UNITED STATES ENVIRONMENTAL PROTECTION AGENCYWASHINGTON, D.C. 20460
OFFICE OF
AIR AND RADIATION

November 14, 2017,Dear Computers Stakeholder:th®

On September 28 , 2017, the U.S. Environment Protection Agency (EPA) released the ENERGY STAR
Computers Version 7.0 Draft 2 specification. EPA held a webinar to discuss proposed updates andthstakeholder feedback on October 12 , 2017. In response, compelling feedback was provided thatadjustments to the notebook category 2 base allowance and notebook memory adder are warranted inorder to allow sufficient selection of certifying models across different hardware platforms. Theseadjustments are also necessary to ensure the memory adder is not penalizing configurations with small
amounts of memory and providing a disproportionate adder amount to configurations with large amountsof memory. EPA is seeking feedback on these potential modifications to the Draft 2 proposal prior toincluding them in the Final Draft specification, expected to be released in early December.
Revised Notebook Category 2 Base Allowance

EPA received stakeholder feedback suggesting that the notebook category 2 base allowance would limit
the certification of different hardware options with 16GB or less of memory. As a result, EPA is proposing
to increase this base allowance from 12 to 14 kWh/year, which better reflects the performance of higerend configurations in a product family that contain notably less memory than the product family’s tested
representative model. The proposed change in Table 8 is shown below:

Revised Notebook Memory Adder
EPA received feedback from stakeholders raising two issues with the memory adder proposed in Draft 2.
They are:
1. Lower-end configurations with 4GB of memory would not be recognized in great enough numbers
based on Draft 2 criteria. Stakeholder comments revealed this issue, which was not apparent in
the certified product data as these lower-end models are not typically reported due to productfamily structure, where the highest memory configurations serve as the representative model.
2. The pass rate for higher-end configurations with memory totals greater than 16GB would be
disproportionately higher, indicating the need for an adder that scales less steeply than thepreviously proposed 0.4 kWh/year per GB adder.
EPA reviewed data that supports these findings and is proposing to adjust the memory adder, providing
slightly more allowance for memory up to 4GB, and less allowance beyond 4GB. This equation scalessimilarly to the memory adder adopted by the California Energy Commission in their latest regulatory
effort on notebooks, but the adder values better serve ENERGY STAR’s purpose of recognizing
leadership. The revised memory adder is shown below:

vi: TECMEMORY Adder: GB applies per GB of memory installed in the system
The combination of the proposed changes to the notebook category 2 base allowance and notebook
memory adder is intended to allow sufficient selection of certified models across different hardware
platforms.
Stakeholders are encouraged to provide feedback on the proposed changes presented here, as well as
any general comments, to computers@energystar.gov no later than November 30, 2017. Please direct
specification related questions to Ryan Fogle, EPA, at Fogle.Ryan@epa.gov, or 202-343-9153; or John
Clinger, ICF, at John.Clinger@icf.com, or 215-967-9407.
Sincerely,Ryan Fogle
EPA Manager, ENERGY STAR for IT and Data Center Products