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 battery 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. These include comments of the Natural Resources Defense 

Council (“NRDC”) and California Investor Owned Utilities (“CA IOUs”). 

 NRDC asserts (Comments at 3) that the DOE test procedure as applied to applications equipped 

with backup batteries does not require modification and that it is manufacturers’ responsibility to design 

products that minimize other functions in maintenance mode, or to provide a mechanism to turn off 

these functions for the purpose of efficiency testing. Similarly, CA IOUs assert (Comments at 3) that 

manufacturers can either minimize standby power of additional functionalities or incorporate 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 Program, Energy Conservation Standards and Test 

Procedure for Battery Chargers: Availability 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 the “results [of its testing] suggest that the 

current test procedure, which is intended to measure battery charging energy consumption, may be 

unable to isolate and measure the energy usage of these particular 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 the 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 result, the DOE test procedure 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 changes 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 reasonable 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 regulations adds additional regulatory 

burdens and cost to manufacturers and consumers without 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 continuous 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 charging 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 standard 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 closer to that published 

in the Technical Support Document ("TSD") for a home security system of n = 0.02 or 

roughly 7 charge cycles 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