Final Draft Version 7.0 Displays Comment Response Summary

U.S. Environmental Protection Agency (EPA) and U.S. Department ofEnergy (DOE) Response
Stakeholder Comment Summary
For greater clarity, one industry group recommended EPA remove the following examples Signage displays must still meet at least two out of the four physical attributes
from the definition of Signage Display as they are extraneous to the qualitative andprovided to meet the definition of signage display. EPA has retained thesequantitative criteria of the definition:
examples in the definition to provide greater ability to distinguish signage“electronic display intended for multiple people to view in non-desk based environments, displays from computer monitors, based on how they are typically used.
such as retail or department stores, restaurants, museums, hotels, outdoor venues,
airports, conference rooms or classrooms.”

Topic
Definitions

Subtopic
Signage
DisplaysDefinition

Sleep Mode

One stakeholder suggested that the description of Sleep Mode activation be slightly
EPA has clarified the definition of sleep mode to include touch functionality.
modified to include the touch functionality as follows: “Sleep Mode may serve the following
functions: facilitate the activation of On Mode via remote switch, display touchfunctionality, internal sensor, or timer; provide information or status displays including
clocks; support sensor-based functions; or maintain a network presence.”

Definition

Plug-in Module

One stakeholder commented that the statement that “modules providing additional input
options are not considered Plug-in Modules” conflicts with the “Process touch signals”
option on line 93 and suggested that the text in line 94 be changed to:“Note: Modules providing any other additional input options are not considered Plug-in
Modules for the purposes of this specification”.

Scope

Excluded
Products

One stakeholder commented that the sentence “Products that are covered under other
EPA has added integrated desktops to the list of computer types excluded fromENERGY STAR product specifications are not eligible for certification under thisthe specification.
specification including Televisions and Computers (Thin Clients, Slates/Tablets, Portable
All-in-one Computers)” does not include mention of Integrated Desktop Computers andrecommended that this subcategory should either be added to the list of excluded
computer types as below or the individual types of computers should be removed.

Full Network
Connectivity

PowerManagement

One stakeholder commented that the following requirement that the display have the
EPA has removed this requirement, instead relying on the test method.
“capability to transition from On Mode to Sleep Mode via a signal over an Internet Protocol
connection” is unnecessary and will add confusion to meeting the definition of Full Network
Connectivity. The stakeholder argued that the ENERGY STAR Displays Test Method V7
Final Draft Section 6.7) B) is sufficient, requiring that the presence of Full Network
Connectivity to be determined by testing the Display for network activity in Sleep Modeaccording to section 6.7.5.2 of CEA-2037-A, Determination of Television Set Power
Consumption.

ComputerMonitors

Resolution
Allowance

One stakeholder commented that each Megapixel of total screen resolution requires 3.37
W and therefore the energy resolution allowance in kWh should equate to 3 W of On
Mode power per Megapixel. The stakeholder suggested the Final Draft resolution
allowance be revised from 6.13 kWh to 9.2 kWh.

Enhanced
Performance
Monitors

Definition

One stakeholder group requested that EPA include the enhanced performance criteria for EPA continues to prefers to address and account for enhanced performancecomputer monitors as a formal definition in the Definitions section of the Specification "as displays by describing the set of features that must be present in order for suchother entities, utilize and refer to ENERGY STAR program requirements for definitions of products to be eligible for a power allowance. EPA maintains that otherstakeholder groups are still able to harmonize their own definition for enhanced
products, it is critical to maintain a clear definition of EPDs" noting that it "appreciates
performance displays with EPA's designated set of criteria for enhanced
EPA’s goal to provide flexibility with the definition of EPDs as technology evolves, but
believes regular updates of the specification will be able to adjust this definition in a timely performance functionality as described in Section 3.3.4 of the Final specification.
manner."Page 1 of 6

EPA has clarified the definition of plug-in module, such that additional inputs
does not include touch, which is explicitly addressed above.

Based on EPA's data analysis in Draft 1 and Draft 2, EPA continues to find acorrelation of 2W/MP and has thus maintained the allowance of 6.13 kWh. EPA
has revised the TEC limit slightly to ensure more even representation across thesize bins (see responses to comments below). As a result, the new TEC limit
also achieves greater representation across all resolution bins.

Final Draft Version 7.0 Displays Comment Response Summary

Topic
Enhanced
Performance
Monitors

Subtopic
Criteria

Enhanced
Performance
Monitors

Allowance

CurvedDisplays

U.S. Environmental Protection Agency (EPA) and U.S. Department ofEnergy (DOE) Response
Stakeholder Comment Summary
One stakeholder argued that "High brightness and color gamut conformity across a display EPA appreciates this feedback on additional features that may be prevalent in
is a clear indication of a display being of enhanced performance" and therefore requested enhanced performance displays. Due to a lack of data, at this time, EPA is not
two additional criteria be added to the Enhanced Performance Display definition :including these additional criteria for products to be considered enhanced- Brightness and color uniformity of >90% across the image; andperformance displays. However, EPA welcomes receiving new data from- Color and brightness stability at the delivered specified performance across the specific stakeholders over the coming year and will monitor the market to determine if
working temperature range and nominal working life.
brightness and color uniformity should be included in a future revision to thespecification.
One stakeholder noted that computer monitors that meet the enhanced performance
EPA is maintaining the current allowance of 15% for EPDs with sRGB color
criteria including “Color Gamut support is 32.9% of CIE LUV or greater” can meet the
gamut, based on data analysis that a small subset of monitors that meet all three
ENERGY STAR Total Energy Requirements at 25% or higher rate without any enhanced EPD criteria for color gamut, viewing angle and resolution require additional
performance allowance. As such the stakeholder requests the Final Draft 15% allowance power. EPA recognizes that sRGB color gamut alone is found in a larger subset
for the monitors meeting these criteria be removed. Additionally it is the stakeholder’sof its dataset. EPA will continue to monitor the market and review the need forunderstanding “that the technology used in the lower performance EPDs is widely used in providing additional allowances for EPDs in a future revision to the specification.
televisions and so a transition across to monitors in a short amount of time is possible.”
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Another stakeholder conversely argued that the additional allowances for enhanced
performance be increased as follows:
32.9% of CIE LUV or greater (≥ sRGB 99%): 0.25 x (ETEC_MAX - 6.13 × r)
38.4% of CIE LUV or greater(≥ Adobe RGB 99%): : from 0.8 to 1.00 x (ETEC_MAX - 6.13
× r)
The stakeholder noted that to make a curved display, the transmittance decreases about EPA appreciates this feedback and explanation. However, at this time, EPA
40% compared to a flat display, and that to account for it, a 25% x (ETEC_MAX - 6.13 × r) lacks enough data to determine the need for additional power allowances for thisallowance is needed.
feature. EPA also lacks information on any additional functionality provided by acurved display, which would thus warrant additional power allowances.
Therefore, EPA will continue to monitor the market and welcomes any additional
data on the utility and power consumption of curved displays for consideration ina future revision to the specification.

ComputerMonitors

Touch
Functionality

One stakeholder requested EPA consider an additional allowance of 20% for touch
New data was also provided for monitors with touch functionality. The expanded
functionality in monitors. The stakeholder noted that additional power is needed fordataset demonstrates that models with this feature consistently consume abacklight power, since a wider masking area that hides the touch circuitry causes the light meaningful amount of additional power, thus supporting the addition of a modest
transmittance to decrease by 8%, with additional losses due to logic circuitry.
power allowance.

ComputerMonitorsSize
Representation

Several stakeholders urged EPA to select energy requirements reflective of the top 25% of EPA received additional data for 223 models, many of which are pending
models within each size bin to maximize the benefit to consumers and maintain industry release. The addition of these models and the performance they reflect supports
participation. One stakeholder group noted that the Final Draft specification had pass rate relaxing the TEC limits somewhat to ensure an adequate selection of qualifyingof 33% for <14 inch displays, 80% for 14-16 inch displays and 43% for 16-19 inch displays models, particularly in key product sizes, namely in the 20-24” and greater than26” size bins. EPA’s minor adjustments to the TEC limits recognize a modest
which does “ not appear to meet the objective of ENERGY STAR in identifying highly
amount of additional models and recognize the top quartile of products in the key
efficient products for a given category.” With larger size displays, the same stakeholder
product size bins.
pointed out that there are pass rates of 19% for 19-20 in displays, 12% for 20-22 inch
displays, 24% for 22-24 inch displays, 17% for 24-26 inch displays and 16% for >26 inch
displays arguing that pass rates for the larger display sizes, with the exception of the 22-24
in category, are excessively low and that preference for small displays does notrealistically meet consumer needs.

Page 2 of 6

Final Draft Version 7.0 Displays Comment Response Summary

Topic
ComputerMonitors

Subtopic
Pass Rate

U.S. Environmental Protection Agency (EPA) and U.S. Department ofEnergy (DOE) Response
Stakeholder Comment Summary
One stakeholder group expressed concern regarding requirements in the Final Draft that EPA has adjusted the TEC limit to ensure that the qualification rate reflects theless than 25% of models currently on the market can meet. The stakeholder argued that it top quartile of products in key size bins containing the majority of currently“introduces a guessing element into what would otherwise be a data-driven process and qualified products. With Displays, unlike with TVs, EPA recognizes that market
while it is true in the past that manufacturers have made advancements to increase theshifts occur over a longer time period. In contrast, new TV models are released
percentage of products on the market that qualify for ENERGY STAR, setting an overly
annually. As such, with the Displays specification, EPA seeks to recognize therestrictive cap penalizes rather than rewards this behavior.” The stakeholder suggested
top quartile of products at the time of finalizing the specification.
EPA instead “reset limits on an appropriate frequency, approximately every two years, andset appropriate limits based on the 25% goal to make sure that customers can stillpurchase an adequate number of qualified products.”

Off Mode

One stakeholder commented that the specification states that products do not need to
By moving to a TEC-based requirement, the Version 7.0 Displays specification
have an Off Mode to be eligible for certification. The stakeholder requested that “monitors” reduces energy consumption with one overall limit. As such, EPA provides
be required to have an Off Mode or another power mode that can meet the Off Modemanufacturers with flexibility in reaching lower energy consumption, either bypower requirement of 0.5W.
further reducing Sleep and Off mode power and/or by reducing On Mode power.
Therefore EPA is not including additional requirements in Off or Sleep modes.

Signage
Displays

Sleep Mode Full One stakeholder again requested that EPA include a Tier II requirement (taking effect at a At this time EPA is not proposing a Tier II requirement in order to retain flexibility
Networklater date) lowering the power limit for Signage Display Sleep Mode below 3.0 W, noting in revising the specification. EPA will continue to monitor the power consumptionof signage displays in Sleep Mode and evaluate the opportunity to further reduce
Connectivity
that while it is technically feasible for products to meet a 1.0 W limit, a delayed
power consumption in a future revision.
requirement would give manufacturers adequate time to alter products.

Signage
Displays

Resolution
allowanced

Signage
Displays

Uniformity Metric One stakeholder requested EPA consider uniformity requirements for Signage Display as Due to a lack of data on the presence of color uniformity in signage displays,
EPA is not including color uniformity as a required definition for signage
and Allowance it is an important aspect of performance and also affects power consumption. The
stakeholder suggested a 5 point weighted approach for quantifying luminance uniformity. displays. However, EPA will monitor the market to determine if color uniformity isa key feature in signage displays and, if so, if its presence impacts power
consumption.

Specification

Editorial

One stakeholder suggested EPA capitalize the word 'display' consistently throughout the
specification.

Specification

Editorial

Two stakeholders noted that Line 319 should state PON_MAX is calculated per Equation 6 EPA thanks the stakeholder for this feedback and has made the editorial change
instead of Equation 7.
to the specification.

Specification

Editorial

Two stakeholders noted that Line 332 should read "Maximum Sleep Mode Power
Requirement (PSLEEPMAX)" instead of "Maximum Sleep Mode Power Requirement(PON_MAX)."Specification

Editorial

One stakeholder commented that the term "power consumption" is not technically correct EPA thanks the stakeholder for this feedback and has made this change to theand so should be changed to "power demand".
specification.

Specification

Editorial

One stakeholder noted Line 407 should reference Version 7.0 and not Version 6.0.

One stakeholder argued that a power allowance be included for Signage Displays with
UHD (4K) resolution similar to the 50% of total power consumption allowance in the
ENERGY STAR Televisions specification.

Page 3 of 6

At this time, EPA lacks sufficient data on 4K signage displays to determine theneed for additional power allowances. In addition, EPA has observed that thepower consumption of 4K TVs has decreased substantially since the TV Version
7.0 specification was finalized. As such, EPA anticipates further gains inefficiency for 4K signage displays since they employ the same technologies usedin TVs.

EPA thanks the stakeholder for this feedback and has consistently capitalized"display" to indicate that the term is listed in the Definitions section.

EPA thanks the stakeholder for this feedback and has made the editorial change
to the specification.

EPA thanks the stakeholder for this feedback and has made the editorial change
to the specification.

Final Draft Version 7.0 Displays Comment Response Summary

Topic
Subtopic
Test Procedure Luminancetesting

U.S. Environmental Protection Agency (EPA) and U.S. Department ofEnergy (DOE) Response
Stakeholder Comment Summary"For a Display with ABC which cannot be disabled, according to section 6.2 D), luminance DOE has clarified that section 4) G) is only required for On mode testing, not foris measured with light entering directly into the UUT’s ambient light sensor at greater than Luminance testing.
or equal to 300 lux. Is it the intent that when the luminance measurements are done in thiscase that test method sections 4 F) and G) are followed, i.e. alignment of UUT, lamp type,light source alignment."

Test Procedure Luminancemeter
requirements"In section 4 I) , I’m not sure why the accuracy of the meter is being linked with the allowed DOE has deleted the line from the Final Test Method
tolerances of the light measurements. I think the last line of this section,
Light measurement accuracy shall be within the tolerance specified in 4.J)4). should bedeleted."

Test Procedure Full Network
Connectivity" 'The presence of Full Network Connectivity shall be determined by testing the Display for This test is applicable to all sleep modes. However, only sleep modes that are
network activity in Sleep Mode according to section 6.7.5.2 of CEA-2037-A, Determination claiming the allowance for Full Network Connectivity need to use this test forof Television Set Power Consumption, with the following guidance:
verification.
1) The Display shall be connected to a network per Section 5.2 C) 1) c) prior to the test.
2) The Display shall be placed into Sleep Mode in place of standby-active, low.'
For UUTs with more than one Sleep mode is it necessary to verify the presence of Full
Network Connectivity in all Sleep modes in order to apply the allowance for Full Network
Connectivity?"

Test Procedure Power Factor

The Test Method says to report the power factor during On mode tests. I assume that it is DOE has clarified in the Final Test Method that True Power Factor reporting is
not necessary to report power factor for the On mode tests of the Test Method section 6.4 needed only for the PON measurement.
B), C), and D) for measurements of P12 and P300, which are used solely to calculate
RABC, is that correct? I believe power factor is only required to be recorded for PON
measurements, correct?

Test Procedure Luminance for
Signage
Displays

The section 6.3)A)1) of the Final Draft Test Method begins:“For Signage Displays with viewable diagonal screen size of 30 inches or more”

DOE has updated the Final Test Method so that Signage Displays, regardless of
size, are set to the same luminance levels (65% of manufacturer reported
maximum).

Since the Eligibility Criteria Section 1)A)1)b revised definition for Signage Display allows
diagonal screen size to be less than 30-inches in some cases, then the phrase “withviewable diagonal screen size of 30 inches or more” should be removed from the Test
Method Section 6.3)A)1). The revised heading would be only, “For Signage Displays”.
This would allow all Signage Displays to be tested similarly.
Test Procedure References

Line 14, 401, 412, 416 – IEC 62301 reference

DOE has updated the Final Test Method to use the correct name and reference
for IEC 62301:2011.

"We note that reference is made to 'International Electrotechnical Commission (IEC)62301 Ed.2.0, "Measurement of Household Appliance Standby Power," ' . The IEC
standard is called, 'IEC 62301:2011 Household electrical appliances - Measurement ofstandby power' and so the reference should be changed. In any case, reference to the IEC
specification should be included as published by IEC to avoid any unintended confusion(e.g. IEC 'Number':'Date')."Test Procedure Editorial

All references to USB 3.0 are used as examples only, but DOE has updated
them to refer to USB 3.1.

Line 27 – Universal Serial (USB) 3.0"Reference is made to 'Universal Serial Bus (USB) 3.0' which we believe should be
updated to 'Universal Serial Bus (USB) 3.1'."

Page 4 of 6

Final Draft Version 7.0 Displays Comment Response Summary

Topic
Subtopic
Test Procedure References

Stakeholder Comment Summary
Line 112, 276, 277, 306, 308, 330, 332, 356, 379 – IEC 62087 reference"We note that the IEC 62087 standard was updated in 2015 and so reference should bemade to this updated standard if appropriate: 'IEC 62087-3:2015 Audio, video, and related
equip-ment - Determination of power consumption - Part 3: Television sets'. In any case,reference to the IEC specification should be included as published by IEC to avoid any
unintended con-fusion (e.g. IEC 'Number':'Date')."U.S. Environmental Protection Agency (EPA) and U.S. Department ofEnergy (DOE) Response
DOE has not yet evaluated the impact of the recently released IEC 62087:2015.
However, DOE has clarified the existing reference to IEC 62087:2011. DOE will
evaluate impact of the 2015 revision in the future.

Test Procedure Battery Operated Line 254 - Battery Operated Products
DOE has removed this section from the Final Test Method.
Products"The ENERGY STAR v7.0 draft specification document states (lines 133 to 135) that 'Dis­
plays with integrated or replaceable batteries designed to support primary operation
without ac mains or external dc power, or device mobility (e.g., electronic readers, battery
powered digital picture frames);' are excluded from the scope of the specification. There­
fore, lines 254 to 266 in the test methodology document could be removed."
Test Procedure References

Line 276, 277 - IEC 62087 Ed. 3.0"The IEC specification has been updated and so it should be reviewed whether thereference in the test procedure document also needs to be updated. In any case,reference to the IEC specification should be included as published by IEC to avoid any
unintended confusion (e.g. IEC 'Number':'Date')."Test Procedure References

Line 405 – Version 5.2 ENERGY STAR Computer specification

DOE has not yet evaluated the impact of the recently released IEC 62087:2015.
However, DOE has clarified the existing reference to IEC 62087:2011. DOE will
evaluate impact of the 2015 revision in the future.

DOE has updated the reference to ENERGY STAR Computers v6.1 in the Final
Test Method.

"Reference is made to the version 5.2 ENERGY STAR Computer specification. This could
be updated to the 'version 6.1 ENERGY STAR Computer specification'."Test Procedure Off ModeLine 419 – Off mode

DOE has updated the text in the Final Test Method to be consistent with the Off
Mode definition.

"The test procedure states that 'D) Off Mode power for products without a physical powerswitch shall be measured with the UUT connected to the Host Machine, with the Host
Machine in the power Off Mode'. The final draft ENERGY STAR v7.0 specification defines'Off mode' as:'3) Off Mode: The mode where the display is connected to a power source, produces novisual information, and cannot be switched into any other mode with the remote control
unit, an internal signal, or an external signal.
Note: The display may only exit this mode by direct user actuation of an integrated powerswitch or control. Some products may not have an Off Mode.'
As such, there is a disconnect between these two statements since a product could notwake from 'off mode' as defined within the draft final specification without direct user
actuation an integrated power switch or control."Page 5 of 6

Final Draft Version 7.0 Displays Comment Response Summary

Topic
Subtopic
Test Procedure Off Mode

U.S. Environmental Protection Agency (EPA) and U.S. Department ofEnergy (DOE) Response
DOE has made this editorial edit in the Final Test Method.

Stakeholder Comment Summary
Line 420 – Off mode
"The test procedure includes the text 'with the Host Machine in the power Off Mode'. If thiswhole sentence is retained after review of the comment above it could be changed to, 'with
the Host Machine in Off Mode. For a computer Host Machine, Off Mode is defined in the
Version 6.1 ENERGY STAR Computers specification'."

Page 6 of 6