ENERGY STAR Small Network Equipment Draft 3 Stakeholder Comments and EPA Response

Index #1

Stakeholder Comment

EPA Response

One stakeholder commented that the definition of Small Network Equipment could cover products listed underSection 2.2 Excluded Products. In order to avoid products falling ambiguously between the definition of Small
Network Equipment and Large Network Equipment, the stakeholders suggested that EPA revised the definition ofLarge Network Equipment to state, "and other networking equipment not included in the definition of Small
Networking Equipment."

EPA recognizes that there are certain product segments that may not be covered by the Version 1.0 Small
Network Equipment (SNE) or Large Network Equipment (LNE) specifications, for example "enterprise"
access point products. EPA aims to cover as much of the network equipment market as possible
between the Version 1.0 SNE and LNE specifications, while acknowledging that particular types ofproducts may not be covered until subsequent specification revisions.

Two stakeholders suggested that EPA further specify the definition of Small Network Equipment such that enterpriseand industrial equipment are excluded by including necessary criteria that the products be designed for "indoor use"or "operation in residential and commercial environments."

2

EPA does not intend to change the SNE definition to specifically address products used indoors or
which operate in residential and commercial environments. EPA has made minor modifications in theOne stakeholder believes that the Small Network Equipment definition language of “a) all Network Equipment withscope exclusion section which do affect some "enterprise" class products.
integral wireless capability” was an effort to include all access points within the SNE specification. As written, thestakeholder noted that such a definition is overly broad and may include many devices such as cellular base stations,
EPA agrees with this suggestion and has proposed a revision to the scope section of the Final Draft
microwave bridges or large-scale routers using Bluetooth/NFC for console connections, which it does not believe isspecification to provide clarity on various forms of wireless capability.
the intent of ENERGY STAR. The stakeholder recommended that the definition be further clarified to define what ismeant by Network Equipment with integral wireless capability. For example, the definition could be limited to network
equipment with 802.11 Wireless LAN access point capability.

3For the definition of Physical Data Port, one stakeholder commented that the term "Ethernet" does not refer to any
specific media but may refer to physical network ports that operate over twisted pair cable, fiber optic cable, coaxial
EPA thanks stakeholders for this feedback and has revised the Physical Data Port definition accordingly.
cable (or backplanes). Therefore the item "a) Ethernet" should be removed and the other items revised as follows, "a.
Twisted pair (Ethernet, DSL, Phone), b. Coaxial cable ( DOCSIS), c. Fiber optic."

4One stakeholder observed that the definition for “Full Network Connectivity” appears to be a definition for some formof “Networked Standby,” although it is also muddled with some definitions for “Network Proxy” near the end. In
normal parlance, “Full Network Connectivity” should refer to the state of network connectivity; “Networked Standby”
should refer to reduced power states where some network connectivity is maintained; and “Network Proxy” shouldrefer to mechanisms by which network connectivity is maintained whilst in reduced power states. The stakeholder
suggested that EPA rewrite the section, possibly splitting into separate definitions for separate terms, and noted thatthe definition for “External Proxy Capability” could be affected (and improved) by this change.

5Stakeholders commented that the ENERGY STAR Large Network Equipment (LNE) specification is the appropriate
specification for addressing enterprise network equipment and that to the degree possible, the SNE specification
should focus on consumer grade equipment. One stakeholder recommended that the EPA consider stating in the SNE
EPA does not have enough data to support the separation of "consumer" vs. "enterprise" in mostspecification the general intent of the SNE specification to focus on consumer equipment.
network equipment product categories, as the products often contain similar functionality. EPA has
removed "enterprise" access points from the scope of Version 1.0, as they have particular features which
Another stakeholder suggested that EPA make the Excluded Products criteria more inclusive of other types ofmodules by revising “Section 2.2.2 i Network Equipment with one or more Small Form-factor Pluggable (SFP) network clearly separate "consumer" access points from "enterprise" access points, and require significantly
more power consumption. EPA hopes to cover these "enterprise" access points in the Version 2.0 SNEports” to “Network Equipment capable to accept interchangeable modules, such as network/line cards or additional
specification with the aid of additional product data.
power supplies; or with one or more network ports using pluggable or modular media adapters such as Gigabit
Interface Convertor (GBIC) modules or Small Form-factor Pluggable (SFP) modules.” Two stakeholders suggested
that the criteria for classifying excluded products include “Equipment powered via POE or providing POE for another EPA has excluded Power over Ethernet (PoE) from the scope of the Version 1.0 SNE specification, asdevices.” and “Equipment that has provisioning for rack mounting.” One stakeholder suggested the following revision there is no way to measure in the Version 1.0 SNE Test Method. This exclusion will remove some"enterprise" type network products that are not intended for use by typical consumers, but also may orfor Section 2.2.2. iii, “Requires a physical or virtual controller for operation of the access points or networking
may not fall into scope of the upcoming Version 1.0 LNE specification depending on their port count.
devices.” The stakeholder also proposes that the EPA adopt the following as one additional bullet to the criteria for
excluded products:
EPA revised the previous Small Form-factor Pluggable (SFP) module scope exclusion in the Draft 3“Products that incorporate the required capabilities or are certified for government or vertical industry specifications specification, now excluding products with other module types such as Gigabit Interface Convertors orany other modular media adaptors (with the exception of USB).
such as:a) TAA (Trade Agreement Act)
EPA did not address the exclusions listed to the left as there is no way to test the relevant functionality inb) Section 508 of the Rehabilitation Act
the test method. Purchasers who require the specific capabilities listed may purchase those productsc) FIPS 140-2 (Federal Information Processing Standards for Cryptology)
regardless of their energy efficiency performance if no qualified ENERGY STAR products can provided) National Security Agency Suite B Cryptographythat capability.
e) Voluntary Product Accessibility Template (VPAT) Policy & Informationf) The Health Insurance Portability and Accountability Act of 1996 (HIPAA) Privacy, Security and Breach NotificationRulesg) The Payment Card Industry (PCI)”Page 1 of 3

The Full Network Connectivity definition section was taken from the ENERGY STAR Version 6.0
Computers specification definition, and is intended to describe functionality that allows end-point
products in sleep mode to remain network connected to the SNE product. This section does notreference standby, and is not intended to address network connected standby of the end-point productor SNE product.

ENERGY STAR Small Network Equipment Draft 3 Stakeholder Comments and EPA Response

Index #Stakeholder Comment

EPA Response6

One stakeholder requested that EPA include an additional functional adder of 0.5 W for a back up battery charger.

EPA has no product data to support a functional adder for back up batteries or battery chargers.

7

EPA will maintain the current External Proxy Incentive to encourage SNE products to allow proxying of
attached end-point devices. The system savings potential of allowing end-point devices (computers,One stakeholder recognizes the External Proxy Incentive would support the awareness of full network connectivity
imaging equipment products, etc.) to enter network connected sleep can far exceed the small incentive
and devices enabling the function, however, the stakeholder believes the incentive values are quite high and not
the SNE product may receive for supporting the proxy functionality. As this functionality becomes more
representative of the additional power consumption of the devices. The stakeholder suggested that the incentive be inmainstream, EPA will discontinue this incentive.
the form of required reporting whereby the added benefits of purchasing devices supporting full network connectivity
are made public and promoted on the ENERGY STAR website.
EPA will make the level of supported External Proxy available on the ENERGY STAR website along withthe other SNE product information.

8One stakeholder asked if their were requirements for multiple voltage power supplies.

9In addition, one stakeholder commented that some of the data provided for DOCSIS 3.0 cable modems and cable IADs
did not involve uniform test configurations. The stakeholder noted that those vendors that provided data with very
low Pavg power consumption may have reported results with the cable modem or cable IAD in DOCSIS 3.0 Energy
Management 1x1 Mode (1 downstream channel and 1 upstream channel). Currently, there is a lack of CMTS support
EPA has provided additional testing guidance for products that are capable of operating in DOCSIS 3.0
for Energy Management 1x1 Mode on commercially available CMTSs and it is unknown when CMTS support will be
Energy Management 1x1 mode. This guidance can be found in Section 4.1.3 of the Final Draft
available on commercially available CMTSs. Other vendors may have provided data in which the CM did not go intospecification.
Energy Management 1x1 mode which would reflect the additional power consumption of having multiple downstream
and multiple upstream channels active. Therefore if these Draft 3 base power allowances are retained, the stakeholder
commented that the Test Method must ensure that conditions are such that the CM or cable IAD goes into Energy
Management 1x1 Mode, ensuring that a CMTS used in testing supports the feature.

10

One stakeholder suggested indicating the different manufacturers in the EPA dataset in order to understand thedistribution between manufacturers per product type e.g. by indicating Company A, B, C, etc.

11One stakeholder submitted data to EPA from reference designs with different configurations to clearly demonstrate
EPA did not include the aforementioned data in the dataset because the data was based on reference
the functional adders across different products. The stakeholder noted that these data were not included in the Draft 3
designs, and not actual products currently sold on the market. EPA did consider this data in the internal
dataset and requested they be incorporated into a revised dataset to determine the base power allowances andevaluation of revisions to existing requirements.
additional functional adders.

Multi-voltage external power supplies are subject to the power supply requirements in Section 3.2.1 ofthe Final Draft specification. This includes meeting the level V performance requirements under theInternational Efficiency Marking Protocol and include the level V marking.

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EPA will release an updated version of the dataset on the SNE product webpage with company identifiersin the form suggested by the stakeholder.

ENERGY STAR Small Network Equipment Draft 3 Stakeholder Comments and EPA Response

Index #12

Stakeholder Comment

EPA Response

One stakeholder noted that the flexibility by the ENERGY STAR program in working with industry to continually revise
specifications based on changes and updates in technologies deployed is critical to the ICT industry as 1) network
equipment products evolve more rapidly than other equipment typically covered by ENERGY STAR, and 2) there arenatural convergence points in ICT equipment where over time various functionalities are consolidated into a single
piece of equipment. Products within the SNE specification will likely see rapid evolution over the next decade basedon market demand and the proliferation of sensors and other connected devices in the home. Thus the stakeholder
EPA acknowledges that SNE is a rapidly changing product category. EPA will track innovations andcommented that the ENERGY STAR SNE specification will require flexibility to adjust to various functionalities being product energy efficiency performance upon the completion of Version 1.0 to assess when to start ofconsolidated into products in the SNE specification.
Version 2.0 development.
Another stakeholder suggested that the following be listed for consideration in future revisions of the specification:• Power management: Powering down at low traffic volume, scheduling WLAN in on and off periods and automatic
switch off of unused interfaces.
• Potential inclusion of professional access point products marketed as enterprise network equipment that are; (1)shipped without a power supply, and/or (2) cannot operate without a separate external access point controller.
• Removal of the fast Ethernet adder. The stakeholder believes that already now most products have this feature, andsuggested that the intention to remove this adder is listed here and that other adders should be reassessed as well.

13For greater accuracy and clarity, one stakeholder recommended that following language revisions throughout thespecification:- "power consumption" to "power" or "energy consumption"- “maximum requirement for Average Power Consumption PAVG_MAX)” to “Average Power Allowance (PAVG_ALL)”

Page 3 of 3

EPA has added new proposed topics in the "Considerations for Future Revisions" section of the Final
Draft specification.

EPA has simplified the existing language in the Draft 3 specification, changing "power consumption" to"power" where appropriate. EPA has retained the maximum requirement language in the Draft 3specification.