Final Draft Version 6.0 Comment-Response Document

Topic
AutomaticBrightness
Control (ABC)

Subtopic

CommentResponse
EPA is changing how models with ABC enabled by default are tested. TheMany stakeholders disagreed with the proposed interim approach to testingmodels with ABC (testing with ABC disabled and providing a 10% allowance if specification will revert to the current Version 5.3 approach, where products are
the model meets the Sensor Validation Test) and commented that EPA should qualified by measuring On Mode power at 0 lux and 300 lux.
revert to the approach currently employed in the Version 5.3 specification (testingwith ABC enabled at 0 and 300 lux and reporting a weighted average of theresults. Stakeholders commented that disabling ABC during testing:- Will not represent real world use because it is equivalent to a measurement at300 lux;
- Will mislead consumers since the resulting power consumption values would
increase dramatically from previous measurements and reports;- Will break harmonization with the values reported under the Federal Trade
Commission EnergyGuide program and the California Energy Commission
requirements (which rely on the Version 5.3 test method), further confusing
consumers; and- May not be possible in the Home Picture Setting on some models.
Two stakeholders suggested reverting to the test conditions of Version 5.3, while
keeping the proposed Sensor Validation Test. This would permit harmonization
with other programs and past data reporting, while ensuring that ABC designs
deliver the expected energy savings.

Allowance
Automatic
AmountBrightness
Control (ABC)

One stakeholder commented that the 10% adder provided to models with ABC This issue is moot because EPA is changing how models with ABC enabled bywhen tested with ABC disabled under the interim testing proposal is too generic default are tested, and will no longer be providing an allowance.
and may favor larger televisions. The commenter further noted that large TVs
are more likely to save more than 10%. Another stakeholder suggested the useof a 20% adder, but stated that measuring On Mode power with ABC enabled(per the Version 5.3 requirements) would be more accurate.

SensorAutomaticValidation
Brightness
Control (ABC)Several stakeholders commented in favor of the Sensor Validation Test
The ABC sensor validation testing at 10 lux, 50 lux, and 100 lux has beenproposed in Section 4.3 of the Final Draft specification, intended to demonstrate retained as proposed. A clarification has been added that the On Mode powerthat a product's ABC sensor reduces power consumption. To pass the test ameasured at 300 lux must be greater than or equal to the average On Mode
product must demonstrate a 5% difference between power measurements at 10 power measured at 100 lux . All power measurements will be published on theand 50 lux, and 50 and 100 lux.
Qualified Products List, as indicted in the Draft QPX CB submission form sent tostakeholders for review following the release of the Draft Final. This proposal
One stakeholder further suggested that all power measurements be published on aligns with most manufacturers' request to maintain the V5.3 approach while also
the Qualified Product List, and that another test point be added above 100 lux
providing the safeguard requested by numerous stakeholders for a means ofand that the power measured at this new point be greater than that at 100 lux.
verifying the savings delivered by ABC.
Two stakeholders, however, voiced opposition:- One noted that small televisions may not be able to meet the 5% difference
required by the Sensor Validation Test, thereby discouraging the use of the ABCfeature in smaller TVs;
- The other commented that EPA should harmonize with a similar requirement
proposed for the Version 6.0 Displays specification which requires a 20%
difference between 10 and 300 lux.

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Final Draft Version 6.0 Comment-Response Document

Topic
Definitions

Subtopic
Comment
Response
Mode/Picture Two stakeholder commented on the Home and Retail Picture Setting definitions EPA will clarify the requirement to indicate that the default picture setting (theproposed in the final draft, and the need to differentiate between options selected default picture setting in “home” mode for TVs with a forced menu) reflects theSetting
Definitions
during the Forced Startup Menu and during later use (sometimes termed "scene settings under which the product qualifies for the ENERGY STAR.
selections").
One of the stakeholders commented that the selections made through theForced Startup Menu are more than just "Picture Settings" because they canpresent different menus, eliminate adjustments, enable demo modes, etc. The
stakeholder commented that the formerly used terms Home Mode and RetailMode are more appropriate and proposed the following definitions:• Retail Mode: “The forced menu selection intended for the retail environment.”• Home Mode: “The forced menu selection intended for the home environment.”• Brightest Picture Setting: “The user-selectable preset picture setting in which
the TV produces the highest luminance during the On Mode conditions. For atelevision with a forced menu, this might be the default setting in Retail Mode ora user-selectable preset picture setting in Home Mode.
• Home Picture Setting: For televisions without a forced menu, this is the default
picture setting. For televisions with a forced menu this is the default picture
setting in Home Mode.

Forced Startup
Menu

One stakeholder commented on the proposed requirement that either a second EPA will not be proposing any changes to the Forced Menu requirements in theprompt or a warning message appear upon selection of the Retail Picture Setting Final Specification (with the exception of the definitional clarifications mentionedabove). Maintaining the existing requirements balances the Agency desire tofrom the Forced Startup Menu. Under the proposal in the Final Draft
specification, the message would warn users that the Home Picture Setting is the help consumers realize the expected energy savings and the comments
received.
setting under which the product qualifies for ENERGY STAR.
The stakeholder commented that the requirement should not be either/or but
both/and: the TV should require users to both confirm the selection of RetailPicture Setting and warn users that the Home Picture Setting is the setting underwhich the TV had qualified for ENERGY STAR. The stakeholder also suggested
expanding the requirement when a higher power setting is selected, not just
Retail and modifying the warning message to inform the user that the non-Home
setting will use more power.

Hospitality TVs

One stakeholder commented that EPA should study the energy savings potential There is already a test that measures the daily energy consumption of Hospitalityof Hospitality TVs in Standby modes and requested the addition of a Section in TVs when they are in Standby-active, High Mode. Based on the Energy Star
database data, roughly 3% of tested TVs are tested for DAM.
the specification addressing future considerations such as this one.

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Final Draft Version 6.0 Comment-Response Document

Topic
On ModeRequirements

PictureSettings

Subtopic

CommentResponse
EPA will retain the On Mode power limits proposed in the Draft 2 Version 6.0
One stakeholder commended EPA for changing the On Mode power
specification.
requirements away from a piecewise-linear function with a hard cap for larger
screen sizes. However, the commenter noted that the proposed tanh-function
requirement also flattens out into a cap, "which disadvantages the most efficient
television products."

Organization One stakeholder noted that some TVs do not have a Forced Startup Menu
EPA will clarify the requirement to indicate that the default picture setting (thefeature and instead have a variety of scene options for customers to chose after default picture setting in “home” mode for TVs with a forced menu) reflects thethe initial startup. This stakeholder further suggested that Section 3.2.3 iii
settings under which the product qualifies for the ENERGY STAR .
(requiring a warning that "Home" is the ENERGY STAR qualified setting any time
another picture setting other than Home is selected ) be separated from Section EPA will separate this requirement from Section 3.2.3 "Forced Menu" to limitconfusion.
3.2.3 (Forced Startup Menu).
A second stakeholder expressed confusion over the applicability of Section 3.2.3iii.

PictureSettings

Warning
Message

Several stakeholders suggested removing Section 3.2.3.iii in the Forced Startup As indicated in the letter to Stakeholders distributed on August 10, EPA will
Menu requirements or modifying it so that a warning message appears only
clarify the requirement to indicate that the default picture setting (the default
when a setting that uses more power than Home is selected, in contrast to the picture setting in “home” mode for TVs with a forced menu) reflects the settings
Final Draft proposal, which would require the message any time a setting other under which the product qualifies for the ENERGY STAR. Furthermore, thisthan Home is selected. The stakeholders noted that the proposed requirement requirement shall apply to major modes selected from a pre-set menu, and EPA
could be confusing for customers if a setting they choose uses less power but a will clarify this in the Final Specification.
message says that it is not qualified.
EPA is interested in the power consumption associated with different picture
Other stakeholders commented that any user selection could alter the Picture
settings and will examine this issue in a future revision once more data become
Setting (e.g., turning off ABC or enabling closed captioning), potentially changing available.
the energy consumption of the TV. Requiring a message every time any setting
is changed could give consumers a negative impression of ENERGY STAR andthe product. Alternatively, if the requirement is changed such that the message isonly displayed when the power increases would require testing power
consumption of every possible scene and setting combination, which would beburdensome and would require further study and development of test methods.

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Final Draft Version 6.0 Comment-Response Document

Topic
PictureSettings

Subtopic
Warning
Message
FormatStandbyStandbyRequirements Passive
Mode andNetworking

CommentResponse
One stakeholder requested the language used in the message to either remove Apart from the clarifications in definitions indicated in the letter to Stakeholders
the words "ENERGY STAR" or to allow a manufacturer to leave this language in distributed on August 10, EPA will not be proposing any further changes to thethe prompt if their TV does not meet requirements of a revised specification incontent of the warning message associated with changes to the picture settings
the future.
in the Final Specification. Maintaining the existing requirements balances theAgency desire to help consumers realize the expected energy savings and thecomments received.
Two stakeholders suggested that instead of a message prompting a user torespond, the ENERGY STAR logo can be required to be located next to only the"home" setting in the picture setting menu. Another stakeholder suggestion was Similar to how manufacturers need NOT remove ENERGY STAR labels fromthat if the message was required, then allow a feature for the user to turn off the models that have lost their qualification, but have already sold to customers,
message as long as the message is enabled by default when the TV is shipped. manufacturers will not be required to change the content of the message after amodel has entered the market.
Another stakeholder suggested that a positive message would be more helpful toconsumers. They gave an example that if a television has settings such as"vivid", "cinema", or similar, then the settings that roughly correspond to the"home" setting be indicated as ENERGY STAR qualified as well using theENERGY STAR logo in the name or the description of the mode.
Several stakeholders expressed confusion between Standby-Passive andStandby-Active, Low Mode in Section 3.4 in the Final Draft; specifically, it wasunclear whether models shall meet the Standby-Passive Mode requirements
while connected to the network.

DOE and EPA will issue a clarification in the Final Version 6.0 specification.

Stakeholders noted that a network-connected Standby-Passive Mode test
method is not specified and that the definition of Standby-Passive Mode cannot
be switched into another mode with an external signal, so it should not be tested
with network connectivity.
Lastly, one stakeholder commented that "Standby-Passive Modes" should beadded to 4.1.1, which currently only lists test methods for On Mode, Luminance,
and DAM.
StandbyMultiple
Requirements StandbyPassive
Modes

One stakeholder requested clarification on which modes must meet the Standby- DOE and EPA will issue a clarification in the Final Version 6.0 specification.
Passive requirements if a product offers more than one Standby-Passive Mode.
For example, will a Standby-Passive Mode with a Mobile High-Definition Link(MHL) be required to meet the requirements?

Another stakeholder commented that the requirement that the Standby-Passive DOE and EPA will issue a clarification in the Final Version 6.0 specification.
StandbyMultiple
Mode with the lowest power consumption be enabled by default should beRequirements StandbyActive Modes extended to other modes, such as Standby-Active, Low Mode.

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Final Draft Version 6.0 Comment-Response Document

Topic
SubtopicStandbyInternet
Requirements Connectivity

Comment
Response
EPA will issue further clarity in the Final Version 6.0 specification on measuring
Two stakeholders commented that the energy use of products with internet
the energy use of products with internet capability. This clarification willcapability be measured and submitted to EPA as part of the data collection
process, with one requesting that the language in the notebox in Section 3.4.3 be supplement the guidance in the NOPR, which does not specify testing in Standby
preserved for clarity in the Final specification
Active, Low Mode.
Another stakeholder commented that the measurement of power in StandbyActive, Low Mode with internet connectivity (per Section 4.2) be removed fromthe specification because it is not required under the DOE NOPR.

EPA will retain the requirement to measure and submit for qualification the power
consumption in Standby-Active, Low Mode with internet connectivity. Given theprevalence of TVs that are being shipped with internet connectivity, EPA isinterested in providing the public with information on the power consumption
associated with this feature.

One stakeholder agreed with the general networking approach and network
connection hierarchy (LAN and not WAN), while another commented that
Standby Mode power while connected to the network under alternate settings(such as "Quick Start") be measured and reported.

Quick Start has been seen on a select few network capable TVs and provides
power to components so the TV can "boot-up" quicker. If Quick Start is enabled
on a TV by default, the energy associated with this feature will be recorded aspart of the Standby-active, Low test.

Test Method

StandbyActive, Low
ModeTimeline

Grandfatherin One stakeholder commented that it would be counterproductive to remove the EPA requires that only newly manufactured products that meet the latest ES
requirements can be labeled. EPA does not require that products that are in thegENERGY STAR label from models that comply with Version 6.0 power
market when the spec changes have their labels removed if they do not meet theconsumption requirements but may not meet some of the other requirements
latest requirements.
that have changed from Version 5.3. The stakeholder commented that suchmodels be permitted to bear the ENERGY STAR mark for an additional period oftime through the use of a different effective date for non-power requirements.

Timeline

DOE Final
Rule

Several stakeholders expressed concern about how a DOE final rule would
affect qualification under Version 6.0. One stakeholder requested that EPA
clarify what would happen under three scenarios:
1. If DOE's test method is effective prior to Version 6.0;
2. If the two become effective concurrently; and3. If DOE's method becomes effective after Version 6.0.

Once the DOE test procedure final rule is published, EPA will evaluate its impact
on the qualification rate to determine the appropriate transition time to using thisfinal test procedure to qualify products with ABC enabled by default. DOE andEPA will work with manufacturers to make this transition smoothly. Note, if DOE
adopts a final test procedure before Version 6.0 becomes effective, EPA intends
to make this assessment quickly, and communicate a timeframe for transitioning
to the DOE test procedure to stakeholders.

Another stakeholder requested that EPA avoid retesting of models following theEPA has previously indicated that products tested to the provisional approach
finalization of the test method.
will not need to be retested.

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Final Draft Version 6.0 Comment-Response Document

Topic
Timeline

Subtopic
Effective
Date

Comment
Response
Two stakeholders commented that it would be beneficial for the specification to EPA will finalize the specification by the end of August or early September, suchcome into effect in Spring 2013 to align with the design/manufacturing cycles for that the Version 6.0 specification can recognize efficient models released in
new TVs introduced in 2013. One of these stakeholder further encouraged EPA Spring 2013.
to finalize the specification as soon as possible.
On the other hand, one stakeholder recommended that EPA wait until the DOE
NOPR is finalized before releasing Version 6.0, while another commented thatsoftware specifications have already been submitted for 2013 models, and thatthe new warning requirement for picture settings other than "Home" cannot beeasily accommodated.

Toxicity/Recyclability

Toxicity

One stakeholder commented on the removal of toxicity and recyclability
EPA will retain the reference to the toxicity and recyclability requirements in therequirements from the specification to the Partner Commitments, stating that
Partner Commitments, as proposed in Final Draft documents.
ENERGY STAR should be limited to energy efficiency in order to avoid confusing
the brand and duplicating other efforts.

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