1. AHAM-PTI Comments CEC Test Procedure April 8, 2008 1

2. CEC Test Procedure AHAM will confine its comments to household-appliance battery chargers. We cannot comment on industrial-commercial chargers (fork lifts, wheelchairs, golf carts). AHAM will confine its comments to household-appliance battery chargers. We cannot comment on industrial-commercial chargers (fork lifts, wheelchairs, golf carts). Our members have nearly 50 years each of experience producing battery powered rechargeable products and battery chargers. Our members have nearly 50 years each of experience producing battery powered rechargeable products and battery chargers. 2

3. PGE-Ecos Test Procedure AHAM appreciates the work of PGE and Ecos on the Test Procedure AHAM appreciates the work of PGE and Ecos on the Test Procedure This test procedure contains the basics of measurement of battery charger energy This test procedure contains the basics of measurement of battery charger energy We appreciate the suggestion that industrial chargers are different from household chargers We appreciate the suggestion that industrial chargers are different from household chargers No major issues on measurement No major issues on measurement 3

4. Our commentary We have addressed the CEC in the past about our concerns and recommendations regarding BCS regulation We have addressed the CEC in the past about our concerns and recommendations regarding BCS regulation While we have begun to consider possible approaches we have restricted our comments to the test procedure While we have begun to consider possible approaches we have restricted our comments to the test procedure Represents the Phase I objectiveRepresents the Phase I objective 4

5. General AHAM and PTI represent manufacturers of appliances and power tools AHAM and PTI represent manufacturers of appliances and power tools PGE/Ecos test procedure attempts to address a broad range of product categories PGE/Ecos test procedure attempts to address a broad range of product categories AHAM/PTI have previously requested separate regulation of appliances AHAM/PTI have previously requested separate regulation of appliances We can only comment on the suitability of the procedure to appliances including tools We can only comment on the suitability of the procedure to appliances including tools 5

6. Scope Appliance battery charging systems Appliance battery charging systems “system” should be defined in Title 20“system” should be defined in Title 20 Employing detachable or integral batteries Employing detachable or integral batteries Detachable – removed from appliance for chargingDetachable – removed from appliance for charging Integral – non-removable, charged in applianceIntegral – non-removable, charged in appliance 6

7. Definitions Need specific definitions in Title 20 for appliance battery chargers Need specific definitions in Title 20 for appliance battery chargers (u1) for industrial-commercial battery chargers(u1) for industrial-commercial battery chargers (u2) for appliance battery chargers(u2) for appliance battery chargers To take precedence over those in the test procedure To take precedence over those in the test procedure 7

8. Measurements - general Concern about sampling errors Concern about sampling errors Increasing concern with technology advancementIncreasing concern with technology advancement Recommend approach of C381.2Recommend approach of C381.2 Test at 115V/60Hz only Test at 115V/60Hz only All our BCS’s are powered as such in CAAll our BCS’s are powered as such in CA Concern about access to battery Concern about access to battery Providing for technician safety while maintaining design confidentialityProviding for technician safety while maintaining design confidentiality 8

9. Specific measurements E24 – simplification: conduct all tests for 24 hours E24 – simplification: conduct all tests for 24 hours Maintenance – simplification: always use last 4 hour Maintenance – simplification: always use last 4 hour Except if periodicity of cycle introduces error (see above)Except if periodicity of cycle introduces error (see above) 9

10. Specific measurements “No battery – reference previously as “standby” “No battery – reference previously as “standby” Detachable – remove battery, measure average power as in procedureDetachable – remove battery, measure average power as in procedure Integral –Integral – Connector between separate power unit (e.g. wall adapter) and product – disconnect Connector between separate power unit (e.g. wall adapter) and product – disconnect AC power cord – zero power AC power cord – zero power 10

11. Battery energy Manufacturers to report energy in Watt Hour Manufacturers to report energy in Watt Hour Manufacturers use Ecos methodManufacturers use Ecos method But – discharge suspended if there is electronic cut-off before end-of-discharge voltage But – discharge suspended if there is electronic cut-off before end-of-discharge voltage Related to newer battery design, especially Li-ion Related to newer battery design, especially Li-ion Simplification: no need to determine Amp Hour capacity Simplification: no need to determine Amp Hour capacity 11

12. Power factor Has no significance to energy efficiency of appliance battery charging systems Has no significance to energy efficiency of appliance battery charging systems No demonstrated need for regulationNo demonstrated need for regulation Simplification – eliminate test for these productsSimplification – eliminate test for these products 12

13. Reporting Report only the data needed for the standard on test report Report only the data needed for the standard on test report Report battery energy in Watt hours Report battery energy in Watt hours Consistent with new UN/DOT requirements for Li-ion batteries shipped by airConsistent with new UN/DOT requirements for Li-ion batteries shipped by air Remove calculation of “efficiency” in test method Remove calculation of “efficiency” in test method Reserved for standard levelReserved for standard level 13

14. Next steps AHAM and PTI continue to offer our willingness to work with CEC staff on appliance standard framework AHAM and PTI continue to offer our willingness to work with CEC staff on appliance standard framework Sets specifics of testing for our productsSets specifics of testing for our products We could provide data based on the specific test requirements We could provide data based on the specific test requirements Believe acceptance criteria should be established from this data Believe acceptance criteria should be established from this data 14

15. CEC Test Procedure The test procedure must be finalized before we can proceed to: The test procedure must be finalized before we can proceed to: Data CollectionData Collection RegulationRegulation 15

16. Thank you 16