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AT&T: Regulation ‘Premature’

Defer Regulations on Set-top Boxes, Embrace Energy Star, CEA tells DOE

The Department of Energy should “defer” pursuit of “conventional regulation” of set-top boxes and instead “participate in and support” the Energy Star program for the devices, the CEA said in comments. Besides being difficult to “properly define,” the boxes are “evolving in numerous ways that affect total power consumption of the household configuration … making single-product regulation possibly improperly focused and even counterproductive to overall energy efficiency,” the group said.

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"Federal regulation in the form of appliance efficiency standards may well be obsolete and technically inappropriate before it becomes effective three years after being published in the Federal Register,” the CEA said. The DOE made a tentative finding that set-tops and network equipment are covered products under the Energy Act, potentially subjecting them to energy conservation standards and labeling requirements (GED June 17 p1).

The Energy Star program has “kept pace so far with the rapidly-evolving set-top market by adding new feature support, revising the levels of feature allowances, redefining definitions of allowance categories, and updating test procedures about every two years in order to keep pace with the changes in this dynamic market,” the CEA said. About 100 models qualified for Energy Star version 2.0 and version 3.0 that took effect in September, prescribing a reduction of 30 percent in energy use compared with the previous specification, it said. More than 20 boxes “representing every box type,” are already qualified for version 3.0, it said.

If all set-tops in the U.S. are Energy Star qualified, they would save consumers $1.8 billion a year and help reduce greenhouse gas emissions equivalent to those from 2 million vehicles, the CEA said, quoting EPA estimates. “CEA strongly supports the Energy Star approach since it rewards energy efficiency innovation, accelerates deployments through the Energy Star service provider program, and is flexible enough to accommodate market, technological and consumer requirements.” The DOE should “fully embrace” Energy Star by working with service providers and box makers to “develop programs” that increase both the deployment of Energy Star products and consumer awareness of Energy Star service providers and box makers, it said.

A CEA standards committee is writing a new standard -- CEA 2043 -- that would combine the group’s two standard test procedures for measuring set-tops in active mode (CEA 2022) and standby mode (CEA 2013), the group said. The new standard will be aligned with the recently released IEC-62087 standard, it said. The CEA also has commissioned a “product-by-product” revision of a 2006 study on power consumption of CE products in households, it said. “Our analysis of set-top boxes is nearly complete,” and CEA will provide DOE with a “final version” of the study once it’s finished, it said.

The energy use of AT&T’s set-tops can’t be “further” substantially reduced without a “significant adverse effect on consumer experience,” the company said. More than 3 million customers get AT&T’s IPTV service, and all of them get the service using an Energy Star certified set-top, the company said.

"Mandating further energy efficiency improvements without sufficient regard to currently available technology, cost and consumer acceptance will be disruptive to an increasingly competitive market for video entertainment services,” AT&T said. The CEA is working on “technology solutions for lowering” power use of the boxes and TVs, it said. “Regulatory intervention may discourage or halt such independent and productive efforts.” The “proposed regulation” of the boxes and network gear is “unnecessary,” it said.

Regulation of set-top boxes (STB) is “premature,” AT&T said. If the DOE decides to proceed, the “proposed definition of STB should be significantly limited,” it said. Any federal conservation standards must be “in synch” with Energy Star program specifications and “minimums should be set at much lower levels” than Energy Star because “standards of a voluntary program can be aspirational as opposed to those that are mandated by regulation,” the company said. The DOE also should restrict regulations to “single function devices which tend to be the most mature technology,” it said. As for advanced STBs with multifunction and networked technology, the DOE should defer regulations “until after Energy Star has had sufficient time” to collaborate with industry to design energy efficiency “targets on a whole-house basis,” AT&T said.

The DOE can best promote energy conservation by consumer education about “energy saving choices they can make and by encouraging businesses to support important voluntary program such as Energy Star,” AT&T said.