ARRIS Group, Inc.

101 Tournament Drive Horsham, PA 19044 USA

www.arrisi.com July 18, 2014

Kathleen B. Hogan Deputy Assistant Secretary for Energy Efficiency Energy Efficiency and Renewable Energy U.S. Department of Energy

EE-5 1000 Independence Avenue, SW Washington, DC 20508

Re: Docket Number EERE-2014-BT-NOA-0012

Dear Ms. Hogan:

ARRIS Group, Inc. (“ARRIS”) has reviewed the comments submitted in response to the Department of Energy’s (“DOE”) Notice of Data Availability (“NODA”) for Energy Conservation Standards and Test Procedure for Battery Chargers. 1 ARRIS believes that it is important to bring certain matters to DOE’s attention concerning those comments.

ARRIS strongly disagrees with the small minority of the comments claiming that the DOE test procedure as applied to “Continuous Use Products,” products that use batte ry power only in the event of power outages or similar emergency conditions, is sufficient and that it is up to manufacturers to modify such products so that they can be tested. Thes e include comments of the Natural Resources Defense Council (“NRDC”) and California Invest or Owned Utilities (“CA IOUs”).

NRDC asserts (Comments at 3) that the DOE test procedure as applied to applications equipped with backup batteries does not requ ire modification and that it is manuf acturers’ responsibility to design products that minimize other functions in maintenan ce mode, or to provide a mechanism to turn off these functions for the purpose of ef ficiency testing. Similarly, CA I OUs assert (Comments at 3) that

manufacturers can either minimize standby power of additional functiona lities or inco rporate an off

switch to turn these functions off. These comments do not withstand analysis and should be rejected.

1 Dep’t of Energy, Energy Conservation Progr am, Energy Conservation Standards and Test Procedure for Battery Chargers: Availabil ity of Data, 79 Fed. Reg. 27774 (May 15, 2014).Kathleen B. Hogan July 18, 2014 Page 2

To begin with, DOE in the NODA acknowledges that th e “results [of its testing] suggest that the current test procedure, which is intended to measure battery ch arging energy consumption, may be unable to isolate and measure the energy usage of these part icular products.” 2 The NRDC and CA IOUs comments seem to completely disregard this DOE analysis.

Continuous Use Products are becoming increasingly more integrated. That is, more functionality is performed by a system chip or chip set. Backup battery charging is not th e primary function of the product. There is no ability to “turn off” the rest of the product or chip and leave only the backup battery charging function on while testing. As a re sult, the DOE test proce dure overstates the energy used, by including not only the energy usage of the backup battery charging system but also the energy usage of the rest of the product. It is not feasible to add off switches to disable the non-charging functionality where the charging functionality is integrated at the system chip or chip set level.

Thus, while ARRIS believes that Continuous Use Products should not be included in the proposed regulations (as discussed below), we agree with comments that change s to the test procedure are necessary in order to accommodate such products if they are included. Our comments of June 30, 2014 recommend appropriate technical changes to the test procedure that would estimate the energy consumption of the battery backup system in a reas onable and cost effective manner if Continuous Use

Products are included in the scope of DOE regulation.

ARRIS agrees with comments that Continuous Use Products should be excluded from the scope of DOE regulation. Including these products in battery charger regula tions adds additional regulatory

burdens and cost to manufacturers and consumers wit hout providing meaningful energy savings. Hence, DOE should determine that no standard is justified for them. In that regard, we extract below our original comment on this point, submitted as Motorola Mobility, Inc., on May 29, 2012:

Motorola urges that DOE not include con tinuous use products – such as answering machines, home security systems, modems, and LAN/WAN adapters – in the standards for battery chargers. The very low frequency of charge combined with the relatively high ongoing power requirements of continuous use, or “always on,” products means that, as a percentage of product power, the battery chargi ng represents a very small fraction and a very small amount of energy. Therefore, little or no value is to be gained from including such products in the DOE standa rd for battery chargers.

2 Id. at 27776.Kathleen B. Hogan July 18, 2014 Page 3

In an example of a typical modem, Motorola measured normal power at approximately 6

watts. This translates to a UEC of 53 kWh/yr (i.e., 6*24*365). At n = 0.1 charges per day (Class 3 BCS) and measured battery charge energy of 21 Wh, the UEC for the battery would be 0.766 kWh (i.e., 0.1*365*21) or 1.4% of the product UEC. The actual UEC is even lower considering that the actual charge frequency is cl oser to that published in the Technical Support Document ("TSD") for a home security system of n = 0.02 or roughly 7 charge cycl es per year.

ARRIS requests that this letter be included in the record of this proceeding.

Sincerely,

/s/ Jason E. Friedrich

Jason E. Friedrich Head of U.S. Government & Regulatory

Affairs ARRIS Group, Inc.

101 Tournament Drive Horsham, PA 19044

cc: Jeremy Dommu, DOE