Version 8.0 TVs Draft 1 Comment Response Document

TopicGeneral

Subtopic

Stakeholder Comment
Several stakeholders agreed with EPA's decision to address issues regarding persistence of energy savingfeatures in the Version 8.0 specification in a quick timeline to impact the 2018 product line. However, two ofthese stakeholders noted that if the timeline extends significantly beyond what was laid out in the Draft 1webinar, EPA should also address adjustments to the Ultra High Definition (UHD) adder and power
consumption of the High Dynamic Range (HDR) effect.

EPA Response
EPA appreciates this stakeholder feedback and intends to finalize the Version 8.0 specification in early
Summer 2017 to affect the 2018 model year.
In addition, EPA has made modifications to the proposal seen in Draft 1 based on stakeholder feedback.

Another stakeholder noted that the Version 8.0 Draft 1 specification will cause most products currently
qualified to not be able to meet the requirements. As a result, they requested the relaxation of the proposedapproach.
Scope

Home Theater
Displays

One stakeholder agrees with the inclusion of Home Theater Displays in the scope for Version 8.0. Anotherstakeholder suggested that educating consumers on the difference between a home theater display (HTD)
and a television is very important to ensure that consumers are not dissatisfied, especially given the growing
number of consumers who are moving away from traditional set-top boxes.

EPA is maintaining the inclusion of HTDs in the scope of the Version 8.0 specification. On the ENERGYSTAR TV product pages, EPA intends to provide consumers with a description of how HTDs differ fromTVs.

Energy Saving
Features

MDD

Several stakeholders characterized MDD as a technology that delivers energy savings only with the IEC test
clip, noting that energy saving features should provide these benefits in actual use as opposed to only duringtesting. Two of these stakeholders suggested that if MDD is an energy saving feature, it should be in effect inall preset picture settings. In contrast, one stakeholder recommended that EPA require MDD be turned off
during testing. Finally, one stakeholder recommended incentivizing energy saving technologies that "cannot
be turned off, that provide a good viewing experience, and that provide energy savings under all viewing
conditions", such as more efficient LEDs. One stakeholder supported the approach to MDD as presented inDraft 1.

To address the concern regarding variability of "typical viewing experiences", EPA encourages
manufacturers seeking greater assurance to share their assessment of any new energy saving feature
with EPA for approval prior to certification. We would expect to see performance data demonstrating
savings over a range of typical viewing content (i.e., full length of popular programming such as news,sports, dramas). For energy saving features dependent on content displayed, using any common lengthof popular programming over a variety of genres should be adequate to determine if the features deliver
similar savings across different content. The requirement in Section 3.2.3 is intended to prevent
certification with features that can detect specific content in a test method and thus demonstratesavings that are less likely to occur in a real world setting with content different from that of the test
method.

Several stakeholders requested that EPA clarify the meaning of "typical viewing experiences", including
length of scenes, to permit a repeatable evaluation of MDD and avoid customer confusion over varying
results. Another stakeholder stated that the goal of the IEC test clip is to provide a uniform standard
representative of real-world viewing and recommended that EPA participate in a process to revise this test
clip to define typical viewing experiences. Finally, two stakeholders noted that there is unlikely to beagreement on representative viewing.

Alerting
Consumers toPower
Consumption
Changes

Two stakeholders commented that the requirement to alert consumers to changes in power consumption due
to special functions was too broad and requires more clarity. One stakeholder noted that notifying each time
power is increased would cause consumer inconvenience (e.g., when increasing the volume). The otherrecommended listing particular functions that warrant notification and pointed out that this be supported bydata (e.g., unclear if HDR, gesture recognition, or voice recognition require more power).

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Other stakeholders recommended that energy saving features should persist across more Preset Picture
Settings, as EPA is proposing to do for ABC. EPA agrees and has clarified language in Sections 3.2.5 and3.2.6 to make the persistence requirements apply to any energy saving features.

EPA understands these concerns and proposes modified language in Section 3.2.7 where the TV/HTDmust provide an alert only when activation of a Special Function disables an energy saving feature.

Version 8.0 TVs Draft 1 Comment Response Document

Topic
ABC andPersistence

Subtopic

Stakeholder Comment
Several stakeholders recommended that EPA require the persistence of ABC in all home preset picture
settings, while several others agreed with also excluding any HDR-upscaling preset picture setting from theproposed requirement. According to one stakeholder, preset picture settings without ABC result in asignificant loss of energy savings.
One stakeholder commented that requiring ABC to be enabled in all modes would provide incentive for aquality implementation. Two stakeholders noted their concern that manufacturers could label the non-ABCpicture settings in a way that would encourage users to switch to them. One stakeholder requested that EPA
add requirements preventing such labeling or otherwise recommend that users disable energy savingfeatures like ABC be disabled. In addition, a stakeholder suggested EPA add language to require that ABC be
turned on again after HDR content is played or after a user switches to a different picture setting. Threestakeholders requested that EPA set requirements such that ABC delivers "relatively similar savings andviewing experiences" across preset picture settings.

EPA Response
Multiple stakeholders requested that EPA require ABC be enabled in all Preset Picture Settings, citingthat at least one prominent manufacturer is already doing so. EPA recognizes and applauds
manufacturers that have ABC enabled in all Preset Picture Settings. However, EPA has also heard fromother manufacturers that implementing ABC in all Preset Picture Settings would not be appropriate.
Although the proposed requirement remains unchanged from Draft 1, EPA is considering requiring thatfor TVs with ABC Enabled by Default, TVs with any number of Preset Picture Settings shall have only one
or no Preset Picture Setting without ABC enabled by default. With this Draft 2, EPA requests more
information from stakeholders for which specific Preset Picture Settings, excluding the picture setting
under the Retail configuration and any picture settings that may only be visible with true HDR content,
manufacturers are unable to implement ABC.
EPA also proposes expanded language under Section 3.2.5 requiring energy saving features (e.g., ABC)
to default back to on when entering preset picture settings where the features were initially enabled as
shipped.
EPA shares stakeholder interest in ensuring that ABC delivers savings across all Preset Picture
Settings, but at this time does not have enough information on variances in ABC savings that may
depend on Preset Picture Setting configurations to propose such a requirement. EPA will continue tomonitor the market to better understand the impacts of ABC in different Preset Picture Settings.
Regarding stakeholder concern that consumers will be incentivized to select Preset Picture Settings
without energy saving features enabled, the Department of Energy’s Test Method Appendix H to Subpart
B of 10 CFR Part 430 already requires the TV to enable the most energy consumptive features ifconsumers are provided with a prompt or information on whether to select them.

Luminance
Requirements

Several stakeholders supported the additional luminance requirements in sections 3.6.3 and 3.6.4. One
stakeholder cited 100 cd/m2 as the minimum screen brightness recommended in the TCO Displays standard,
whereas another manufacturer confirmed that the 150 cd/m2 at 3 lux requirement would be acceptable.
Two other stakeholders requested that EPA allow a tolerance to account for luminance deviations caused byeach module's brightness and light sensor. One of these stakeholders noted that a 20% brightness deviation
could be generated from light sensors, and without an allowable tolerance, manufacturers would need to set
a screen brightness of over 190 cd/m2 to meet the requirement. This stakeholder suggested that if anallowance is not provided, EPA should lower the requirement at 3 lux illuminance condition to 80 cd/m2 toprovide the user with a comfortable viewing experience and energy savings benefit. The stakeholder statedthat:• A 150 cd/m2 minimum could make the luminance curve almost flat, causing limited energy savings benefit
from ABC;• This requirement, in addition to the requirement that the average luminance in the default picture setting begreater than or equal to 50% of the brightest selectable picture setting, would increase overall energy
consumption and impose a duplicative requirement; and• In some full-HD models, the module brightness is natively low, and thus the TV would not be able to meet the150 cd/m2 requirement.

In response to varied feedback, EPA requested additional insight from the Imaging Science Foundation(ISF) on how it arrived at its recommended screen brightness of 150 cd/m2 for dark room viewing. ISF
provided input based on its 10-15 years of gathering insights and field data that consistently showedviewer preferences for a screen luminance of 150 cd/m2 in dark rooms for LCD TVs.
Balancing stakeholder input, EPA proposes setting a minimum screen luminance of 125 cd/m2 at 3 lux toaccount for variations in measured screen luminance, as noted by some manufacturers, and to maintaina minimum floor to guard against TVs certified with ABC enabled from shipping too dim. EPA maintains
its proposal to set a minimum required luminance instead of a ratio to guard against TVs withcomparatively low Brightest Selectable Preset Picture Settings from shipping too dim. EPA welcomes
additional feedback and data regarding this proposal.

Two stakeholders suggested that EPA remove this requirement and instead define a ratio of the requirement
luminance in the 3 lux illuminance condition to the brightest selectable picture setting. One of thesestakeholders recommended 30%.

HDR Upscaling

Three stakeholders commented in agreement to HDR testing and all suggested that the results be madepublic by model. Two of these stakeholders requested that EPA add requirements for native HDR content andHDR upscaling in the next specification revision, especially once a consensus test clip emerges that contains
native HDR content.

EPA appreciates this stakeholder feedback and maintained the testing of the HDR upscaling feature in
the Version 8.0 specification. EPA will monitor the market to assess the opportunity to improve energy
efficiency of HDR upscaling in a future revision.
EPA supports stakeholder efforts to develop an updated test clip that addresses scene cut frequency andis more representative of the HDR-encoded (and native 4K) content increasingly being watched bypurchasers of new televisions.

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Version 8.0 TVs Draft 1 Comment Response Document

Topic
UHD Allowance

SoftwareUpdates

Subtopic

Stakeholder Comment
Several stakeholders recommended that EPA include a UHD adder reduction in the Version 9.0 specification
revision as long as the timeline for Version 8.0 remains as short as possible. Other stakeholders supported
the inclusion of a reduction to the UHD adder in the Version 8.0 specification since UHD models comprise asignificant portion of the Qualified Product List. Numerous ENERGY STAR qualified UHDs fall below theadder level, demonstrating that products are easily able to meet the current requirement. Two of thesestakeholders suggested lowering the current 50% UHD allowance to 30%, based two different large datasets
and analyses of UHD power consumption analyses. One of these stakeholders suggested a 22 W flatallowance as alternative option to lowering the power limits for UHD TVs. Another stakeholder suggested a25% adder, which they noted would be double the level seen in European TVs, where UHD TVs consume
approximately 13% more power than HD TVs. Another stakeholder suggested maintaining the current
allowance until the impacts of the other changes can be reflected in the data. Should the UHD allowance bechanged in Version 8.0, this stakeholder supported lowering it to 40% and gradually decreasing it through aphased approach.

EPA Response
EPA shares stakeholder interest in reducing the power draw of UHD TVs, however, since its proposal torequire a minimum luminance at 3 lux will most likely impact overall power consumption of TV models
qualifying with ABC enabled by default, many of which are UHD models, EPA is choosing to wait until thenext specification revision to address UHD power consumption limits.

Two stakeholders noted that software updates could potentially modify or disable some energy savingfeatures. As a result, they recommended that EPA address this in the Version 8.0 specification by requiring
TVs to continue meeting the requirements following an update.

ENERGY STAR brand owner Partners are required to update their ENERGY STAR certification if asoftware update changes the television's reported energy consumption. Disabled energy saving features
would be uncovered in the course of ENERGY STAR verification testing and would result in
disqualification as appropriate.

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