Televisions Version 8.0 Final Draft Comment-Response Document

Stakeholder Comment

EPA ResponseGeneralTopic

Subtopic

A stakeholder noted that the Version 8.0 specification will cause most products
currently qualified to not be able to meet the requirements. As a result, they requested
the relaxation of the proposed approach. Another stakeholder offered support for theapproach to energy saving features.

With Version 8.0, EPA seeks to ensure that ABC and other energy savings features persist
across the majority of preset picture settings. As such, given EPA's proposed approach in theFinal Draft, where products that qualify with ABC enabled by default must meet luminancethresholds, EPA recognizes that a subset of products may no longer qualify for ENERGY
STAR. As ENERGY STAR qualified TVs represent a significant share of the televisions market(initial estimates indicate 70% in 2016), this revision will ensure the ENERGY STAR isassociated with the more efficient products today.

Home Theater
Displays

A stakeholder supported the inclusion of Home Theater Displays (HTDs) in the Version
8.0 specification and recommended that EPA study the power requirements of thesemodels for Version 9.0 to determine if there is a need to set separate requirements.

EPA will monitor the market to determine if an opportunity exists to differentiate HTDs and TVs
based on their associated energy consumption in a future revision.

Persistence ofEnergy Saving
Features

Language
Encouraging
Users to Disable

Three stakeholders supported prohibiting language encouraging users to switch to a
picture setting without energy saving features or to disable an energy saving feature.
Two of these stakeholders noted that while the DOE test method discourages
manufacturers from providing a prompt to disable an energy saving feature duringinitial set-up, it does not test how the TV behaves after initial set-up. This could allow
for suggestive language or prompts to encourage the disabling of energy savingfeatures. The other stakeholder requested that EPA require retesting with the moreconsumptive features enabled to obtain qualification, if those features are encouraged.

In response to stakeholder concerns that users would be prompted to select settings whereenergy savings features are disabled, EPA proposes additional language in Section 3.2.5) iv.) toguard against users being encouraged to select non-default Preset Picture settings for generalviewing. EPA's intent is to allow consumer choice while encouraging the setting under which
the TV qualifies for the ENERGY STAR.

Persistence ofEnergy Saving
Features

Preset Picture
Setting Alerts

Two stakeholders supported EPA's proposal in Section 3.2.5 to require energy savingfeatures to default back to an enabled state.

EPA has retained this requirement in the Final Draft.

Persistence ofEnergy Saving
Features

Adjustment of
Two stakeholders supported EPA's proposal in Section 3.2.6 to prevent manual
Picture Parameters adjustment to TV picture parameters from affecting energy saving features.

EPA has retained this requirement in the Final Draft.

Persistence ofEnergy SavingFeatures

Special FunctionAlerts

One stakeholder supported EPA's proposal in Section 3.2.7 to require alerts whenever
special functions disable energy saving features.

EPA has retained this requirement in the Final Draft.

Two stakeholders supported EPA's proposal to prohibit TVs from being certified withenergy saving features enabled if the resulting savings from testing with the IEC test
clip are not comparable to those realized during a typical viewing experience, alongwith the option for EPA to review testing results to determine if the savings arecomparable. However, one of these stakeholders recommended that EPA require thatthe content used during testing for 'typical content' be submitted to EPA for review so
EPA can review to ensure it is representative.

EPA encourages manufacturers to share data, when available, to help improve understandingof how emerging energy savings features perform. EPA understands that some manufacturers
may have an interest in continuing to certify products with features such as motion detectiondimming. Since the release of Draft 2, EPA has some indication that the implementation ofmotion detection dimming has improved in 2017 models. EPA encourages manufacturers toshare additional data to help improve understanding of such energy savings features acrossdifferent content. As with ABC, where its energy savings potential has been demonstrated andwidely accepted by stakeholders, once energy savings of this feature is well understood, EPA
will be in a better position to encourage its use.

Requiring Energy
Saving Featuresthat Offer
Comparable
Savings

Two stakeholders stated that this proposed approach will not work because the IEC
test clip is the only standardized methodology for manufacturers to determine what a'typical viewing experience' would be and using other content would have results thatvary widely. One of these stakeholders recommended that EPA offer suggestions torevise the IEC test clip, if EPA believes it is inadequate.
Another stakeholder noted that this proposal will cause uncertainty which may
eliminate manufacturer's incentives to seek new, innovative methods to reduce energyconsumption because they must perform all R&D, testing, and have a final design
before submitting a request to EPA for approval. They noted that this would cause
manufacturers to not invest in new energy saving solutions in the case that EPA would
not approve certification if EPA believes the savings are not comparable.

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Televisions Version 8.0 Final Draft Comment-Response Document

Topic
Automatic
Brightness
Control (ABC)
Requirements

Subtopic

Stakeholder Comment
A number of comments on Draft 2 related to the implementation of ABC.

EPA Response
EPA considered these competing comments and has retained the Draft 2 requirement that TVscertifying with ABC enabled maintain it in all but one setting if they have up to four settingsand in all but two settings if they have more than four settings. EPA notes that certification
with ABC is optional, and the Agency has not prescribed how to implement ABC in eachsetting, only that it be maintained in the setting.

Some stakeholders asked that EPA require that TVs choosing to certify with ABC
enabled maintain it in all picture settings. They noted that some manufacturers had
already demonstrated the ability to implement ABC across all picture settings and that
manufacturers have not provided data that support disabling energy saving features(e.g., ABC) in certain preset picture settings. One stakeholder noted that a correct
In follow-up to the Draft 2, EPA analyzed two popular TV models on the market to determine
implementation of ABC should already accommodate bright-room situations, and thus a how ABC is most currently being implemented across some manufacturers and found that
separate brighter mode should not be necessary. However, two of these stakeholders
significant variability exists that may not allow for a direct comparison. EPA found that 1) there
noted that energy saving features may need to be disabled when true HDR content isis typically at least one preset picture setting where ABC is not enabled by default (EPA
being played (if it reverts back after the content is no longer being viewed) and whenlearned that often the Vivid Preset Picture Setting lacks ABC and that certain instances exist
the retail picture setting is selected. These stakeholders noted that manufacturers could when it is used in store demos in lieu of the Retail picture mode) and 2) HDR upscaling may be
encourage users to switch to preset picture settings that don't have energy saving
a separate picture setting or it could be a separate feature that may be enabled in a certain
features enabled by default through the name of picture settings (e.g., "Best Picture" or picture setting. This finding reinforces EPA's proposal requiring that TVs certifying with ABC"Preferred") and by encouraging language in the user manual or after initial start-up.
enabled maintain it in all but one setting if they have up to four settings and in all but twosettings if they have more than four settings.
Conversely, another stakeholder asserted that manufacturers would lose the ability toprovide differentiation in picture settings if ABC were enabled in each picture setting,citing that TV manufacturers' decisions reflect their experience, expertise, andconsumer feedback regarding present picture settings.
Another stakeholder commented that manufacturers need at least two preset picture
settings which can provide the brightest picture:
1. Vivid allows the brightest picture that the TV can support to demonstrate the model's
performance, and2. HDR upscaling, which provides HDR-like picture experiences to the user.
Two stakeholders noted that EPA is already ensuring that ABC is being used properly
because users are already being notified whether energy saving features are enabled ineach picture setting in the user manual or through alerts.

ABC Requirements

Luminance
Requirements

Meeting

One stakeholder requested that EPA hold a conference call if the Agency receives
additional input from the manufacturers regarding ABC.

In response to a stakeholder request, on June 23, 2017, EPA hosted a public webinar for all
stakeholder participation to discuss the proposed requirements to ensure persistence of ABCin TVs.

2EPA thanks stakeholders for their feedback. EPA is proposing to retain the requirement that
Several stakeholders supported EPA's luminance requirements of 125 cd/m at 3 lux,
intended to prevent TVs with ABC from being too dim and unsatisfactory for users, who TVs that qualify with ABC enabled by default must meet at minimum 125 cd/m2 at 3 lux in orderto ensure that TVs do not ship too dim. EPA is basing its proposal on data from the following
will switch to a different picture setting or end up disabling ABC.
sources: Imaging Science Foundation (ISF) data from over 15 years of calibrating TVs inhomes for dark room viewing, which points to 150 cd/m2 as the optimal screen brightness for
Two stakeholders suggested that EPA replace this absolute requirement with a ratio,such that that the luminance in the 3 lux illuminance condition be a fixed fraction of the dark environments; EPA's additional testing of screen brightness in different TVs with a limited
number of subjects to see firsthand how viewers may demonstrate different preferences, as aluminance in the brightest selectable picture setting. One noted that the absoluteluminance may vary significantly from unit-to-unit, unlike a ratio, which would result in supplement to ISF's findings; and the Japanese study "Survey of actual viewing conditions at
significant testing burden because the manufacturer would need to test each unit. One home and appropriate luminance of LCD-TV screens," published by the Society for Information
stakeholder recommended 30% for all models, while another recommended the ratio for Display in 2008, that considered TV luminance preferences as a function of room illuminance,
TV type, subject age, and video content characteristics. The study showed that most viewers
models with peak brightness less than 200 cd/m2.
preferred a screen brightness of 150-200 cd/m2.

In addition, one stakeholder stated that the sample size used in EPA's subjective testingof preferences was too small and EPA should draw on technical resources beyond the EPA is proposing 125 cd/m2 to allow for some flexibility in user preferences, without varying
too much from ISF's findings. EPA has evaluated all comments and accompanying data andrecommendations of the ISF to determine an appropriate requirement.
found that the data provided was not comparable to the industry accepted ISF field researchreflecting consumer preferences, or to additional data sources consulted, and thus did notjustify a lowering in the screen brightness.

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Televisions Version 8.0 Final Draft Comment-Response Document

Topic
High Dynamic
Range (HDR)
Upscaling

Ultra High
Resolution (UHD)
Adder

Subtopic

Stakeholder Comment
Three stakeholders support EPA's proposal to test the power use of the HDR upscaling
feature and publish it on the Qualified Product List (QPL) in order to appropriately
address this feature in a Version 9.0 specification, given predictions that market shareof TVs with this feature is expected to increase significantly. One of these stakeholders
requested that EPA explicitly note in the specification the plan to publish this data onthe QPL.

EPA Response
EPA has retained this requirement in the specification. On EPA's forthcoming QPX, which
certification bodies will use to report to EPA for product certification, EPA will include arequirement to report the power consumption associated with HDR upscaling, which will befeatured on the QPL.

A stakeholder recommended that EPA monitor the market and reduce the on-mode
power allowance for ultra-high definition (UHD) TVs, given data that has been produced
from several studies showing that the power use of these TVs has been reduced
significantly in a Version 9.0 specification.

With Version 8.0, EPA is not proposing to address the power consumption of UHD models.
Rather, the intent of this specification revision is to ensure the persistence of ABC and otherenergy savings features. EPA will continue to monitor the market and plans to revisit thepower consumption limits for both HD and UHD TVs with the next specification revision.

Another stakeholder maintained that reducing the UHD adder in the Version 8.0
specification was necessary because leaving a generous UHD adder will give
preference to UHD technology, which occurs in larger, more expensive, and moreenergy consumptive models. They requested that if EPA is unable to address the adderin Version 8.0, then they consider doing so in the Version 9.0 specification revisiononce the qualification impacts of Version 8.0 are understood.
Software Updates

Several stakeholders supported language that would address software updates andtheir potential impact on TV energy use and to require retesting if there is an impact on
power consumption. They noted that this is an important requirement to prevent
software updates from increasing energy use when the TV is in the home, thereby
negating the user's energy savings that was indicated by the ENERGY STAR logo. One
stakeholder noted that EPA's current guidance to certification bodies does not address
this and requested that EPA explicitly state this requirement within the specification.

In response to stakeholder concerns that software updates at initial set up may impact a TV's
energy consumption, such that it would no longer meet the power consumption requirements,
EPA is requiring that TVs demonstrate that they meet these requirements after updates havecompleted. All TVs/HTDs shall continue to meet the On Mode and Standby-Active, Low Mode
requirements following the installation of software updates as demonstrated per testing inSection 4.5.2 of this specification

Timeline

Several stakeholders supported EPA's timeline for finalizing the Version 8.0
specification in order to impact products entering the market in 2018. Thesestakeholders noted that if the timeline should be extended, then EPA should address
active mode power, such as the reduction of the UHD allowance in Version 8.0, insteadof waiting for Version 9.0.

As noted above, EPA intends to address the power consumption of TVs in the next
specification revision, instead focusing on the persistence of ABC and other energy savings
features in this Version 8.0 specification. EPA believes that in addressing the persistence ofthese features, TVs that will certify to Version 8.0 will deliver energy efficiency gains while also
providing users with quality viewing experiences.

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