Test ) Procedur
Contents
1. or if not supported view on a Client mode as defined in section 2 25 2 of the NOPR Text will also be added to clarify that devices b Momentarily lt 1 sec press the Some clients may require a short period of time are to be placed into Sleep Mode without Power button on the remote foreach before they actually enter a lower power indicating it must be done with a remote locally connected Display Device and consumption mode If more than one display control button since any means of placing a Client device is locally connected to the STB press the device in Sleep mode is acceptable c Do not use or move the UUT Power button for the additional locally remote control after step b connected display devices and stream content to d Begin the elapsed time measurement one display device only e Wait until the UUT power consumption equals PSLEEP 8 3 4 0 5W 0 0W f Record the power consumption as PON _to_SLEEP over a sufficient period of time to assure that the UUT has entered SLEEP and record the elapsed time as TON_to_SLEEP Tl Disagree 8 4 1 OFF Off Mode Power Measurement Tester instructions outside the scope of a a Place the UUT in OFF mode Place the STB in off mode If the STB cannot be test standard Q31 b Wait until the UUT enters OFF mode laced off mode as defined in section 2 25 3 of c Record POFF the NOPR then this test shall be skipped Tl OPEN Off Mode Power Measurement Covered by existing tex2. 2 SLEEP Definitions The standard should not contain but A range of reduced power states where Sleep mode a range of reduced power states performance limitations in a definition Q6 clarifying the STB is connected to a mains power where the STB is connected to a mains power However the following text will be appended text source and is not providing any Principal source and is not providing any principal STB to the definition in lieu of the DOE proposed added STB Function The STB may transition to function The STB may transition to on or off mode text An STB may be expected to transition ON or OFF mode due to user action internal signal or external signal The power consumed in this mode may vary based on specific use or configuration If any Principal STB Function is activated while operating in this mode the STB is assumed to transition to ON mode Monitoring for user or network requests is not considered a Principal STB Function due to user action internal signal or external signal The power consumed in this mode may vary based on specific use or configuration If any principal STB function is activated while operating in this mode the STB is assumed to transition to on mode Monitoring for user or network requests is not considered a principal STB function The STB shall be able to transition from this mode to on mode within 30 seconds to be considered in sleep mode from Sleep mode to On mode withi
3. CEA 2043 standard EPA s Version 3 ENERGY STAR Set top Box Specification referenced CSA C 380 8 a Canadian Standards 7 See Hanford Nuclear Reservation Workers Hit By Sequestration Layoffs Huffington Post March 21 2013 and letter from Daniel B Poneman Deputy Secretary of Energy to the Honorable Jay Inslee Governor of Washington dated March 5 2013 Association derivation of ANSI CEA 2013 ANSI CEA 2022 and IEC 62087 EPA s plan was to use CEA 2043 directly hence its active participation in the CEA process EPA s proposed Version 4 1 specification references DOE s NOPR but also references CEA 2043 October 2012 draft for tests not covered by the NOPR If the NOPR is dropped the ENERGY STAR program easily can adopt CEA 2043 as has been its original intent The disadvantages and harm caused by a federal test procedure are not raised as an exercise in rhetoric and are quite different than the considerations that apply to more stable and mature consumer products and equipment Digital set top boxes the focus of DOE s NOPR only have existed in widespread use since the mid 1990s In the relatively short time since then their use and design has evolved in several significant ways including in response to requirements of the Federal Communications Commission and the transition to digital television broadcasting It is therefore likely and predictable that a DOE test procedure promulgated today and locked into law will soon
4. ON to Sleep Transition CEA Technical Comments NOPR for Test Procedure for Set top Boxes Page 16 of 18 Docket Number EERE 2012 BT TP 0046 RIN 1904 AC52 TI Disagree Q30 Accepted R Disagree but add Q30 clarifying text PON_to_APD over a sufficient period of time to assure that the UUT has entered APD and record the elapsed time as TON_to_APD Auto Power Down APD Test If the STB supports multi streaming operate the STB in the multi stream configuration for at least 5 minutes If the STB does not support multi streaming operate the STB in the on watch TV configuration for at least 5 minutes Current text accommodates a warm up time Auto Power Down APD Test Momentarily lt 1 second press the Power button on the remote only for any locally connected clients to place the clients into sleep mode as defined in section 2 25 2 of the NOPR Some clients may require a short period of time before they actually enter a lower power consumption mode If more than one display device is locally connected to the STB press the Power button for the additional locally connected display devices and stream content to one display device only CEA 2043 text will be modified to make it clear to place all clients and directly connected displays except a single display into Sleep mode Text will also be added to clarify that devices are to be placed into Sleep M
5. The maximum number of connected The following order of preference shall be used to Display Devices for each test if connect each display device to the STB The first applicable available connection that the STB supports shall be d The maximum number of Clients for used each test if applicable 1 HDMI e Devices in the network configuration 2 Component Video that cannot to be tested e g PCs 3 S Video Tablets etc 4 Composite Video f Required tests to be run on each 5 Other video interface Os Disagree device Test Configuration Information Keeps original text as it accommodates an g Test parameters for each required Connecting to a Client The STB shall be connected entity specifying the HNI interface test e g TON TSLEEP to the number of clients required based on the requirements setup requirements specified in Table 1 of the Annex D section D 2 includes NOPR An HNI connection shall be used to recommended CEA 2043 test connect the client to the STB The order of procedures for common STB types preference in which an HNI connection shall be selected is specified in section 4 6 1 Of the NOPR CEA Technical Comments NOPR for Test Procedure for Set top Boxes Docket Number EERE 2012 BT TP 0046 Page 7 of 18 RIN 1904 AC52 Accept 8 2 2 1 ON Watch TV Test Conduct Change step d to but The ON Watch TV mode power level The following section is provided as guidance R
6. administrator and auditors to verify data submitted are reliable and demonstrate that key commitments of the VA are met The VA also provides for not only laboratory testing but also testing in the home environment to better assure energy efficiencies are delivered No federal or state standard can accomplish all this in such a short period of time while being sufficiently agile to adjust to market and technological realities and changes In light of these meaningful industry efforts DOE s continued pursuit of a test procedure and standards is irrational Whether justified by politics bureaucratic momentum or excessive funds in certain departmental accounts millions of dollars will be wasted on the test procedure and standards rulemaking with no public benefit Meanwhile 244 employees are being laid off at DOE s Hanford Nuclear Reservation in the State of Washington and 2 000 others will receive multiple week furloughs delaying toxic waste contamination cleanup No one else will do that work Here in the case of DOE s proceeding for set top boxes hundreds of thousands of dollars or more are being squandered when there are productive active energy conservation efforts already underway Certainly DOE at least should allow a period of time to monitor and evaluate the achievements and credibility of the VA before proceeding with a federal mandate A federal test procedure is not needed to achieve uniform testing provide a test proc
7. be specified by Q32 g Wait until the UUT enters ON mode desired value as specified in section 5 8 2 of the entity requesting the test channel viewing supported NOPR remain in sleep mode for at least 5 h Record the power consumption as minutes PSLEEP_to_ON or PSLEEP_SP_n_to_ON over a sufficient period of time to assure that the UUT has entered ON mode and record the elapsed time as TSLEEP_to_ON or TSLEEP_SP_n_to_ON Accept 7 3 Test room States that the test shall be done on thermally The last sentence The UUT shall be tested Tests shall be carried out in a room non conductive surface This statement is vague on a thermally non conductive surface will Qs where the air speed surrounding the and be removed unit under test UUT is lt 0 5 m s and the ambient temperature is maintained at 23 5 C throughout the test The UUT shall be tested on a thermally non conductive surface has no meaning every surface including air is thermally conductive therefore it needs to be re written to spell out what your intention
8. display device shall be different Streaming to a Connected Client The content streamed to a client shall be selected in the order of preference proposed in the NOPR depending on the number of streams enabled The first available stream that is supported by each connected client shall be enabled and the content on each stream shall be different Stream with recorded content That is previously recorded content shall be viewed on a display device connected to a client Stream with channel content That is a channel SD stream for an SD client and HD stream for an HD client shall be viewed on the connected display device For clients that do not support channels select an appropriate SD or HD test stream and view the content as indicated Other streaming option If the streams from sections 5 3 3 1 and 5 3 3 2 of the NOPR are not supported use another stream that is available Add text to 8 1 2 indicate if entity wants to specify additional stream parameters that can be done but is outside the scope of the test procedure Review 8 1 11 allows for specification of content stream sources A configuration diagram should include the sources for test streams CEA Technical Comments NOPR for Test Procedure for Set top Boxes Page 8 of 18 Docket Number EERE 2012 BT TP 0046 RIN 1904 AC52 Q22 Accept 8 2 2 3 ON Record DVR STB The ON Record power level shall be determined as fol
9. function of the UUT it shall be tested connected to a broadband network Broadband New text while connected to a broadband performance criteria that is download speed 8 1 5 STBs requiring additional data network Broadband performance upload speed latency etc shall meet the connections criteria i e download speed upload specified requirements of the STB to fulfill the All data connections required for normal speed latency etc must meet the principal STB functions operation of Principal Functions must be specified requirements of the UUT to For STBs designed to operate both with a connected Data connection performance fulfill the principal functions broadband connection and a service provider criteria i e download speed upload speed network connection the service provider latency etc must meet the specified connection takes precedence and the broadband requirements of the UUT to fulfill the connection shall only be made if the STB requires principal functions it for operating a principal STB function Accept 8 1 7 Input Signal Equipment Input Signal Equipment Section 8 1 7 will adopt the DOE proposed When an ODU OTA antenna amplifier When an ODU OTA antenna amplifier CATV comment Q17 CATV distribution amplifier or similar distribution amplifier or similar signal equipment signal equipment is required and the is required and the power for that equipment is power for that equipment is supplied supplied from the STB then th
10. multi streaming If the STB does not support multi streaming operate the STB in the on watch TV configuration for at least 5 minutes immediately before beginning the test This is sufficient to address the DOE request CEA Technical Comments NOPR for Test Procedure for Set top Boxes Page 15 of 18 Docket Number EERE 2012 BT TP 0046 RIN 1904 AC52 Tl Disagree 8 3 2 Determining when a UUT has Manual Sleep Test The standard supports three methods to entered SLEEP mode Ensure that the STB and each locally connected determine if an STB has entered Sleep mode Q29 A UUT must be in an ON Watch TV client has entered sleep mode by verifying no DOE is specifying the use of a particular mode when each SLEEP procedure channel viewing or recording is supported on the method and this should be specified outside begins Using the UUT remote control STB and client s That is there shall be no video the standard the tester should momentarily lt 1 sec output on the connected display device s from press the Power button In practice a the STB and any locally connected clients UUT may require a short period of time before it actually enters a lower power consumption mode if at all Before the SLEEP mode power consumption measurement can begin it must be verified that the UUT has actually entered SLEEP mode This can be done using any of the following methods a No channel viewing or recording is su
11. the public requiring that new regulation take into account the evolving nature of emerging technologies and promoting innovation Under this policy there is no justification for a federally adopted test procedure for set top boxes unless it is a predicate for federal standards In the separate DOE covered product proceedings for set top boxes a multitude of comments have shown that a federal energy standard is clearly ill advised and not compatible with the law The covered product threshold cannot be met the set top box is not an appropriate consumer product and the myriad contractor analyses are looking at the wrong issues in the wrong ways Forthcoming comments on the documents contained in DOE s recent Notice of Document Availability NODA will specify the flawed assumptions and gross incompatibility of the shopworn DOE contractor models and analyses for this product category II A Federal Test Procedure is Unnecessary and Deleterious to Public Policy Not only has the consensus process satisfied the need for a national uniform test procedure for set top boxes but a Set Top Box Energy Conservation Agreement Voluntary Agreement or VA entered into by the key purchasers and manufacturers of set top boxes ensures enormous short term and long term energy savings while allowing set top boxes and related technology and networks to innovate and drive toward system wide efficiencies Although it is unfortunate that ener
12. the test requester i e the DOE that should be communicated directly to the party executing the test rather than documented within a test standard 2 the input reiterated provisions already memorialized within the test standard or 3 the input specified parameters relevant to regulation were such regulation to exist but were not appropriate for documentation within a test standard To facilitate the review process by interested parties cross reference is generally provided to the DOE NOPR question that addresses the proposed modification y Conclusion CEA opposes the adoption of a federal test procedure and federal energy standards which are the only credible and legal rationale for a federal test procedure 1 e for a covered product DOE s effort in this rulemaking is totally unnecessary Rather DOE should defer to the consensus process where interested industry and non industry stakeholders are completing the test procedure known as CEA 2043 which properly constitutes the United States testing standard for measuring power consumption in set top boxes Respectfully submitted CONSUMER ELECTRONICS ASSOCIATION By sl Douglas K Johnson Vice President Technology Policy Bill Belt Senior Director Technology amp Standards 1919 S Eads Street Arlington VA 22202 703 907 7600 Charles Samuels Mintz Levin Cohn Ferris Glovsky and Popeo P C 701 Pennsylvania Ave N W Suite 900 Washington DC 200
13. 04 April 8 2013 12 APPENDIX A CEA Technical Comments NOPR for Test Procedure for Set top Boxes 13 CEA Technical Comments NOPR for Test Procedure for Set top Boxes Docket Number EERE 2012 BT TP 0046 Page 1 of 18 RIN 1904 AC52 CLASS Accept Existing Text DOE Comment Modification Addition CEA 2043 Work Group Consensus Disagree NOPR Quest ion No os Disagree 4 16 Set top Box STB a device Definitions The current Set top Box definition covers the whose primary purpose or function is to Set top box means a device combining hardware expanded details proposed by the DOE Q3 receive video content which is then components with software programming designed comment delivered to a Display Device recording for the primary purpose of receiving television and For instance device or Client related services from terrestrial cable satellite 1 hardware components with software broadband or local networks providing video programming is covered by the general output using at least one direct video connection term of a device 2 and related services from terrestrial cable satellite broadband or local networks is covered by the general term video content which covers all of DOE proposed sources plus any other possible delivery technology 3 providing video output using at least one direct video connection would exclude headless devices e g an S
14. Before the UNITED STATES DEPARTMENT OF ENERGY Washington D C In the Matter of Energy Conservation Program Test Procedure for Set top Boxes 10 CFR Parts 429 and 430 Docket No EERE 2012 BT TP 0046 RIN 1904 AC52 COMMENTS OF THE CONSUMER ELECTRONICS ASSOCIATION I Introduction and Summary The Consumer Electronics Association CEA appreciates the opportunity to submit comments on the Department of Energy s proposed test procedure for set top boxes as published in a notice of proposed rulemaking on January 23 2013 We recognize the substantial efforts DOE and its contractors have made to develop a federal test procedure but we firmly believe that these resources are wasted and the efforts are misguided CEA is the preeminent trade association promoting growth in the 209 billion U S consumer electronics industry CEA represents more than 2 000 companies across the consumer electronics industry including a wide range of set top box manufacturers component manufacturers and service providers in a number of sectors For many years CEA has been on the vanguard of energy efficiency initiatives related to the consumer electronics industry and has supported and advanced energy efficiency as part of the industry s broader commitment to environmental sustainability CEA s comprehensive approach to energy efficiency includes initiatives related to public policy consumer education research and analysis and
15. Page 12 of 18 Docket Number EERE 2012 BT TP 0046 RIN 1904 AC52 R TI Disagree 8 3 1 SLEEP Mode Power Consumption Sleep Mode Power Measurement DOE requested changes are already Measurement Only run the test for each mode if the STB accommodated by the current text The Q26 SLEEP mode power consumption supports this functionality as defined in section standard as written will support testing of Q27 measurements must use the following 2 25 2 of the NOPR If the STB cannot be placed devices with a variety of sleep modes No Q28 procedure Specific power consumption in sleep mode as defined in section 2 25 2 of the text changes are required A test method parameter names are identified in each NOPR using a remote control then this test shall should identify the method for obtaining test be skipped energy efficiency measurements rather than a Use the time period for SLEEP mode to define performance standards which is a power consumption measurement from NOPR 2 25 2 Sleep mode means a range of separate undertaking 8 1 11 TSLEEP reduced power states where the STB is connected b Assure no recording events are to a mains power source and is not providing any scheduled during this time period principal STB function The STB may transition to c Assure no Service Provider network on or off mode due to user action internal signal initiated actions requiring a transition to or external signal The power consum
16. STB The ON Play power level shall be determined as follows a Configure the UUT as specified in 8 1 11 b Select a previously recorded program and view on a connected Display Device or Client c Begin ON mode power consumption measurement and record the power consumption as PPLAY_n where n is the total number of Display Devices and Clients d Repeat steps b and c up to the maximums specified in 8 1 11 8 2 2 3 ON Record DVR STB The ON Record power level shall be determined as follows a Configure the UUT as specified in Multi stream The multi stream test proposed by DOE is one scenario test as specified in section 8 1 11 of the dra CEA 2043 standard Configure the STB as specified in section 5 2 of this appendix Table 2 of this appendix describes how to setup the multi stream test Choose the highest priority smallest number option that the STB supports Table 2 Priority List for the Multi stream Test Already accommodated by standard multi stream configurations must be specified outside of standard Priority for Enabling Multi streaming Lis highest priority 9 is lowest priority Number of Streams Enabled To Display Devices To Record on DVR To Connect to Clients 1 1 1 5 o oj a a a 4 Lo ro n f uf f f of o CEA Technical Comments NOPR for Test Procedure for Set top Boxes
17. TB that delivers video using Wi Fi MoCA 802 11 etc The standard as written will support testing of devices without direct video connections Os Disagree none Definitions Only required if new DOE proposed Direct Video Connection any connection type that definition was accepted is one of the following High Definition Multimedia Interface HDMI Component Video S Video Composite Video or any other video interface that may be used to output video content Os Disagree none Definitions The term content provider is considered Content provider means an entity that provides self explanatory and does not require a Q5 video programming content definition Classification TI Tester Instructions outside the scope of a test standard OS Over Specification covered by current CEA 2043 language R Regulatory parameter outside the scope of a test standard CEA Technical Comments NOPR for Test Procedure for Set top Boxes Docket Number EERE 2012 BT TP 0046 Page 2 of 18 RIN 1904 AC52 OSs Disagree 4 4 Digital Video Recorder DVR a Definitions Adding integrated into the STB would STB feature that records television Digital video recorder DVR means a STB feature exclude a device that is designed to always Q5 signals on a HDD or other non volatile that records television signals on a HDD or other use an external HDD as supplied by the storage d
18. a federal department is required to use technical standards that are developed or adopted by voluntary consensus standard bodies unless these standards are inconsistent with applicable law or otherwise impractical The law codifies OMB Circular A 119 which also explains that the term use means incorporation of a standard in whole in part or by reference for procurement purposes and in regulation s The Congressional findings in NTTAA provide that the legislation is intended to among other things enhance technological innovation for commercial and public purposes and to promote the adaptation of technological innovations A mandatory testing standard for set top boxes promulgated by DOE would not serve these purposes Similarly OMB Circular A 119 notes that use of voluntary consensus standards is aimed at encouraging long term growth for U S enterprises and promoting efficiency and economic competition through harmonization of standards Given the fast pace of technology innovation DOE s adoption of a mandatory test procedure would be inefficient and only hinder these goals Further this Administration in Executive Order 13563 and other pronouncements set as federal policy the promotion of innovation and consideration of regulatory approaches that See http www whitehouse gov omb circulars_a119 at 6 a 1 5 See 15 U S C 3701 reduce burdens and maintain flexibility and freedom of choice for
19. acturer pursuant to 10 CFR Part 429 71 Information will be added to Section 8 1 Test Procedures General OS TI Q14 Disagree 8 1 4 STB configurations that require a home network STB configurations that require the use of a home network shall use the Home Network Interface option HNI as provided by the entity specifying the use of CEA 2043 The HNI option used for the testing must be recorded by the tester Home Network Connection STB configurations that require the use of a home network shall use the HNI option according to the following order of preference The first available connection that the STB supports shall be used 1 MoCA 2 HPNA 3 Wi Fi 802 11 or 4 Other HNI connection HNI Technologies will change over time so it is best to specify the list of types and preferred order of use outside of the standard CEA Technical Comments NOPR for Test Procedure for Set top Boxes Docket Number EERE 2012 BT TP 0046 Page 5 of 18 RIN 1904 AC52 Accept 8 1 5 STBs requiring broadband service Broadband Service Section 8 1 5 will be rewritten to If the UUT includes a HNI and the HNI If the STB includes an HNI and the HNI shall be accommodate the DOE comment and clarify Q15 must be connected to broadband connected to broadband service for operation ofa the requirement service for operation of a principal principal STB function it shall be tested while
20. ate number of For example EPA has already found it network technology most commonly capaDMy O1 Me 31i Me appropria numaerol i 7 necessary to propose a test supplemental to used in subscriber installations display devices and clients shall be connected the DOE s proposal in order to test a device Identically featured STBs often have when some outputs are constrained By pea Table 1 Display Device and Client Connection Setup i different performance capabilities Supports Multiple Supports Supports _ Number of Number of keeping the standard flexible the test Additionally not all CEA 2043 tests ered Meee Aertel cet E R e eeec method can be more useful apply to all STB types or configurations X X X 1 I i Therefore the entity specifying the use E x x of CEA 2043 is expected to provide the X I 0 following information x 7 a Test Configurations a configuration T EES TCS Cnn ARONA Ny Ae STD Bnd Be OS TI Disagree diagram of the STBs Clients Display Test Configuration Information Add the following clarifying text to item C but Devices and any other devices required Connecting to a Display Device and by priority specified if desired Q20 clarifying for each requested CEA 2043 test The STB shall be connected to the number of text b The specific network technology to display devices required based on the setup added be used for each test if applicable requirements specified in Table 1 of the NOPR c
21. be at best irrelevant not covering future and unanticipated applications and designs Worse a federal test procedure and related energy standard could stifle innovation and be detrimental to the U S economy and our international technological competitiveness Even in the European Union where regulatory mandates are frequently favored a voluntary agreement for set top box energy efficiency was established with support and encouragement by the European Commission which officially recognized the agreement Unnecessary U S federal regulation of set top box energy efficiency and test methods could impact our leadership competitiveness and innovation in the rapidly evolving market for video programming distribution First and foremost is the grave threat that this test procedure poses for innovation and future consumer benefits and services The nature of the set top box its constantly evolving design and technology and its place in a home network and content delivery system sets a federal mandated and rigid test procedure on a collision course with the evolving market and technology Adapting testing standards and product standards which inevitably cannot anticipate and account for innovation not only means the consequential energy representations are inaccurate but it also creates perverse incentives not to innovate Similarly deep sleep or off modes which are capabilities for reducing energy consumption by the set top box dur
22. d with changing consumer demand due to constraints of an ossified test procedure The condition described is not idle speculation or arm waving by the industry One need only look to other areas where government has intervened in a highly dynamic and complex product category One can contrast DOE s record in adopting revised test procedures with the ability of industry to quickly make revisions driven by the market An accredited standards developing organization such as CEA has an agility that DOE does not For example CEA 861 A DTV Profile for Uncompressed High Speed Interfaces which defines digital output data requirements for set top boxes was developed in 2001 and has been revised as was required to keep up with innovations impacting previous versions eight times in 10 years CEA 2013 2022 CSA C 380 and IEC 62087 are set top box power consumption measurement test procedures They have been adopted and revised 10 times over a seven year period In stark contrast DOE s test procedure for measuring power consumption in televisions was adopted in 1979 After 30 years and only after being prompted by outside petitions DOE repealed the test procedure in 2009 Its proceeding to adopt a new one commenced in September 2010 and is still pending Many DOE test procedures take more than 10 years to amend even just to cross reference current consensus test procedures We also note that there is no purpose in adopting an annualized energy me
23. e measurement from the UUT then the measurement shall not include the power consumption of that must not include the power equipment unless the equipment cannot be consumption of that equipment powered from a source other than the STB If the Accordingly the signal equipment shall signal equipment cannot be powered from a be powered from a source other than source other than the STB then the power for this the UUT equipment shall be included in the STB power consumption measurement However if the signal equipment can be powered from a source other than the STB then it shall be powered from another source and such equipment shall not deliver any power to the connected STB CEA Technical Comments NOPR for Test Procedure for Set top Boxes Docket Number EERE 2012 BT TP 0046 Page 6 of 18 RIN 1904 AC52 Tl Disagree 8 1 11 Test Configuration Information Since 2043 supports user specified A STB is configured with one or more Test Configuration Information configurations for testing a STB it is better to Q7 devices e g display devices network Test Configuration The display device and client sety keep the standard flexible to accommodate devices service delivery devices etc is described in Table 1 of the NOPR Based on the other possible configuration test requests and if applicable configured with the cababilitv of the STB the appropri
24. ed in this ON mode are scheduled during this time mode may vary based on specific use or period e g content downloads configuration If any principal STB function is software updates activated while operating in this mode the STB is d Assure no local area network assumed to transition to on mode Monitoring for initiated actions requiring a transition to user or network requests is not considered a ON mode are scheduled during this time principal STB function The STB shall be able to period e g mobile applications other transition from this mode to on mode within 30 network devices requesting service seconds to be considered in sleep mode e Record the energy consumed over the predetermined time period f Record the average power consumption as the energy divided by the time period Tl Disagree Sleep Mode Power Measurement DOE requested changes are already The time period for each test in the sleep mode TSLEEP shall be between 4 to 8 hours The time period shall be extended beyond 8 hours only if required as described in section 5 6 4 of the NOPR accommodated by the current text The standard as written will support testing of devices with a variety of sleep mode measurement time periods CEA Technical Comments NOPR for Test Procedure for Set top Boxes Page 13 of 18 Docket Number EERE 2012 BT TP 0046 RIN 1904 AC52 Accept Sleep Mode Power Measurement Assure no rec
25. edure for Federal Trade Commission EnergyGuide labeling purposes or support the ENERGY STAR program Industries throughout the United States have developed useful technically sound and widely adopted testing procedures That is exactly the case with respect to CEA 2043 No information has been submitted which suggests that other test procedures will be adopted or used Industry s and the VA s adoption of the CEA 2043 test procedure will ensure its preeminence Although FTC EnergyGuide labeling might be considered as a consequence of the adoption of the test procedure and standards the absence of a federal test procedure is not problematic for FTC purposes because an EnergyGuide label is neither justified nor useful Only a miniscule number of set top boxes are purchased directly by consumers who might benefit from a comparative label Consumers purchase the services of a system not a set top box The service providers who are signatories to the voluntary agreement as well as smaller service providers have access to plentiful energy use information when they make their procurement decisions Moreover under the VA service provider signatories shall provide their subscribers and potential customers with reasonable access to energy efficiency information about the set top boxes subject to the VA no later than January 1 2014 EPA s Version 2 ENERGY STAR Set top Box Specification referenced ANSI CEA 2013 and ANSI CEA 2022 predecessor to the
26. efits into the future II DOE is Required by Law and Policy to Defer to the CEA 2043 Standard The American National Standards Institute ANSI formally recognizes select organizations to develop essential industry standards CEA is accredited by ANSI to create and maintain American National Standards ANS This accreditation ensures that CEA s standards development program meets strict procedures and requirements for due process and criteria for the approval and withdrawal of ANS With more than 70 committees subcommittees and working groups and roughly 1 100 participants the CEA Technology amp Standards program maintains an unmatched reputation as a credible and flexible standards making body When a CEA standard is developed for submission to ANSI as an American National Standard the rules and procedures described in ANSI Essential Requirements Due process requirements for American National Standards Edition January 2013 must be strictly followed Due process demands openness lack of dominance balance of interests coordination and harmonization with other standards bodies public notification prompt consideration of views and objections consensus vote procedures an appeals mechanism and written procedures These due process requirements are described in detail by ANSI CEA as an ANSI accredited standards developer is required to comply with the normative policies and administrative procedures established by the ANSI Executi
27. epeat steps b and c using different Q20 simplify shall be determined as follows when conducting the various on sleep and off content up to the maximums specified in Q21 DOE text a Configure the UUT as specified in mode tests When multiple streams are enabled 8 1 11 8 1 11 b Select a channel and view on a connected Display Device if supported or if not supported view on a Client c Begin ON mode power consumption measurement and record the power consumption as PWATCH TV_n where n is the total number of Display Devices and Clients d Repeat steps b and c up to the maximums specified in 8 1 11 For STBs using a content provider that does not support channels select content that meets section 8 1 2 requirements and view the content as indicated different content shall be selected to output to a display device record on a DVR integrated into the STB and stream to a connected client Output to a Display Device For tests requiring output to a display device a channel shall be selected and viewed on the connected display device s as required by the test configuration For STBs using a service provider that does not support channels an appropriate SD or HD test stream shall be selected and the content shall be viewed as indicated If more than one display device is connected to the STB based on the test configuration from Table 1 of the NOPR then the content outputted on each
28. ernative energy efficiency steps which provide energy efficiency gain superior to those required by the voluntary agreement This includes home networking and multi room solutions to share the resources of a primary device with lower functionality home 99 66 network devices moving set top box recording other functionality or applications into the network or cloud delivering video services via Internet protocol without the need for a set top box and using digital transport adapters or using other adapters in lieu of set top boxes Ina number of these cases under a federal test procedure and associated energy standard these designs would be irrelevant penalized or perhaps even prohibited thus hindering innovative broader solutions which overall save more energy than direct set top box measurement related to a standard It is critical to recognize that if the federal test procedure is established it will become the law of the land Absent the waiver or hardship petitions or the laborious multiyear process of revision it must be followed scrupulously in all statements of energy use regardless of the pace at which the underlying technology changes or the consumer needs evolve Deviation can result in compliance actions under EPCA by DOE FTC EPA and even possibly state attorneys general and private parties Thus the adoption of a federal test procedure sets up an environment where innovation cannot move forwar
29. evice A DVR often includes non volatile storage device integrated into the manufacturer Section 8 1 8 indicates the features such as Play Record Pause STB correct treatment for essential peripheral Fast Forward FF and Fast Rewind FR A DVR often includes features such as Play devices STBs that support a Service Provider Record Pause Fast Forward FF and Fast Rewind delivery network based DVR service FR STBs that support a service provider delivery are not considered DVR STBs for network based DVR service are not considered purposes of this standard The presence DVR STBs for purposes of this test procedure The of DVR functionality does not mean the presence of DVR functionality does not mean the device is defined to be an STB device is defined to be a STB Accept 4 5 Display Device DD a Display Definitions Add and renders it for viewing but Device e g TV Computer Monitor Display device means a device example TV Q5 simplify Portable TV etc receives its content Computer Monitor or Portable TV that receives DOE text directly from an STB through a video its content directly from a STB through a video interface e g HDMI Component interface example HDMI2 Component Video Composite S Video etc and not Composite Video or S Video not through an HNI through a Home Network Interface and displays it for viewing Os Disagree 4 8 Home Network Interface HNI Definitions The add
30. gy advocates ultimately chose not to join the Voluntary Agreement the process was and remains open to such parties Energy efficiency advocates are encouraged to re engage and provide technical and policy input particularly with respect to ensuring compliance with the commitments and developing future commitments and hopefully become signatories in the future It is particularly inappropriate and unjustified for DOE to take the position in the NODA with respect to energy standards analysis that DOE only will consider a non regulatory agreement reached between all stakeholders as an alternative to a regulatory standard emphasis added This not only defies reality but it is unnecessary and undesirable under the law A voluntary agreement in Europe has been entered into unilaterally by industry with active The Voluntary Agreement was announced on December 6 2012 and is available at http www ce org News News Releases Press Releases 2012 Press Releases Set Top Box Energy Conservation Agreement Expected aspx European Commission participation and support Industry seeks substantial involvement by DOE and energy efficiency advocacy groups in the U S VA Fundamentally however the energy savings are no less real or meaningful because certain parties who manufacture nothing and purchase no set top boxes are not participating DOE should not allow such stakeholders to effectively hold hostage legitimate actions by industry We rec
31. iew the content as indicated 2 If the STB supports HD streaming repeat the test section 5 5 2 of the NOPR using HD content instea of SD content and record this value as PWATCH HD 5 5 2 3 Calculation of Prarcy Compute Pwarcy according to the following equation Pwar CH_SD T Pwarch no s STB supports HD Pwarca 2 PP Pwarcu_soo STB doesn t support HD Previously accepted changes will accommodate DOE requirement for both SD and HD streams The standard as written will support testing with both SD and HD test streams No text changes are required CEA Technical Comments NOPR for Test Procedure for Set top Boxes Page 11 of 18 Docket Number EERE 2012 BT TP 0046 RIN 1904 AC52 Tl Q25 Disagree 8 2 2 ON Mode Test Procedures 8 2 2 1 ON Watch TV The ON Watch TV mode power level shall be determined as follows a Configure the UUT as specified in 8 1 11 b Select a channel and view on a connected Display Device if supported or if not supported view on a Client c Begin ON mode power consumption measurement and record the power consumption as PWATCH TV_n where n is the total number of Display Devices and Clients d Repeat steps b and c up to the maximums specified in 8 1 11 For STBs using a content provider that does not support channels select content that meets section 8 1 2 requirements and view the content as indicated 8 2 2 2 ON Play DVR
32. industry standards One of these initiatives industry s involvement in the successful ENERGY STAR program is over 20 years old CEA opposes the adoption of a federal test procedure and federal energy standards which are the only credible and legal rationale for a federal test procedure i e for a covered product DOE s effort apparently conducted in indifference to the sequestration and other federal spending constraints is totally unnecessary Rather DOE should defer to the consensus process where interested industry and non industry stakeholders are completing the test procedure known as CEA 2043 which properly constitutes the United States testing standard for measuring power consumption in set top boxes DOE its contractors the U S Environmental Protection Agency and energy advocates are and have been represented in the consensus standard development of CEA 2043 DOE s development of a test procedure to facilitate a federal energy standard is unnecessary and deleterious to the national interest because such standards cannot be justified under the Energy Policy and Conservation Act EPCA and will be harmful to innovation consumer choice and product utility As explained further below a voluntary agreement adopted by all the major multichannel video providers and set top box manufacturers already has saved an enormous amount of energy will evolve progressively and will continue to cumulatively provide enhanced ben
33. ing extended periods of inactivity or at specific times save energy but absent specific accounting in a test procedure it would be discouraged The next innovation or potential energy saving trend in this category is unpredictable What is predictable is that a federally mandated test procedure for set top boxes will not be sufficiently nimble to account for rapid product evolution DOE s proposed test procedure also treats as a separate model every combination of hardware and software having a different energy use profile Literally thousands of models will need to be tested and then as software hardware combinations evolve thousands more will need to be tested before any energy declaration can be made This violates the unduly burdensome to conduct prohibition Variations or exceptions from the federal test procedure will need to be justified and approved either through the laborious process of waivers under 10 CFR Section 430 27 or the even slower onerous and uncertain process of hardship petitions under the Office of Hearings and Appeals In contrast the VA provides for efficient technically competent and expeditious procedures to deal with proposed variances or alternative measures including those not recognized by a mandated test procedure that meet or exceed the energy saving goals specified in the agreement Section 12 of the VA relates to noncompliance and dispute resolution and provides for credits for alt
34. ition of that is capable of the interface with external devices over Home network interface HNI means an interface transmitting video content is not sufficient Q5 a local area network e g IEEE with external devices over a local area network to distinguish a class of HNls All HNIs are 802 11 Wi Fi MoCA HPNA IEEE 802 3 example IEEE3 802 11 Wi Fi MoCA HPNA IEEE capable of transmitting video at some level HomePlug AV 802 3 HomePlug AV that is capable of The standard as written will support testing transmitting video content of devices with all HNI types so the definition of HNI should not be restricted A list of HNIs may be specified and updated outside of the standard Os Open none Definitions Not required since current text allows the Multi stream means a STB feature that may entity using CEA 2043 to specify various Q5 provide independent video content to one or configurations for testing more clients one or more directly connected TVs or a DVR CEA Technical Comments NOPR for Test Procedure for Set top Boxes Docket Number EERE 2012 BT TP 0046 Page 3 of 18 RIN 1904 AC52 Accept none Acronyms Add acronyms with meanings to standard ANSI means American National Standards Institute IEC means International Electrotechnical Commission ISO means International Organization for Standardization SCTE means The Society of Cable Telecommunications Engineers Inc R Disagree 6
35. lows a Configure the UUT as specified in 8 1 11 b Select a channel using a connected Display Device or a Client and record the program c Begin ON mode power consumption measurement and record the power consumption as PRECORD_n where n is the total number of recordings d Repeat steps b and c up to the maximums specified in 8 1 11 Recording for a STB with DVR capability For tests that require recording on a DVR a channel shall be selected using a connected display device or a client and the program shall be recorded If more than one recording is enabled ona DVR that is integrated into the STB the content for each recording shall be different Change step d to Repeat steps b and c using different content up to the maximums specified in 8 1 11 OS Disagree 8 2 2 2 ON Play DVR STB The ON Play power level shall be determined as follows a Configure the UUT as specified in 8 1 11 b Select a previously recorded program and view on a connected Display Device or Client c Begin ON mode power consumption measurement and record the power consumption as PPLAY_n where n is the total number of Display Devices and Clients d Repeat steps b and c up to the maximums specified in 8 1 11 Stream with recorded content That is previously recorded content shall be viewed on a display device connected to a client Current text accommodates request CEA Tech
36. ment No text changes are required measurements must use the following procedure Specific power consumption parameter names are identified in each test a Use the time period for ON mode power consumption measurement from 8 1 11 TON b Record the energy consumed over the predetermined time period c Record the average power consumption as the energy divided by the time period CEA Technical Comments NOPR for Test Procedure for Set top Boxes Page 10 of 18 Docket Number EERE 2012 BT TP 0046 RIN 1904 AC52 Q24 Disagree 8 2 2 1 ON Watch TV The ON Watch TV mode power level shall be determined as follows a Configure the UUT as specified in 8 1 11 b Select a channel and view on a connected Display Device if supported or if not supported view on a Client c Begin ON mode power consumption measurement and record the power consumption as PWATCH TV_n where n is the total number of Display Devices and Clients d Repeat steps b and c up to the maximums specified in 8 1 11 For STBs using a content provider that does not support channels select content that meets section 8 1 2 requirements and view the content as indicated On Watch TV SD and On Watch TV HD 1 If supported select an SD channel and view on th connected display device For STBs using a content provider that does not support channels select an appropriate SD test stream and v
37. n a specified time interval however such considerations are outside the scope of this standard CEA Technical Comments NOPR for Test Procedure for Set top Boxes Page 4 of 18 Docket Number EERE 2012 BT TP 0046 RIN 1904 AC52 Q7 Accept but simplify DOE text none Test Conditions 1 For STBs that require subscription to a service select the simplest available video subscription that supports all functionality specified in this test procedure example HD streaming multi stream DVR etc That is select a subscription with TV services only services with non video capability such as telephony shall not be selected 2 If the STB can be installed by the consumer per the manufacturer s instructions without the service of a technician then install and setup the STB according to the instructions provided in the user manual shipped with the unit Setup the STB using only those instructions in the user manual Setup is considered complete once these instructions are followed 3 If the STB must be installed by a technician per the manufacturer s instructions then it shall be setup as installed by the technician using this test procedure All steps that a technician would follow when installing a STB for use in a consumer residence should be followed Information about each of the steps that were performed to setup the STB by a technician shall be recorded and maintained by the manuf
38. nical Comments NOPR for Test Procedure for Set top Boxes Docket Number EERE 2012 BT TP 0046 Page 9 of 18 RIN 1904 AC52 Accept 8 2 1 ON Mode Power Consumption Calculation of Average and Rated Power Accept as proposed by DOE Measurement Consumption Q23 ON mode power consumption For all tests in the on sleep and off modes measurements must use the following sections 5 5 5 6 and 5 7 the average power procedure Specific power consumption shall be calculated using one of the following two parameter names are identified in each methods test 1 Record the accumulated energy Ei in kilo watt a Use the time period for ON mode hours kWh consumed over the time period power consumption measurement from specified for each test Ti The average power 8 1 11 TON consumption is calculated as Pi Ei Ti b Record the energy consumed over 2 Record the average power consumption Pi by the predetermined time period sampling the power at a rate of at least 1 sample c Record the average power per second and computing the arithmetic mean of consumption as the energy divided by all samples over the time period specified for each the time period test Ti Tl Disagree 8 2 1 ON Mode Power Consumption On Mode Power Measurement The standard as written will support testing Measurement The time period for each test in the on mode of devices with this ON mode time Q23 ON mode power consumption TON is 2 minutes measure
39. ode without indicating it must be done with a remote control button since any means of placing a device in Sleep mode is acceptable Auto Power Down APD Test Allow the STB to operate until the STB enters sleep mode or until 4 hours have elapsed whichever occurs first Add text to indicate the tester should verify with entity requesting test what the max test time is for the Auto APD test CEA Technical Comments NOPR for Test Procedure for Set top Boxes Page 17 of 18 Docket Number EERE 2012 BT TP 0046 RIN 1904 AC52 R OPEN Auto Power Down APD Test Outside of a test standard since this is If 4 hours have elapsed and the STB is notin sleep specific instructions related to regulatory Q30 mode then the unit is not considered to support AEC calculations A maximum test time APD and PSLEEP APD shall be set equal to parameter will be added to CEA 2043 to PWATCH inform a tester when the APD initiated ON to SLEEP test may be stopped Accepted 8 5 2 Power Mode Transition ON to Auto Power Down APD Test CEA 2043 text will be modified to make it SLEEP Transition Momentarily lt 1 second press the Power clear to place all clients and directly Q32 a Select a channel and view ona button on the remote only for any locally connected displays except a single display connected Display Device if supported connected clients to place the clients into sleep into Sleep mode
40. ognize that DOE has a fast track regulatory process which does depend on the consensus of industry and non industry parties but that is not the activity in question here DOE must take into account the reality of industry s own efforts through the VA and give the VA an opportunity to work The essence of the Voluntary Agreement is that 90 percent of all new set top boxes that a service provider signatory purchases and deploys after December 31 2013 shall meet the efficiency standards established in the ENERGY STAR Version 3 0 specification In addition the relevant sectors the cable industry satellite and telecommunications firms have made their own specific additional undertakings Critically the agreement allows for the commitments to be revised and additional goals established over time in order to keep pace with the technological capabilities and architectural evolutions occurring within subscription video delivery sector The VA has been adopted with specific intent not only to save energy but to ensure there are no restrictions on future innovation technology or competition to the detriment of the United States economy or consumers There are also strong provisions in place to ensure reasonable transparency public reporting and verified compliance with these commitments Under the VA an organization has been created with a steering committee and rules These provisions enable among other things establishment of an independent
41. ording events are scheduled over the entire duration of the test including the time prior to transitioning to sleep mode If the STB is capable of scheduling a recording schedule a recording 24 or more hours into the future This will be added to the Sleep mode test OS Q26 Disagree but add clarifying text 8 3 1 SLEEP Mode Power Consumption Measurement SLEEP mode power consumption measurements must use the following procedure Specific power consumption parameter names are identified in each test a Use the time period for SLEEP mode power consumption measurement from 8 1 11 TSLEEP b Assure no recording events are scheduled during this time period c Assure no Service Provider network initiated actions requiring a transition to ON mode are scheduled during this time period e g content downloads software updates d Assure no local area network initiated actions requiring a transition to ON mode are scheduled during this time period e g mobile applications other network devices requesting service e Record the energy consumed over the predetermined time period f Record the average power consumption as the energy divided by the time period Sleep Mode Power Measurement Assure no service provider network initiated actions requiring a transition to on mode occur during the 4 to 8 hour time period that the STB is in sleep mode example content downloads or software updates If a
42. pported on a UUT or Client b Observation of a SLEEP mode indicator on the UUT consult the UUT user manual c A predetermined wait time TSLEEP_WAIT provided by the entity specifying the use of CEA 2043 The tester must record the method used when performing a SLEEP mode test Tl Disagree 8 5 1 Power Mode Transition ON to Auto Power Down APD Test DOE comment should be handled outside but APD Transition Perform this test only if the STB supports auto the standard The standard will be modified Q30 clarifying a Select a channel and view ona power down as defined in section 2 2 of the NOPR to improve the name of the tests to be more text will connected Display Device if supported descriptive be added or if not supported view on a Client 2 2 Auto power down APD means a STB feature This transition test will be renamed APD b Do not use or move the UUT remote control after step a c Begin the elapsed time measurement d Wait until the UUT exits ON mode no channel viewing or recording supported e Record the power consumption as that monitors parameters correlated with user activity or viewing If the parameters collectively indicate that no user activity or viewing is occurring the APD feature enables the STB to transition to sleep or off mode initiated ON to SLEEP Transition instead of ON to APD since APD is not a power mode Section 8 5 2 will also be renamed to Manual initiated
43. rs and energy efficiency advocates The current roster of the CEA R4 Committee This document is publicly available at http www ansi org essentialrequirements This document is publicly available at http www ce org CorporateSite media Standards Media EP23 N_Final pdf 3 This document is publicly available at http www ce org CorporateSite media Standards Media CEA Legal Guides 7 15 09 pdf Working Group 13 R4WG13 Committee which is developing CEA 2043 includes DOE EPA Lawrence Berkeley National Laboratory Navigant the Natural Resources Defense Council Energy Solutions and Terra Novum as well as numerous service providers and manufacturers of both set top boxes and their internal components Although we recognize and appreciate that DOE has proposed adopting in large measure CEA 2043 U S law and good public policy favors simply relying on the standard rather than borrowing from modifying or reinventing it Revisions to the draft CEA standard that DOE believes would be beneficial can and will be incorporated into CEA 2043 where technically justified as discussed in detail in an appendix to these comments CEA Technical Comments NOPR for Test Procedure for Set top Boxes attached The National Technology Transfer and Advancement Act NTTAA and the Office of Management and Budget OMB Circular A 119 evidence clear preference for voluntary and market solutions in these circumstances Under the NTTAA DOE as
44. service provider network initiated activity cannot be disabled then this shall be monitored as follows 1 The power consumption shall be sampled at a rate of at least 1 sample per second 2 For input powers less than or equal to 1 W a linear regression through all power readings shall have a slope of less than 10 milli watts per hour mW h If the slope of the linear regression is equal to or greater than 10 mW h the test shall either be restarted or extended until a slope of less than 10 mW h is achieved 3 For input powers greater than 1 W a linear regression through all power readings shall have a slope of less than 1 percent of the measured input power per hour If the slope of the linear regression is equal to or greater than 1 percent the test shall either be restarted or extended until a slope of less than 1 percent is achieved 4 If the test is extended beyond 8 hours to achieve the desired condition the average power consumption over the entire test duration shall be reported for PSLEEP_MANUAL and PSLEEP_APD and these values shall be used to determine the AEC Append to c If the tester cannot guarantee that a SP initiated action will be prevented during the test period then they must notify the entity requesting the test to determine if additional action must be taken Note If a service provider initiated activity occurs during a Sleep mode test the tester can just rerun the test instead of adding this
45. t Q31 Record the average power for 2 minutes as POFF CEA Technical Comments NOPR for Test Procedure for Set top Boxes Page 18 of 18 Docket Number EERE 2012 BT TP 0046 RIN 1904 AC52 Accept 8 5 5 Power Mode Transition SLEEP Sleep to On Mode Transition Time Measurement Action modify text to support both APD and to ON Transition For the manual sleep test place the STB in sleep manual entered SLEEP mode Also address Q32 a Select a channel and view ona mode according to the steps specified in sections momentarily press connected Display Device if supported 5 6 7 2 through 5 6 7 5 of the NOPR For the APD or if not supported view on a Client test place the STB in sleep mode according to the b Momentarily lt 1 sec press the steps specified in sections 5 6 8 2 through 5 6 8 6 Power button on the remote control of the NOPR of each Display Device and Client c Wait until the UUT power consumption reaches PSLEEP or PSLEEP_SP_n 8 3 4 0 5W 0 0W d Remain in SLEEP or Special SLEEP mode for the predetermined stabilization time from 8 1 11 TSLEEP_to_ON_WAIT e Momentarily lt 1 sec press the Power button on the remote or front Tl Disagree panel of the UUT Sleep to On Mode Transition Time Measurement Addressed in current text f Begin the elapsed time measurement After the STB power consumption reaches the TSLEEP_to_ON_WAIT is to
46. the DOE test procedure Would every innovation be barred from the U S market until it receives a DOE waiver grant For the reasons stated above a federal test procedure is not only unnecessary but it is also detrimental to the national interest in sound and progressive energy policy Although we do not support a federal test procedure the CEA R4WG13 Committee most definitely is not dismissing DOE s proposed variances from the draft CEA test procedure As discussed in Appendix A a number of these differences likely will be incorporated in the final CEA standard There are a few proposals in the NOPR which are either technically unsound or not suitable for a consensus test procedure The CEA standard will be finalized and re balloted in May 2013 in contrast to an undoubtedly prolonged DOE proceeding IV CEA Provides Technical Comments on Variances Between the Draft CEA 2043 Standard and the NOPR In Appendix A we evaluate the NOPR s variances from the CEA draft standard test procedure and explain how those variances are being addressed by the working group consensus process Where the DOE NOPR is consistent with CEA 2043 we are not commenting Where changes suggested in the DOE NOPR were not adopted by the working group an explanation of why the changes were not accommodated is provided Generally a change was not adopted for 8 See 42 U S C 6293 11 one of the three following reasons 1 the input was additional instruction by
47. time consuming analysis to determine if it impacted the test results CEA Technical Comments NOPR for Test Procedure for Set top Boxes Page 14 of 18 Docket Number EERE 2012 BT TP 0046 RIN 1904 AC52 R Disagree none Manual Sleep Test This DOE request is related to the DOE If the STB does not support sleep mode then set proposed AEC calculation and is considered Q29 PSLEEP_MANUAL equal to PWATCH out of scope of a test standard A test method should identify the method for obtaining energy efficiency measurements rather than to define consumption standards which is a separate undertaking Os Disagree 8 3 4 SLEEP Mode Test Procedure Manual Sleep Test Section 8 1 1e of the standard indicates the a Select a channel and view ona For STBs that are capable of transitioning to sleep UUT be run in ON mode for 15 minutes to Q29 connected Display Device if supported mode operate the STB in the multi stream test achieve stability before any tests are started or if not supported view on a Client b Momentarily lt 1 sec press the Power button on the remote for each locally connected Display Device and Client c Do not use or move the UUT remote control after step b d Wait until the UUT enters SLEEP or Special SLEEP mode using 8 3 2 e Begin SLEEP mode power consumption measurement and record PSLEEP or PSLEEP_SP_n configuration for at least 5 minutes if the STB supports
48. tric duty cycle or usage measures and it is infeasible to do so The CEA standard and most of DOE s proposal measure power consumption using a defined configuration and performing a specific task Attempting to predict annual energy consumption by taking a snapshot of constantly changing data in order to bootstrap standards and justify labeling is futile and dangerous Such an approach requires specifying duty or usage cycles and hours of operation in various categories 10 power modes which are known to change and evolve every year Duty cycle specifications necessarily place in regulatory concrete categories and times in these categories Unless the definitions of all possible categories are 100 percent correct and future proof the annual power metric will be wrong in both axes neither properly categorizing usage states nor the correct hours per day for each usage state This metric fails the EPCA requirement that test procedures be reasonably designed to produce test results reflecting representative average use Duty cycles set in federal concrete will be made obsolete by the consumer electronics marketplace and evolving consumer demand almost immediately Worse yet mandated duty cycles will inhibit innovation and energy saving improvements In this way DOE s proposed test procedure could foreclose opportunities to develop new duty cycles that save energy if such efforts could not be accommodated and measured under
49. ve Standards Council In addition to the ANSI Essential Requirements CEA maintains its own additional layer of procedures to further guide participants in standards setting activities CEA s Technology amp Standards Council TSC formed in accordance with CEA s corporate bylaws is responsible for overseeing CEA s standards programs All CEA standards committees are created by the TSC In addition the TSC is responsible for the creation maintenance and revision of the procedures manual known as CEA Procedures Technology amp Standards Procedures Manual EP 23 N revised July 2011 Finally the Consumer Electronics Association Legal Guides revised July 2009 supplements the procedures contained in EP 23 N i The open transparent and fair development of consensus standards that accurately reflect the interests of all stakeholders can only be ensured through the rigorous process described here Draft CEA 2043 Set top Box STB Power Measurement is consistent with ANSI rules and procedures which are well recognized in the United States and throughout the world Dozens of meetings multiple draft revisions and countless technical discussions and debates have led to a robust draft testing procedure that will serve all stakeholders equally The development of CEA 2043 has been open for participation by all interested parties As noted previously participants include DOE both its employees and contractors EPA and its contracto
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