2010-08-31 Comment regarding efficacy levels (modification of version submitted 7/08/10)

Subject: Docket number EERE‐2010‐BT‐STD‐0005 and RIN 1904‐AC15 Auto forwarded by a Rule Below are comments relating to the subject above: In the transcript from the May 26, 2010 hearing on the subject matter there is extensive discussion of the efficacy level adopted for PAR lamps in 2009 legislation and whether that efficacy level, EL 5, would be appropriate for ER/BR and small diameter lamps. Much of that discussion centered on two assertions by industry representatives: 1) the beam patterns of ER/BR lamps, as compared to those of PAR lamps, are distinctive and highly desirable in the market place; and 2) LpW efficacies adopted for PAR lamps in 2009 are not physically achievable on ER/BR or small R lamps. Therefore, it was argued, adoption of 2009 levels for ER/BR would force these lamps from the market place, depriving the consumer of a desirable product. One measure of the accuracy of the efficiency argument can be readily had by examining BR, ER and small R products already on the market. One of these, an R 20 product, already exceeds EL 5 if one accepts the lumens, watts and lifetimes on the packaging. Two others, a BR 30 and a BR 40, are just short of the EL5 level. The best of these currently marketed products use aluminum coatings on the lamp envelope and IR reflecting coatings on the incorporated halogen burners. Improvements in both the reflector and the coated halogen burners are readily achievable. For the reflective coating, high quality Al or Ag should be considered, as the DOE is now doing. For the halogen burner, IR coated products used in PAR lamps and now A‐line lamps, can be directly transferred to ER/BR and small R products. The question remaining concerns higher efficacy levels achievable for these IR coated burners. If one selects an IR ER/BR coated product on the market, removes the IR coated burner from its reflective envelop and measures the LpW of the bare burner, one sees, as examples, about 22 LpW and 25 LpW efficacies for 40 W and 60 W burners respectively. Efficiencies of 30 LpW and higher are readily achievable with present IR coatings on similar burners. Use of such IR coatings, especially in conjunction with silver or improved Al refectors, readily achieves EL 5 levels. Futher discussion by contacting the undersigned is welcome. Norman Boling Deposition Sciences Inc. Santa Rosa Ca. 707 573 6713