Suite 800 

1919 Pennsylvania Avenue NW 

Washington, DC 20006-3401 

Paul Glist 

202.973.4220 tel 

202.973.4420 fax 

paulglist@dwt.com 

MEMORANDUM 

Washington DC Office 

To: expartecommunications@hq.doe.gov 

From: Paul Glist

Date: May 7, 2012

Re: Docket No. EERE-2011-BT-NOA-0067 and RIN Number 1904-AC52 

Ex Parte Communication 

Department of Energy 

Meeting of May 1, 2012 

This Memorandum for the Record provides a summary of a May 1, 2012, meeting with 

DOE officials concerning potential test procedures and energy conservation standards for set-top 

boxes and network equipment. 

Meeting attendees: 

John Cymbalsky (DOE-Office of Energy Efficiency and Renewable Energy) 

Jeremy Dommu (DOE-Office of Energy Efficiency and Renewable Energy) 

Ashley Armstrong (DOE-Office of Energy Efficiency and Renewable Energy) 

Daniel Cohen (DOE-Office of General Counsel) 

Francine Pinto (DOE-Office of General Counsel) 

Celia Sher (DOE-Office of General Counsel) 

Neal Goldberg (National Cable & Telecommunications Association) 

Paul Glist (Davis Wright Tremaine) 

Andrew deLaski (Appliance Standards Awareness Project) 

Meg Waltner (Natural Resources Defense Council) 

Jennifer Thorne Amann (American Council for an Energy-Efficient Economy) 

The parties discussed the presentation in the attached slide deck which was distributed to 

attendees. 
5/1/2012

1

ENERGY CONSERVATION IN CABLE 

SET-TOP BOXES: 

Developing a Voluntary Agreement

National Cable & Telecommunications Association

Natural Resources Defense Council

Appliance Standards Awareness Project

American Council for an Energy-Efficient Economy

1

May 1, 2012

Industry Overview

• Cable “service providers” purchase the set-top 

boxes and provide them to their customers. 

Customer pays the electric bill.

• Set-top boxes include DVRs (digital video 

recorders) and basic boxes 

• By CEA estimates approximately 180 million settop boxes in US consume 25 TWh/yr. Cable 

represents approximately half.

• Cable industry launched aggressive energy 

initiative in 2011.

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5/1/2012

2

Proposal

• NCTA, CableLabs, and the Energy Advocates 

propose to jointly develop a Voluntary 

Agreement that would deliver significant energy 

savings in lieu of mandatory efficiency standards

• Negotiations would occur during temporary 

suspension of DOE and CEC processes with 

respect to Cable equipment (set-top boxes and 

small network equipment like cable modems)

• Commitments in final Voluntary Agreement 

would be contingent on termination of DOE and 

CEC regulatory approaches for equipment 

covered by the V.A.

3

Benefits of Voluntary Agreement

• Faster results than 2018 DOE standard.

• Some existing set-top boxes can be updated 

with software downloads.

• Can leverage existing CableLabs R&D and test 

facility.

• More flexible for rapid innovation cycle, 

competitive market, complexity of networks.

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5/1/2012

3

Efficiency Requirements

• Short term (2012): “light sleep.”

• Mid-term (2013): By the end of 2013, largest 

NCTA member companies who serve 

approximately 85% of cable subscribers will buy 

90% ENERGY STAR 3.0 set-top boxes.

• Longer term (2014): begin field tests of next 

generation energy-efficient cable set-top boxes 

which include power scaling (target <= 5W in 

deep sleep) followed by deployment of 

successfully tested boxes. Efforts will also include 

whole-home approaches that provide additional 

energy savings.

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Potential Savings

• Current test results indicate savings of 350 

million kilowatt hours in first year of light 

sleep in cable set-top boxes. 

• ENERGY STAR Version 3 set-top boxes are 

designed to be approx 30% more efficient 

than conventional models.

• “Deep sleep” chipsets with power scaling 

could result in annual energy savings of 50% 

or more.

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5/1/2012

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Elements and Timing

• Scope: Initial scope is cable HD-DVRs, non-DVR set-top 

boxes. Parties to discuss including other equipment (e.g. 

cable modems) offered or used by cable service provider at 

a later time.

• Agreement will include - definitions, test method, technical 

requirements, procurement commitments, dates, methods 

for verification and accountability, and protection of the 

consumer experience and innovation.

• Agreement from six largest NCTA member companies who 

serve approximately 85% of cable subscribers, Energy 

Advocates. Manufacturers and suppliers and others invited.

• Progress expected by 6/30/2012, agreement by 10/1/2012.

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Voluntary Agreement Would Replace 

Regulatory Approach

• Seek temporary suspension of DOE rulemaking 

with respect to cable products (e.g. hold off on 

further manufacturer and service provider 

interviews, publication of test method and 

standards NOPR, etc.) while Voluntary Agreement 

negotiations are occurring and making progress.

• Request DOE technical support for negotiation 

process.

• Acceptable Voluntary Agreement would replace 

regulatory approach.

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