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# U.S. Department of Energy Set
- Top Box Proceeding March 7, 2012Page 2 

## The High Points:

• AT&T’s U
- verse® receivers should not be regulated under EPCA.
• U
- verse® receivers are already among the most energy efficient of the major video service providers, and AT&T continues to work to increase their efficiency.
• Regulation under EPCA, particularly if it mandates particular functionality, likely will suppress innovation and artificially channel product development, reducing efficiency over the long term.
• EPCA regulation would achieve minimal additional energy savings, at the cost of substantial industry distortion.
• Given the number of U
- verse® receivers in the market, the service falls far below the statutory threshold for EPCA regulation.Page 3 

## AT&T U
- verse
• Internet Protocol TV (IPTV), available in AT&T’s 22
- state footprint. Switched video carried over AT&T’s fiber network.
• 3.8 million subscribers as of December 2011.
• The same distribution infrastructure carries customer voice service and Internet data traffic.
• Intelligence in the network streams only the desired programming to customer’s U
- verse® receiver. Consumer equipment does not have to extract desired channel from larger data stream.
• Efficient system design causes consumer equipment to use less power.Page 4Page 5Page 6 

## U
- verse: Category of One

• AT&T U
- verse® is essentially a category of one.
• U
- verse® is very energy efficient.
• AT&T is only major provider in its product class.
• Demanding additional efficiency from this single provider
– which already has some of the lowest consumption levels in the industry
– would effectively penalize company that has been aggressive in pushing energy efficiency for years.
• Significant industry disruption and regulatory cost for very minor reduction in energy consumption.Page 7 

## Distinct from Over
- The Top (OTT) Services

• “IPTV” is overly broad category for this proceeding.
• OTT box converts a single
- source IP stream for viewing by a single user, typically with no additional features.
• Category of One: U
- verse® is a managed service designed to deliver scheduled TV service to millions of people. Has significant additional (energy consuming) features:  Electronic Programming Guide  Favorites List  Picture In Picture  Encryption and access control for third party content  FCC’s MVPD obligations: Emergency Alert, Disability Access, Closed CaptioningPage 8 

## U
- verse : Efficiency and Evolution

• All receivers have been Energy Star certified since 2008.  Energy Star target for DVR receiver dropped from 216 kWh/yr (version 2) to 180 kWh/yr (version 3). Version 4 target for 2013 is 121 kWh/yr.  Energy Star target for non
- DVR receiver dropped from 132 kWh/yr (version 2) to 105 kWh/yr (version 3). Version 4 target for 2013 is 63 kWh/yr.
• Meanwhile, U
- verse® pursued innovation.  Additional functionality built into receivers for richer consumer experience.  Reduced household power consumption, with the Total Home DVR®
– single central DVR that serves content to more energy
efficient, satellite receivers in household.
• Envision future when in
- home equipment will support video entertainment; home monitoring and security; home healthcare; smart appliance and energy management.Page 9 

## DOE Regulation:

• Should not mandate
-- explicitly or implicitly
-- particular energy efficiency functionality like deep sleep.
• Functionality mandates dampen innovation, channeling new product developments along the line that DOE has prescribed, rather than allowing innovation to flourish and pursue energy efficiency from various different angles.
• Tight regulation of energy consumption could have prevented Total
- home DVR® from coming to market.
• Could disrupt plans for multi
- service in
- home equipment.Page 10 

## Legal Authority:

• To support regulation, EPCA requires Secretary to determine that aggregate energy consumption for a product class exceeds 4.2 billion kWh/year.
• AT&T had 3.8 million U
- verse® subscribers at the end of 2011.
• Given current energy consumption of AT&T’s U
- verse® receivers and their distribution in customer households, IPTV customer base would need to increase by a factor of 4 before it approached EPCA’s statutory threshold.Page 11 

### Architecture Appendix