ENERGY STAR Computers
Discussion Guide
December 2018

Overview
The U.S. Environmental Protection Agency (EPA) is sharing this ENERGY STAR Computer Program
Discussion Guide: Version 8.0 to invite early stakeholder input on aspects under consideration for therevision of this specification. The topics that EPA feels are of particular importance for discussion prior toa Draft 1, Version 8.0 release are:
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Categorization system used to set leadership levels.
Duty cycle and mode weightings, including incentives for features promoting more functionalpower management
Internal Power Supplies
Resume time from sleep
Scope
Treatment of non-traditional SSD options

EPA will host a webinar on Monday, January 14, 2019 from 1-3 PM Eastern Time to engage withstakeholders on the content included in this discussion guide. Stakeholders are asked to share written
feedback with EPA by January 25, 2019. As always, stakeholder engagement is a vital ingredient in thesuccess of the ENERGY STAR program and EPA looks forward to working with all parties to develop theENERGY STAR Version 8.0 Computers specification.

Categorization SystemIn March 2018, EPA held a stakeholder meeting to discuss categorization of desktop computers for
Version 8.0. EPA and stakeholders presented three different categorization systems that the Agency wasconsidering for Version 8.0 desktop categorization: p-score, currently used by EPA for the ENERGYSTAR program, expandability score, which is used by the California Energy Commission (CEC), andsimplified expandability score, which had been proposed by the California Investor Owned Utilities. Inaddition, EPA held one-on-one conversations with each of the major desktop manufacturers to get moredetailed thoughts on each of the categorization systems. The general conclusion from this set of meetings
was that while there is a strong preference from industry to not introduce an additional categorization
system, there is not a strong preference between p-score and the expandability score.
In order to more fully vet expandability score and its applicability to the ENERGY STAR program, EPA
collected data as part of the Version 7.0/7.1 recertification of desktops and gave manufacturers time tosubmit data on non-certified products. This data, which includes data from the ENERGY STAR certified
product list and data submitted by ITI on non-certified systems, is presented here and provides acomparison of how p-score and expandability score sort products and to what extent one or both metrics
are appropriate for identifying leadership levels for desktop computers.

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In Figure 1 below, 834 desktop configurations were separated out based on their expandability bins1, withthe “max” bin equating to products which fall under max expandability exempt (e.g. workstation)requirements for CEC, although they are defined and treated as desktops for ENERGY STAR purposes.
While there is a general trend upward in energy usage as the CEC categories increase, there issignificant overlap and reduced differentiation between the medium and high expandability categories,
which is where the majority (74%) of the configurations sit. Additionally, there is a notable group of highexpandability bin products with TEC lower than the 25th percentile of medium bin products, which arepredominately desktops with integrated graphics, which shows that the expandability score does notserve as a differentiator for energy use.

Figure 2 shows the same data but is further broken out by current p-score category. The red box
highlights the lack of differentiation particularly between integrated graphics desktop products in themedium and high categories. This pattern holds true for most integrated graphics products found in themaximum category and to a lesser degree the discrete graphics products whose median power usage
levels are similar across the entire expandability score category spectrum.
EPA acknowledges that p-score needs some updating particularly to address the I3 category, but thedata indicates that p-score better addresses the TEC differences between integrated and discretegraphics. Median marks (Boxplot center lines) in Figure 2 highlight power usage profile differences
between integrated and discrete graphics in each expandability score category. Also notable areintegrated systems found in the CEC max expandability bin (exempt), which are comparable to systems
within lower expandability bins which are non-exempt products.

The CEC broke out the expandability score into the following bins: Low: EXP ≤ 250, Med: 250 < EXP ≤425, High: 425 < EXP ≤ 690, Max: 690 < EXP.
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Based on these findings, and lack of stakeholder feedback advocating for a change, EPA currently
believes that maintaining the p-score category system in Version 8.0, with upcoming modifications to pscore boundaries and performance categories as needed to best fit the latest data set, is the best pathforward for Version 8.0. Categorizing our data set using the expandability approach alone does notappear to create meaningful differentiation across the bulk of products in the medium and high categories
and does not differentiate sufficiently well between the power profiles of integrated and discrete graphics
products. EPA thanks stakeholders for the data that has been provided to date and welcomes commenton the data presented in this guide and will continue to monitor the development of the expandability
score in future specification revisions, as appropriate.
1. Are there other considerations that EPA should evaluate before deciding on use of an updated pscore desktop categorization approach in Version 8.0?
2. Are there additional data points that stakeholders would like to share on non-certified products tosupport this decision making regarding categorization?

Mode Weightings
EPA has received partial mode weighting data from partners which may provide a foundation for revisedmode weightings in Version 8.0. This data was provided in aggregate form from over 1.8 million desktop
systems and 3.5 million notebook systems over a period of nearly two years (ending in 2017). The data
includes products used in both residential and commercial settings and provides much better clarity ontime products spend in off mode vs. on mode (sleep + long idle + short idle). Unfortunately, the current
data do not distinguish clearly between the various on modes, although EPA is looking forward toreceiving additional data in advance of Draft 1 that will do so.
The initial data received suggest that the mode weightings the ENERGY STAR computer specificationreferences presently do not accurately reflect the way computers are currently used today. Figure 3
shows the proposed breakdown of sleep and off mode based on data received to date.

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Desktops

Desktops

Notebooks

Notebooks(Current)(Proposed)(Current)(Proposed)

TOff

45%

30%

25%

25%

TSleep

5%

30%

35%

45%

Tlong_Idle

15%

PowerState

10%
40%

Tshort_Idle

35%

30%
30%

In particular, the initial data results indicate that desktop computers spend about a third of their time insleep and a third of their time in off mode. Notebook computers were found to spend roughly half of theirtime in sleep and about a third of their time in off mode. EPA would like to consider changes to the mode
weightings as part of the Version 8.0 process and encourages any other stakeholders with data that
supports or refutes these initial findings to provide it.
A priority of the ENERGY STAR Version 7.0/7.1 notebook requirements was increasing the adoption ofhighly functional power management settings, with the stated aim to improve the amount of people who
maintained the power management settings. A key component of this strategy was allowing alternative
low power modes, such as connected modern standby and comparable functions to obtain more
beneficial mode weightings. Since the implementation of that strategy, EPA has learned new details
about the use of power management by end-users and the ability of manufacturers to successfully
implement connected modern standby and comparable functions. In particular, EPA has found thatpeople are already increasing the amount of time the product remains in sleep or off mode, as indicatedby the mode weighting discussion above. In addition, the Agency has seen data, which indicates thattraditional power management is maintained at a much greater rate than previously believed. EPA is now
assessing additional opportunities to increase or improve the service offered in low power mode throughthis specification revision.

1. Do additional stakeholders have large scale mode weighting data to help inform potential
modified mode weightings for use in Version 8.0? If so, when can they be shared?
2. The existing mode weightings are based solely on enterprise systems, as this was the information
available at the time, while the proposed weightings include residential usage as well. Is this anappropriate focus for ENERGY STAR, or should enterprise systems continue to be the focus?

43. During the development of Version 7.0, EPA received information that manufacturers weretargeting connected Modern Standby as the key feature to reach the CEC standard levels for2021. Is this no longer the case or what other options are being considered to reach these levels?
4. Data shared with EPA appears to indicate that power management is not turned off in the vast
majority of systems, which is also supported with the mode weighting data shared above. Is there
additional data that stakeholders have which would support or refute this conclusion?
a. Additionally, the original data that EPA received, which indicated that power management
was being turned off, focused on enterprise systems, while the current dataset is a mix ofboth. Is there any nuance that EPA should be aware of related to enterprise computersthat would lead to a different conclusion in the adoption of power management?
5. Given the mode weighting data and the potential dramatic increase in power management
adoption, is there a reason for EPA to consider continuing to incentivize features such as EMCA393 full capability, connected Modern Standby, and other solutions with comparable functions?
Or does a need remain to incentivize these features due to the increased functionality to ensurethat there is no risk to power management being turned off in the future?
During the meeting with stakeholders in March, the National Resources Defense Council presented its
work on developing a test method for active mode testing. EPA continues to monitor the progress of thisinitiative and welcomes any update on this process from stakeholders.

Internal Power Supplies
In January 2018, EPA held a stakeholder meeting to discuss interest in developing alternativerequirements for internal power supplies, focusing on low-load power. EPA has maintained
communication with the 80Plus program and has found that overall, power supply efficiency at lower load
levels is consistently efficient. More specifically, the 80Plus program found that it is able to accurately
measure data as low as the 5% loading point via its testing protocol. In addition, the analysis of thedataset, which includes testing on over 100 products, shows that there is good correlation between the50% load efficiency and the 5% load efficiency. There was also a likely correlation between the 100%load correlation and the 5% load efficiency. For this reason, the Agency is not considering setting levels
for the 5% load at this time. However, the Agency is interested in further data collected by the 80Plus
program at the 5% load as part of its program.
As part of V7.1, EPA amended the internal power supply requirements for products at 500W or higher.
For V8.0, EPA will take a second look at the requirements for power supplies less than 500W to consider
the need to raise those requirements.
1. Do stakeholders agree with the assessment, based on 80Plus data, that the efficiency of thepower supplies at 5% load is at an adequate level to not require specific criteria?
2. Is there any additional data that EPA should consider when determining if power supply efficiency
has improved to the point that greater savings are possible for those products under 500W?
3. Is there any further data or comment on increasing the internal power supply requirements for
products operating at less than 500W to 80Plus gold or equivalent to match the requirements atgreater than 500W?

Resume Time from Sleep
As part of the Version 7.1 specification development effort, EPA was approached by stakeholders toreconsider the sleep definition, particularly the inclusion of a five second resume time. Stakeholders
shared concerns that there was no test method element to accurately test this and therefore the definition

5requirement was inconsistently applied. The U.S. Department of Energy has worked with stakeholders todevelop a test method, which will be included in Draft 1. EPA has received data, which indicates thatwhile five seconds is reasonable for notebooks, further consideration should be given to desktops andworkstations, which may take additional time to resume.
1. Are there any additional data points that stakeholders would like to share to help inform EPA’s
assessment of resume time?

Scope
Since the release of the Version 7.1 specification, EPA has been made aware of new technologies thatare being developed for the market, which require clarification of if and how these products fit within theENERGY STAR program structure. These products include:••Multi-Screen Notebooks
Mobile Phone, which can convert to a Tablet

EPA proposes a new definition for Multi-Screen Notebooks, which will be used to bring these products
under scope. The definition EPA proposes for these products, as a sub are:
•A computer that resembles a traditional notebook computer with a clam shell form factor, but has
a second display that can be used a touch screen keyboard in place of a traditional mechanicalkeyboard. Multi-screen notebooks are considered notebooks in the remainder of this specification
and are therefore not referenced explicitly.

EPA plans to exclude products, such as this, which are a mobile phone device, which can be converted
into a tablet. As their primary function is a mobile phone device, the Agency does not believe that it isappropriate to consider these under the computers specification. EPA is interested in stakeholder
feedback on how to define these products so the Agency can make clear the scope of this specification.
1. Are there any other products that manufacturers will be releasing that EPA should consider forinclusion under the Version 8.0 specification?
2. Does the definition for multi-screen notebooks capture the various iterations of these productsthat are expected to be released over the life of the Version 8.0 specification?

Treatment of Non-Traditional SSD Options
EPA is aware of an increasing number of non-traditional SSD storage device options that are being
shipped in M.2 slot form factors. Currently, these products are not eligible for storage device adders in thecomputer specification. EPA welcomes energy and performance data on these devices so that we may
consider whether it is appropriate to apply the current storage device adders to them, or whether amodified adder for them makes sense.
1. Are there any other forms of non-traditional based storage device that EPA should consider in
Version 8.0? If so, is there data available to address them if appropriate?
2. Are there other M.2 devices that provide functionality different than a storage device that EPA
should account for in Version 8.0? If so, what are they and is there data available to address
them if appropriate?

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Version 8.0 Revision Schedule
EPA sees value in giving stakeholders insight into the anticipated timeline for the Version 8.0 specification
development early in our process. Following this discussion guide, EPA expects to release a draft 1 and2 by the end of June 2019 with publication of a final specification in September 2019 that takes effect inJuly 2020.
1. Are there market issues that impact the anticipated timing of this development that warrant
consideration, such as retail and corporate/government purchaser cycles?

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