Building Technologies Program 1 eere.energy.gov

Public Service of Colorado Ponnequin Wind Farm

BUILDING TECHNOLOGIES PROGRAM

Framework Public Meeting on Energy 

Conservation Standards for Set-top 

Boxes and Network Equipment

Jeremy Dommu

Department of Energy

Energy Efficiency & Renewable Energy

STB-RFI-2011-NOA-0067@ee.doe.gov 

January 26, 2012
Building Technologies Program 2 eere.energy.gov

• Introductions

• Role of the Facilitator

• Ground Rules (norms)

– Listen as an ally

– Use short, succinct statements/keep to the point

– Hold sidebar conversations outside the room

– Focus on issues, not personalities

– One person speak at a time (raise hand to be recognized; state 

your name for the record)

– Set cell phones to silent/vibrate

• Housekeeping Items

Welcome and Introduction
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Rulemaking Analyses

Closing Remarks

Public Meeting Agenda

4

5

2 Rulemaking Overview

3

1 Introduction

Test Procedure Rulemaking Overview
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Purpose of the Framework Public 

Meeting

• Present the procedural and analytical approaches to evaluate energy 

conservation standards for set-top boxes.

• Provide a forum for public discussion of rulemaking issues.

• Encourage interested parties to submit data, information, and written 

comments.

• Inform interested parties and facilitate the rulemaking process.
Building Technologies Program 5 eere.energy.gov

Agenda

9:00 – 9:30 am

9:30 – 10:00 am

10:00 – 11:00 am

11:00 – 11:15 am

11:15 – 12:30 pm

12:30 – 1:30 pm

1:30 – 3:00 pm

3:00 – 3:30 pm

Welcome, Introductions, Agenda Review, & Opening Statements

Standards Rulemaking Overview

Test Procedure Rulemaking Overview

Break

Standards Rulemaking Analyses

Lunch

Standards Rulemaking Analysis - continued

Next Steps and Closing Remarks
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Interested Parties Opening 

Statements

• At this time DOE welcomes opening remarks from interested parties.
Building Technologies Program 7 eere.energy.gov

Request for Comment

Issue Box Throughout this presentation, specific issues will 

be raised for discussion on slides such as this, with 

identifying numbers. Comments concerning any part of this 

presentation are welcome.
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Feedback Is Requested 

Especially on Items Identified in Request for Information

• In all correspondence, please refer to the Set-top Boxes rulemaking by:

– Set-top Boxes Rulemaking,

– Docket Number EERE–2011–BT–NOA–0067, and

– Regulatory Identification Number (RIN) 1904-AC52

• Email: STB-RFI-2011-NOA-0067@ee.doe.gov 

• Comment period closes: March 15, 2012

Postal: Hand Delivery/Courier:

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program, Mailstop EE-2J

1000 Independence Avenue, SW

Washington, DC 20585-0121

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program, Suite 600

950 L’Enfant Plaza, SW

Washington, DC 20024

Tel: 202-586-2945
Building Technologies Program 9 eere.energy.gov

Rulemaking Analyses

Closing Remarks

Public Meeting Agenda

4

5

2 Rulemaking Overview

3

1 Introduction

Test Procedure Rulemaking Overview
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• Goal: “Achieve the maximum improvement in energy 

efficiency which is technologically feasible and 

economically justified.”

Rulemaking Goals

• Open Honest Dialogue with all stakeholders

• More involvement and input from 

stakeholders helps establish the best 

possible rule

• Data and Information from Stakeholders 

helps expedite rulemaking process

Stakeholder

Engagement

• Recognize the challenges present for 

creating a rulemaking in a rapidly changing 

industry

• Create a rulemaking that increases energy 

efficiency while not impacting consumer 

utility or restriction of innovation.

Innovation
Building Technologies Program 11 eere.energy.gov

Regulatory History

• Part A of the Energy Policy and Conservation Act 

(EPCA) of 1975 (Public Law 94-163)

– Established the “Energy Conservation Program for 

Consumer Products Other Than Automobiles.”

– Subsequent amendments to EPCA gave DOE the 

authority to regulate the energy efficiency of several 

types of equipment.

– DOE also has authority to classify additional types of 

consumer products as covered products (average 

annual per-house hold energy use of that product is 

likely to exceed 100 kWh/year).

• Energy Policy Act (EPACT) of 1992 (Public Law 102-

486) & Energy Policy Act (EPACT) of 2005 (Public 

Law 109-58)

• Energy Independence and Security Act (EISA) of 

2007 (Public Law 110-140)
Building Technologies Program 12 eere.energy.gov

Regulatory History (Continued)

• Notice of Proposed Determination (76 FR 34914, June 15, 

2011)

– DOE preliminarily determined that set-top boxes and network 

equipment meet the criteria for covered products

• Request for Information (76 FR 32325, December 16, 

2011)

– DOE seeks information and comments from stakeholders

• Today ...

– DOE begins the process to consider potential energy 

conservation standards for set-top boxes.

– Covered products must meet additional criteria before DOE 

may prescribe an energy conservation standard (Average 

household energy use exceeds 150 KWh/year and the 

aggregate national energy use exceeds 4.2 TWh).

– DOE will issue a final determination at a later stage
Building Technologies Program 13 eere.energy.gov

Regulatory Issues for Set-Top Boxes

• 5-Year Compliance Period from the issuance of a 

Final Rule to the Compliance Date

• Rules apply to products manufactured for sale, 

assembled, or imported into the U.S. after the 

compliance date

• Products manufactured before the compliance date of 

the new standard may still be sold after the effective 

date

• No Requirement for consumers to replace existing 

products
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Test Procedures

Today...

• DOE is initiating the rulemaking and data collection process for a Federal 

test procedure.

• Test Procedure will specify the test conditions for measuring the energy 

consumption of the product in various power modes
Building Technologies Program 15 eere.energy.gov

Stages for the Energy Conservation 

Standards for Set-top Boxes

Milestones for DOE

2014 2013 2015 2016 2017 2018 2019

Standard

Test 

Procedure

Framework 

Public Meeting
Building Technologies Program 16 eere.energy.gov

Framework Public Meeting

Today

• Today’s public meeting covers the rulemaking process for Set-top Boxes

• Federal Register Notice of Public Meeting, FR DOC # 2011-32325, 

December 14, 2011.

– Gives notice of the public meeting and availability of the other materials 

being discussed today.

– DOE encourages interested parties to submit comments by March 15, 2012.

– Materials from today’s public meeting and other materials related to this 

rulemaking are available online:

http://www1.eere.energy.gov/buildings/appliance_standards/residential/set_top_boxes.html

Framework 

Public 

Meeting

NOPR Final

Rule

Effective

Date
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EPCA Factors

42 U.S.C. 6295(o)(2)(B)(i) directs DOE to consider seven factors when 

considering energy conservation standards for set-top boxes:

EPCA Factors DOE Analysis

1. Economic impact on consumers and 

manufacturers

Life-Cycle Cost Analysis

Manufacturer Impact Analysis

2. Lifetime operating cost savings compared 

to increased cost for the product

Life-Cycle Cost Analysis

3. Total projected energy savings National Impact Analysis 

4. Impact on utility or performance Engineering Analysis

Screening Analysis

5. Impact of any lessening of competition Manufacturer Impact Analysis

6. Need for national energy conservation National Impact Analysis

7. Other factors the Secretary considers 

relevant

Environmental Assessment

Utility Impact Analysis

Employment Impact Analysis
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Steps in the Standards Rulemaking: 

Notice of Proposed Rulemaking

Market & 

Technology 

Assessment

Screening 

Analysis

Engineering

Analysis

Energy Use 

Characterization

Shipments

Analysis

National

Impact

Analysis

Markups for 

Product Price 

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Framework 

Public 

Meeting

NOPR Final

Rule

Effective

Date

Life-Cycle 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Utility 

Impact 

Analysis

Employment 

Impact 

Analysis

Emissions 

Analysis

Monetization 

of Emissions

Regulatory 

Impact 

Analysis

Test Procedure
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Analyses for Final Rule

Revise NOPR 

Analyses

Framework 

Public 

Meeting

NOPR Final

Rule

Effective

Date
Building Technologies Program 20 eere.energy.gov

Test Procedure Rulemaking Overview

Closing Remarks

Public Meeting Agenda

4

5

2 Rulemaking Overview

1 Introduction

Rulemaking Analysis

3
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• Objectives

• To develop a representative test for measuring energy 

consumption

• To measure active, standby, and off power modes as defined by 

EPCA (42 U.S.C 6295 (gg) (1))

• To support data collection used in setting efficiency standards

• DOE will investigate test method to ensure that it:

• Is repeatable

• Represents typical household usage

• Minimizes burden on labs

Test Procedure: Objectives
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Test Procedure: Rulemaking Flow

• Rule is split into three phases:

• Request for Information (RFI)

• Notice of Proposed Rulemaking (NOPR)

• Final Rule

• Test procedure typically goes into compliance 75 days 

after Final Rule is published

• For both RFI and NOPR, stakeholders will be able to 

provide feedback:

• Attend a public meeting held by DOE

• Submit written comments

• Process will run concurrently with Standards 

rulemaking

RFI NOPR Final 

Rule

Effective

Date
Building Technologies Program 23 eere.energy.gov

Existing Test Procedures

• DOE will leverage existing test procedures

• ENERGY STAR

• IEC 62087

• Industry test procedures

• The test procedure will need to:

• Describe power measurements for different modes of 

operation

• Define energy efficiency metric(s) used for standards
Building Technologies Program 24 eere.energy.gov

Test Procedure: Modes of Operation

• The relevant modes of operation need to be identified

• ENERGY STAR measures power in the following modes 

of operation

• Watching live TV

• Recording live TV to DVR

• Playing back DVR recording

• Recording live TV to removable media

• Playing back removable media recording

• Playing video through a multi-room setup

Active

• Sleep

• Auto Power Down

• Deep Sleep

Standby 

/ Off
Building Technologies Program 25 eere.energy.gov

7 hours

6 hours

7 hours

4 hours

24 hour period

On

Sleep

Auto Power Down 

(if available)

Deep Sleep (if 

available)

Test Procedure: Energy Metrics

• DOE can consider different metrics for energy 

efficiency

• For example, ENERGY STAR uses a single metric 

(Typical Energy Consumption) based on the following 

time spent in each mode of operation
Building Technologies Program 26 eere.energy.gov

• Service providers program Set-top Box units

• The software permits added functionality and, as a consequence, 

dictates the unit’s behavior

Test Procedure Questions:

Impact of Service Provider Software

Added Functions Controlled Behavior

• Increased Security

• Increased Communication w/ SP

• Video on Demand

• Electronic Program Guide

• Low Power Modes (Idle/Sleep)

• Automated Updates

• Hardware Utilization

Issue #1: DOE seeks comment on how service provider software

impacts Set-top Box energy consumption.

Issue #2: DOE seeks comment on how service provider software 

impacts idle or sleep behavior.
Building Technologies Program 27 eere.energy.gov

• Testing environment determines the nature/format of the incoming 

signal

• DOE is considering testing with a live service subscription

Test Procedure Questions:

Live Network Testing

Live Network Closed Network

Pros • Reflects Typical Usage

• Simple Test Setup

• Low Service Provider 

Involvement

• Controlled Environment

Cons • Subscription Availability

• Geographical Variation

• Time of Day Variation

• Weather Variation

• Video Format 

Uncontrollable

• Large/Costly Equipment

• Complex Setup

• May Lack Certain 

Service Features

• Heavy Service Provider 

Involvement
Building Technologies Program 28 eere.energy.gov

Test Procedure Questions:

Live Network Testing

Issue #3: DOE seeks comment on how STB behavior will differ when 

on a live network as opposed to a closed network.

Issue #4: DOE seeks comment on how STB energy consumption will 

be affected by geographic location, time of day, and subscription 

package selected. 
Building Technologies Program 29 eere.energy.gov

Test Procedure Questions:

Video Source

ENERGY STAR Reference Channels

• Any channel that meets the following 

requirements

• STBs without conventional tuners (e.g., IPTV) 

use equivalent video content from a source 

representative of typical usage

Reference 

Channel

Video

Content

Minimum

Resolution

A Network Television 480i

B Live or Recorded Sports 720p*

C 24-Hour News 480i

* If UUT is HD capable, otherwise 480i
Building Technologies Program 30 eere.energy.gov

Test Procedure Questions:

Video Source

Issue #5: DOE seeks comment on the modification service providers 

make to content providers’ signals. Does a specific channel use similar 

frame rates, encoding, and bit rates across different service providers 

or locations?

Issue #6: DOE seeks comment on the variance in energy based on the 

video content. Would sports content (more dynamic) have significant 

differences in energy consumption compared to news content (more 

static)?

Issue #7: DOE seeks comment on the feasibility of determining frame 

rate, bit rate, and video format being received by the STB.

Issue #8: DOE seeks comment on any other parameters of the video 

source that impact the energy consumption STBs 
Building Technologies Program 31 eere.energy.gov

• ENERGY STAR testing requires splitting the active mode 

measurement between Pause, Fast Forward, Rewind, and Play for 

units with DVR

• A single measurement is taken, divvied up as indicated in the chart 

below

Test Procedure Questions:

DVR Testing

5% 10% 10% 75%

DVR Testing Breakdown

Pause Fast Forward Rewind Play
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• DOE has concerns that the DVR test results depend on the order in 

which the operations are performed as well as the speed of Fast 

Forward and Rewind

• Furthermore, the ENERGY STAR method introduces an 

unnecessary human element into the results as testers must 

manually switch between DVR operations

• DOE is considering separating each DVR operation into 

independent tests

Test Procedure Questions:

DVR Testing

Issue #9: DOE seeks comment on handling DVR testing and requests

data pertaining to typical usage of each operation (e.g., amount of time 

spent and speed used for each operation).

energy consumption
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• Low Noise Blocks (LNB) improve signal reception for satellite STBs 

by down converting the high frequency television signal to 

frequencies more suitable for cable transportation

• LNBs can be powered independently or by a STB

Test Procedure Questions:

LNB Energy Consumption

Issue #10: DOE seeks comment on including LNB energy consumption 

in measurements. How much power does the LNB consume compared 

to the STB?

Issue #11: DOE seeks comment on what factors impact LNB energy 

consumption and whether they can be controlled in a lab setting. 

Issue #12: DOE seeks comment on excluding LNB power from 

measurements. Is it possible to test the STB with the LNB disabled or 

disconnected? Are there any known methods for accurately measuring 

the LNB power to exclude it from the STB energy consumption? 
Building Technologies Program 34 eere.energy.gov

Test Procedure Rulemaking Overview

Closing Remarks

Public Meeting Agenda

4

5

2 Rulemaking Overview

3

1 Introduction

Rulemaking Analysis
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Steps in the Standards Rulemaking: 

Notice of Proposed Rulemaking

Market & 

Technology 

Assessment

Screening 

Analysis

Engineering

Analysis

Energy Use 

Characterization

Shipments

Analysis

National

Impact

Analysis

Markups for 

Product Price 

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Framework 

Public 

Meeting

NOPR Final

Rule

Effective

Date

Life-Cycle 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Utility 

Impact 

Analysis

Employment 

Impact 

Analysis

Emissions 

Analysis

Monetization 

of Emissions

Regulatory 

Impact 

Analysis
Building Technologies Program 36 eere.energy.gov

Market and Technology Assessment

Purpose

• Characterize the markets, the relevant industries, and the 

measures to improve efficiency

Method

• Identify and characterize manufacturers and service providers of 

set-top boxes;

• Estimate shipments and trends in the market;

• Identify existing regulatory and non-regulatory initiatives 

applicable to the equipment covered under this rulemaking;

• Establish product classes; and

• Identify technologies that could improve efficiency.
Building Technologies Program 37 eere.energy.gov

Relationship of Market and Technology 

Assessment to Other Analyses

Market and Technology 

Assessment Product Classes

Technology Options to improve efficiency

Screening Analysis

Design Options to improve efficiency

Engineering Analysis
Building Technologies Program 38 eere.energy.gov

Product Classes

• ENERGYSTAR currently categorizes STBs into base functionalities 

(e.g., cable, satellite, IPTV) and additional allowances (e.g., HD, DVR, 

multi-room)

• For ENERGYSTAR, Each STB would have a specific energy 

consumption qualification based on the unique functionality and 

features of the STB.

ENERGYSTAR Allowances

Base Functionality

Version 3.0 Allowance 

(kWh/year)

Version 4.0 Allowance 

(kWh/year)

Cable 60 45

Satellite 70 50

Cable DTA 35 25

Internet Protocol (IP) 45 25

Terrestrial 22 18

Thin-Client / Remore 35 20

Additional Functionality

Version 3.0 Allowance 

(kWh/year)

Version 4.0 Allowance 

(kWh/year)

Advanced Video Processing 12 8

CableCARD 15 15

Digital Videio Recorder (DVR) 45 36

DOCSIS® 20 15

High Definition (HD) 25 16

Home Network Interface (HNI) 10 8

Multi-room 40 30

Multi-stream (Cable/Satellite) 16 8

Multi-stream (Terrestrial/IP) 6 6

Removable Media Player 8 8

Removable Media Player/Recorder 10 10
Building Technologies Program 39 eere.energy.gov

Product Classes

• In general, classes are defined using information obtained in 

discussions with manufacturers, trade associations, and other 

interested parties. 

• DOE is reviewing the ENERGY STAR base functionalities and energy 

allowances and seeing how DOE’s product class criteria may be 

applied.

• DOE believes that some of these functionalities and allowances could 

be combined into the base product and thus, would not require 

separate product classes
Building Technologies Program 40 eere.energy.gov

Example of Cable Product Classes

Description Base Type HD AVP DVR

MultistreamMultiroom HNI DOCSIS

Cable 

CARD

Cable Base Cable X X X

Cable with 

Networking Cable X X X X X

Cable DVR Cable X X X X X X

Cable DVR with 

Networking Cable X X X X X X X X

• Advanced Video Processing (AVP), High Definition (HD), and Cable 

CARD assumed to be included in all future cable STBs.

• Removable Media does not require a different product class.

• DVRs would include multi-stream and multi-room functionality.

• Home Network Interface (HNI) and DOCSIS would be combined into 

a single “networking” functionality.
Building Technologies Program 41 eere.energy.gov

Example of Satellite Product Classes

Description Base Type HD AVP DVR

MultistreamMultiroom HNI

Satellite Base Satellite X X ?

Satellite DVR

Satellite 

DVR X X X X X X

• AVP and HD assumed to be included in all future satellite STBs.

• Removable Media does not require a different product class.

• DVRs would include multi-stream and multi-room functionality.

• HNI would not require a different product class, but may be folded 

into the DVR or base type.
Building Technologies Program 42 eere.energy.gov

Example of IP Product Classes

Description Base Type HD AVP DVR

MultistreamMultiroom HNI

IP Base IP X X X

IP with Multi-room IP X X X X X

IP DVR IP X X X X X X

IP DVR with Multiroom IP X X X X X X

• AVP, HD, and HNI assumed to be included in all future IP STBs.

• Removable Media does not require a different product class.

• IP boxes can provide multi-stream and multi-room independent of 

DVR functionality.
Building Technologies Program 43 eere.energy.gov

Example of Other Product Classes

Description Base Type HD AVP DVR

MultistreamMultiroom HNI

Terrestrial Terrestrial X X

Thin-Client

ThinClient X X

• Other product classes assumed to include HD and AVP.

• Terrestrial and Thin-Client would not be expected to have any other 

features requiring different product classes.
Building Technologies Program 44 eere.energy.gov

Product Class Comments

Issue #16: DOE welcomes comment on consideration of ENERGY 

STAR’s definitions of base functionalities and additional features, as a 

starting point for determining product classes.

Issue #13: DOE welcomes feedback on what product classes should be 

considered, how many classes to consider. and potential methods to 

combine or reduce the number of product classes.

Issue #14: DOE welcomes feedback and the impact on baseline energy 

consumption of potential product classes

Issue #15: DOE welcomes feedback on the market share of potential 

product classes. 
Building Technologies Program 45 eere.energy.gov

Steps in the Standards Rulemaking: 

Notice of Proposed Rulemaking

Market & 

Technology 

Assessment

Screening 

Analysis

Engineering

Analysis

Energy Use 

Characterization

Shipments

Analysis

National

Impact

Analysis

Markups for 

Product Price 

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Framework 

Public 

Meeting

NOPR Final

Rule

Effective

Date

Life-Cycle 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Utility 

Impact 

Analysis

Employment 

Impact 

Analysis

Emissions 

Analysis

Monetization 

of Emissions

Regulatory 

Impact 

Analysis
Building Technologies Program 46 eere.energy.gov

Screening Analysis

Impacts on health or safety

Adverse impacts on product or equipment utility or 

availability to consumers

Practicability to manufacture, install, and service

Technological feasibility

Purpose

• Screen out technology options that DOE will not consider in the 

engineering analysis for set-top boxes.

Approach

• DOE will evaluate each technology option based on the following criteria:

Issue #17: DOE welcomes comments on how the above four 

screening criteria might apply to the technology options discussed in 

the preliminary market and technology assessment.
Building Technologies Program 47 eere.energy.gov

Technologies to Improve Efficiency

• DOE has preliminarily identified the following strategies for improving 

the efficiency of STBs

• Lower power sleep modes (e.g., light and deep sleep). 

• Place processor and video decoder in a low power state (e.g. 

powered off or low voltage/performance state).

• Maintain active network connections needed for security.

• Keep RAM powered to maintain state.

• Multi-room setups. Secondary STBs in a home could be replaced by 

lower power thin clients that interface with a primary STB in the home. 

Whole-house STB energy use may be lower using multi-room setups. 

• Higher efficiency power supplies.

• Lower power electronic devices.

• Use of solid state disk drives (for DVR STBs).
Building Technologies Program 48 eere.energy.gov

Technology Option Comments

Issue #18: Comments, data, and input into technological, economic, and 

competitive impacts of using lower power light sleep and deep sleep 

modes for STBs. DOE also seeks feedback on any other issues related 

to lower power sleep modes. DOE is particularly interested in 

technological features that could significantly reduce energy consumption 

while providing for adequate communication with services providers and 

minimizing wake-up times when consumers power on their devices. 

Issue #19: DOE is also interested in other examples and data of energyreducing technologies, configurations, or product designs, other than 

sleep modes, that could help improve the efficiency of STBs?

Issue #20: What design limitations are imposed on STBs by the cable, 

satellite, terrestrial, or internet infrastructure? How might this affect STB 

behavior/usage profiles? How might this affect STB energy consumption?
Building Technologies Program 49 eere.energy.gov

Steps in the Standards Rulemaking: 

Notice of Proposed Rulemaking

Market & 

Technology 

Assessment

Screening 

Analysis

Engineering

Analysis

Energy Use 

Characterization

Shipments

Analysis

National

Impact

Analysis

Markups for 

Product Price 

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Framework 

Public 

Meeting

NOPR Final

Rule

Effective

Date

Life-Cycle 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Utility 

Impact 

Analysis

Employment 

Impact 

Analysis

Emissions 

Analysis

Monetization 

of Emissions

Regulatory 

Impact 

Analysis
Building Technologies Program 50 eere.energy.gov

Goals of the Engineering Analysis

• A key factor in setting the standard is the increased cost of a 

more efficient product.

• The Engineering Analysis determines the relationship between 

cost and efficiency.

Rulemaking Analyses

• Life-Cycle Cost and 

Payback Period

• Manufacturer Impact 

Analysis 

• Employment Impact 

Analysis

Manufacturer Selling Price –

Efficiency Relationship

Manufacturer 

Selling Price

Efficiency Level
Building Technologies Program 51 eere.energy.gov

Engineering Analysis Methodology

 Choose product classes to be analyzed in the engineering 

analysis. 

 Define characteristics of models in each representative 

product class, which will serve as reference points to assess 

changes due to more stringent standard levels.

 Identify set-top box models for testing and teardown.

 Determine manufacturer production costs and selling prices for 

the different models of set-top boxes.

 Develop candidate standard levels that span the range of settop box efficiencies.

 Scale results to product classes not analyzed.

Scale 

Results

Choose 

Representative 

Product Classes

Define Baseline 

Models

Identify

STB

Models

Develop

Cost-Efficiency 

Curves

Develop

Candidate 

Standard Levels
Building Technologies Program 52 eere.energy.gov

Choose Representative Product 

Classes

• DOE will choose a subset of product classes called 

“representative product classes” to analyze in the 

engineering analysis and life-cycle cost analysis. 

• Representative product classes are generally based on:

• High volume products

• Ability to scale to other classes

• Unit availability

• For Set-top Boxes, all features relevant to energy 

consumption will be included in at least one representative 

product class.

Scale 

Results

Choose 

Representative 

Product Classes

Define Baseline 

Models

Identify

STB

Models

Develop

Cost-Efficiency 

Curves

Develop

Candidate 

Standard Levels
Building Technologies Program 53 eere.energy.gov

Define Baseline Models

After the product classes are chosen, the characteristics 

of the baseline unit for each class are defined:

• Defines a reference point against which changes in 

efficiency and cost can be measured.

• Represents a commercially available unit including 

operating capabilities, energy efficiency and price.

• The baseline model is used in the life-cycle cost and 

payback analyses.

• To determine energy savings and change in price, each 

higher efficiency design option is compared with the 

baseline model. 

Scale 

Results

Choose 

Representative 

Product Classes

Define Baseline 

Models

Identify

STB

Models

Develop

Cost-Efficiency 

Curves

Develop

Candidate 

Standard Levels
Building Technologies Program 54 eere.energy.gov

Identify Higher Efficiency Set-top Box 

Models

• In identifying higher-than-baseline-efficiency set-top 

boxes for analysis, DOE will begin by utilizing the 

ENERGY STAR qualified product lists for set-top boxes.

• Higher efficiency models will be used to create cost vs. 

efficiency curves for each product class.

• DOE will evaluate all design options that are 

commercially available or present in a working prototype, 

including proprietary designs and technologies.

• DOE will include STBs with a wide variety of features in 

order to determine the cost and energy use related to 

each feature.

• Example: Units with DVR and without DVR would be 

included in this selection.

Scale 

Results

Choose 

Representative 

Product Classes

Define Baseline 

Models

Identify

STB

Models

Develop

Cost-Efficiency 

Curves

Develop

Candidate 

Standard Levels
Building Technologies Program 55 eere.energy.gov

Identify Higher Efficiency Set-top Box 

Models

• Proprietary designs will only be considered if they do not 

present a unique path to a given efficiency level.

Issue #21: DOE welcomes comment on whether there are 

proprietary designs it should consider for any of the settop box product classes under consideration in this 

rulemaking and, if so, how DOE should acquire the cost 

data necessary for evaluating these designs.

Scale 

Results

Choose 

Representative 

Product Classes

Define Baseline 

Models

Identify

STB

Models

Develop

Cost-Efficiency 

Curves

Develop

Candidate 

Standard Levels
Building Technologies Program 56 eere.energy.gov

Develop Cost-Efficiency Curves

The engineering analysis may use one or more of the 

following approaches:

• The survey approach (the efficiency is known) relies on 

costs provided by manufacturers or from retail surveys to 

estimate the costs for various efficiency levels. (Quickest 

method)

• The design options approach (the technology path is 

known) uses estimates of the costs and performance of 

particular designs that increase efficiency. Design option 

efficiency increases can either be based on engineering 

calculations, test results or through the use of engineering 

computer simulation models.

• The cost assessment approach (the efficiency is 

known) estimates the manufacturing costs of efficiency 

levels by analyzing existing products, possibly including 

teardown of some units on the market.

Scale 

Results

Choose 

Representative 

Product Classes

Define Baseline 

Models

Identify

STB

Models

Develop

Candidate 

Standard Levels

Develop

Cost-Efficiency 

Curves
Building Technologies Program 57 eere.energy.gov

Develop Cost-Efficiency Curves

Scale 

Results

Choose 

Representative 

Product Classes

Define Baseline 

Models

Identify

STB

Models

Develop

Cost-Efficiency 

Curves

Develop

Candidate 

Standard Levels

Issue #22: DOE welcomes comment on markup 

approaches for developing estimates of manufacturer 

selling prices.

Issue #23: DOE welcomes comment on the abovedescribed approaches to determining the relationship 

between manufacturer selling price and set-top box 

efficiency.
Building Technologies Program 58 eere.energy.gov

Develop Candidate Standard Levels

Scale 

Results

Choose 

Representative 

Product Classes

Define Baseline 

Models

Identify

STB

Models

Develop

Cost-Efficiency 

Curves

Develop

Candidate 

Standard Levels

• Develop candidate standard levels (CSLs) that span 

the range of set-top box efficiencies from the baseline 

to the maximum technologically feasible.

• DOE is required to analyze maximum technologically 

feasible (“max-tech”) efficiency levels

• “Max available” may not correspond to “max-tech” if 

some design options are not yet commercially available.

• DOE will seek input from interested parties to develop a 

max-tech efficiency and cost.

• DOE may use ENERGY STAR specifications as 

intermediate CSLs
Building Technologies Program 59 eere.energy.gov

Develop Candidate Standard Levels

Scale 

Results

Choose 

Representative 

Product Classes

Define Baseline 

Models

Identify

STB

Models

Develop

Cost-Efficiency 

Curves

Develop

Candidate 

Standard Levels

Issue #24: DOE welcomes interested parties to comment 

on methods and approaches employed to improve the 

efficiency of the set-top boxes, including the max-tech 

model. Detailed information on set-top box performance 

and the incremental manufacturing costs would be useful.
Building Technologies Program 60 eere.energy.gov

Scale Results

• Scale analyses conducted on representative product 

classes to other product classes.

• Representative set-top boxes will need to be scaled 

based on optional features TBD by DOE (e.g. DVR, 

Home networking, HD).

• Cost and efficiency values for each relevant feature 

will be generated by comparing STBs with and 

without each feature:

• Component differences

• Power differences

• Architectural differences relevant to sleep/standby 

power modes

Scale 

Results

Choose 

Representative 

Product Classes

Define Baseline 

Models

Develop

Cost-Efficiency 

Curves

Develop

Candidate 

Standard Levels

Identify

STB

Models
Building Technologies Program 61 eere.energy.gov

Scale Results

Scale 

Results

Choose 

Representative 

Product Classes

Define Baseline 

Models

Identify

STB 

Models

Develop

Cost-Efficiency 

Curves

Develop

Candidate 

Standard Levels

Issue #25: DOE welcomes comment from interested 

parties on the best methodology for scaling from the 

representative product classes to the remaining product 

classes, including the proposed methodology of 

assigning specific power requirements for additional 

features, similar to ENERGY STAR allowances.
Building Technologies Program 62 eere.energy.gov

Outside Regulatory Changes

• DOE takes into consideration the effects on manufacturers of 

other regulatory changes outside of the standards rulemaking 

process.

Issue #26: DOE welcomes comment on whether there are 

outside regulatory changes that DOE should consider in its 

engineering analysis of set-top boxes.
Building Technologies Program 63 eere.energy.gov

Additional Engineering Issues

Issue #27: DOE seeks data on the energy use and 

configurations of current STBs in the market. 

Issue #28: DOE would like to gain access to a subscription or 

head-end equipment similar to that of the consumer’s access 

in order to test and perform physical teardowns of STBs. 

Issue #29: DOE seeks additional data on STB markets and 

technologies, including updated energy use data on STBs by 

potential product class. This data includes numbers of 

installed devices, unit energy consumption, efficiency ranges, 

and usage profiles
Building Technologies Program 64 eere.energy.gov

Steps in the Standards Rulemaking: 

Notice of Proposed Rulemaking

Market & 

Technology 

Assessment

Screening 

Analysis

Engineering

Analysis

Energy Use 

Characterization

Shipments

Analysis

National

Impact

Analysis

Markups for 

Product Price 

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Framework 

Public 

Meeting

NOPR Final

Rule

Effective

Date

Life-Cycle 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Utility 

Impact 

Analysis

Employment 

Impact 

Analysis

Emissions 

Analysis

Monetization 

of Emissions

Regulatory 

Impact 

Analysis
Building Technologies Program 65 eere.energy.gov

Energy Use Analysis

Purpose

• Develop annual energy use data for set-top boxes based on field 

operating conditions, television viewing patterns, and STB usage 

patterns.

Method

• Develop average energy use values by using typical television viewing 

patterns (both live and playback) and average set-top power levels in 

each mode.

• Develop distributions of set-top box operating hours and standby 

hours. 

• Take into account operating variability by using a distribution of 

operating hours.
Building Technologies Program 66 eere.energy.gov

Request for Comments

Issue #30: DOE seeks to identify and obtain detailed data on 

the typical usage profiles for set-top boxes considered in this 

rulemaking. If the range of energy use determined for each 

product class is large enough, DOE will conduct a sensitivity 

analysis to determine how high and low estimates of energy 

use might impact the economic feasibility of any potential 

energy conservation standards. DOE welcomes 

recommendations on sources of data that would provide 

usage profiles for each of the product classes covered under 

this rulemaking.

Issue #31: DOE welcomes comments on how the usage 

profiles are different (or similar) for each of the product 

classes covered under this rulemaking.

Issue #32: DOE welcomes comment on other end-use issues 

that could impact the energy use analysis
Building Technologies Program 67 eere.energy.gov

Steps in the Standards Rulemaking: 

Notice of Proposed Rulemaking

Market & 

Technology 

Assessment

Screening 

Analysis

Engineering

Analysis

Energy Use 

Characterization

Shipments

Analysis

National

Impact

Analysis

Markups for 

Product Price 

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Framework 

Public 

Meeting

NOPR Final

Rule

Effective

Date

Life-Cycle 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Utility 

Impact 

Analysis

Employment 

Impact 

Analysis

Emissions 

Analysis

Monetization 

of Emissions

Regulatory 

Impact 

Analysis
Building Technologies Program 68 eere.energy.gov

Markups for Equipment Price 

Determination

Purpose

• Determine consumer and service provider set-top box prices based on 

manufacturer costs, both for baseline and higher efficiency products.

• Characterize set-top box distribution channels.

Method

• Identify distribution channels. 

• Estimate the consumer and service provider prices by applying 

markups (consisting of distribution channel markups and sales tax, if 

applicable) to manufacturer selling price estimates. 

• Collect retail price data for validation purposes, if applicable.

• The engineering analysis will develop manufacturer markups. 

• U.S. Census Bureau data

– Manufacturing Industry Series data for calculating original 

equipment manufacturer (OEM) markups

– Business Expenditure Survey for calculating distributor markups.
Building Technologies Program 69 eere.energy.gov

Markups for Equipment Price 

Determination

Unique Issues with STBs

• Equipment price actually paid by consumers can be difficult to assess

• Device may be “free”, though cost of device is actually included in 

base subscription fee

• Premiums for additional features (e.g., HD, DVR) 

• Exact pricing strategy proprietary to service providers

• Some STBs rented or leased, others purchased from service 

providers

• Possible solutions: 

• confidential submission of data to accurately model equipment 

price markups from service providers to consumers

• Simplifying assumptions – adopting same markups as from 

manufacturers to service providers

Issue #33: DOE welcomes feedback and data on how to properly address 

equipment price markups for set-top boxes. DOE also welcomes comment 

on the distribution chain for set-top boxes.
Building Technologies Program 70 eere.energy.gov

Network Infrastructure Issues

Issue #34: What changes to network infrastructure would be 

necessary for STB efficiency design options? What would 

be the cost of these changes? Would service providers 

pass these costs onto consumers in the form of increased 

fees?
Building Technologies Program 71 eere.energy.gov

Steps in the Standards Rulemaking: 

Notice of Proposed Rulemaking

Market & 

Technology 

Assessment

Screening 

Analysis

Engineering

Analysis

Energy Use 

Characterization

Shipments

Analysis

National

Impact

Analysis

Markups for 

Product Price 

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Framework 

Public 

Meeting

NOPR Final

Rule

Effective

Date

Life-Cycle 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Utility 

Impact 

Analysis

Employment 

Impact 

Analysis

Emissions 

Analysis

Monetization 

of Emissions

Regulatory 

Impact 

Analysis
Building Technologies Program 72 eere.energy.gov

Life-Cycle Cost and Payback Period 

Analysis

Purpose

• Assess the LCC impacts and PBP for the consumers of set-top boxes 

under the considered efficiency levels.

Method

• LCC equals first costs plus the sum of annual operating costs 

discounted to a particular base year

• Analysis will model the uncertainty and variability of inputs using Monte 

Carlo approach and probability distributions.

• Analysis will be implemented in MS Excel® spreadsheet combined with 

Crystal Ball.®

First Cost

(Consumer Price +

Installation Cost)

Operating 

Expenses

Combine Changes 

in Costs

LCC Results

Convert to Present Value
Building Technologies Program 73 eere.energy.gov

Life-Cycle Cost and Payback Period 

Analysis

Baseline

Manufacturer

Price

Std-Level

Manufacturer

Price

Sales Tax

Installation

Cost

Total Installed

Cost

Energy Prices

 Energy Use

Equipment

Price

Lifetime

Operating

Expense

Annual Energy

Expense

Lifetime

Repair Cost

Discount Rate

Maintenance

Cost

Energy Price

Trends

Annual

Operating

Expense

Payback

Period

Life-Cycle

Cost

Distribution

channel

Markup

From

Engineering

Analysis

(Price is a

function of

Efficiency)

From

Markups for

Equipment

Price

Determination

From Energy

Use Analysis

(Use is a

function of

Efficiency)
Building Technologies Program 74 eere.energy.gov

Energy Prices

• Electricity prices are used to convert energy use to energy costs. 

• DOE will use projections of national average energy prices for 

residential customers – from the most recent EIA Annual Energy 

Outlook (AEO) – to forecast future energy prices for the LCC analysis.

Issue #35: DOE welcomes input on the proposed methodology 

for estimating current and future electricity prices.
Building Technologies Program 75 eere.energy.gov

Life-Cycle Cost Discount Rates

• DOE uses the discount rate to determine the present value of lifetime 

operating expenses.

• DOE will derive a distribution of discount rates for the residential sector.

– These distributions will be developed by estimating the weighted average 

cost of capital (WACC) for residential consumers of set-top boxes.

– WACC includes:

• Financial cost of any debt incurred to purchase products. 

• Opportunity cost of any equity to purchase products.

Issue #36: DOE welcomes input on the proposed approaches 

for estimating discount rates for consumers of set-top boxes 

covered under this rulemaking.
Building Technologies Program 76 eere.energy.gov

Installation, Maintenance, and Repair 

Costs

• DOE will evaluate how installation, maintenance, and repair costs change 

with increased efficiency, if applicable. 

• DOE does not currently have information indicating that installation, routine 

repair, and maintenance costs are different for more efficient set-top boxes.
Building Technologies Program 77 eere.energy.gov

Set-top Box Lifetimes

• DOE will use information from:

– Manufacturer literature, 

– Various literature sources such as technical reports and conference 

proceedings, and 

– Inputs from manufacturers and other interested parties. 

• DOE uses a distribution of lifetimes, based on the data available.

• For set-top boxes, will need to consider equipment returns and 

refurbishments when estimating total lifetimes

Issue #37: DOE welcomes comment and data on appropriate 

set-top lifetimes. DOE also welcomes comment on how returns 

and refurbishments impact total set-top lifetimes. 
Building Technologies Program 78 eere.energy.gov

Steps in the Standards Rulemaking: 

Notice of Proposed Rulemaking

Market & 

Technology 

Assessment

Screening 

Analysis

Engineering

Analysis

Energy Use 

Characterization

Shipments

Analysis

National

Impact

Analysis

Markups for 

Product Price 

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Framework 

Public 

Meeting

NOPR Final

Rule

Effective

Date

Life-Cycle 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Utility 

Impact 

Analysis

Employment 

Impact 

Analysis

Emissions 

Analysis

Monetization 

of Emissions

Regulatory 

Impact 

Analysis
Building Technologies Program 79 eere.energy.gov

Shipment Analysis

Purpose

• To estimate set-top shipments in the base case and standards 

cases

Method

• The shipments model will rely on a range of data sources e.g.:

– Manufacturers and industry organizations; 

– National market research reports; 

– National energy and set-top box use surveys. 
Building Technologies Program 80 eere.energy.gov

Shipments model - Methodology

• Option 1: Accounting methodology

– New Installations: New STBs that are installed each year due to 

equipment growth in new housing. DOE proposes to determine this 

by using the EIA AEO 2011 projection of new housing starts.

– Replacements: STBs that have failed. DOE bases this calculation on 

equipment sales and retirement rates. 

– Retrofits (early replacements): STBs replacing existing STBs during 

repair/update of equipment. This replacement may occur before the 

original STB has failed.

• Option 2: Model driven by total forecasted growth

– Shipments model top-down, based on total shipments projections. 

Total shipments can be correlated to total housing projections or total 

population projections. This generally results in a changing household 

saturation of STBs.
Building Technologies Program 81 eere.energy.gov

Base-Case Shipments Forecast 

Approach

• Provides the basis to compare forecasts for higher efficiency levels 

(standards case)

• Depicts the situation where new or amended standards are not 

adopted.

• Depicts the current and forecasted mix of STB efficiencies sold in 

the absence of new regulation.

– DOE will develop projected market shares of products by efficiency 

under the base case. 

– DOE will use data on recent market trends in STB efficiency, as well 

as efficiency distributions based on available models and information 

from STB experts, as a proxy.

• Data requirements:

– Historical shipments.

– Breakdown of shipments product class.

– Market share efficiency data 
Building Technologies Program 82 eere.energy.gov

Standards Impacts on STB 

Shipments

• DOE develops Standards-Case Forecasts from the same data it 

will use to develop the Base-Case Forecast.

• Standards-Case Forecasts may also use purchase price increases 

and operating cost savings to estimate shipments impacts (noninteractive effects).

• DOE is interested in cross-elasticity between different STB product 

classes covered in this rulemaking (interactive effects).

• DOE will also consider impacts from market-pull programs.
Building Technologies Program 83 eere.energy.gov

Request for comment

Issue #38: DOE welcomes recommendations on data sources for 

shipments of STBs by different product classes and long-term trends 

in STB shipments.

Issue #39: DOE welcomes comment on the shipment forecasting 

methodologies described above for each product class covered in this 

rulemaking. DOE also invites comments regarding the stock of STBs 

in use.

Issue #40: DOE welcomes comment on how any standard for STBs 

might impact shipments of these STBs, as well as interactions 

between various STB product classes. DOE also invites information 

about market-pull programs that promote the adoption of moreefficient STBs.
Building Technologies Program 84 eere.energy.gov

Steps in the Standards Rulemaking: 

Notice of Proposed Rulemaking

Market & 

Technology 

Assessment

Screening 

Analysis

Engineering

Analysis

Energy Use 

Characterization

Shipments

Analysis

National

Impact

Analysis

Markups for 

Product Price 

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Framework 

Public 

Meeting

NOPR Final

Rule

Effective

Date

Life-Cycle 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Utility 

Impact 

Analysis

Employment 

Impact 

Analysis

Emissions 

Analysis

Monetization 

of Emissions

Regulatory 

Impact 

Analysis
Building Technologies Program 85 eere.energy.gov

National Impact Analysis

Purpose

• To assess the aggregate impacts at the national level of potential 

energy conservation standards for each of the product classes, in 

terms of net present value of total consumer economic impacts 

and national energy savings.

Method

• DOE calculates annual equipment expenditures by multiplying 

the price per unit by forecasted shipments. Operating expenses 

for each unit are tracked every year over the course of its 

lifetime.

• The difference between base- and standards-case scenarios 

gives the national energy bill savings and increased expenditure 

in dollars.

• The difference each year between energy bill savings and 

increased equipment expenditures is the net savings (if positive) 

and net costs (if negative).
Building Technologies Program 86 eere.energy.gov

National Energy Savings Flow 

Diagram

Base Case

Annual Energy

Consumption

2048

Base Case

Annual Energy

Consumption

2021

Base Case

Annual Energy

Consumption

2020

Base Case

Annual Energy

Consumption

2019

Shipments

Analysis StandardsCase Projection

Base-Case 

Projection

Base Case

Annual Energy

Consumption

2048

Base Case

Annual Energy

Consumption

2021

Base Case

Annual Energy

Consumption

2020

Standards Case

Annual Energy

Consumption

2019

Base-Case

Cumulative

Energy Use

Standards-Case 

Cumulative

Energy Use

Site to Full-Fuel

Cycle

Energy

Conversion

National Energy

Savings
Building Technologies Program 87 eere.energy.gov

National Consumer Net Present 

Value Flow Diagram

Shipments

Analysis StandardsCase Projection

Energy

Cost

(2019 –

2048)

Base-Case 

Projection

Cumulative

Operating Cost 

Savings

Cumulative

Total Equipment

Cost Increase

Discount 

Rate

Net Present

Value

Rep, Maint,

Cost

(2019 –

2048)

Total Install 

Cost

(2019 –

2048)

Energy

Cost

(2019 –

2048)

Rep, Maint,

Cost

(2019 –

2048)

Total Install

Cost

(2019 –

2048)
Building Technologies Program 88 eere.energy.gov

Calculation of National Energy 

Savings

• DOE intends to calculate national energy consumption for each 

year beginning with the expected compliance date of the 

standards and over a 30 year period.

• DOE will use the DOE National Energy Savings (NES) 

spreadsheet for standard rulemakings.

Issue #41: DOE welcomes comment on the NES spreadsheet models 

it proposes to use for estimating national impacts of energy 

conservation standards for STBs.
Building Technologies Program 89 eere.energy.gov

Steps in the Standards Rulemaking: 

Notice of Proposed Rulemaking

Market & 

Technology 

Assessment

Screening 

Analysis

Engineering

Analysis

Energy Use 

Characterization

Shipments

Analysis

National

Impact

Analysis

Markups for 

Product Price 

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Framework 

Public 

Meeting

NOPR Final

Rule

Effective

Date

Life-Cycle 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Utility 

Impact 

Analysis

Employment 

Impact 

Analysis

Emissions 

Analysis

Monetization 

of Emissions

Regulatory 

Impact 

Analysis
Building Technologies Program 90 eere.energy.gov

Life-Cycle Cost Subgroup Analysis

Purpose

• Analyze the economic impacts of standards on consumers, 

including subgroups who may be disproportionately impacted 

compared with the general user population.

– A subgroup comprises a subset of the population likely to be 

disaffected disproportionately by new or revised energy 

conservation standards (e.g., low-income households, seniors).

Method

• Extend the LCC analysis to examine the impacts for defined 

subgroups.

• DOE will use inputs specific to each of the considered consumer 

subgroups.
Building Technologies Program 91 eere.energy.gov

Steps in the Standards Rulemaking: 

Notice of Proposed Rulemaking

Market & 

Technology 

Assessment

Screening 

Analysis

Engineering

Analysis

Energy Use 

Characterization

Shipments

Analysis

National

Impact

Analysis

Markups for 

Product Price 

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Framework 

Public 

Meeting

NOPR Final

Rule

Effective

Date

Life-Cycle 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Utility 

Impact 

Analysis

Employment 

Impact 

Analysis

Emissions 

Analysis

Monetization 

of Emissions

Regulatory 

Impact 

Analysis
Building Technologies Program 92 eere.energy.gov

Manufacturer Impact Analysis

Purpose

• Assess the impacts of standards on manufacturers. 

• Identify and estimate impacts on manufacturer subgroups that 

may be more severely impacted than the industry as a whole.

• Examine the impact of cumulative regulatory burden on the 

industry.

Method

• Analyze industry cash flow and net present value through use of 

the Government Regulatory Impact Model (GRIM).

• Interview manufacturers to refine inputs to the GRIM, develop 

subgroup analyses, and address qualitative issues.

Output

• Industry NPV impacts

• Subgroup NPV impacts

• Direct employment impacts
Building Technologies Program 93 eere.energy.gov

Steps in the Standards Rulemaking: 

Notice of Proposed Rulemaking

Market & 

Technology 

Assessment

Screening 

Analysis

Engineering

Analysis

Energy Use 

Characterization

Shipments

Analysis

National

Impact

Analysis

Markups for 

Product Price 

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Framework 

Public 

Meeting

NOPR Final

Rule

Effective

Date

Life-Cycle 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Utility 

Impact 

Analysis

Employment 

Impact 

Analysis

Emissions 

Analysis

Monetization 

of Emissions

Regulatory 

Impact 

Analysis
Building Technologies Program 94 eere.energy.gov

Utility Impact Analysis

Purpose

• Assess the overall impacts on domestic energy supplies that 

would result from the imposition of standards. 

• DOE will model the energy savings impacts from amended 

energy conservation standards using NEMS-BT, developed and 

used by DOE/EIA for the AEO report, to generate forecasts that 

deviate from the AEO reference case.

• Outputs of the utility impact analysis include forecasts of 

electricity generation, and avoided capacity resulting from a 

comparison of base and standards cases.

Method
Building Technologies Program 95 eere.energy.gov

Steps in the Standards Rulemaking: 

Notice of Proposed Rulemaking

Market & 

Technology 

Assessment

Screening 

Analysis

Engineering

Analysis

Energy Use 

Characterization

Shipments

Analysis

National

Impact

Analysis

Markups for 

Product Price 

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Framework 

Public 

Meeting

NOPR Final

Rule

Effective

Date

Life-Cycle 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Utility 

Impact 

Analysis

Employment 

Impact 

Analysis

Emissions 

Analysis

Monetization 

of Emissions

Regulatory 

Impact 

Analysis
Building Technologies Program 96 eere.energy.gov

Employment Impact Analysis

Purpose

• Assess the overall impact on national employment from the imposition 

of energy conservation standards at differing levels.

• Include both direct and indirect employment impacts.

– Direct employment impacts are estimated in the manufacturer impact 

analysis.

– Indirect employment impacts result from shifting consumer expenditures 

among goods and services ( “substitution effect”) and changing equipment 

and energy costs (“income effect”).

Method

• DOE intends to use the Impact of Sector Energy Technologies (ImSET) 

model for the evaluation of indirect employment impacts. (Note: ImSET

is an update of IMBUILD.)
Building Technologies Program 97 eere.energy.gov

Steps in the Standards Rulemaking: 

Notice of Proposed Rulemaking

Market & 

Technology 

Assessment

Screening 

Analysis

Engineering

Analysis

Energy Use 

Characterization

Shipments

Analysis

National

Impact

Analysis

Markups for 

Product Price 

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Framework 

Public 

Meeting

NOPR Final

Rule

Effective

Date

Life-Cycle 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Utility 

Impact 

Analysis

Employment 

Impact 

Analysis

Emissions 

Analysis

Monetization 

of Emissions

Regulatory 

Impact 

Analysis
Building Technologies Program 98 eere.energy.gov

Emissions Analysis

Purpose

• To report environmental impacts resulting from amended energy 

conservation standards, from changes in power plant emissions. 

Method

• DOE intends to use the environmental impacts projected from the 

NEMS-BT modeling analysis used for the Utility Impacts Analysis. 

– Carbon dioxide (CO2) will be the primary emissions reported.

– Mercury (Hg) emissions will also be reported.

– Nitrogen Oxide (NOx) emissions will be reported for the 22 states 

where emissions are not capped.

– Existing legislation cap Sulfur Dioxide (SO2), so physical emission 

reductions will be zero or nearly zero from any single energy 

conservation standard. 

• The emissions analysis will include a monetization of reduced emissions.

• Monetization values are based on most recent interagency reviews.
Building Technologies Program 99 eere.energy.gov

Steps in the Standards Rulemaking: 

Notice of Proposed Rulemaking

Market & 

Technology 

Assessment

Screening 

Analysis

Engineering

Analysis

Energy Use 

Characterization

Shipments

Analysis

National

Impact

Analysis

Markups for 

Product Price 

Determination

Life-Cycle

Cost and

Payback 

Period Analysis

Framework 

Public 

Meeting

NOPR Final

Rule

Effective

Date

Life-Cycle 

Subgroup 

Analysis

Manufacturer 

Impact 

Analysis

Utility 

Impact 

Analysis

Employment 

Impact 

Analysis

Emissions 

Analysis

Monetization 

of Emissions

Regulatory 

Impact 

Analysis
Building Technologies Program 100 eere.energy.gov

Regulatory Impact Analysis

Purpose

• To investigate the national impacts of non-regulatory alternatives 

compared with mandatory energy conservation standards.

• The non-regulatory alternatives that may be considered include: 

– Consumer rebates; 

– Consumer tax credits; 

– Manufacturer tax credits; 

– Voluntary efficiency targets; 

– Early replacement; and

– Bulk government procurement.

Method

• Modify NES spreadsheet model to consider non-regulatory scenarios.

• Estimate impacts of non-regulatory scenarios based on experience with 

the considered policies.

• Output will include National Energy Savings and Net Present Value of 

the non-regulatory alternatives.
Building Technologies Program 101 eere.energy.gov

Request for Comment

Issue #42: DOE welcomes feedback and comments on any aspects of 

the Life-Cycle Subgroup Analysis, Manufacturer Impact Analysis, 

Utility Impact Analysis, Employment Impact Analysis, Emissions 

Analysis and Monetization, and/or Regulatory Impact Analysis.
Building Technologies Program 102 eere.energy.gov

Rulemaking Analyses

Closing Remarks

Public Meeting Agenda

4

5

2 Rulemaking Overview

3

1 Introduction

Test Procedure Rulemaking Overview
Building Technologies Program 103 eere.energy.gov

Feedback Is Requested 

Especially on Items Identified in Request for Information

• In all correspondence, please refer to the Set-top Boxes rulemaking by:

– Set-top Boxes Rulemaking,

– Docket Number EERE–2011–BT–NOA–0067, and

– Regulatory Identification Number (RIN) 1904-AC52

• Email: STB-RFI-2011-NOA-0067@ee.doe.gov 

• Comment period closes: March 15, 2012

Postal: Hand Delivery/Courier:

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program, Mailstop EE-2J

1000 Independence Avenue, SW

Washington, DC 20585-0121

Ms. Brenda Edwards

U.S. Department of Energy

Building Technologies Program, Suite 600

950 L’Enfant Plaza, SW

Washington, DC 20024

Tel: 202-586-2945
Building Technologies Program 104 eere.energy.gov

Relevant URLs

• DOE Appliance Standards

– http://www1.eere.energy.gov/buildings/appliance_standards/

• STBs & Network Equipment Rulemaking and Test Procedure

– http://www1.eere.energy.gov/buildings/appliance_standards/residential/

set_top_boxes.html

• Regulations.gov Rulemaking Docket

– http://www.regulations.gov/ • RFI) Docket ID# EERE-2011-BT-NOA-0067-0001

• Determination) Docket ID# EERE-2010-BT-DET-0040-0001
Building Technologies Program 105 eere.energy.gov

DOE Project Manager

Mr. Jeremy Dommu

Jeremy.Dommu@ee.doe.gov

(202) 586-9870

Building Technologies Program, Mailstop EE-2J

1000 Independence Avenue, SW

Washington, DC 20585-0121

DOE General Counsel

Ms. Celia Sher

Celia.Sher@hq.doe.gov

(202)-287-6122

Office of General Counsel, Mailstop GC-71

1000 Independence Avenue

SW., Washington, DC 20585–0121

Contact Information