ENERGY STAR Version 9.0 Final Draft Specification Comment Response Document
TopicGeneralOn ModeCriteria

Comment Summary

EPA Response

Several stakeholders expressed support for the Version 9.0 specification, noting that the updated
criteria will be more representative of average consumer use of the latest television technology.
Specifically, stakeholders supported the revised HCR definition and alignment with the ANSI/CTA‐2037‐C test method.
EPA appreciates these comments.
A stakeholder proposed the use of weighted On Mode metrics that factor in the typical usage ofeach preset picture setting based on recent survey data. The survey included 100 participants from
EPA appreciates this additional information and understands the merits of this suggestion to improve
California and indicated that 26% consumers keep their TV in the default picture setting while
representativeness of how the TV is being used. However, this suggestion warrants further research andabout 58% change to the brightest picture setting. This stakeholder recommended using thisinformation to weight the results of each of the three picture settings being considered as part of investigation of more consumers and in diverse geographical locations. EPA included this in thethe Version 9.0 criteria.
Considerations for Future Revisions section of the specification.
EPA reviewed the full data set of 12 HCR models, which demonstrated a 25% pass rate (3 out of 12) of HCR‐
capable TVs. One of these models were within 1% of meeting the requirements without the adjustment
factor but the vast majority of the models could not meet with the adjustment factor. Based on this data,
EPA believes the adjustment factor reflects the intention to recognize the top‐performing HCR models.
Several stakeholders supported the updated HCR definition to prevent misidentification. Onestakeholder supported the updated preset picture setting requirements and interpolation
instructions.

High ContrastRatio (HCR)
Test Method

Also, the observed increases in efficiency between the 2020 and 2021 models supports EPA’s belief that
there are readily available means by which manufacturers can increase efficiency and reinforces theviewpoint that by making ENERGY STAR certification obtainable for these products, there is an incentive for
A stakeholder suggested reviewing additional HCR model data to determine if the HCR adjustment manufacturers to do so. Additionally, these models observed to meet requirements after someredevelopments are significantly more efficient than comparable models that have not been updated,factor should be reduced. Another stakeholder recommended removing the HCR adjustment
which supports the notion that the models that have been engineered to perform well above the baseline
factor for the following reasons:should be recognized.
• It will discourage energy efficiency. Some models are close to meeting without an adjustment
factor, which demonstrates that if efficiency gains are implemented, OLED models would not needan adjustment factor to meet.
EPA acknowledges that as new technologies emerge, these proposed criteria levels may need to beadjusted. However, there is no current data to support that future technologies will increase efficiency• Test data shows that certain OLED TVs would qualify without an adjustment factor and thatwhile providing a similar contrast ratio or when these technologies may be available on the market. The
there has been an efficiency improvement of 16.9% when comparing 2020 and 2021 models.
appropriateness of the HCR adjustment factor will be reevaluated as additional models that qualify for it are• Lowering the bar for OLED technology would not be technology‐neutral.
• It conflicts with precedent as plasma TVs had HCR, yet were not given an adjustment factor tointroduced to the market or when new technology is available that demonstrates similar contrast ratio withmeet ENERGY STAR.
increased efficiency.
A stakeholder noted that the latest version of the ANSI/CTA‐2037‐C test method has 150 lux as the EPA appreciates this clarifying comments and has made the necessary updates to reflect this in thehighest illuminance testing condition, not 140 lux.
specification.

Page 1