Draft 2 Version 8.0 Computers Comment Summary

TopicGeneral

Subtopic

Pass Rate

Comment Summary
One stakeholder recommended that EPA target a pass rate of 15 to 20 percent of theENERGY STAR QPL in order to account for likely increases in efficiency due toincreasing adoption of the California Energy Commission minimum efficiency
requirements by other states.
Industry partners requested that EPA target a pass rate of 33.7% based on analysis that
this would align with 25% of the market in terms of shipments (as opposed to modelavailability).

GeneralCertification Criteria

Certification CriteriaEPA Response
EPA has targeted the top quartile of products in the ENERGY STAR dataset
in the Final Draft specification. This incorporates the adjustments to the adderstructure. As noted in the ENERGY STAR Guiding Principles, experience has
shown that it is typically possible to achieve the necessary balance among
the key principles of the program by selecting efficiency levels reflective ofthe top 25% of models available on the market when the specification goes
into effect. These principles include ensuring national energy savings,
maintaining product performance, reasonable payback period for consumers,
and effectively differentiating products for consumers with the ENERGYSTAR label.

Recertification

Industry stakeholders expressed the expectation that, pending EPA direction to CBs, onlya small number of notebook computers that exhibit cyclical behavior would require
EPA thanks stakeholders for the feedback that the impact of this test method
retesting. Industry also commented that retesting should not be necessary forchange will be minimal on existing products. Given this feedback, EPA will
workstations, arguing that while mode weightings have changed the pass rate has
require retesting for products impacted by this test method change.
increased.

Energy Efficient
Ethernet

Two stakeholders commented that EPA should require energy efficient ethernet (EEE) tobe enabled on all ports in Version 8.0 as opposed to waiting to require this in Version 9.0.
Stakeholders cited the long lead time industry has had to prepare for this change and thelow cost to enable EEE in a compatible port. Given the relative ease of implementation,commenters argued, there is no reason to delay the requirement.

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

Industry proposed aligning allowances for computers with External Power Supplies withthose for Internal Power Supplies and provided proposed allowances.

EPA does not have any data indicating the benefit that the program would
accrue from this type of incentive. Nor is the Agency aware of any data thatexists from other programs, such as EPEAT, which currently alreadyincentivizes pushing beyond federal requirements. Given that many products
seeking ENERGY STAR certification are also seeking EPEAT recognition,
EPA believes there is already enough incentive in place.

External Power
Supplies

One stakeholder and utility partners expressed support of the ten percent loadrequirements for internal power supplies and EPA's proposal to maintain respective 80
PLUS Bronze and 80 PLUS Gold equivalent levels at other load points.
Certification Criteria Internal Power Supplies

Industry partners recommended combining desktops with integrated desktops, aligningwith 80 PLUS levels, and specifying an efficiency of 80% at the ten percent load point for
all cases except aligning with 80 PLUS Titanium for power supplies with greater than
500W output, which requires 90%.

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EPA received a variety of comments regarding internal power supply testingover the course of this specification development process and believes thatthe criteria and incentive structure is an appropriate compromise for all
stakeholders. EPA considered the incentive structure that stakeholders
proposed and believes that there is enough incentive in place, by reducing
the TEC as part of the test method, for 80Plus Silver and Gold equivalent
products. However, EPA has maintained the incentive structure for 80Plus
Platinum and Titanium as the Agency believes that this remains anopportunity to transform the market.