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U.S. Department of Energy

Set-Top Box Proceeding

March 7, 2012
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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. 
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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.
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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.
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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 Captioning
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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 energyefficient, 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.
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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.
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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.
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Architecture Appendix