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ENERGY STAR Criteria for CFLs Partner & Stakeholder Meeting

ENERGY STAR Criteria for CFLs Partner & Stakeholder Meeting. U.S. Department of Energy April 29, 2003 ~ Washington, D.C. Richard Karney, U.S. Department of Energy Ron Lewis, U.S. Department of Energy. Mission of the ENERGY STAR CFL Criteria.

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ENERGY STAR Criteria for CFLs Partner & Stakeholder Meeting

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  1. ENERGY STAR Criteria for CFLs Partner & Stakeholder Meeting U.S. Department of EnergyApril 29, 2003 ~ Washington, D.C. Richard Karney, U.S. Department of EnergyRon Lewis, U.S. Department of Energy

  2. Mission of the ENERGY STAR CFL Criteria • To provide specific parameters and direction to produce high quality, highly efficient CFLs for residential applications that are steps above the norm.

  3. Why Revise the ENERGY STAR Criteria for CFLs Now? Reason 1: • With the CFL qualified product list growing by leaps and bounds, the time is right to raise the bar

  4. Growth of ENERGY STAR Qualified CFLs

  5. Why Revise the ENERGY STAR Criteria for CFLs Now? Reason 2: • ENERGY STAR wants to continue to drive the market to offer the highest quality products – keep the integrity of the what the label stands for Reason 3: • Through the required qualification testing and 3rd party testing by PEARL, we are still finding issues with some CFLs meeting lumen maintenance and interim life time tests at 40% of life and rated lifetime.

  6. ENERGY STAR CFL Program and PEARL Testing PEARL testing provides clear picture to verify qualified CFLs in the marketplace are continuing to meet the ENERGY STAR Criteria requirements. • Cycle 1: ENERGY STAR used the PEARL data as a “litmus test” – follow-up with partners that had poor results and encouraged product improvements to rectify problems. • Cycle 2: Products tested against the original and current ENERGY STAR Specifications (included 1,000-hour lumen maintenance & rapid cycle stress test). • ENERGY STAR sent a letter to all partners to provide clear message program would act on poor PEARL results • Sent letters to specific partners that had poor test results and strongly encouraged them to “voluntarily de-list” their product – 3 were unqualified and other partners submitted verification that the product’s issues were rectified.

  7. ENERGY STAR CFL Program and PEARL Testing, continued • Cycle 3 and Beyond: For Cycle 3, ENERGY STAR is contacting partners who had products tested to review the results and again, are encouraging partners to voluntarily remove poor performing products from carrying the ENERGY STAR logo. • Partners who have products with extensive criteria failures, especially for the 40% lumen maintenance requirement, will be contacted and informed their product will be immediately removed from the CFL qualified product list.

  8. History of the ENERGY STAR CFL Specification • Program and Specification was established in 1999 • Initial Specification established the baseline for efficiency testing criteria since there is no federal regulation covering CFLs • Most important data collected was: • Efficacy (lumens/watt) • Lumen Maintenance at 40% of the model’s rated life* • Average Rated Lifetime Test* *Partners were given an 18-month grace period from their initial qualification date to complete these two tests

  9. History of the ENERGY STAR CFL Criteria Revision Process • In March 2001, ENERGY STAR held a partner/stakeholder meeting to discuss upgrading the Specification • Topics discussed were: • lumen equivalency • Efficacy • Early failures on lumen maintenance and average rated life tests • Protocol for “de-listing” a qualified model • Based on the meeting and partner comments, the Criteria was updated and was put into effect in October 2001

  10. Important Additions to the 2001 Criteria Version Required Testing Requirements: • Rapid Cycle Stress Test: • Must meet 5 out of 6 cycles • provides early warning for early life time failure • 1,000 Hour Lumen Maintenance Test: • Must meet or exceed 90% lumen maintenance at 1,000 hours • Provides early warning for lumen maintenance issues • Interim Lifetime Testing: • Must have at least 8 out of 10 samples burning at 40% of rated life; 3 or more failures result in immediate unqualification

  11. ENERGY STAR Qualified CFLs – Current Criteria Development Process Criteria Development from December 2002 to today: • Ongoing process – DOE is open to all partners’ views and thoughts on how to make the program better. • Partner and stakeholder comments and thoughts were collected throughout the period. • Criteria revisions include other comments and suggestions that were received in addition to the official comments that were submitted.

  12. Current Criteria Review Ron Lewis U.S. Department of Energy

  13. ENERGY STAR® Program Requirements for CFLsPartner Commitments – Page 1 Opening Statement: The following are the terms of the ENERGY STAR Partnership Agreement as it pertains to the manufacturing and/or distributing of ENERGY STAR qualified CFLs. Bullet 3: Qualify, or private label at least one ENERGY STAR qualified CFL model within one year of activating the CFL portion of the agreement. When PARTNER qualifies the product, it must meet the criteria in effect at that time Bullet 4: Once the PARTNER submits its first qualified model to ENERGY STAR, the PARTNER’s company name will be listed as an ENERGY STAR PARTNER (http://www.energystar.gov);

  14. ENERGY STAR® Program Requirements for CFLsPartner Commitments – Page 1 Bullet 9 - Shipment Data: • Provide to DOE, on a bi-annual basis, unit shipment data or other market indicators to assist in determining the market penetration of ENERGY STAR CFLs. Specifically, PARTNER must submit the total number of ENERGY STAR qualified CFLs shipped (in units by model) or an equivalent measurement as agreed to in advance by DOE and PARTNER. PARTNER is also encouraged to provide ENERGY STAR qualified unit shipment data segmented by meaningful product characteristics (e.g. bulb type/style) total unit shipments for each model in its product line, and percent of total unit shipments that qualify as ENERGY STAR. The data for each half of the calendar year should be submitted to DOE, preferably in electronic format, no later than March 31st (for second half of the year) and July 31st (for first half of the year),and may be provided directly from the PARTNER or through a third party. The data will be used by DOE only for program evaluation purposes and will be closely controlled. If requested under the Freedom of Information Act (FOIA), DOE will argue that the data is exempt. Any information used will be masked by DOE so as to protect the confidentiality of the PARTNER;

  15. ENERGY STAR Eligibility CriteriaEnergy-Efficiency Specification – Page 3 Current Criteria – 8/9/01: Scope: This ENERGY STAR CFL specification covers the requirements for self-ballasted, screw-based CFLs and lamp systems, comprising: A. Single-based, bare compact fluorescent lamps with integral electronic ballasts; B. Circle and square lamps with a maximum diameter of 9 inches or a maximum side length of 8 inches and having electronic ballast adapters that are tested and packaged with the lamp; C. Single based compact fluorescent lamps with integral electronic ballasts and which have a translucent cover over the bare fluorescent tube. The cover may be globe, bullet, pear or other shape; D. Single based compact fluorescent lamps with integral electronic ballasts and which have a reflector that may be open or enclosed. The lamp shall be primarily intended to replace wide beam incandescent reflector lamps. Draft Criteria – 4/15/03:Scope: This ENERGY STAR CFL Criteria covers the requirements for self-ballasted, screw-based CFL and lamp systems, including: A. Medium-based, compact fluorescent lamps with integral electronic ballasts; B. Circline lamps with a maximum diameter of 9 inches and square lamps, with a maximum side length of 8 inches with medium base electronic ballasts that are tested and packaged with the lamp. C. Medium-based compact fluorescent lamps with integral electronic ballasts, which have a translucent cover over the bare fluorescent tube. The cover may be globe, bullet, pear, torpedo, or any other shape. D. Medium-based compact fluorescent lamps with integral electronic ballasts, which have a reflector that may be open or enclosed. The lamp shall be primarily intended to replace wide beam incandescent reflector lamps.

  16. ENERGY STAR CFL Eligibility CriteriaReference Standards – Page 4

  17. ENERGY STAR CFL Eligibility CriteriaPhotometric Requirements – Page 5 EFFICACY LEVELS:Efficacy Levels in 3/15/03 draft remain the same as current criteria.

  18. 4/15/03 Draft Text: 10 units per model – 5 base-up/5 base-down unless specific use or position restricted by the manufacturer. If position restricted, manufacturer must test all 10 samples in restricted position (i.e. – reflector lamp used in recessed cans – must test all 10 samples in base up position) Current Specification Text: A minimum of five (5) lamps tested in the base up position unless the product is labeled as a position-restricted by the manufacturer. If position restricted, test lamps in specified position. ENERGY STAR CFL Eligibility CriteriaPhotometric Requirements – Page 5 SAMPLE SIZE REVIEW:

  19. 4/15/03 Draft Text: Average of 10 lamps must be greater than 90.0% of initial (100-hour) lumen output @ 1,000 hours of rated life. Current Specification Text: The average of at least 5 lamps must be a minimum 90% of initial (100-hour) lumen output @ 1,000 hours of rated life. ENERGY STAR CFL Eligibility CriteriaPhotometric Requirements – Page 5 1,000-HOUR LUMEN MAINTENANCE:

  20. Current Specification Text:Between 2700K and 3000K. If not, packaging should clearly state temperature and color of product (cool or warm).Laboratory Requirement:Self-Certification 4/15/03 Draft Text:Average of 10 samples must be one of the following discreet temperatures:2700K2850K3000K4100K 6500Kand the exact temperature must be displayed on the packaging.Laboratory Requirement:NVLAP only ENERGY STAR CFL Eligibility CriteriaPhotometric Requirements – Page 5 CORRELATED COLOR TEMPERATURE:

  21. 4/15/03 Draft Text: Average of 10 samples must be greater than 80.0% of initial (100-hour) lumen output at 40% of model’s rated life (per ANSI C78.5, Clause 4.10) Current Specification Text: 80% of initial (100-hour) lumen output at 40% of rated life (per ANSI C78.5, Clause 4.10) ENERGY STAR CFL Eligibility CriteriaPhotometric Requirements – Page 5 LUMEN MAINTENANCE AT 40% OF RATED LIFE:

  22. 4/15/03 Draft Text: • Efficacies are based on measured values for lumens and wattages from pertinent test data. • Wattages and lumens placed on packages may not be used in calculation and are not governed by this criteria. • For multi-level, such as 3-way, or dimmable systems, measurement must be at the highest wattage setting listed for model. • Acceptable efficacy and lumen output measurement error is - 3%. • Current Specification Text: • Efficacies are based on measured values for lumens and wattages from pertinent test data. • Wattages and lumens placed on packages may not be used in calculation and are not governed by this specification. • For multi-level or dimmable systems, measurement shall be at the highest setting. • Acceptable measurement error is +/- 3%. ENERGY STAR CFL Eligibility CriteriaPhotometric Requirements – Page 5 FOOTNOTE2- EFFICACY:

  23. ENERGY STAR CFL Eligibility CriteriaElectrical Requirements – Page 6 TRANSIENT PROTECTION: Current Specification Text: Per ANSI/IEEE C62.41, Category A, 7 strikes Sample Size:A minimum of five (5) lamps tested in the base up position unless the product is labeled as a position-restricted by the manufacturer. If position restricted, test lamps in specified position. Must be unique sample for this test only. Laboratory Requirement:Use NVLAP or A2LA4 accredited labs or manufacturer may self test and self certify. 4/15/03 Draft Text: Per ANSI/IEEE C62.41, Category A, 7 strikesNote: one failure to meet 7 strikes will result in test failure and therefore, failure to meet the Criteria. Sample Size:A minimum of five (5) lamps tested in the base up position unless the product is labeled as a position-restricted by the manufacturer. If position restricted, test lamps in specified position Must be unique sample for this test only. Laboratory Requirement:Use NVLAP or A2LA4 accredited labs.

  24. 4/15/03 Draft Text:Product packaging must state “Warranty” (and not “guarantee” or any other term), Warranty must cover at least 24 months (2 years) from date of purchase, An 800 number, or address or e-mail address for consumer complaint resolution. ENERGY STAR CFL Eligibility CriteriaLifetime Performance Requirements – Page 7 WARRANTY INFORMATION: Current Specification Text:At least 12 months from date ofpurchase, and an 800 number, or address for consumer complaint resolution.

  25. 4/15/03 Draft Text:In English, or English with additional languages. Packaging must meet FTC 16CFR Part 305.1-.19. ENERGY STAR logo must be located on the front of the packaging. Current Specification Text:In English, or English with additional languages. Label must meet FTC 16CFR Part 305.1-.18.8 Inclusion of an incandescent equivalence is optional.9 ENERGY STAR CFL Eligibility CriteriaLifetime Performance Requirements – Page 7 LABELING/PRODUCT PACKAGING INFORMATION:

  26. 4/15/03 Draft Text:Partner must use the chart below to declare an incandescent equivalency based on the initial average 100-hour lumen output measurement. If the luminous flux falls outside of the specified range, either do not display an incandescent equivalence or display the lower incandescent wattage equivalence. Current Specification Text:Not included as a requirement in this Criteria; was optional. ENERGY STAR CFL Eligibility CriteriaLifetime Performance Requirements – Page 7 CFL/INCANDESCENT EQUIVLANCY9:

  27. ENERGY STAR CFL Eligibility CriteriaLifetime Performance Requirements – Page 7 CFL/INCANDESCENT EQUIVLANCY9: 9 If displaying an incandescent equivalence for commonly used A-shaped bulbs, the CFL’s initial luminous flux must meet the following levels. The table shows typical luminous flux for A-shaped, soft white, incandescent bulbs. Based on research conducted by NLPIP, luminous flux varies considerably among bulbs. The table below is intended to aid in consumer choice and in no way supercedes or replaces any requirement for product performance contained in this specification. If the luminous flux falls outside of the range, either do not display an incandescent equivalence or display the lower incandescent wattage equivalence. IF displaying an incandescent equivalent for Globe, Reflector, or Decorative type bulbs, the initial luminous flux for both the CFL and the appropriate Globe, Reflector, or Decorative incandescent bulb must be displayed side by side in a comparison panel, along with the wattage ratings for both the CFL and incandescent bulb.

  28. CFL/INCANDESCENT EQUIVALANCY TABLE: ENERGY STAR CFL Eligibility CriteriaLifetime Performance Requirements – Page 7

  29. 4/15/03 Draft Text (not in the 12/12/02 draft):Per ANSI C78.5 and IESNA LM-65 (clauses 2,3,5, and 6) Exception: cycle times must be5 minutes on, 5 minutes off.Lamp will be cycled once forevery two hours of rated life. At least 5 lamps must meet orexceed the minimum number ofcycles. Sample Size:6 units, base up or down as stated by manufacturer, must be unique sample for this test only. Current Specification Text:Per ANSI C78.5 and IESNA LM-65 (clauses 2,3,5, and 6) Exception: cycle times must be 5 minutes on, 5 minutes off. Lamp will be cycled once for every two hours of rated life. At least 5 lamps must meet or exceed the minimum number of cycles. Sample Size:6 units, base up or down as stated by manufacturer, must be unique sample for this test only ENERGY STAR CFL Eligibility CriteriaLifetime Performance Requirements – Page 7 RAPID CYCLE STRESS TEST:

  30. 4/15/03 Draft Text:@ 40% of rated life report on lamp life: • One failure, acceptable- Two failures, does not qualify • Sample Size:10 units per model, 5 base-up/ 5 base-down, unless specific use or position appears on packaging. Interim and final average rated lifetime tests must use the same samples. • Current Specification Text:@ 40% of rated life report on lamp life: • One failure, acceptable- Two failures, requires justification- Three failures, immediate de-listing • Sample Size:10 units per model, 5 base up/ 5 base down, unless specific use or position appears on packaging ENERGY STAR CFL Eligibility CriteriaLifetime Performance Requirements – Page 7 INTERIM LIFE TEST:

  31. 4/15/03 Draft Text:> 6,000 hours as declared by the manufacturer on packaging and qualification form. Partner must complete lifetime test to stated lamp life on packaging (i.e. – if CFL is marketed as a 10,000 hour CFL, it must complete the life time test to 10,000 hours).Sample Size:10 units per model, 5 base-up/ 5 base-down, unless specific use or position appears on packaging. Interim and final average rated lifetime tests must use the same samples. Current Specification Text:> 6,000 hours as declared by the manufacturer on packaging. At 80% of rated life, statistical methods may be used to confirm lifetime claims based on sample performance. Sample Size:10 units per model, 5 base up/ 5 base down, unless specific use or position appears on packaging ENERGY STAR CFL Eligibility CriteriaLifetime Performance Requirements – Page 7 AVERAGE RATED LAMP LIFE TEST:

  32. ENERGY STAR CFL Eligibility CriteriaCertification – Page 8 Current Specification Text: Manufacturers shall certify that ENERGY STAR qualified compact fluorescent lamps and lamp systems sold using the ENERGY STAR label have:1) Been tested and third party listed to UL Standard 1993 by a Nationally Recognized Testing Laboratory (NRTL) accredited by Occupational, Safety, and Health Administration (OSHA),2) Met the manufacturers’ declared performance criteria,3) Meet or exceed the minimum performance criteria contained in this ENERGY STAR specification for the characteristics shown above. 4/15/03 Draft Text:Manufacturers shall certify that ENERGY STAR qualified compact fluorescent lamps sold using the ENERGY STAR label have:1) Been tested and third party listed to UL Standard 1993 for Self-Ballasted Lamps and Lamp Adapters by a Nationally Recognized Testing Laboratory (NRTL) accredited by Occupational, Safety, and Health Administration (OSHA),2) Meet the manufacturers’ declared performance and use criteria that is found on the packaging,3) Meet or exceed the minimum performance criteria contained in this ENERGY STAR Specification for the characteristics shown above.

  33. ENERGY STAR CFL Eligibility CriteriaQualification Process – Page 8-9 Current Specification Text:Alternative 1: Full Qualification. Manufacturer may submit, up front, all data indicating that a new or previously tested, listed, or labeled model meets the specification.Alternative 2: Early Labeling. This alternative requires three testing stages, Initial, Interim, and Full qualification, but allows the manufacturer to label the model after pre-qualification testing results have been verified. • 4/15/03 Draft Text:Manufacturers can submit their CFL for ENERGY STAR qualification by the following 2-step procedure: • Initial Qualification (submission of all tests up to 40% of rated life)- Full Qualification (submission of completed average rated lamp life test)

  34. Current Specification Text:Manufacturers and other ENERGY STAR partners may cross-list products by completing a Private Labeler qualification form (available from your account manager). The privately labeled products, or products with different model numbers, fall under the same quality assurance and de-listing protocol as the originally tested model. 4/15/03 Draft Text: AdditionsPackaging for Private Labeled CFLs: Partners must submit packaging proofs for each of their privately labeled CFLs with the exact information (wattage, lumen output, rated lifetime, equivalency, etc.) their supplier has submitted to ENERGY STAR, since the products is exactly the same. If packaging is submitted with incorrect information, the model will not be qualified as ENERGY STAR until the correct packaging has been submitted. Changing of Qualified CFL Supplier: Partners are required to inform ENERGY STAR within 30 days of changing their supplier of one or more of their privately labeled CFLs. Partners must submit a new Private Labeler Form and new product packaging for each product to reflect the updated information. ENERGY STAR CFL Eligibility CriteriaPrivate Labeling Products – Page 9

  35. Current Specification Text:Within 5 business days of receiving all appropriate test results, ENERGY STAR shall confirm that a model meets the specification and provide the manufacturer with authorization to use the ENERGY STAR certification mark. ENERGY STAR shall list the qualified model on the web site. All labeling must be in accordance with ENERGY STAR logo use guidelines found in the Partnership Agreement and on the web site. Packaging and promotions using the label should be submitted to ENERGY STAR for final review and approval. 4/15/03 Draft Text: AdditionsAll partners who are qualifying a CFL must submit electronic or hard-copy labeling and packaging samples for the specific CFL model. Packaging must include the following information to be reviewed for qualification requirements: model number, wattage, lumen output, average rated lifetime, warranty/800 number or address, equivalency to incandescent, starting temperature, electromagnetic interference, compatibility with controls. Failure to meet the packaging requirements of the Criteria will delay the qualification process. No new models will be qualified until all packaging requirements are met. The specific qualified model must be distributed within this approved product packaging. If products are found being sold or distributed in alternative non-approved packaging, that model will be immediately unqualified from the ENERGY STAR for failure to meet the Criteria. If a partner has multiple cases where products are being sold in unapproved packaging, then it may result in their ENERGY STAR Partnership Agreement to be terminated. ENERGY STAR CFL Eligibility CriteriaLabeling & Product Packaging Review – Page 9

  36. ENERGY STAR CFL Eligibility CriteriaLabeling & Product Packaging Review – Page 9 4/15/03 Draft Text Packaging Addition: Commercial packaging of products - Qualified CFL products that will be bulk packaged for commercial sales must submit a package proof for the container that the qualified products will be shipped in and that clearly displays all of the required criteria to fulfill the packaging requirements for ENERGY STAR. Note: Those partners found distributing qualified CFL products in unidentified packaging or white boxes will be contacted immediately and may immediately have that specific model unqualified from the program.

  37. Current Specification Text:De-listing of a model may result from evidence of non-compliance with the ENERGY STAR partnership agreement and/or specification. If a product is de-listed the manufacturer must wait six months from the date of the de-listing to re-submit that model, qualify any other new or existing model, or private label an existing qualified model. A pattern of de-listings may result in termination of the partnership agreement. 4/15/03 Draft Text: AdditionsUnqualification, or de-listing, of a model may also result from evidence of non-compliance with the ENERGY STAR partnership agreement and/or criteria. If a product is unqualified, the manufacturer must retest that specific model and complete ALL criteria requirements before it will be reviewed for ENERGY STAR qualification status again. If a partner submits a new CFL product under a previously qualified model number and has not completed the full qualification set of tests, the program will not accept the test information. In addition, a pattern of de-listings may result in termination of the partnership agreement. ENERGY STAR CFL Eligibility CriteriaQuality Assurance/Retirement of Products – Page 10

  38. ENERGY STAR CFL Eligibility CriteriaQuality Assurance/Retirement of Products – Page 10 CLARIFICATIONS FROM 12/12/02 VERSION: Should a product be unqualified, or de-listed, the manufacturer, distributor, or retailer must cease use of the ENERGY STAR logo on the model’s packaging, product’s web site, and other marketing materials. Partners found with unqualified product out in the market still identified as ENERGY STAR will receive a logo use violation letter and may face the possible termination of the partner’s Partnership Agreement. Removed: When a product is unqualified, the partner has a 60-day “grace period” from the date of notice to complete any utility or Regional Energy-Efficiency Program Sponsor (REPS) rebate program, or begin to phase out the specific model from any utility or REPS rebate if special deal promotion will run longer than 60 days. The partner is responsible for resolving any resulting issues with retailers and REPS after this 60-day grace period has ended.  Result: No grace period means once a model is identified as unqualified, then it is unqualified, no questions asked.

  39. ENERGY STAR CFL Eligibility CriteriaQuality Assurance/Retirement of Products – Page 10 ADDITION FROM 12/12/02 VERSION: Retirement/Discontinuation of Products: Partners who are discontinuing or retiring a model need to submit to their ENERGY STAR account representative a formal letter stating the specific date this model will be out of the marketplace so it can be identified on the qualified product list as “unqualified”, since it will no longer be available.

  40. ENERGY STAR CFL Eligibility CriteriaEffective Date – Page 10 Current Specification Text:The effective date for the Energy Star Program Requirements for CFLs is October 1, 2001, and replaces all previous versions. At this time, manufacturers that qualified products that meet the former specification must submit average rated life and lumen maintenance data by their 18-month due date or byJuly 1, 2002(whichever date comes first) in order to remain qualified. Manufacturers that have received full Energy Star qualification prior to October 1, 2001, will be considered in compliance with the new Specification and therefore, do not need to submit any new testing data. 4/15/03 Draft Text: The effective date for the ENERGY STAR Program Requirements for CFLs will be determined at a later date and replaces all previous versions. On TBD, those partners who qualified products based on the older version of the CFL Criteria and have outstanding test data still due will be required to continue testing based on issued due dates they received in their initial qualification letter. Any partner who fails to submit test data according to their due dates for specific model(s) will have their products immediately removed from the qualified product list for failure to complete the full qualification process. At this time, partners who have products that have met full qualification under the former Criteria and received a full qualification from ENERGY STAR will remain qualified.

  41. ENERGY STAR CFL Eligibility CriteriaEffective Date – Page 10 Suggested Timing of new Criteria Roll-out: • Official Comments due to DOE by May 16th • DOE Review of comments through May 31st • 3rd and final draft criteria distributed on June 2nd • Effective Date – October 1, 2003 • Models still in process of testing would follow older criteria version – complete their submission process • Other thoughts?

  42. ENERGY STAR CFL CriteriaNext Steps • Overview of the topics discussed during this meeting will be developed and distributed to all partners for their use • Any official partner and stakeholder comments can be submitted to DOE – by May 31th to: • Richard Karney, Richard.karney@ee.doe.gov • Ron Lewis, Ronald.lewis@ee.doe.gov • Susan Gardner, sgardner@drintl.com • After review of this meeting’s discussion and official comments, the 3rd draft criteria distributed the first week of June • DOE may follow-up with specific partners and/or stakeholders if further clarification or additional information is needed to finalize part of the version of the criteria

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