Final Draft Version 6.0 Computers Specification Comment Response Document

TopicDefinitions
Definitions

Subtopic
Frame Buffer
Width
Full NetworkConnectivity

Comment
One stakeholder commented that the term “Frame Buffer Width” isundefined.
A stakeholder noted that the definition of Full Network Connectivity
requires operation in Sleep Mode or another mode with equal or
lower power. The stakeholder commented that this would require
testing a product in both connected and unconnected Sleep Mode todetermine if this condition was met.

Response
EPA has included a footnote with an explanation of Frame Buffer Width in theFinal Specification
EPA has clarified this requirement by specifying that the power in analternative low power mode can be less than or equal to 5 watts.

Another stakeholder noted that according to the definition for Full
Network Connectivity, it would not be possible for computers tooffer connectivity unless their Long Idle or Connected Sleep Modepower is equal to or less than the power demand in Sleep Mode.

Definitions

Graphics
One stakeholder expressed concern that the statement "apart fromProcessing Unit the CPU" may be confused with the physical proximity of the GPUand suggested changing this language.

EPA has replaced "apart" with "separate" in the Final Specification.

Definitions

Idle State, Long A stakeholder suggested altering the Idle State, Long Idle, and Short
Idle, and Short Idle definitions to reflect that the computer is not in any other low
power modes in addition to Sleep Mode.
Idle

Since an Idle State can be the alternative low power mode for a system, Idle
States should not be defined in opposition to low power modes. Therefore,
EPA has maintained the pervious definition.

Definitions

Notebook
ComputerA stakeholder requested that the Notebook definition reference a'physical' keyboard and pointing device, as opposed to integrated,
and further include touch‐sensitive screens and "detachable andconvertible configurations".

EPA has clarified the Notebook definition to refer to physical keyboards withmoveable keys that cannot be detached from the screen. EPA will consider theinclusion of detachable and convertible configurations in the Version 6.1
specification development process. The inclusion of these products as well asslates/tablets should be subject to a more formal stakeholder process.

DefinitionsPoint‐of‐Sale
ComputerA stakeholder recommended the addition of a Point of Sale (POS)
product definition that included PC‐based products.

POS products are included in the scope of the specification only if they meetthe definitions of the other computer types. Therefore, no specific definition
has been added to the Final Specification.

Definitions

Slate Computing A stakeholder stated that excluding a definition for Slate/Tablet could EPA intends some devices falling within the popular categories of "Slates" andDevice
cause confusion because these products may fall under the definition "Tablets" within the Version 6.1 specification revision and will propose adefinition at that point. That will allow stakeholders a chance to provideof Notebook Computer and also suggested limiting the term to"Slate". The stakeholder further requested a timeline for Version 6.1 feedback on the scope of included products. Version 6.1 will start immediately
after v6.0 is published, and the targeted Final date of v6.1 will be the effective
if this definition if it not included in Version 6.0.
date of v6.0, or earlier.

Definitions

SwitchableGraphics

A stakeholder noted that some switchable graphics systems employ EPA has amended the definition of Switchable Graphics to include systems thatthe integrated GPU at all times and switch on the discrete GPU when keep their Integrated Graphics on at all times.
instructed and requested they be included through the following
definition: "Functionality that allows discrete graphics to be disabled
when not required in favor of an integrated graphics solution."

Definitions

Wake/Wake
Event

One stakeholder requested that these definitions be revised to take
into consideration all other low power modes that a computer may
be woken from in addition to Sleep and Off Modes.

Since alternative low power modes still in a state of flux and are not clearly
defined either in industry or in the specification at this time, EPA has continued
to restrict Wake On LAN functionality to those systems that implement Sleepmode. When clearer definitions for alternative low power modes are available
in future revisions, EPA will update these definitions as necessary.

A stakeholder stated that the requirements regarding power
management documentation (Section 3.4 User Information
Requirements) may limit manufacturers from providing informationto consumers of non‐ENERGY STAR computers, which could be atodds with other environmental initiatives.

The User Information requirements specify that documentation may beprovided with non‐ENERGY STAR certified computers as long as manufacturers
provide information on how to identify an ENERGY STAR certified
configuration.

Documentation

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Final Draft Version 6.0 Computers Specification Comment Response Document

Topic
Full Network
Connectivity
Weightings

Subtopic

Comment
A stakeholder expressed concern regarding the incentive for Full
Network Connectivity because it would allow the product to be lessefficient while still meeting the requirements. Although thefunctionality can reduce overall energy use in computers, without
further research on actual use, the savings potential is uncertain,
especially since computers are already required to enter Sleep Mode
within 30 minutes. On the other hand, there is a risk of highqualification rates: 40% of Version 5.2 notebooks and 62% ofdesktops could meet the draft Version 6.0 TEC requirements if using
the Full Capability mode weightings, with qualification rates evenhigher for 2012 models.

Response
EPA does not expect a majority of computers to implement a proxy with Full
Capability and therefore expects qualification rates to remain much lower thanunder that scenario. Therefore, EPA has maintained the previously proposedmode weightings in the Final Specification.

High qualification rates of 30‐‐60% would persist even if the Sleep
Mode power were to increase by 5 watts (e.g., to reflect the higher
power needs of Full Network Connectivity). Therefore, thestakeholder suggested alternative use profiles for models with Full
Network connectivity that feature a reduction in time assumed inLong Idle and Off Mode.

Full NetworkConnectivityWeightings

ResearchFunctionalAdderAllowances

A stakeholder suggested further research on the use profiles for Full
Network Connectivity for the next specification to understand theactual savings potential of this functionality.

EPA looks forward to working with stakeholders to validate the mode
weightings against updated usage data in the near future.

A stakeholder had the following comments and suggestions for theThe Integrated Display allowance differs from the requirement levels in theFunctional Adder Allowances:
Version 6.0 ENERGY STAR specification due to lower display luminance in theComputers test method compared to the Displays test method.
• It is unclear why Integral Displays in Computers have different
requirements than in the Version 6.0 Displays specification.
The 4 GB base memory for application of the Memory adder was removed as• The memory adder for Notebooks has doubled Since Version 5.2
part of the ITI proposal for computer categorization. However, similar to thewhile the efficiency of RAM modules has actually improved.
changes in the Additional Internal Storage allowance, the effects of theseMoreover, the memory allowance now applies to all Computers,changes on the TEC requirement are small and should have been reflected inrather than just above a base memory of 4GB.
• Similarly, the internal storage allowance for Desktop and Integrated the resulting base allowances. Moreover, when qualifying a product family, allconfigurations in the family (even ones without large adders) must meet thedesktop computers has increased since Version 5.2 as well despite
requirements.
market improvements.

This commenter believed that providing large adders for memory andstorage will encourage manufacturers to qualify a configuration byadding in extra memory and/or storage devices.

FunctionalAdderAllowances
Power in Long
Idle State

IntegratedDisplay Adder

One stakeholder requested that EPA clarify if the Integrated Display EPA has clarified that the Integrated Display adder can be applied for additional
adder can be applied more than once if a product has more than one Integrated Displays.
display.
A stakeholder suggested that the term "Connected Sleep State" bechanged to "Always‐Connected State", while another asked for adefinition to be provided for this term.

As the names and capabilities of low‐power non‐Sleep states continue toevolve, EPA has not included a definition in the Final Specification, relying on
their difference from the other defined states and modes. All suchstates/modes are referred to now as "alternative low power modes"
throughout the specification.

Another stakeholder asked if the requirements for using Long Idle inplace of Sleep for products that do not support a Sleep Mode should
EPA will only allow substitution of Long Idle for Sleep mode in Notebooks,
also be included for Workstations.
Desktops, and Integrated Desktops, as alternative low power modes do notappear to be a candidate for use in workstations at this time.

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Final Draft Version 6.0 Computers Specification Comment Response Document

TopicPowerManagement

Subtopic

PowerManagementSleep ModeCommentResponse
One stakeholder did not support the division of products into
EPA thanks stakeholders for their input on this issue. As of the writing of thisConsumer and Enterprise due to complexity. Instead, the stakeholder comment, EPA has proposed recognizing alternative low power modes fornotebooks and desktops (in place of Sleep) so long as those modes consume
recommended that all products be required to meet the TEC limit
and support either sleep or an alternative low power mode without less than or equal to 5 W. EPA intends to make this requirement part of theFinal Version 6.0 Computers specification, but is still in discussion withthe proposed 5 W limit. The stakeholder further forecast thatstakeholders.
models with Sleep Mode will remain dominant and noted that theTEC ENERGY STAR limits were calculated with a database of systems
EPA believes that new low power modes that serve as alternatives to Sleep orthat used Sleep technology, not “always on” technology.
as improvements to Long Idle should be recognized and, when truly energy
efficient, encouraged via inclusion in the ENERGY STAR Computers
Another stakeholder commented that removing the Sleep Modespecification. Given the nebulous status of many of these new modes, EPA has
requirement would conflict with forthcoming EU Ecodesign
regulations and requested its restoration, and requested that models proposed a very generic way of referencing them (simply as "alternative low
with Sleep Mode continue to meet the requirements if Full Network power modes") and has proposed a generic modal limit of less than or equal to
5 W to ensure continued efficiency of products that implement them. As theConnectivity is disabled. Lastly, a third stakeholder suggested
modes are better defined and understood, they can be formally added toclarifying in Table 2 that only the Display Sleep Mode Requirement
future revisions of the ENERGY STAR Computers specification and incorporated
would apply to models without Sleep Mode.
into the overall TEC calculations.

A stakeholder noted that power management requirements may not
be applicable under alternative low power modes. Therefore, users
should be informed if power management settings have been
disabled due to alternative low power modes and instructed how tore‐enable them.

Full Network Connectivity refers to a suite of capabilities present when asystem enters Sleep Mode or (with language currently being inserted into v6.0Final) an alternative low power mode consuming less than or equal to 5 W.
Power management requirements for Sleep Mode are as listed in Table 2.
Power management requirements for alternative modes are restricted to
Display Sleep Mode, as the remainder of the power management requirements
apply specifically to capabilities developed for ACPI S3 Sleep Mode.
Regarding user information, manufacturers are provided several options forproviding information to users. Per section 3.4.2, if the power management
settings are not present due to alternative low power modes, option (i) would
apply and manufacturers would have to provide a list of the default power
management settings.

TEC
Requirements

TECRequirements

Power SupplyEfficiency
Incentive

A stakeholder noted that the Desktop I3 and D2 categories have thesame base allowance although the Desktop D2 category has a higher
performance score. They suggested that the base allowance for
Desktop I3 be reduced or if warranted, extra allowance be given in
the GPU adder for the Desktop D2 category.

Although the performance score of D2 Desktops may be higher than that of I3
Desktops, the base allowance for the I3 must also accommodate graphics
energy consumption, which can be covered by the Discrete Graphics Adders or
the Switchable Graphics Incentive in the case of D2.

A stakeholder supported the inclusion of the incentive for internal
power supplies that are more efficient than the minimum 80 PLUS
Bronze requirement because it will create demand for more efficientinternal power supplies in real‐world usage conditions. However, thestakeholder recommended increasing the 10% load requirement to
82% to reflect current average performance in the market and yield
greater savings.

Due to the lack of opportunity for discussion at this late stage and the potential
for excluding otherwise‐efficient 80 PLUS Silver power supplies, EPA has notmade any changes to the efficiency criteria for receiving power supply
efficiency incentive. However, EPA has revised the incentives table to include
Desktops with external power supplies with the same incentive level as
Desktops with internal power supplies.

Another stakeholder noted that there is no incentive for desktop
computers that are supplied with more efficient external powersupplies.

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Final Draft Version 6.0 Computers Specification Comment Response Document

Topic
TEC
Requirements

Subtopic
Switchable
Graphics

Comment
A stakeholder noted the substantial energy savings that could be
gained from switchable graphics, but expressed concern that thecurrent draft provides a disincentive since manufacturers can claim afull discrete graphics adder by disabling the switchable graphics butonly a small incentive in the case of Desktops and Integrated
Desktops and no incentive in the case of notebooks if they do enableit.

Response
Although the incentive for Switchable Graphics is smaller than the allowances
for Discrete Graphics Adders, those can only be applied when the Discrete
Graphics is enabled (and therefore using energy). Therefore, on balance, theSwitchable Graphics incentive continues to provide a benefit.
EPA will consider further proposals to testing Switchable Graphics in a futurespecification revision.

The stakeholder therefore suggested that EPA increase the incentiveto a full G1 adder for Desktops and Integrated Desktops and notallow Notebooks capable of switchable graphics to claim a discrete
graphics adder. Instead, these Notebooks should be required to haveswitchable graphics enabled by default in Short Idle State to qualify
for ENERGY STAR.
This stakeholder recommended that triggers for graphics switching
be verified to prevent a loophole from manufacturers configuring
products to switch based on AC/DC status as well as graphics
intensity. They also stated that forcing notebooks to switch tointegrated graphics during testing removes the incentive to improve
discrete graphics energy use, which could discourage low‐power
discrete graphics. As a result, they requested testing with thediscrete GPU switched on and off in future specifications.

Scope

IncludedProducts

The Included Products section is based on the five computer types (Desktop,One stakeholder requested that POS products based on
Notebook, etc.) which each have separate definitions and requirements. As
Desktop/Integrated Computer designs and standard
POS systems do not have an agreed‐upon definition or requirements, EPA has
Desktop/Integrated Computer operating systems be added to thescope. Another stakeholder requested that mention of Tablets either instead kept the current exclusion of non‐PC products in the Final Draft.
be removed from the scope or a definition for Tablets be re‐added.

Scope

Excluded
Products

A stakeholder suggested adding Docking Stations to the Excluded
Products section.

Although docking stations do not meet the computers specification, EPA has
added them to the list of excluded products for clarity.

Thin Clients

Adder
Allowances

A stakeholder requested that the TEC base allowance be changed to60 kWh (in Table 11) as previously agreed.

EPA has changed the TEC base allowance for Thin Client.

Workstations

PMAXA stakeholder noted that P MAX for Workstations is measured three
DOE has clarified that PMAX is the average of the three measured values.
times in the test procedure and asked which measurement should be
used in the PTEC_MAX formula. Furthermore, the stakeholder
Also, although the workstation performance and requirements are power
questioned the appropriateness of referring to both P TEC and PTEC_MAX values, both include modal assumptions, and therefore EPA has retained theTEC designation in their symbols.
as "TEC" because they are power, not energy, values.

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