Draft 2 Version 1.0 Small Network Equipment Specification Comment Summary

Ref. #

Topic

1

Definitions

2

Subtopic

Stakeholder Comment

EPA Response

Due to limited data on this type of access point, EPA has added an exclusion which removes products
One stakeholder suggested clarifying whether larger, professional Access Points are excluded from scope. marketed as enterprise network equipment and are; (1) shipped without a power supply, and/or (2) cannot
The stakeholder also noted that Figure 1: Product Type Assignment could be revised to make clear where a operate without a separate external access point controller. EPA welcomes stakeholder feedback on thisbox with a Router, Switch, and Access Point (and possibly more functions) belongs.
exclusion. EPA intends to cover these types of products in the future when more data on their power
consumption is available .

One stakeholder commented that service providers are likely to integrate broadband capability (e.g., highProducts with broadband modem capability and TV functionality will be covered by the ENERGY STAR
speed internet) and potentially routing capability into their set top boxes (STB) that currently provide
Set Top Box (STB) Specification. Broadband modem products that do not have TV functionality and meet
consumers with access to live pay TV. The stakeholder suggested that EPA carefully review the scope andthe definitions within scope of the ENERGY STAR Small Network Equipment (SNE) specification are
definitions of its SNE and STB specifications to ensure that these multi-function “gateway” devices are
considered SNE products.
appropriately covered and remain within the scope of the ENERGY STAR program.

Scope

Another stakeholder recommended that equipment with hardware to support security functions, such as
firewall and VPN, should be included in scope if they meet Small Network Equipment definition.

3

Base Power
Allowances

EPA agrees that products with security functions shall be included in scope if they meet the SNE
definition.

Two stakeholders commented that test results indicate that the current Cable allowances are not taking
DOCSIS bonded cable configurations into consideration and suggested the Broadband Model – Cable
allowance be raised to 6.7 W to allow for higher density channel bonding. One stakeholder recommended
that a 0.5 W allowance should be given to each additional 4 downstream channels. This stakeholder also
requested a 1.0 W allowance for a 4DS x 1US channel DOCSIS 3.0 IAD – Cable over the DOCSIS 2.0 IAD –Cable and specified that the maximum number of channels provided by the design be configured during
testing.

EPA has analyzed the Broadband Modem - Cable data and observed that several DOCSIS 1.0 and 2.0
products have a higher adjusted average power values than the DOCSIS 3.0 products in the dataset.
Furthermore the only 8x4 channel DOCSIS 3.0 cable modem in the dataset is the second lowest power
consuming cable modem in the dataset. Without additional product data, EPA cannot justify allowances
for additional DOCSIS 3.0 downstream channels. A similar situation occurs in the Cable - IAD productBroadband
category, where a DOCSIS 3.1 modem with 8x4 channel configuration has one of the lowest adjusted
Modem - Cable
The other stakeholder explained that the DOCSIS 3.0 specification (standardized in ANSI/SCTE 135 and ITU average power values in the product category,
J.222) requires cable modems to support channel bonding, with a minimum of 4x4 channels. Deployed
EPA has not received data on cable modems or IADs with greater than 8x4 channel configuration and
DOCSIS 3.0 cable modems support an 8x4 channel configuration, but products are being developed withtherefore cannot investigate the need for functional adders for additional DOCSIS 3.0 channel supportchannel densities of up to 24x8 channels. However, the stakeholder commented that it is premature to
beyond 8 downstream channels.
provide accurate measurements for cable modems with greater than 8 downstream channels at this timeand suggested instead that a note below Table 2 indicate that the Base Power Allowance for the Broadband
Modem – Cable applies to cable modems that support bonding of 8 or less downstream channels.

4

Base Power
Allowances

IAD - Cable

5

Base Power
Allowances

General

Stakeholders noted that the IAD – Cable Draft 2 allowance of 6.0 W allotted only 0.1 W for additional
functions (wired network routing, multi-port Ethernet port functions) compared to the Broadband Modem –Cable Draft 2 allowance of 5.9 W. To be more in line with the DSL Broadband Modem and IAD Draft 2
allowance differential of 1.5 W and product data, stakeholders suggested the following revisions for the
Cable IAD base allowance:• CABLE IAD – 7.4 W (Broadband Modem allowance + 1.5 W)• CABLE IAD – 7.7 W (Broadband Modem of 6.7 W + 1 W for IAD functionality)• At least a 2.5 W difference between a core Cable Modem and a Cable Modem + Wireless Gateway

The proposed base power allowances for the Broadband Modem - Cable and Cable - IAD productcategories, along with the functional adders present in the Draft 3 specification, yield 25% or higher passrates in both product categories, and allow several DOCSIS 3.0 products (including those with 8x4
channel configuration) to qualify. Thus EPA sees the Draft 3 levels as appropriate.

One stakeholder commented that the stringency of most of the base power allowances appears adequate
After receiving additional stakeholder submitted data in the final dataset assembly effort in March 2013,
for the first version of this specification; however, more stringent base allowances for products on the EPA
EPA has revised the base power allowances for several product categories to achieve qualification rates
data set with pass rates greater than 30% including Broadband Modem – ADSL (50%), ONTs (38%), andat or slightly above 25% wherever possible.
ADSL IADs (45%) should be considered.

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Draft 2 Version 1.0 Small Network Equipment Specification Comment Summary

Ref. #

6

7

Topic

Base Power
Allowances

Additional
Functional Adders

Subtopic

ONT

General

Stakeholder Comment

EPA Response

One stakeholder commented that the EPA dataset includes some ONT models that appear to have only
modem capability, but other models appear to have additional functionality such as data and phone signal
routing. Therefore, EPA should classify the former as Broadband Modem – ONT and the latter as IAD –EPA has relocated and revised the Optical Network Termination Device (ONT) definition to clarify that it
ONT and include the following base power allowances:
will not be treated as a type of modem or IAD, but rather a separate distinct product type which may have
- Broadband Modem - ONT : 4.3 W , Pass Rate: 22%
variable connectivity options. This change is consistent with the analysis of ONT data in both Draft 2 and- IAD- ONT: 5.5 W, Pass Rate: 29%
Draft 3 of the specification. ONT qualification rates based on the proposed base power allowances andfunctional adders in the Draft 3 specification are roughly 25%.
The stakeholder further noted that all IAD – ONTs listed in the EPA dataset that would qualify with a 5.5
Watt base allowance are devices that have modem and phone functionality only (i.e., they do not include
data routing or Wi-Fi). Two IAD - ONTs with Wi-Fi, however, are within 0.1 Watts of qualifying.

One stakeholder recommended that EPA to be very selective and limiting, when including adders in
product specifications since it is difficult to distinguish between general and brand specific functions andthere are available products that provide extensive functionality with low power consumption: a fully
integrated IAD with a consumption of 6-8 W. The stakeholder suggested excluding adders for MoCA, HPNA,
EPA creates functional adders when the dataset supports the need to compensate for additional power
integrated storage and VOIP, as well as a Wi-Fi adder for each Wi-Fi interface present, as data do notconsumption created by a feature which benefits the end-user. EPA received additional data whichindicate additional power demand required for these features nor is there explanation for why thesewarranted new functional adders explained in Index #8 and Index #9 below. The product mentioned whichfeatures cannot be turned off during testing. The stakeholder also recommends a ceiling limit be applied togains a 7.2W Gigabit Ethernet adder is out of scope as it contains 24 ports. This product was not included
the adders to avoid excessive allowance being applied. For example, there is an ONT modem in the datain the analysis to create base power allowances and functional adders for Draft 2 or Draft 3, and has been
set that would currently gain an additional 7.2 W through the Gigabit Ethernet adder – which is more thanremoved from the most recent version of the dataset to avoid confusion.
the base allowance for this product.
EPA will maintain the current adder structure and base power allowances, which are currently constructed
The stakeholder also suggested that Ethernet allowance be only applied to ports that are active under test
to allow at least the top quartile of each product type in the dataset to meet the energy efficiency criteria.
since unused ports should always power down to a minimum power level. Similarly, another stakeholder
Removal of the Fast Ethernet functional adder call for an increase in base power allowances across all
suggested that EPA consider applying a 0.6 Watt Gigabit Ethernet allowance to half the number of Gigabit
product types to arrive at similar qualification rates.
ports present rather than 0.3 Watts to all ports present. This stakeholder also recommended that EPA
eliminate the fast Ethernet functional adder since most, if not all, devices on the market today are capableof Fast Ethernet. Because a Gigabit Ethernet port draws about 0.6 Watts more than a fast Ethernet port, thestakeholder does agree that Gigabit Ethernet warrants an additional power allowance.

Stakeholders commented that the Draft 2 0.7W Wi-Fi allowance does not effectively capture highperformance with multiple bands and chains. One stakeholder noted that only 13% (2 of 15) of Routerswith in the EPA data set met the draft limit and no routers with dual-band meet the draft limit. When data
are normalized to remove applicable allowances, there is a 4W difference in average power between dualband and single-band routers (normalized data) whereas the there is only a 0.1W difference in average
power between single-band routers and routers without Wi-Fi. The stakeholder proposed separate Wi-Fi
allowances for 2.4 GHz and 5.0 GHz radios based on number of chains (1-3) to accommodate highperformance routers that allow devices to connect at the optimal frequency for the environment, improvedata transfer speed and integrity, and replace multiple single radio routers.

8

Additional
Functional Adders

Based on stakeholder feedback on the Draft 2 specification, as well as additional product data received in
the final data assembly effort in March 2013, EPA has created new Wi-Fi adders to account for productswith simultaneous dual band Wi-Fi and multiple chains. EPA conducted an analysis on the expanded
dataset and developed an adder structure which results in qualification rates at or above 25% for single
Another stakeholder similarly commented that their product data indicates that the actual power for a Wi-Fi
and dual band simultaneous Wi-Fi products. Please note that the new Wi-Fi adders are in addition to themodule is 1.5W for each band provided in the product. The Access Point may require more power than aexisting base Wi-Fi adder, and that all products with Wi-Fi functionality may still claim the base adder.
Wi-Fi module, but not as much additional power as represented by the difference between 2.0W for the
EPA welcomes feedback on this proposed adder.
Access Point (Table 1) and 0.7W for the Wi-Fi feature (Table 2). This stakeholder noted that both the use of
20MHz or 40MHz channel bonding and the number of antennas used in a MIMO configuration also affects
the required power. Another stakeholder stated that since tests are based on a low data rate the receive
power will dominate the overall increase of 0.35W per additional antenna whereas the power consumption
for channel bonding increases at higher data traffic. Based on these points, the stakeholder suggested a
Wi-Fi (802.11a/b/g/n) allowance per band present, an additional allowance per bonded pair; and anallowance for each extra antenna for Wi-Fi MIMO Capabilities (802.11 n).

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Draft 2 Version 1.0 Small Network Equipment Specification Comment Summary

Ref. #

Topic

Subtopic

Stakeholder Comment

EPA Response

9Additional
Functional Adders

Telephony
Service

One stakeholder commented that additional power is required to support the generation of Ringing Voltage
EPA has reviewed the feedback and data provided by stakeholders on this issue and has developed aand Loop Current for the telephones as well as the interface processing to the DOCSIS channel even when
Plain Old Telephone Service (POTS) functional adder as a result. When analyzing the dataset, EPA did
idle or not configured for use. Based on its own data the stakeholder thus recommends an allowance ofobserve an increase in power consumption between 1 POTS port and 2 POTS ports, but did not see
1.0W for the Telephone service (1 or 2 phone) and an additional 1.0W per each additional 2 lines. Anotheradditional power consumption when analyzing similar products with 4 POTS ports. For this reason, thestakeholder suggested only a single additional allowance of 1.5W for VOIP configurations as indicated by
telephony adder is capped at 2 ports. EPA welcomes feedback on this proposed adder.
its own test data.

10

Additional
Functional Adders

VDSL

One stakeholder commented that based on their own test results the current allowances do not account for
Bonded VDSL2 configurations. Thus, it suggested that an additional adder of 1.4 W be applied to the
EPA has not received enough product data to support a higher base allowance or functional adders for
additional VDSL2 lines for bonded configurations. The stakeholder also noted that the current allowances bonded VDSL2 or VDSL 30a.
do not account for VDSL 30a functionality based on a product's test result.

11

Optional
Performance
ReportingTo ensure EPA has all the raw data needed during its revision process to create Version 2.0, and for all
relevant information to be readily available to consumers and other interested stakeholders, one
stakeholder encouraged EPA to develop a data entry reporting form that clearly spells out the exact datathat must be reported and revise the existing language in the specification (Section 4.4) and test method(Section 9.1-9.2) that could result in inconsistent and potentially incomplete data reporting.
The stakeholder noted that the ENERGY STAR Qualified Product List could have two layers, one for thehigh level data that consumers would be interested in followed by a more complete set of data that would
include raw power measurements, test unit features (speed, number of ports, standards (including
wireless, EEE, DOCSIS and DSL information), external proxy capability), etc.

EPA is currently developing the Qualified Product eXchange (QPX) document which will be used to collect
all reported test data for ENERGY STAR certification. Manufacturers, CBs, and labs will have an
opportunity to review this document prior to finalization. All data the EPA intends to publish will be
displayed on the Qualified Product List (QPL) on the ENERGY STAR website. A subset of high level
consumer friendly information will be presented in the new ENERGY STAR Product Finder Tool, which canbe found at: http://www.energystar.gov/productfinder/

One stakeholder suggested EPA require that devices be shipped with EEE enabled, particularly if thespecification effective date is pushed back from March 2013, for the following reasons:- a broad range of stakeholders have worked together to develop the EEE protocol (IEEE 802.3az standard),- per unit annual EEE energy savings are 20 to 30%,
- there is little to no incremental cost associated with adding EEE to new chips, and- the share of models with EEE is expected to increase significantly in 2013.
12

Energy Efficiency
Ethernet

If a requirement is not possible, the stakeholder recommended EPA:
- require manufacturers report whether or not their models ship with EEE enabled,- commit to a timely revision process to update the specification so that it includes this requirement; and- add language that requires devices with EEE capability to be shipped enabled (opt-in not needed) andencourages simple and easy-to-use set-up menus

EPA thanks the stakeholder for this comment but will maintain its current approach on the EEE incentive,
as discussions with manufacturers have shown that EEE is not yet widely adopted in the SNE market.
Furthermore, only a few products in the SNE dataset have EEE capability. EPA encourages the adoptionof EEE by all stakeholders and believes that the current approach supports this position.

Another stakeholder acknowledges the need to encourage EEE but suggests that an upper limit be placedon the total allowance that can be gained via this incentive to avoid disproportionate energy allowances
being allocated.

13

14

External Proxy
Incentive

One stakeholder acknowledged the need to encourage adoption of external proxy capability so that end
point devices can maintain full network connectivity whilst in a sleep state, and expressed support for the
proposed levels.

Future Revisions

One stakeholder suggested including a discussion around how power management might be considered infuture specifications, listing out the following:
EPA thanks the stakeholder for this comment and will look to address these issues in the Version 2.0 SNE- Powering down at low traffic volume
specification.
- Scheduling WLAN on and off periods- Automatic switch off of unused interfaces

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EPA thanks the stakeholder for this comment.

Draft 2 Version 1.0 Small Network Equipment Specification Comment Summary

Ref. #

15

Topic

Specification
Effective Date

Subtopic

Stakeholder Comment

EPA Response

One manufacturer commented that the effective date of March 2013 is too early considering the current
debate and changes in Draft 2 and suggested a one year period from the release of requirements to allow
manufacturers time to design to the requirements and complete all testing and be consistent with otherdocuments.
Another stakeholder noted that the immediate effective date cannot be implemented in the European Unionand instead 6 to 8 months are required to allow for appropriate administrative processes.

16

Dataset17

Savings Potential

18

DSL Testing

One stakeholder commented that the EPA dataset on routers is limited:- data on only 15 routers with capability is available- 80% of routers with are from the same vendor- Additional test data is necessary from a larger diversity of vendors

EPA will issue a Final Draft after this Draft 3 and expects to complete the specification development
process in the coming few months. Partners will be invited to certify products to Version 1.0 as soon as itis published. EPA's dataset demonstrates that there are already products on the market that meet theDraft 3 levels, making a near term effective date appropriate.

EPA conducted a final data assembly effort in March 2013 and received significant additional product dataon routers. EPA has used this information to revise the router base power allowances, and also create
new simultaneous dual band Wi-Fi functional adders for products with multiple chains.

Recent analysis performed by one stakeholder and its consultant found that SNE equipment consumes
roughly 4 power plants worth of electricity and costs consumers more than $1billion/yr to operate, and that
EPA thanks the stakeholder for this comment.
more efficient designs could reduce their annual energy use by 30% or more. As such, the stakeholder
expressed strong support for EPA’s decision to establish a specification for small network equipment.

One stakeholder commented that the Draft 2 requirement to test products with both ADSL and VDSL
capability only in ADSL mode does not limit power consumption for the native VDSL2 mode and theallowance for the whole product is based only on the non-native ADSL mode. Since it is better to test and EPA agrees with the stakeholder feedback and is proposing that products with both ADSL and VDSL
impose a total allowance on the native mode of the product, the stakeholder suggested that “Products that functionality be tested using VDSL connections. EPA welcomes feedback on this revision
have both ADSL and VDSL functionality shall be tested using their VDSL functionality” which is similar to
the European Code of Conduct for Broadband approach.

One stakeholder commented that it is difficult to understand how many ports need to be connected foreach test. As such, it suggested revising Section 6.6-6) of the Test Method to clarify that the first connected
port may be a WAN port, not an Ethernet port, and that the number of connected ports during the test is
not defined by this figure since IADs do not need multiple Ethernet ports connected. Further it suggested
EPA feels that the current language in Section 6 and Section 7 of the SNE Test Method is unambiguousthat Section 7.1 be revised to state “If additional Ethernet ports are required during testing, they shall bewhen addressing IAD testing.
connected sequentially...”19

Test Configuration

The stakeholder also noted that the line #223 contradicts line #147:- Line 223: “Note: MoCA, HPNA and WiMAX (802.16e) connection types have been removed from Table 6,due to limited data and inability to test them in the current test method. These protocols should be turned
off during testing.“- Line 147: “Peripheral Devices: Non-Ethernet wired ports (e.g., HPNA, MoCA, USB, analog connections,
POTS, audio) shall not be connected”.
For consistency, the stakeholder suggested line 147 be revised to: “Peripheral Devices: Non-Ethernet
wired ports (e.g., HPNA, MoCA, USB, analog connections, POTS, audio) shall be turned off during testing”.

EPA will maintain the language "should be turned off" in line 223 of the test method as it may not be
possible for all products to accomplish at this time. In those cases, any additional power consumption
caused by not powering down those features will count towards the power consumption used for
qualification.

20

Active Ports

One stakeholder expressed support for the methodology proposed by EPA that has half or fewer of theavailable ports connected during power measurement testing for two reasons: a) while there does notappear to be any field data, anecdotal evidence suggests that most consumers only use zero, one or two of EPA thanks the stakeholder for this comment.
the available ports and rarely populate all of the available ports, b) it will reward those manufacturers who
deploy designs that power down any unused ports.

21

Test Labs

One stakeholder commented that third-party test labs with the capability to test small network equipment EPA will clarify in the Final SNE Test Method that commercially available traffic generators are not
per the ENERGY STAR Test Procedure could not be identified. Labs cited the expense of test equipment as required for ENERGY STAR SNE testing. Any combination of hardware and software used to generate
a concern.
traffic must meet all of the requirements in Section 5.C of the Final SNE Test Method.

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