 

13 1993?

14 MR. DUFFY: Well, I may be able to 

15 speculate. I think it would be helpful if I work with 

16 my NEMA compatriots to give you a NEMA response to 

17 that.

18 MS. THAKKAR: Okay. Sure.

19 MR. DUFFY: Did you note that, Alex?

20 MR. BOESENBERG: Yes.

21 MR. BROOKMAN: Okay, so now we’re to sample 

22 size requirements.

23 MS. THAKKAR: DOE proposes that the sample 

24 size requirement for testing the LED source should be 

25 as specified in TM-21, which is necessary for the 
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1 projection method outlined in TM-21 to be valid. At 

2 least ten units should be tested at a given case 

3 temperature and drive current to project the lumen 

4 maintenance data. 

5 DOE requests comment on the proposed sample 

6 size requirements for testing the LED sources.

7 MR. BROOKMAN: We already touched on this a 

8 little. Have we addressed this, or is there more to 

9 be said? Alex.

10 MR. BOESENBERG: Alex Boesenberg. The 

11 previous discussion was about lifetime lumen 

12 maintenance testing. This is a different test, hence 

13 the different – ten appears here versus 21 on the 

14 previous. But what –

15 PARTICIPANT: The 21 was about lamps, LM-79. 

16 This is LM-80. This is sources.

17 MR. BOESENBERG: Yeah. So I don’t know, I 

18 would ask Ralph, what does TM-21 say for sample size?

19 MR. BROOKMAN: Ralph, please.

20 MR. TUTTLE: Actually TM-21 recommends a 

21 minimum of 20 LEDs to be used during LM-80 testing to 

22 allow projections of long term lumen maintenance. We 

23 did allow fewer units to be used, but then reduced the 

24 maximum number of hours that could be projected with 

25 the fewer units. But for a minimum of actually 35,000 
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1 hours, we recommend 20 LEDs.

2 MR. BROOKMAN: Okay. Do we have additional 

3 comments on this point? I see none. Okay. 

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

5 estimated burden to small businesses. DOE is required 

6 to analyze the testing burden to small businesses once 

7 this rulemaking is established. Do you have a 

8 question?

9 MR. COOK: Yeah, I do have a question. 

10 MR. BROOKMAN: Keith, please.

11 MR. COOK: I’m sorry, Keith Cook. 

12 Repeatedly, it seems like the question is whether or 

13 not we should make changes to an already approved 

14 standard, and I’m really concerned that if we follow 

15 that path, it’s going to lead to a lot of confusion 

16 out there, as to which test I’m running and which data 

17 needs to be supplied to who. I think we need to be 

18 consistent and stay with something that’s already been 

19 approved.

20 MR. BROOKMAN: Okay. Thanks for that 

21 comment. Got it. Now to burden on small businesses.

22 MS. THAKKAR: So DOE is required to analyze 

23 the testing burden to small businesses once this 

24 rulemaking is established, and if it is adopted by FTC 

25 for the lighting facts label. To determine this 
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1 burden, DOE estimated the number of small businesses 

2 that manufacture LED lamps in the United States, and 

3 estimated the cost burden to these manufacturers. DOE 

4 estimated that of the 32 manufacturers of LED lamps in 

5 the US, about 17 manufacturers are small businesses. 

6 Further, DOE estimated that these small manufacturers 

7 produce about 17 basic models of LED lamps each. For 

8 these 17 models, DOE estimates a one-time setup cost 

9 of $12,000 to build racks to test the LED lamp. The 

10 cost to test these lamps will be approximately $68,000 

11 for determining input power, lumen output, CCT, and 

12 rated lifetime for the first year. The cost for 

13 subsequent years should be less than $68,000 because 

14 only new products or redesigned products would be 

15 tested. 

16 Finally, in its light bulb rulemaking, FTC 

17 determined that the cost for changing package and 

18 product labeling, as well as the cost for updating 

19 retail catalogues would not impose a significant 

20 burden on small entities. Because the values would 

21 potentially need updating, only for LED lamps, DOE 

22 does not expect this to be a significant burden 

23 either.

24 DOE requests comment on the estimated number 

25 of small businesses impacted by this rulemaking, as 
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1 well as the estimated costs and associated burden to 

2 small businesses by this rulemaking once it is adopted 

3 by FTC.

4 MR. BROOKMAN: Mark.

5 MR. DUFFY: Yeah, this is Mark Duffy. Well, 

6 I don’t work for one of those small manufacturers. 

7 I’m a little concerned by the assumption that they 

8 would want to setup an accredited laboratory to do 

9 this. I suspect that most of those small 

10 manufacturers are going to be sending their product 

11 out for a third party test and receiving certification 

12 of compliance or whatever, to use for their labels.

13 MR. BROOKMAN: Would that mean the cost 

14 would be higher?

15 MR. DUFFY: I don’t know.

16 MR. BROOKMAN: Keith.

17 MR. COOK: I guess I’m not sure where we’re 

18 going with this particular question. If we show undue 

19 burden to the small manufacturers, does that mean they 

20 don’t have to comply with FTC requirements?

21 MR. BROOKMAN: No.

22 MR. COOK: Then this is an academic 

23 question. I don’t understand why we’re even asking 

24 it.

25 MR. BROOKMAN: John. Excuse me. Dave, go 
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1 ahead.

2 MR. SZOMBATFALVY: Yeah, I’m not – you had 

3 mentioned that this – the cost was associated with the 

4 test procedures for input power, lumen, and output –

5 lumen output and CCT. But what about the cost if we 

6 have to execute the test procedure for rated life. I 

7 think that’s a significant cost to a manufacturer, 

8 even like GE, if we need to do that.

9 MR. BROOKMAN: I guess – go ahead.

10 MS. THAKKAR: To clarify, the $68,000 that’s 

11 put there includes the rated lifetime as proposed as 

12 well. The assumption there being that the in-situ

13 temperature measurement test is performed by the 

14 manufacturer, but LM-80 data is typically available, 

15 so you may not have to test the source itself.

16 MR. BROOKMAN: Yes, go ahead, please.

17 MR. SZOMBATFALVY: Yes, I was going down the 

18 path when we don’t have LM-80 data, so there is a 

19 significant cost if we don’t have the LM-80 data to do 

20 that testing that’s proposed.

21 MR. BROOKMAN: Okay. Thanks, Dave. Yes, 

22 Chip.

23 MR. CHIPALKATTI: Chip Chipalkatti. I’m 

24 just asking about the number 17, the magic number 17. 

25 I think that there’s evident and not so evident small 
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1 companies that are present today in this field. 

2 Though I’m not working for a small company, I do have 

3 contact with a lot of them, and I think that might be 

4 an underestimate of how many small companies there 

5 are.

6 MR. BROOKMAN: Underestimate?

7 MR. CHIPALKATTI: Yes.

8 MR. BROOKMAN: Could you speculate? Twice 

9 as many? Ten times as many?

10 MR. CHIPALKATTI: Twice, heading towards ten 

11 times.

12 PARTICIPANT: Are you talking about just US 

13 manufacturers?

14 MS. THAKKAR: Just the US?

15 MR. CHIPALKATTI: Yes, US. And that’s a 

16 speculation, because a lot of these companies are 

17 under the radar, if you will, what you call operating 

18 in stealth mode, and so on, so trying to get into the 

19 market. And I don’t know if that’s a concern at all, 

20 but if the underlying reason for this question is the 

21 impact on innovation and new companies and all of 

22 that, then that should be a matter for further study.

23 MR. BROOKMAN: Okay. I saw both Pekka and 

24 Alex. I think Pekka was first.

25 MR. HAKKARAINEN: Pekka Hakkarainen. I 
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1 wanted to ask our friend Julia, is it from UL, whether 

2 this cost estimate is reasonable for third party 

3 testing? 

4 MR. BROOKMAN: Julia.

5 MS. FARBER: I’ll have to get back to you.

6 MR. BROOKMAN: Alex, please.

7 MR. BOESENBERG: Alex Boesenberg, NEMA. 

8 Relative to the number of small businesses, I would 

9 ask, since he’s not here I can’t ask him, did your 

10 offices ask Jim Brodrick, because he is in direct 

11 contact with hundreds of companies, some of which will 

12 be small.

13 MR. BROOKMAN: Austin, did you have a 

14 comment?

15 MR. GELDER: Yeah, Austin Gelder. ICF 

16 International. I was wondering where the $12,000 

17 estimate came for initial setup, because if you’re 

18 talking about all of the measurement devices to 

19 measure things such as CCT, lumens, power, plus all of 

20 the racks, I could see one piece of equipment costing 

21 $10,000 to set this up for some of these – some of 

22 these small manufacturers who maybe all they’re making 

23 is they came out and they started making LED lamps. 

24 They may not have the lab already in place, so their 

25 cost to set up a lab could be a huge multiple of that.
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1 MR. BROOKMAN: Would you – could you provide 

2 a range? What do you think to have it, to actually 

3 set up a lab, the initial set up, what would it be?

4 MR. GELDER: Oh, you could easily get over 

5 $100,000, between the facilities and all of the 

6 additional equipment and the cost to have someone 

7 trained to run that equipment, because – in addition, 

8 I’m pretty sure we’ve talked about getting accredited, 

9 and that in and of itself ends up being a very 

10 expensive process, both from the accreditation 

11 standpoint, as well as getting the quality management 

12 system in place from a labor perspective.

13 MR. BROOKMAN: I see. Ralph.

14 MR. TUTTLE: A type C goniometer, you’re 

15 probably talking about $200,000. A one meter 

16 integrating sphere with the associated equipment is 

17 easily $100,000. So maybe building racks would cost 

18 $12,000, but that’s about it.

19 MR. HAKKARAINEN: Pekka Hakkarainen. Am I 

20 understanding correctly that small business is defined 

21 as company that has fewer than 500 people, is that the 

22 definition?

23 MS. THAKKAR: It’s – for electric lamps, 

24 it’s actually fewer than 1000 employees. Electric 

25 lamp manufacturers.
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1 MR. BROOKMAN: Oh. Yesterday in the 

2 appliance standard proceeding yesterday, I’m pretty 

3 sure the slide said SBA says under 500. That’s my 

4 recollection.

5 MS. KOHL: This is Betsy Kohl. It depends 

6 on the industry. The SBA has a table of size 

7 standards based on your industry code, and it’s up on 

8 their website if you’re interested in looking at it, 

9 but that’s where we get them from.

10 MR. BROOKMAN: Thank you. The source. 

11 Useful. Okay. So thank you. That was also 

12 illuminating, that information there. Yes. Are there 

13 other follow on questions that you have?

14 MS. THAKKAR: No. I was going to hand it 

15 over to Lucy deButts for –

16 MR. WALKER: We do have one more – sorry, 

17 this is Matthew Walker, Navigant. We do have one more 

18 comment from the webinar, webinar participant. Joel 

19 Jacobson, “the number of models introduced into the 

20 market are increasing rapidly, so cost estimates are 

21 significantly underestimated.”

22 MR. BROOKMAN: Okay. 

23 MR. WALKER: Then we have, regarding set up 

24 cost for testing, from Jacki Swiernik. 

25 “Goniophotometer, $200,000 minimum. Two meter 
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1 integrating sphere with accessories, $60,000 average.” 

2 And that’s all from the webinar.

3 MR. BROOKMAN: Thank you. So at the outset, 

4 we promised you another opportunity to make comments 

5 at the end of the meeting. We’ve arrived at the end 

6 of these presentation slides and the discussion. 

7 Any closing remarks before I turn it back to Lucy? 

8 Nothing here in closing. Okay, back to Lucy.

9 Closing Remarks

10 MS. DEBUTTS: Well, I hope nobody minds that 

11 I’m talking, sitting here and not standing there. 

12 Okay. So I just wanted to thank everyone. This 

13 actually was very good, productive, and helpful. And 

14 to make sure that everybody understands how to reach 

15 us, you know, and submit the written comments, the 

16 slide represents all the information that you need to 

17 have. Several avenues are explained, you know. Of 

18 course, we prefer the electronic method, as usual, 

19 however if it’s not possible, postal service or 

20 courier can be used. And Brenda Edwards, our public 

21 meeting coordinator would be taken care of – she’s 

22 out there somewhere – she will be taking care of the 

23 comments and – as they come in. We will address them 

24 and review them and come back to you if we have 

25 additional questions. So hopefully, it’s okay for us 
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1 to seek some clarification.

Again, comment period ends on June 25th 2 , but 

3 to address the previous concerns, if the comments 

4 that we receive state that DOE needs to give more 

5 time to developing the test procedure as Betsy Kohl 

6 stated, there are avenues of doing that as well.

7 So just want to thank everyone for coming 

8 and see if any other questions are there in the room. 

9 Back to Doug.

10 MR. BROOKMAN: Thanks to all of you. Safe 

11 travels. 

12 (Whereupon, (end time not specified), the 

13 meeting in the above captioned matter was adjourned.)

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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 and 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