Final Draft Version 8.0 Computers Specification Comment Summary

Topic

SubtopicGeneralCertification

Stakeholder Comment Summary
One stakeholder requested that EPA allow them to provide input on any language shared withCertification Bodies regarding retesting for Version 8.0 certification.

EPA Response
EPA released the Version 8.0 QPX for stakeholder review on 9/19/2019.

Two stakeholders submitted comments regarding EPA's methodology for setting requirements
reflective of the top 25% of models available on the market.

GeneralGeneral

Overall Pass Rate

EPA has targeted the top quartile of products in the ENERGY STAR dataset in the Final
One stakeholder requested that EPA reassess its guiding principles regarding targeting an
Draft specification. As noted in the ENERGY STAR Guiding Principles, experience has
overall pass rate to include an analysis of product shipments and suggested that EPA engage inshown that it is typically possible to achieve the necessary balance among the key
discussion with industry on this point prior to the next specification revision. Industry also provided
principles of the program by selecting efficiency levels reflective of the top 25% of models
an analysis comparing the ENERGY STAR Qualified Product List pass rate with the overall
available on the market when the specification goes into effect. These principles include
market pass rate.
ensuring national energy savings, maintaining product performance, reasonable payback
period for consumers, and effectively differentiating products for consumers with theAnother stakeholder recommended that EPA anticipate market improvements in the 9 months
ENERGYbetween finalizing specifications and their taking effect, including taking into account the effect ofSTAR label.
states adopting the California Energy Commission standards on the overall market. Theysuggested that pass rates at the time of specification should be reduced significantly to accountfor these future improvements.

The ENERGY STAR certified product list will look very similar to the certified product list
One stakeholder requested that EPA provide an opportunity for public comment regardingused for Version 7.0 as this is the public facing list rather than the list utilized forrevisions to the ENERGY STAR Qualified Products List (QPL). They further indicated that certain specification development purposes. EPA understands the stakeholders concern
Qualified Products Listrevisions to the QPL that clarified the calculation of relevant allowances would assist with industry regarding the ability to do certain calculations during the specification revision process andanalysis and accelerate industry response times during comment periods.
looks forward to speaking with stakeholders on how to make the dataset as usable aspossible for the Version 9.0 specification development process.

Allowances

Full Network
Connectivity

Allowances

GeneralOne stakeholder encouraged EPA to re-evaluate the full network connectivity incentive,
suggesting that it may no longer be required as a number of systems were able to meet theproposed Version 8.0 requirements without applying the incentive.

The intent of the full network connectivity allowance is to encourage the adoption of more
efficient product behavior that would otherwise not be be adopted as quickly by products,
which are not optimized for battery life. EPA looked at the savings garnered byincentivizng many more models to mainatin a connection in a low power mode versus theAnother stakeholder expressed support of the full network connectivity incentives proposed in the cost of giving these models an incentive. EPA concluded that it is wrothwhile to maintain
Final Draft specification
the incentive.

One stakeholder expressed support of the addition of the internal power supplies ten percent
load requirement and encouraged EPA to further pursue low-load efficiency in future versions of
the specification.

Allowances

One stakeholder supported the inclusion of 80 Plus Gold equivalent efficiency requirements forlarge internal power supplies and requested that EPA increase internal power supply efficiency
Internal Power Supplies
requirements for power supplies less than 500 watts in future versions should higher
performance become cost effective.

Allowances

One stakeholder requested that EPA wait to include allowances for new power-consuming
features until efficient implementations of such features emerge and it is possible to set
allowances that differentiate such efficient implementations. They further cautioned EPA against
setting adders based on industry information for expected power requirements for new featuresthat may be significantly higher than the power needed to implement such features efficiently.

New Features

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EPA thanks stakeholders for their support.

EPA will continue to monitor the progress of IPS efficiency in future revisions.

EPA received information suggesting that adders for new technologies such as higher
speed Ethernet ports primarily impact high end content creation products which have lowshipments but are important for federal procurement. As such, EPA wants to ensure thatpurchasers have sufficient choice in efficient computing products for content creation.
EPA will collect energy use associated with these new featiures and adjust adders in thenext revision if needed.

Final Draft Version 8.0 Computers Specification Comment SummaryTopic

Allowances

Base TECAllowances

Subtopic

Touch Technology

Stakeholder Comment Summary

EPA Response

EPA reviewed the products listed in the dataset and found that nearly half of the productsthat meet the proposed Version 8.0 requirements have touch functionality and meet therequirements without the need for an adder. EPA does not believe that the touch adder
One stakeholder requested that EPA implement an allowance for touch technology equivalent to used in the ENERGY STAR display specification is appropriate to the entire integrated
that provided in the ENERGY STAR Displays Version 8.0 specification.
desktop product, as the display represents only a part of the product's overall energy use.
Additionally, EPA does not understand why integrated desktops require this adder whennotebooks and slate/tablets in the ENERGY STAR program do not, despite being subject
to more stringent energy requirements.

One stakeholder indicated that the Final Draft base TEC allowance for category 1 integrated
desktops were not sufficient for many products in that category and would thus force
Category 1 Integrated
manufacturers to add components to platforms in order to meet the ENERGY STAR
Desktops
requirements. Industry requested that EPA reassess the base TEC requirements for thiscategory and provided a proposal for such revisions.

EPA thanks stakeholders for their additional feedback, but has determined that it does notserve program goals to accept the proposed iDT1 base allowance with a change to theswitchable graphics allowance for Integrated Desktops. Over the past months, it has been
EPA’s understanding from industry that the need to break out iDT1 and iDT2 was rooted
in the need to isolate those products from other desktops due to their use of notebook
components, which use less energy than those for traditional desktops. This proposal
appears to contradict this feedback and the efforts undertaken by the Agency and industry
to date. In addition, EPA notes that in its research for this specification, that switchable
graphics tend to predominate in computers with notebook components, argues against
this change to the adder structure. Finally, EPA noted that when the storage adder wasadjusted as part of the Final Draft, iDT1 was not impacted, which would also indicate thatmost products in that product class utilize notebook components. The Agency does notbelieve that there is as high a risk for unintended consequences, given that therepresentative model submitted for testing, by definition, would already be the highest
energy consuming product and that roughly half of the products are single products
submitted to ENERGY STAR.

Required Capabilities

Energy Efficient
Ethernet

One stakeholder expressed discontent with EPA's decision to delay requiring that Energy
Efficient Ethernet be enabled by default until the Version 9.0 specification, and argued that thetechnology was sufficiently mature to be required.

EPA shares the goal of having all EEE ports enabled as-shipped as soon as possible, but
given the current state of the market, the Agency is not comfortable removing nearly 1/3of products which otherwise meet the Version 8.0 requirements due to this single issue.
EEE is now required to be present in all 1Gbs or faster Ethernet ports in Version 8.0, withtheexpectation that all will be enabled in all products in Version 9.0.

Considerations for
Future Revisions

Notebook Mode
Weightings

One stakeholder suggested that EPA indicate its intent to implement new mode weightings for
Notebooks in the next version of the specification in the Consideration for Future Revisions
section.

EPA thanks stakeholders for their feedback and anticipate adopting the new mode
weightings for notebooks in Version 9.0 if market conditions permit at that time.

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