Draft 2 Version 7.0 ENERGY STAR Displays Specification Stakeholder Comment Summary and Response
Topic

Subtopic

Stakeholders Comment Summary

U.S. Environmental Protection Agency ResponseDefinitions

Product TypeOne stakeholder expressed support for the Draft 2 proposal to define EPA thanks the stakeholders for this feedback. EPA has chosen toretain the proposed definition for Signage Displays presented in Draft
a Signage Display as having a diagonal screen size greater than 30
inches and pixel density less than or equal to 5,000 pixels per square 2, where signage products can be defined as having a maximum
inch but suggested that the maximum reported luminance criterion be reported luminance greater than 400 cd/m2. Since many computer
2lowered to 250 rather than 400 cd/m2. The stakeholder noted thatmonitors have a maximum reported luminance greater than 250 cd/m ,some signage displays are designed for indoor applications where the lowering the maximum reported luminance would not provide a robust
enough differentiator between products. EPA understands that manymaximum luminance is 250 cd/m2.
signage products are also intended for outdoor use, where theAnother stakeholder commented that many computer monitors have maximum reported luminance would need to be higher than it is for2luminance above 400 cd/m so that only pixel density and area criteria indoor use. However, to help differentiate those signage products withare relevant to defining a Signage Display. The same stakeholder also a lower maximum reported luminance from computer monitors, EPA
noted that the proposed ENERGY STAR definition is not harmonized proposes including "ships without a mounting stand" to furtherdistinguish the two types of products.
with the definition that is likely to be used in the EU Ecodesign
Regulation for displays.

Definitions

Enhanced
Performance
Display

EPA proposes to retain its approach from previous drafts, where theOne stakeholder commented that "other entities, utilize and refer tospecification provides a set of allowances for monitors containing a
ENERGY STAR program requirements for definitions ofcombination of criteria based on contrast ratio, viewing angle,
products" and thus recommended that EPA clearly define enhanced
resolution and color gamut. EPA proposes not to create a separate
performance displays in the Definitions section of the specification
definition for monitors at this time because features that create
rather than including the criteria for receiving the enhanced
performance display allowance in the Certification Criteria sections of 'enhanced performance' functionality can evolve. For example, withthis specification revision, EPA has seen further differentiation among
the specification. The stakeholder also suggested EPA retain theenhanced performance displays based on color gamut, indicating that
Version 6.0 definition of enhanced performance displays.
increased performance and functionality are not static. In order tomaintain flexibility in the future, where the criteria for enhanced
performance displays may further evolve, EPA prefers to address andaccount for enhanced performance displays by describing the set offeatures that must be present in order for such products to be eligible
for a power allowance. In addition, EPA considers that otherstakeholder groups are still able to harmonize their own definition forenhanced performance displays with EPA's designated set of criteria
for enhanced performance functionality as described in Section 3.3.4of the draft specification.

Definitions

To maintain the simplicity of the definition, EPA proposes adding aAutomaticOne stakeholder commented that the definition of Automaticnote that the ABC functionality must be enabled to control theBrightness Control Brightness Control suggests it functions without user intervention
brightness of a Display.
(i.e. does not need to be enabled) and thus suggested that thewording be changed to:“Automatic Brightness Control (ABC): The self-acting mechanism
that, when enabled, controls the brightness of a Display as a functionof Ambient Light Conditions”.

Page 1 of 6Draft 2 Version 7.0 ENERGY STAR Displays Specification Stakeholder Comment Summary and Response
Topic

Subtopic

Stakeholders Comment Summary

U.S. Environmental Protection Agency Response

Definitions

Native VerticalResolution

One stakeholder suggested a revised definition of Native Vertical
Resolution to clarify the visibility of the pixels:“Native Vertical Resolution: The number of physical lines along thevertical axis of the Display within the visible area of the Display that
produces images”.

In this case to maintain the simplicity of the definition, EPA proposes
adding a note that the physical lines must be visible and not hidden
under a bezel.

Scope

Professional
Signage Screen
Brightness

One industry organization suggested EPA limit the scope of Signage EPA proposes not to exclude displays with maximum luminance above
Displays to those intended for indoor operation by excluding displays 950 candelas per square meter at this time. EPA will continue tomonitor the market and determine the appropriateness of maintaining
with maximum luminance above 950 candelas per square meter.
a scope that includes all potential brightness levels once more data
becomes available.

AutomaticBrightness
ControlOne stakeholder reiterated that there are many unknowns with regard
to the operation of Automatic Brightness Control with considerable
variation among manufacturers and the implementation of software.
Therefore the stakeholder suggested harmonizing ABC testing with
the TV test method where possible and collected data from industry
on ABC control curves at typical ambient light conditions. Thestakeholder additionally noted that many monitors in the EPA dataset
do not appear to need the ABC allowance to reach the 25 percent
qualification threshold. To better ensure actual energy savings, thestakeholder therefore suggested that the incentive require bestpractice ABC implementation based on efficient control curves thatcomplement the ability of the human eye to resolve bright and dark
sections of a display screen.

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EPA has maintained the Draft 2 Automatic Brightness Control (ABC)approach given the lack of data on how ABC is used by consumers.
The 5% ABC allowance for computer monitors is relatively
conservative compared to the On Mode Power calculation savings
offered under the ENERGY STAR TV specification. EPA notes that TVs
are likely to operate under more widely varying illuminance thancomputer monitors and thus it is more appropriate to place a greater
emphasis on this functionality in the TV specification.

Draft 2 Version 7.0 ENERGY STAR Displays Specification Stakeholder Comment Summary and Response
Topic

Subtopic

Stakeholders Comment Summary

U.S. Environmental Protection Agency Response

Total EnergyConsumption

Duty Cycle

One industry group asked for clarification of how EPA arrived at theTotal Energy Consumption duty cycle weighting of 35% of time spentin On Mode and 65% of time spent in Sleep Mode. The groupsuggested EPA determine appropriate factors for differing groups ofmonitors under consideration because as proposed the formula insome cases will not yield realistic results.

Given that the majority of computer monitors operate with a hostcomputer, EPA has adopted the Version 6.1 ENERGY STAR computersspecification Total Energy Consumption duty cycle weighting of 35%of time spent in On Mode and 65% of time spent in Sleep Mode forconventional Desktops, Thin Clients, and Integrated Desktop
Computers. This duty cycle was originally derived from an industry
study capturing millions of computers conducted within the past
decade. A more recent December 2014 study published by Lawrence
Berkeley National Laboratory confirms that Desktop computers are in
active/active-idle mode for 7.3 hours a day which is roughly 30% of thetime. Previous studies estimated a range of 4.5 to 11.2 hours a day.
For consistency EPA has harmonized with the ENERGY STAR
computers specification duty cycle. Additionally, EPA notes that theduty cycle is intended to represent an average use profile whereby
product energy consumption can be compared side-by-side for thepurposes of ENERGY STAR certification.

A separate stakeholder suggested Off Mode be included in the Total
Energy Consumption cycle in addition to Sleep and On Modes.

Source: Desroches et al. December 2014. Computer usage andnational energy consumption: Results from a field-metering study,
Lawrence Berkeley National Laboratory
http://eetd.lbl.gov/sites/all/files/computers_lbnl_report_v4.pdf
EPA thanks the stakeholder for the suggestion to include Off Mode inthe Total Energy Consumption duty cycle. EPA does not have clear
data on how often users manually turn off their computer monitor.
Furthermore, the dataset indicates a minimal average power differenceof 0.1 W between Sleep and Off Mode for those monitors that have an
Off Mode function. Therefore EPA is retaining a separate power limit
for Off Mode rather than integrating it into the Total Energy
Consumption duty cycle.
Total Energy
Consumption
Requirements

Resolution
Allowance

One stakeholder recommended EPA set the Total Energy
Consumption resolution allowance at 12.264 kilowatt-hours permegapixel (equivalent to 4 W per megapixel in On Mode). Lowering
the allowance from 6 W per megapixel in Version 6.0 to the proposed
2 watts per megapixel in Version 7.0 (Total Energy Consumption
equivalent of 6.13 kilowatt hours per megapixel) is too drastic andcannot sufficiently capture models at 4K resolution.

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EPA has maintained the 6.13 kilowatt hours per megapixel resolution
allowance noting that it sufficiently captures models across a wide
range of resolutions up to 4K/Ultra High Definition. Energy efficienttechnology employed in today's UHD models allows a reasonableproportion of high performance models to meet the proposed Version
7.0 Total Energy Consumption requirements. The data do not support
an increased resolution allowance equivalent to 4 W per megapixel inOn Mode power as subtraction of this allowance from measured On
Mode power values results in negative values for several more
efficient models.

Draft 2 Version 7.0 ENERGY STAR Displays Specification Stakeholder Comment Summary and Response
Topic

Subtopic

Stakeholders Comment Summary

U.S. Environmental Protection Agency Response

Total Energy
Consumption
Requirements

Pass Rate

One industry group commented that as currently proposed in Draft 2, Over 20% of computer monitor models in the current Version 6.0
the Total Energy Consumption requirements for computer monitors
ENERGY STAR dataset meet the proposed Draft 2 Version 7.0 Total
would result in significantly less than 25% of products qualifying for Energy Consumption requirements. EPA also analyzed separate data
ENERGY STAR and therefore recommended further review to ensure submitted by industry in response to Draft 2, which show over 23% ofmodels can meet the proposed criteria. EPA expects technology tothat it does not excessively restrict products from qualifying for
ENERGY STAR. Conversely, another stakeholder commented that they continue to improve by the time Version 7.0 takes effect so that the top
would not be supportive of less stringent Total Energy Consumption quarter of energy efficient computer monitors on the market arerecognized.
monitor requirement as the Draft 2 proposed levels allow anappropriate amount of models to be eligible for ENERGY STAR
certification.

Enhanced
Performance
Displays

Criteria

One stakeholder commented that there are technologies that may
meet and exceed by far the contrast ratio and color gamut, but do notmeet the total native resolution requirement of greater than or equal
to 2.3 megapixels. The group argued that these technologies stillneed more energy and would benefit from the enhanced performanceallowances.

EPA found only one example of a <2.3 MP monitor meeting EPD color
and viewing angle criteria in its and stakeholders' datasets. EPA
therefore concludes that all three criteria together serve as reasonably
useful differentiators.

EPA will also include optional reporting of color uniformity to assess if
this criterion can serve to further distinguish EPDs in a future version
Another commented that high brightness and color gamut conformity of the specification.
across a display is a clear indication of a display being of enhanced
performance and requested that the following two additional technicalfeatures be added to the Enhanced Performance Display (EPD)
definition to ensure that only displays offering truly enhanced
performance are able to take advantage of the extra allowances:- a brightness and color uniformity of >90% across the image;- color and brightness stability at the delivered specified performanceacross the specific working temperature range and nominal working
life.
This stakeholder also suggested that additional models may be able
to meet EPD criteria even if not indicated as such in EPA's dataset.
Additional effort should therefore be spent on identifying thesemodels rather than increasing the allowance to ensure sufficient
selection.

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Draft 2 Version 7.0 ENERGY STAR Displays Specification Stakeholder Comment Summary and Response
Topic

Subtopic

Stakeholders Comment Summary

U.S. Environmental Protection Agency Response

Full Network
Connectivity

Allowance

One stakeholder recommended that EPA adopt the ENERGY STAR
Version 7.0 Televisions specification 3.0 watt allowance due to "thecommonality of network connection circuitry used for Signage
Displays and televisions." The stakeholder also noted that theENERGY STAR displays test method specifies connection preferencewith Wi-Fi as the highest priority and that this distinction is importantbecause Wi-Fi active connections generally require more power fromthe display circuitry than other types of connections.

Curved Monitors

Viewing Angle
Requirement

One stakeholder commented about the challenges of measuringcontrast ratio of curved monitors with a smaller radius of curvature.
Therefore the stakeholder proposed that the enhanced performanceallowance requirement for contrast be at an 80° viewing angle ratherthan 85°.

Based on stakeholder feedback on the limits of measuring equipment,
EPA is proposing to have curved displays measure contrast ratio at 83
degrees for the enhanced performance display criteria.

Curved Monitors

Additional
Enhanced
Performance
Allowance

One stakeholder requested the following additional allowances forcurved monitors because the transmittance decreases
about 30% from normal flat display:- For ≥99% sRGB: 0.50 x ETEC_MAX- For ≥96% Adobe RGB: 0.90 x ETEC_MAX- Normal model without wide color gamut : 0.25 x ETEC_MAX

EPA does not have significant data isolating the effect of a curved
configuration on power demand and has therefore not proposed anadditional allowance in the Final Draft. EPA will watch the energy useof curved displays and is able to amend this specification in thefuture, if warranted. As new data becomes available once thisspecification is in effect, EPA encourages manufacturers to submit
data particularly for models that are not certified to ENERGY STAR.

Based on information from multiple stakeholders, EPA understands
that Signage Displays and Televisions are built with the same, orsimilar, network connection circuitry. As such, EPA proposes a 3 wattallowance for Signage Displays to harmonize with the power
allowance for network connectivity in a TV's Standby-active low mode
under the Televisions Version 7.0 specification. However, as EPA
signaled to stakeholders under the Version 7.0 revision to theTelevisions specification, EPA also anticipates that Signage Displays
will continue to reduce their power consumption in network connected
Another stakeholder expressed support for a relaxed requirement for low power states. As such, EPA anticipates further reducing thisSignage Displays Sleep Mode Full Network Connectivity since while 1 allowance in future revisions to the specification.
W may be technically feasible many manufacturers have been
designing products to meet higher allowances in the ENERGY STAR At this time, EPA proposes to retain the Draft 2 TEC allowance for Full
Network Connectivity for computer monitors, which similarly to otherspecification for televisions and the EU Ecodesign Regulation onIT devices, have demonstrated the ability to implement network
Networked Standby. The stakeholder therefore suggested that EPA
consider a more stringent, Tier II, requirement to take effect at a later connectivity in low power states more efficiently than TVs.
date.

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Draft 2 Version 7.0 ENERGY STAR Displays Specification Stakeholder Comment Summary and Response
TopicTouch Allowance

Subtopic

Stakeholders Comment Summary

U.S. Environmental Protection Agency Response

One stakeholder commented that a display with touch technology
takes more power due to touch-enabled circuits and design. Anotherstakeholder requested EPA provide evidence to support a touchtechnology allowance if proposed under Version 7.

While the data indicate a lower pass rate for computer monitor models
with touch functionality, one stakeholder has indicated that extra
power is required even when the monitor is asleep and there is noUSB data connection to the host computer, indicating that the power
requirement is for the USB communication rather than touch. Since
the test method does not require connecting the USB, nor does it test
the touch functionality, such functionality should remain disabled andnot consume additional power.
Since the release of Draft 2, EPA has received new data on touchfunctionality indicating that optical touch technology used in larger
displays requires more power than capacitive technology used incomputer monitors, and that this touch technology is enabled in Sleep
Mode for certain models. Given this usage case and the opportunity toencourage models to spend more time in Sleep Mode while not in use
and to be woken up effectively by users, EPA is proposing a 1.5 W
allowance in Sleep Mode for signage displays.

Signage Displays Automatic
One stakeholder recommended "retaining the ENERGY STAR Displays EPA agrees and has maintained the 5% ABC allowance for Signage
Displays.
Brightness Control V6 ABC power allowance of 10% of the maximum On Mode power
requirement as it should provide a greater incentive for manufacturers
to implement an Automatic Brightness Control which will saveenergy."
Timeline

One stakeholder requested additional time to factor in new features
and technologies, such as new versions of DisplayPort or USB.

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Although new features are always emerging, EPA proposes to finalize
the Version 7.0 based on data on existing models, but is open toreopening the specification if necessary in the future.