Summary and Response to Stakeholder Comments from theENERGY STAR Program Test Method for Determining Telephony Energy Use Version 3.0 Draft 1

I.

DEFINITIONS/SCOPE

Comment#Comment Summary

Stakeholders recommended including a definition for the term
“wireless,” as wireless may be confused with “cordless.”
1Stakeholders also recommended consolidating the terms Wireless
VoIP Telephones and Wireless IP telephones to Wireless VoIP
Telephones for clarity.

Stakeholders recommended the following update to thedefinition of Hybrid Telephones as the definition proposed in theDraft 1 Test Method was incorrect:
2“3.A)1)a.iii. Hybrid Telephone: A Telephone or component of aTelephone system that has the ability to ultimately convert soundinto both analog waveforms for transmission through an RJ11
connection and Internet Protocol data packets for transmission
through an Ethernet connection.”

December 4, 2012

Response
DOE agrees with both comments and has included the following definition
for “Wireless Telephone” in the Draft 2 Test Method for Telephony, Rev.
Aug-2012 (Draft 2 Test Method), as well as ensured the term Wireless VoIP
Telephones is used consistently throughout the Draft 2 Test Method.
“3.A)1)b.v. Wireless Telephone: A Telephone consisting of a handset,charger, and battery that connects to a network via an IEEE 802.11 (WiFi)
connection.”

DOE agrees that the definition for Hybrid Telephone needs to be updated
and has included the definition proposed by stakeholders in the Draft 2 TestMethod.

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Summary and Response to Stakeholder Comments from theENERGY STAR Program Test Method for Determining Telephony Energy Use Version 3.0 Draft 1Comment#Comment Summary

Stakeholders recommended updating the Operating Mode terms
to the following to coincide with current industry-used terms:
3

Partial On (Sleep) Mode -> Idle ModeIdle Mode -> Dial Tone Mode
Operation Mode -> Communication Mode

4

Stakeholders asked whether Additional Handsets qualify asaccessories under the definition of UUT, which includes “the baseproduct and any accessories packaged with it.”December 4, 2012

Response
In an effort to harmonize with the upcoming IEC 62542—Standardization ofenvironmental aspects - Glossary of terms, EPA and DOE propose to retain
Partial On (Sleep) Mode as specified in the Draft 1 Test Method.
Idle Mode has traditionally been used by industry to describe an “on-hook”
state. To further avoid confusion, EPA and DOE have decided to rename Idle
(Off-hook) Mode used in the Draft 1 Test Method to Call Origination Mode inthe Draft 2 Test Method.
Additionally, stakeholders commented that using the term Operation Modeas one of the group of terms named Operational Modes was confusing.
Therefore, EPA and DOE are proposing to change the term Operation Modeto Active Mode, to minimize confusion.
The term “accessories” in the Draft 1 Test Method definition of UUT was notintended to include Additional Handsets sold and packaged with the basestation. Accessories were intended to mean the other items shipped withthe base station, excluding the Additional Handsets and their charging bases.
As such, DOE and EPA have updated the definition of UUT in the Draft 2 Test
Method to the following:“3.E)6) Unit Under Test (UUT): The specific sample of a representative model
undergoing measurement which can include the base product (theTelephone) and any Additional Handsets and accessories packaged with it, oran Additional Handset, with any accessories packaged with it, depending on
the product type being tested for qualification.”

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Summary and Response to Stakeholder Comments from theENERGY STAR Program Test Method for Determining Telephony Energy Use Version 3.0 Draft 1

Comment#Comment SummaryResponse

Stakeholders recommended including video-capable telephonydevices in the scope of the Telephony program and proposed thefollowing updates to the Definitions section:“3.A)1) Telephone: A commercially available electronic productwhose primary purpose is to transmit and receive sound and/or
full-motion video over a distance using a voice or data network.

53.A)1)a.ii. Voice over Internet Protocol (VoIP) Telephone: ATelephone or component of a Telephone system that ultimately
converts sound and/or full-motion video into Internet Protocol
data packets for transmission through an Ethernet connection.
3.A)1)a.iii. Hybrid Telephone: A Telephone or component of aTelephone system that ultimately incorporates the functions ofboth the analog telephone and VoIP telephone above.
3.A)1)b.v. Video Telephone: Telephone device with screencapable of making full-motion video and voice calls. Devices witha screen size > 10” diagonal may be considered to be Video
Conferencing Systems rather than telephony devices, and hence
are specifically not covered by this program.”

December 4, 2012

DOE and EPA have decided not to include video-capable telephony devices inthe scope of the Version 3.0 Telephony Program but may consider them forinclusion in later revisions of the Program. As such, DOE and EPA haveincluded language explicitly stating that Telephones with full-motion video
capabilities are excluded from the Version 3.0 Telephony Program. DOE has
included the following definition in the “Functionalities” subset of definitionsin the Draft 2 Test Method. DOE and EPA have not included the proposed
definition for Video Telephone in the “Sound Transmission Mechanism”
section, as they do not consider video calling to be a new transmission
mechanism but an additional functionality provided by a Telephone.
“3.C)1) Video Calling: The capability of a Telephone to convert both fullmotion video and sound into Internet Protocol data packets for transmission
through an Ethernet connection.”

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Summary and Response to Stakeholder Comments from theENERGY STAR Program Test Method for Determining Telephony Energy Use Version 3.0 Draft 1Comment#Comment Summary

Stakeholders proposed updating the definitions for both High
Resolution Display and Status Display to the following to moreaccurately represent the types of displays present in products
currently being sold:6“3.C)4) High Resolution Display: A function by which a device
provides a pixel‐based visual display with resolution greater thanor equal to 480x234 pixels. This definition does not include Status
Displays.
3.C)5) Status Display: A function by which a product provides avisual display of less than 480x234 pixel resolution, including aback‐lit alphanumeric clock or channel indicator. This definition
does not include single indicator lamps.”

7Stakeholders proposed removing the reference to IEEE 802.3af
from the Power over Ethernet (PoE) definition, as IEEE 802.3af
has been superseded by subsequent versions and proposedadditions to include further detail in the definition. Stakeholders
also commented that IEEE 802.3 was undergoing a revision at thetime of the publication of the ENERGY STAR Version 3.0Telephony Draft 1 Test Method.

December 4, 2012

Response
EPA and DOE agree with the proposed stakeholder suggestion to update thedefinitions for High Resolution Display and Status Display to more accurately
represent the types of displays present in the market today, recognizing that
displays smaller than 5” could meet both definitions, while displays greaterthan 5” could meet neither definition. EPA and DOE have updated thedefinitions to the following“3.C)4) High Resolution Display: A function by which a device provides apixel-based visual display with resolution greater than or equal to 480x234
pixels, including an LCD panel. This definition does not include Status
Displays.
3.C)5) Status Display: A function by which a product provides a visual displayof less than 480x234 pixel resolution, including a back-lit alphanumeric clock
or channel indicator. This definition does not include single indicator lamps.”
EPA and DOE have not set a limit on the dimensions of High Resolution
Displays or Status Displays in the definitions but will consider information
received from manufacturers in the call for data to determine if any furtherexclusion is warranted.
The revision to IEEE 802.3, IEEE 802.3-2012, was ratified on September 5,2012. DOE has updated the definition for PoE to reference this newest
version of IEEE 802.3.
“3.E)5) Power over Ethernet (PoE): A technology which enables transfer ofelectrical power, along with data, to network end point devices through an
Ethernet cable. Currently specified by IEEE 802.3-2012.”

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Summary and Response to Stakeholder Comments from theENERGY STAR Program Test Method for Determining Telephony Energy Use Version 3.0 Draft 1

Comment#8II.

Comment SummaryResponseStakeholders commented that Power over HDBaseT (PoH) should
be included in the Draft 2 Test Method.

DOE is currently unaware of PoH being used by any Telephones covered
under the scopeof the Draft 2 Test Method. Because HDBaseT is designed tosupport higher bandwidths, DOE believes including PoH is not currently
needed for non-video capable Telephony products. As such, DOE has notincluded PoH in the Draft 2 Test Method. However, DOE and EPA arerequesting information from stakeholders regarding any Telephones thatsupport PoH.

TEST SETUP

Comment#Comment SummaryResponse

9Stakeholders recommended removing Gigabit Power over
Ethernet (PoE) from the list of PoE methods as it is not a PoEMode.

DOE agrees with the comment that Gigabit does not refer to a method oftransmitting power over an Ethernet cable but to the speed at which data
are transferred over a cable. As such, DOE has removed it from the list ofPoE Power Modes in section 4.F of the Draft 2 Test Method.

10

Stakeholders recommended excluding “4-pair” (Mode A + B)
powering schemes from the scope of the Telephony program
because they are not covered under IEEE 802.3.

DOE agrees with the comment and will exclude all designs not covered byIEEE 802.3 from the ENERGY STAR Telephony Draft 2 Test Method.

11Stakeholders commented that requiring the input voltage to be
48 ± 2 volts for PoE testing removes the possibility of testing withType 2 Power Sourcing Equipment (PSE), as defined in IEEE 802.3.

DOE has updated the input voltage requirements for PoE testing to be 53 ± 2
volts to allow the use of Type 2 PSEs during testing. DOE also has also
requested feedback regarding whether any product models would not becapable of operating in this voltage range.

12Stakeholders commented that some PSEs must use voltages
lower than the specified range during detection and classificationof PDs for compliance with IEEE 802.3.

DOE has updated the input power requirements to allow for lower voltages
during detection and classification prior to testing. DOE has also specified
that the PSE must be compliant with the latest version of IEEE 802.3.

December 4, 2012

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Summary and Response to Stakeholder Comments from theENERGY STAR Program Test Method for Determining Telephony Energy Use Version 3.0 Draft 1

Comment#Comment Summary
Stakeholders recommended defining a “PoE Power Meter” as thefollowing, to allow for meters that act as PSE as well as power
meters:13Response“1) Measures PoE Power Draw on ALT-A and ALT-B at bothpolarities

DOE agrees that power meters which act as sourcing equipment should beallowed for use during testing and has included the following language toSection 4.F of the Draft 2 Test Method:2) Enables Ethernet link and packet traffic to the PD at all linkrates (10/100/1000) from a link partner“4.F)2) Enables Ethernet link and packet traffic flow to UUT from a link
partner at all network speeds at which the UUT is capable.

3) Sources PD Power on ALT-A and ALT-B at both polarities orallows a PSE (switch) to source power to a PD on ALT-A and ALT-B
at both polarities”

4.F)3) Acts as a PSE or allows another PSE to source power to the UUT.”

14

Stakeholders recommended testing using a 1-port Midspan that isconnected to an AC power meter for the purpose of testing
efficiency, as there are no PoE power meters on the market.

DOE is currently aware of PoE power meters on the market that meet thespecifications proposed in the Draft 2 Test Method. Furthermore, DOE isinterested in measuring, as closely as possible, only the power consumptionof the Telephone itself, as the Midspan would not typically be included witha Telephone product. As such, DOE has made no changes to the power
meter requirements for measuring PoE.

15

Stakeholders commented that since the power consumption ofthe second phone used during testing of Voice over Internet
Protocol (VoIP) phones is not measured, the test method should
not require the second phone to be a PoE phone.

DOE agrees that the second phone should not be required to be a PoE unit
since its power consumption is not measured. DOE’s original intention wasto ensure the second phone is a VoIP unit. DOE has updated section 6.1 theDraft 2 Test Method to reflect this intention.

16

Stakeholders commented that a cable length of 100 meters
between the PSE and the UUT would be more representative ofnormal operation.

DOE understands that PoE Telephones are normally installed using longcable lengths; however, DOE is interested in measuring, as closely aspossible, only the power consumption of the Telephone and not theadditional power loss due to long cable runs. As such, DOE has made nochanges to the cable length requirements in the Draft 2 Test Method.

December 4, 2012

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Summary and Response to Stakeholder Comments from theENERGY STAR Program Test Method for Determining Telephony Energy Use Version 3.0 Draft 1III.

TEST CONDUCTComment#17

Comment Summary

Stakeholders commented that the test setup for units withAdditional Handsets was unclear and recommended updating thetest method to specify, exactly, the number of Additional
Handsets that should be in Operation Mode along with the UUT
during the UUT’s Operation Mode Test.

Response
When testing a base unit with Additional Handsets set up, all Additional
Handsets shall remain in Partial On Mode for the duration of testing, as DOE
believes that using one handset at a time most accurately reflects normal
usage. To clarify, DOE has included the following language in section 5.C ofthe Draft 2 Test Method:“5.C)2)i) Additional Handsets set up during testing shall remain in Partial On
Mode for the duration of testing.”

Stakeholders supported testing units with the as-shippedbrightness settings.
1819

Stakeholders also commented that, for cordless handsets withbacklit displays, the display should not be required to be lit during
testing, as the light stays on only for a brief period.
Stakeholders requested clarification regarding whether the power
consumption of just the base unit, the base unit and one
Additional Handset, or the base unit and all Additional Handsets
set up should be measured and reported during testing.

December 4, 2012

DOE thanks stakeholders for their support of the proposed test settings. DOE
also agrees with the stakeholders’ comment regarding backlit cordlesshandset displays and has not added any specifications for these displays in
the Draft 2 Test Method. DOE also believes that the 10 minute stabilization
period required for all tests is sufficient time for the backlight to turn off
and, as such, has not included any new language in the Draft 2 Test Method.
DOE requires only measuring the UUT’s power consumption. As such, DOE
has updated Section 5.C of the Draft 2 Test Method to state:“5.C)2)ii) When testing a UUT with Additional Handsets, only the power
consumption of the base unit should be measured.”Page 7 of 10

Summary and Response to Stakeholder Comments from theENERGY STAR Program Test Method for Determining Telephony Energy Use Version 3.0 Draft 1IV.

TEST METHOD

Comment#20

Comment Summary
Stakeholders recommended clarifying Sections 6.2 and 6.3 to thefollowing, as the language in the Draft 1 Test Method allowed fortaking as few as one measurement during the test period:“…accumulating true power values at a rate greater than or equal
to 1 reading per second.”

December 4, 2012

Response

DOE agrees with the stakeholders’ recommendation and has updated
Sections 6.2.A)4, 6.3.7, and 7.1.4 in the Draft 2 Test Method with theproposed language.

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Summary and Response to Stakeholder Comments from theENERGY STAR Program Test Method for Determining Telephony Energy Use Version 3.0 Draft 1Comment#Comment Summary

Response
DOE agrees with the stakeholder’s comment that the 5 minute Partial On
Mode test measurement period is too short for units with cordless handsets.
As such, DOE has updated Section 6.2 of the Draft 2 Test Method to include
the following, to accommodate for units with cordless handsets. Units
without cordless handsets shall not be affected by these changes.
“6.2.A) For units with cordless handsets:

21

Stakeholders commented that the 5 minute test period could
result in non-representative power consumption values for some
types of phones due to phone charging cycles and should bereconsidered. Stakeholders also proposed a revised test methodfor testing units with cordless handsets.

22

Stakeholders agreed that Idle Mode does not represent anappreciable portion of the normal usage profile for telephones
and should not be tested.

December 4, 2012

1) Place the handset with a fully charged battery in the charge cradleat least 2 hours prior to the beginning of testing.
2) Ensure the UUT is in the Partial On Mode.
3) If the UUT can be placed in Call Origination Mode while the handset
is in the cradle:a. Place the UUT in Call Origination Mode for less than 1minute.
b. Confirm the presence of a dial tone.
c. Return the UUT to Partial On Mode.
4) If the UUT cannot be placed in Call Origination Mode while thehandset is in the cradle:
a. Remove the handset from the cradle.
b. Confirm the presence of a dial tone.
c. Return the handset to the cradle, within one minute ofremoving it, and the Telephone to Partial On Mode.
d. Wait 10 minutes.
5) Measure and record the ac input voltage and frequency.
6) Set the meter to begin accumulating true power values at a rate
greater than or equal to 1 reading per second. Accumulate power
values for 2 hours and record the average (arithmetic mean) value.”
DOE thanks stakeholders for their support of the proposal not to test Idle
Mode (now labeled Call Origination Mode in the Draft 2 Test Method).

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Summary and Response to Stakeholder Comments from theENERGY STAR Program Test Method for Determining Telephony Energy Use Version 3.0 Draft 1

Comment#23

V.

Comment Summary

Response

Stakeholders commented that, since the transmission of soundcan affect the power consumption of the UUT, testing using afixed tone at a specified level during Operation Mode tests.

As mentioned by the stakeholders in their comment, small amounts ofambient noise caused, in some cases, significant changes in the power
consumption of the UUT. However, in order to ensure the repeatability ofthe test method, testing using sound would require specifications regarding
not only the sound but also the level of ambient noise in the test room. DOE
believes these additional specifications would increase test burden
unnecessarily. As such, the Draft 2 Test Method does not include any
provisions for testing with sound.

MISCELLANEOUSComment#Comment Summary

Response24

Stakeholders requested clarification on additional energy usage
allowances being made for products with differentfunctionalities.

Energy usage allowances for different functionalities will be covered as partof the Specification development process. As such, all comments regarding
this topic should be resubmitted upon the publication of the Draft 1
Specification.

December 4, 2012

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