## Energy Conservation Standards Rulemaking Framework for Computer and Battery Backup System s

U.S. Department of Energy
Office of Energy Efficiency and Renewable Energy

Building Technologies Office

July 9, 2014i TA BLE OF CONTENTS

1. Introduction

................................ ................................ ................................ ............................ 1 1.1 Authority and Background

................................ ................................ ................................ .. 1 1.2 Ene rgy Savings Opportunity

................................ ................................ ............................... 3 1.2.1 Energy Consumption of Computers

................................ ................................ ................. 3 1.2.2 Energy Consumption of Computer Servers

................................ ................................ ..... 6 1.2.3 Energy Consumption of Uninterruptible Power Supplies

................................ ............... 6 1.2.4 Technology Options for Improved Efficiency

................................ ................................ . 7 2. Overview of the Rulemaking Process

................................ ................................ .................... 7 2.1 Test Procedures

................................ ................................ ................................ ................... 7 2.2 Energy Conservation Standards

................................ ................................ .......................... 7 2.2.1 Preliminary Analysis

................................ ................................ ................................ ........ 9 2.2.2 Notice of Proposed Rulemaking

................................ ................................ .................... 10 2.2 .3 Final Rule

................................ ................................ ................................ ..................... 11 2.2.4 Overview of Analyses for Rulemaking

................................ ................................ .......... 12 3. Scope of Coverage

................................ ................................ ................................ ............... 14 3.1 Definition of Computers

................................ ................................ ................................ ... 14 3.2 Definition of Computer Servers

................................ ................................ ........................ 15 3.3 Definition of Uninterruptible Power S upplies

................................ ................................ .. 16 3.4 Scope of Computer Systems Test Procedure and Standards Rulemakings

...................... 16 3.4.1 Computers

................................ ................................ ................................ ..................... 17 3.4.2 Computer Servers

................................ ................................ ................................ ........... 19 3.4.3 Uninterruptible Power Supplies

................................ ................................ ..................... 21 4. Test Procedures

................................ ................................ ................................ .................... 23 4.1 Methods of Measurement for Computers

................................ ................................ ......... 23 4.1.1 Existing Industry and Regulatory Test Procedures

................................ ........................ 23 4.1.2 Proposed DOE Test Method for Computers

................................ ................................ .. 24 4.1.3 Annual Energy Consumption Metric

................................ ................................ ............. 25 4.1.4 Ann ual Energy Consumption Metric for Computers with a Network Proxy

................ 26 4.2 Methods of Measurement for Computer Servers

................................ .............................. 27 4.2.1 Exist ing Regulatory and Voluntary Test Procedures

................................ ..................... 27 4.2.2 Proposed DOE Test Method for Computer Servers

................................ ...................... 28 4.3 Methods of Measurement for Uninterruptible Power Supplies

................................ ........ 30 4.3.1 Existing Industry Test Procedures

................................ ................................ ................. 30 4.3.2 Proposed DOE Test Method for Uninterruptibl e Power Supplies

................................ . 31 5. Product Classes

................................ ................................ ................................ .................... 31 5.1 Computer Product Classes

................................ ................................ ................................ 32 5.1.1 Existing Voluntary and Regulatory Standards

................................ ............................... 32 5.1.2 ENERGY STAR Computers V. 5.2 Product Overview

................................ ................ 32 5.1.3 ENERGY ST AR Computers V. 6.0

................................ ................................ ............... 35 5.2 Computer Server Product Classes

................................ ................................ ..................... 37 5.3 Uninterruptible Power Supplies Product Classes

................................ ............................. 38 6. Market and Technology Assessment

................................ ................................ ................... 40 6.1 Market Assessment

................................ ................................ ................................ ........... 40ii

6.1.1 Market Asse ssment for Computers

................................ ................................ ................ 41 6.1.2 Market Assessment for Computer Servers

................................ ................................ .... 41 6.1.3 Market Assessment for Uninterruptible Power Supplies

................................ ............... 42 6.2 Technology Assessment for Computers

................................ ................................ ........... 43 6.2.1 Efficient Power Supplies

................................ ................................ ................................ 44 6.2.2 Efficient Hard Drives

................................ ................................ ................................ ..... 44 6.2.3 Energy

- Efficient Ethernet

................................ ................................ .............................. 45 6.2.4 Passive Cooling

................................ ................................ ................................ .............. 45 6.2.5 ACPI

- Compatible Devices

................................ ................................ ............................. 45 6.2.6 Switchable Graphics

................................ ................................ ................................ ...... 45 6.2.7 Dynamic Voltage and Freq uency Scaling

................................ ................................ ...... 46 6.2.8 Resilient Circuitry

................................ ................................ ................................ .......... 46 6.2.9 Clock Gating

................................ ................................ ................................ .................. 46 6.2.10 CPU Utilization Management

................................ ................................ ........................ 47 6.2.11 Suspended State to Flash

................................ ................................ ............................... 47 6.2.12 Internal Network Proxy

................................ ................................ ................................ .. 47 6.3 Technology Assessment for Computer Servers

................................ ................................ 47 6.3.1 Fan Speed Control Algorithms

................................ ................................ ...................... 48 6.3 .2 Management Interface Low

- Power States

................................ ................................ ..... 48 6.4 Technology Assessment for Uninterruptible Power Supplies

................................ .......... 48 6.4.1 Semiconductor Im provements

................................ ................................ ....................... 48 6.4.2 Digital Signal Processing and Space Vector Modulation

................................ .............. 49 6.4.3 Transformer

- less UPS Topologies

................................ ................................ ................. 49 7. Screening Analysis

................................ ................................ ................................ ............... 49 8. Engineering Analysis

................................ ................................ ................................ ........... 50 8.1 Engineering Analysis Ov erview

................................ ................................ ....................... 51 8.2 Engineering Analysis Methodology

................................ ................................ ................. 52 8.2.1 Representative Units and Baseline Models

................................ ................................ .... 52 8.3 Proprietary Designs

................................ ................................ ................................ ........... 53 8.4 Efficiency Levels

................................ ................................ ................................ .............. 53 8.5 Outside Regulatory Changes Affecting the Engineering Analysis

................................ ... 54 9. Markups Analysis

................................ ................................ ................................ ................ 54 10. Energy Use Analysis

................................ ................................ ................................ ............ 55 11. Life

- Cycle Cost and Payback Period Analyses

................................ ................................ ... 56 11.1 Approach

................................ ................................ ................................ ........................... 56 11.2 Electricity Prices

................................ ................................ ................................ ............... 58 11.3 Maintenance, Repair, and Installation Costs

................................ ................................ ..... 59 11.4 Product Lifetimes

................................ ................................ ................................ .............. 59 11.5 Discount Rat es

................................ ................................ ................................ .................. 59 11.6 Energy Efficiency in the Base Case

................................ ................................ .................. 60 12. Shipments Analysis

................................ ................................ ................................ .............. 61 12.1 Base

- Case Forecast

................................ ................................ ................................ ........... 61 12.2 Impact of Standards on Product Shipments

................................ ................................ ...... 61 13. National Impact Analysis

................................ ................................ ................................ ..... 62 13.1 Energy Efficiency Trends

................................ ................................ ................................ . 62 13.2 National Energy Savings

................................ ................................ ................................ ... 63iii

13.3 Net Present Value

................................ ................................ ................................ ............. 63 14. Consumer Subgroup Analysis

................................ ................................ .............................. 64 15. Manufacturer Impact Analysis

................................ ................................ ............................. 64 15.1 Sources of Information for the Manufacturer Impact Analysis

................................ ........ 65 15.2 Industry Cash Flow Analysis

................................ ................................ ............................ 65 15.3 Manufact urer Subgroup Analysis

................................ ................................ ..................... 66 15.4 Competitive Impacts Assessment

................................ ................................ ..................... 66 15.5 Cumulative Regulatory Burden

................................ ................................ ........................ 67 16. Emissions Analysis

................................ ................................ ................................ .............. 67 17. Monetizing Reduced Carbon Dioxide and other Emissions

................................ ................ 69 18. Utli ty Impact Analysis

................................ ................................ ................................ ......... 70 19. Employment Impact Analysis

................................ ................................ .............................. 71 20. Regulatory Impact Analysis

................................ ................................ ................................ . 72 Appendix A. Scope of Industry Standards

................................ ................................ ................ 73 Appendix B. List of Items for Comment

................................ ................................ .................. 76iv

LIST OF FIGURES Figure 1

- 1: Histogram showing Normalized Energy Consumption of ENERGY STAR Qualified Desktop Computers after January 1, 2012

................................ ................................ ...................... 4 Figure 1

- 2: Histogram showing Normalized Ene rgy Consumption of ENERGY STAR Qualified Integrated Desktop Computers after January 1, 2012

................................ ................................ ..... 5 Figure 1

- 3: Histogram showing Normalized Energy Consumption of ENERGY STAR Qualified Notebooks afte r January 1, 2012

................................ ................................ ................................ .... 5 Figure 2

- 1: Flow Diagram of Analyses for a Traditional Standards Rulemaking Process

........... 13 Figure 6

- 1: Current and Projected Device Shipments by Year

................................ ..................... 41 Figure 6

- 2: Worldwide Quarterly Server Shipments (3Q12 to 3Q13)

................................ ......... 42 Figure 6

- 3: World UPS Ma rket Development

................................ ................................ .............. 43

LIST OF TABLES

Table 1

- 1: Estimated U.S. Energy Use of Computer Servers in 2010

................................ ............ 6

Ta ble 4

- 1: ENERGY STAR Computers V. 6.0 Modal Weightings, based on ECMA

- 383 Ed. 3 25

Table 4

- 2: ENERGY STAR Computers V. 6.0 Modal Weightings with Proxy for Desktop, Integrated Desktop, and Thin Client Computers

................................ ................................ .......... 26

Table 4

- 3: ENERGY STAR Computers V. 6.0 Modal Weightings with Proxy for Notebook Computers

................................ ................................ ................................ ................................ ..... 26

Table 5

- 1: ENERG Y STAR Computers V. 5.2 Categories for Desktop, Integrated Desktop, and Notebook Computers

................................ ................................ ................................ .................... 33

Table 5

- 2: ENERGY STAR Computers V. 5.2 Allowance Classification

................................ ... 34

Table 5

- 3: ENERGY STAR Computers V. 5.2 Categories for Small

- scale Servers and Thin Clients

................................ ................................ ................................ ................................ ........... 35

Table 5

- 4: ENERGY STAR Computers V. 6.0 Base Categories for Deskto p and Integrated Desktop Computers

................................ ................................ ................................ ....................... 36

Table 5

- 5: ENERGY STAR Computers V. 6.0 Base Categories for Notebook Computers

........ 36

Table 5

- 6: ENERGY STAR Computers V. 6.0 Discrete Graphics Allowance

............................ 36

Table 5

- 7: ENERGY STAR Computer Servers V. 2.0 Categories

................................ ............... 38

Table 5

- 8: ENERGY STAR UPS V. 1.0 Efficiency Levels for AC

- Output UPS

........................ 39

Table 5

- 9: ENERGY STAR UPS V. 1.0 Efficiency Levels for DC

- Output UPS

........................ 40

Table A

- 1: ENERGY STAR Computers V. 5.2 Scope of Coverage

................................ ............ 73

Table A

- 2: Scope Updates in ENERGY STAR Computers V. 6.0 from V. 5.2

........................... 73

Table A

- 3: Differences in Scope of Coverage for Regulatory Programs

................................ ..... 74

Table A

- 4: ENERYGY STAR Computer Servers V. 2.0 Scope of Coverage

............................. 74v

LIST OF A CRONYMS AND ABBREVIATIONS

AC alternating current
ACEEE American Council for an Energy

- Efficient Economy ACPI Advanced Configuration and Power Interface AEC annual energy consumption
AEDM alternate efficiency determination method AEO Annual Energy Outl ook
AMD Advanced Micro Devices
APPA American Public Power Association ASAP The Appliance Standards Awareness Project AS/NZS Australian/New Zealand standard BIOS basic input/output system BOM bill of materials
BT O Building Technologies Office BOB bu ffered on board
BW bandwidth CEA Consumer Electronics Association CFR Code of Federal Regulations CPU central processing unit CSAPR Cross

- State Air Pollution Rule CSL candidate standard level DC direct current
DIMMs dual in

- line memory modules DO E U.S. Department of Energy DOJ U.S. Department of Justice DSP digital signal processing
DVD digital video disc
DVR digital video recorder ECC error

- correcting code
EEE Energy

- Efficient Ethernet
EEI Edison Electric Institute
EERE Office of Energy E fficiency and Renewable Energy EGU electric generating units
EIA Energy Information Administration
EMI electromagnetic interference
EPA U.S. Environmental Protection Agency EPCA Energy Policy and Conservation Act
EU European Union FFC full fuel cycl e FOIA Freedom of Information Actvi

FR Federal Register GB gigabyte GHG greenhouse gas GPU graphics processing unit

GREET Greenhouse Gases, Regulated Emissions, and Energy Use in

Transportation GRIM government regulatory impact model
HAP hazardous ai r pollutants
HDD hard disk drive
IBM International Business Machines Corporation IDC International Data Corporation IEC International Electrotechnical Commission
IEEE Institute of Electrical and Electronics Engineers IGBT insulated gate bipolar trans istors ImSET Impact of Sector Energy Technologies
ITI Information Technology Industry Council kWh kilo

- watt hours
LBNL Lawrence

- Berkeley National Laboratory LCC life

- cycle cost MATS Mercury and Air Toxics Standards
MIA manufacturer impact analysis MSP manufacturer selling price NCI Navigant Consulting, Inc. NEEA Northwest Energy Effici enc y Alliance
NEEP Northeast Energy Efficiency Partnerships NEMA The National Electrical Manufacturers Association NEMS National Energy Modeling System NES natio nal energy savings NIA national impact analysis NOPD notice of proposed determination NOPR notice of proposed rulemaking
NPV net present value NRDC Natural Resources Defense Council OMB U.S. Office of Management and Budget OS operating system
PBP p ayback period
PDA personal digital assistant
PM particulate matter POS point of sale PSU power supply unit R&D research and developmentvii

RIA regulatory impact analysis
RPM rotations per minute SCC social cost of carbon SCR silicon controlled rectif ier SERT Server Efficiency Rating Tool SPEC Standard Performance Evaluation Corporation SSD solid

- state drive SVM space vector modulation TCO total cost of ownership
TIA Telecommunications Industry Association TSD technical support document TSL tri al standard level UPS u ninterruptible power supply U.S.C. United States Code
VFD voltage and frequency dependent
VFI voltage and frequency independent
VI voltage independent WOL wake

- on

- LAN1

1. INTRODUCTION

The U.S. Department of Energy (DOE) Applia nces and Equipment Standards Program, within the Office of Energy Efficiency and Renewable Energy’s Building Technologies Office (BT O ), establishes test procedures and energy conservation standards for certain consumer appliances and commercial and industr ial equipment. The process for considering whether to establish standards involves analysis, public notice and comment, and consultation with interested parties. Interested parties include manufacturers, consumers, energy conservation and environmental adv ocates, s tate and f ederal agencies, and any other groups or individuals with an interest in these standards and test procedures.

The purpose of this document is to describe the procedural and analytical approaches DOE anticipates using to evaluate potentia l new energy conservation standards or energy use standards for computer and battery backup systems (computer systems) . This framework document is intended to inform interested parties of the process DOE will follow for this standards rulemaking

, and to en courage and facilitate the input of interested parties during the rulemaking. This document is merely the starting point for evaluating energy conservation standards or energy use standards and is not a definitive statement on any issue to be determined in the rulemaking.

Section 1 of this report includes an overview of DOE’s appliances standards program, the statutory authority for this rulemaking, and the energy savings opportunity through this rulemaking. Sect ion 2 includes an overview of the rulemaking process. S cope of coverage and test procedures are described in section s 3 and 4 . Sections 5 through 20 discuss the analyses DOE intends to conduct to fulfill the statutory requirements and guidance for this energy conservation standards rule making. DOE’s analys e s will determine whether new energy conservation standards or energy use standards are technologically feasible, economically justified, and would result in significant energy savings. DOE will maintain information about this rulemakin g on its website at: www1.eere.energy.gov/buildings/appliance_standards/product.aspx/productid/81

.

While DOE invites comment on all aspects of the material presented in this document, several specific issues on which DOE seeks comment are set out in comment boxes like this one. DOE uses these comment boxes to highlight issues and ask specific questions on the approaches DOE plans to follow to conduct the ana lyses required for the energy conservation standards rulemaking. Such requests for feedback are numbered sequentially throughout the document and are repeated in Appendix A.

1.1 Authority and Background

Title III of the Energy Policy and Conservation Act of 19 75 ( EPCA ) sets forth a variety of provisions designed to improve the energy efficiency of various products and equipment.2

Part B of Title III (42 U.S.C. 6291

– 6309) established the “Energy Conservation Program for Consumer Products Other Than Automobiles,” which covers consumer products and certain commercial equipment (hereafter referred to as “covered products”). 1 In addition to specifying a list of covered residential and commercial products, EPCA contains provisions that enable the Secretary of Energy (S ecretary) to classify additional types of consumer products as covered products. (42 U.S.C. 6292(a)(20)) For a given product to be classified as a covered product, the Secretary must determine that:

(1) Classifying products of such type as covered products is necessary or appropriate to carry out the purposes of EPCA, and

(2) Average annual per

- household energy use by products of such type is likely to exceed 100 kilowatt

- hours (kW h ) per year. (42 U.S.C. 6292(b)(1))

Under this authority, DOE published a notice of p roposed determination (NOPD) on February 28, 2014 (the February 2014 NOPD) that tentatively determine d that computer systems meet the criteria for a covered product because classifying products of such type as a covered product is necessary or appropriate to carry out the purposes of EPCA, and the average U.S. household energy use for computer s ystems is likely to exceed 100 kWh per year. 7 9 FR 11345

. Computers, computer systems, and uninterruptable power supplies (UPSs) are considered in the scope of the F ebruary 2014 NOPD

. For any product that DOE classifies as a covered product, it may prescribe test procedures. (42 U.S.C. 6293(b)) EPCA also specifies that the Secretary may prescribe an energy conservation standard pursuant to 42 U.S.C. 6295(o) and (p) fo r covered products added pursuant to 42 U.S.C. 6292(b)(1), if the Secretary determines that:

(1) The average household energy use of the products has exceeded 150 kWh per household for a 12

- month period;

(2) The aggregate 12

- month energy use of the products has ex ceeded 4.2 billion kWh;

(3) Substantial improvement in energy efficiency is technologically feasible; and

(4) The application of a labeling rule under 42 U.S.C. 6294 is un likely to be sufficient to induce manufacturers to produce, and consumers and other persons t o purchase, covered products of such type (or class) which achieve the maximum energy efficiency which is technologically feasible and economically justified. (42 U.S.C. 6295(l)(1))

Because DOE has tentatively determined that computer s ystems are a covered product and meet the statutory thresholds for setting energy conservation standards

, DOE is undertaking this rulemaking process , including the publication of this framework document, to meet the

1 Part B was re

- designated Part A on codification in the U.S. Code for editorial reasons.3

above described EPCA requirements. This framework document a nd the associated public meeting represent the first step in the rulemaking process to consider whether to establish a test procedure and energy conservation standard for computer systems

. DOE recognizes that different test methods and efficiency metrics w ould be necessary to measure the energy consumption and energy efficiency of different product types such as computers, computer servers, and UPSs. Therefore, DOE is considering different test procedures for computers, servers, and UPSs as discussed in sec tion 3 of this framework document

. Additionally, for the efficiency standards rulemaking, product classes may be established based on the type of energy used, the capacity, and any other performance

- related feat ure that justifies different standard levels, such as features affecting consumer utility. (42 U.S.C. 6295(q))

1.2 Energy Savings Opportunity

DOE analyzed energy consumption data for computers

, computer servers , and UPSs to evaluate their energy saving opport unities . This investigation explore d the total energy consumption for each product as well as the range in energy consumption between comparable products.

1.2.1 Energy Consumption of Computers

In June 2014, t he Consumer Electronics Association (CEA) published a study that quantifies the electricity consumption of consumer electronics in US households in 2013. 2 Among other products, the study evaluated the annual electricity consumption of desktop and portable computers. While the annual electricity consumption h as decreased from 2010, according to the study, desktop computers consume 16 TWh/year and portable computers consumer 4.9 TWh/year. The CEA study considered t he ENERGY STAR ® Version 6.0 Specification for Computers, Rev. October 2013 (ENERGY STAR Computers V. 6.0) dataset to represent computers sold from 2011 to 2013, and data from a previous study (Fraunhofer 2011) to represent older computers.

To further evaluate the energy consumption profile of computers, DOE used the ENERGY STAR qualified product list f or computers 3 and focused its analysis on products that were available on the market after January 1, 2012

, because newer computers have the latest features in terms of functionality and energy saving options

. Figure 1

- 1 through Figure 1

- 3 show the variation in energy consumption for desktop, integrated desktop, and notebook computers in each product category
, as classified by ENERGY STAR Version 5.2 Specification for Comput ers , Rev. August 2010 (ENERGY STAR Computers V. 5.2)

. 4 DOE also normalized data

2 Energy Consumption of Consumer Electronics in US Homes in 2013. Fraunhofer USA, Final Repor t to the Consumer Electronics Association. June 2014.

3 ENERGY STAR Program Requirements for Computers, Qualified Computers, September 13, 2013

< http://downloads.energystar.gov/bi/qplist/Computers_Product_List.xls >

4 ENERGY STAR Program Requirements Produc t Specification for Computers: Eligibility Criteria Version 5.2 Rev. Aug

- 2010.4

available on ENERGY STAR’s qualified product list with respect to functional energy allowances to ensure that the variation in energy was due solely to differences in efficien cy of technologies, and not due to differen ces in additional functionality

. This variation is expressed in box and whisker plots which show the relative max imum and min imum annual energy consumption as well as the median value, the 25 th quartile, and the 7 5 th quartile. To calculate the normalized annual energy consumption ( A EC) 5 , DOE used the following equation:
( ) ( )

Figure 1

- 1 : Histogram show ing Normalized Energy Consumption of ENERGY STAR

Qualified Desktop Computers after January 1, 2012

5 ENERGY STAR uses the term “typical energy consumption (TEC),” which is referred to as “annual energy consumption (AEC)” in this document to conform to DOE convention.5

Figure 1

- 2 : Histogram showing Normalized Energy Consumption of ENERGY STAR

Qualified Integrated Desktop Com puters after January 1, 2012

Figure 1

- 3 : Histogram showing Normalized Energy Consumption of ENERGY STAR

Qualified Notebooks after January 1, 2012

As seen in Figure 1

- 1 through Figure 1

- 3 , the energy consumption of computers in most categories shows a significant variation . It is also important to note that the dataset for these graphs was limited to ENERGY STAR Computers V. 5 .2 qualified computers only, which comprise only a portion of the market . DOE expects the variation in energy consumption to be equal or larger if the entire market is analyzed.

Based on this analysis, DOE believes there are opportunities to improve the en ergy efficiency of computers.6

1.2.2 Energy Consumption of Computer Servers

DOE ’s investigation on the energy consumed by computer servers in the U.S. was based on a publication by the Analytic s Press, which estimated data center energy consumption from 2005

- 201 0

. 6 This analysis is summarized in Table 1

- 1 and shows a granular breakdown of energy usage by “cost level” . Additionally, t his data is separated into high and low energy estimates to account for the uncertainty in the average operating power of each computer server type. The low estimate assumes no increase in the average per

- server power consumption from 2005 to 2010 while the high estimate assumes an annual increase of 3.3%, 8.1%, and 6.7% for volume servers, mid

- range servers, and high

- end servers respectively.

Table 1

- 1 : Estimated U.S. Energy Use of Computer Servers in 2010

Server Type I nternational D ata

C orporation Definition: Server Cost is... Low Estimate (Billion kWh/year) High Estimate (Billion kWh/year)

Volume Less than $25,000 22.5 26.4

Mid

- range $25,000 to $500,000 1.7 2.5

High

- end Greater than $500,000 2.3 3.2

Total 26.5 32.1

DOE believes that due to the larger amount of energy consumed at lower price p oints, there are potential opportunities for significant energy savings with more efficient computer

servers

.
1.2.3 Energy Consumption of Uninterruptible Power Supplies

DOE’s review of UPSs has shown an estimated national energy consumption of 8.1 TWh/yr in 201 3 of which 3.5 TWh/yr is contributed by mixed use and residential only units. 7 The need to protect information technology infrastructure and the high cost of not doing so has pushed consumers to invest heavily in backup power. 8 This has contributed to the overall growth of the UPS market and its corresponding national energy usage. With the recent upward trend in cloud storage, the UPS market is expected to continue growing. 9 This fact leads DOE to recognize that this estimated total energy use is a lower l imit. DOE will conduct an engineering

6 Koomey , Jonathan. Growth in Data Center Electricity Use 2005

- 2010 . Analytics Press. 2011.

7 Analysis based on data compiled from (a) ENERGY STAR UPS Program Qualified Products List, (b) Zogg, R. et al., 2009. Energy Savings Potential and RD&D Opportunities for C ommercial Building Appliances and (c) TIAX, “U.S. Residential Information Technology Energy Consumption in 2005 and 2010, Final Report”. Prepared for the U.S. Department of Energy, Building Technologies Program, March 2006. Analysis includes only standby a nd line

interactive UPSs, and assumes an average load of approximately 0.7.

8 World Data Center UPS Market, Frost & Sullivan, December 1, 2011.

9 Meir Portnoy, Impact of Cloud Computing on UPS Market & Systems, March 2011

.7

and market analysis to understand if technologies exist to improve the efficiency of consumer UPSs and help reduce its energy burden.

1.2.4 Technology Options for Improved Efficiency

DOE has begun investigat ing technologies that may potentially improve energy efficiency in computers

, computer servers , and UPSs . The existence of these technology options indicates that improvement of energy efficiency in these products is feasible and a n energy conservation standard could fulfi ll the purposes of EPCA in reducing energy consumption . DOE will conduct a technology assessment to generate a thorough list of technolo gy options and then screen out technology options that are not (1) technologically feasible; (2) practical to manufactur e, install, and service; (3) have adverse impacts on product utility or availability; or (4) have adverse impacts on health or safety

. This is discussed in more detail in section s 6 and 7

.

2. OVERVIEW OF THE RULE MAKING PROCESS

2.1 Test Procedures

Under 42 U.S.C. 6293, EPCA sets forth the criteria and procedures DOE must follow when prescribing or amending a test procedure for covered products. EPCA provides in relevant
pa rt that any test procedure prescribed or amended under this section shall be reasonably designed to produce test results that measure energy efficiency, energy use

, or estimated annual operating cost of a covered product during a representative average use cycle or period of use and shall not be unduly burdensome to conduct. (42 U.S.C. 6293(b)(3)) If the Secretary determines that a test procedure should be prescribed for a covered product, a proposed test procedure should be published in the Federal Registe r and interested persons should be provided an opportunity to present oral and written data, views, and arguments with respect to the proposed procedure. (42 U.S.C. 6293(b)(2))

DOE is considering initiating a test procedure rulemaking for computer systems b ecause it has been tentatively determined that computer systems meet the criteria for a covered product and a test procedure will be required to determine the energy conservation standard for this product.

As a first step in the rulemaking process , DOE ev aluates available industry test procedures and requests comment on specific topics in section 4 of this framework document. DOE will review comments received in response to today’s framework document and publish a notice of proposed rulemaking (NOPR) in the Federal Register as the next step in establishing a regulatory test procedure for computer s ystems

. The NOPR and associated public meeting will provide interested parties an opportunity to provide comments on the proposed test procedure. Following the end of the NOPR comment period, a final rule will be published in the Federal Register

.

2.2 Energy Conservation Standards

When DOE evaluates any new or amended en ergy conservation standard for covered products, EPCA, as amended, specifies that any standard DOE prescribes for consumer products8

must be designed to achieve the maximum improvement in energy efficiency that is technologically feasible and economically justified. (42 U.S.C. 6295(o)(2)(A)) Moreover, the Secre tary may not establish a new or amended standard if such standard would not result in significant conservation of energy. (42 U.S.C. 6295(o)(3)(B)) In determining whether a standard is economically justified, DOE must consider, to the greatest extent pract icabl e, the following 7 factors:

(1) The economic impact of the standard on the manufacturers and on the consumers of

the product s subject to such standard;

(2) The savings in operating costs throughout the estimated average life of the covered product in the type (or class) compared to any increase in the price of, or in the initial charges for, or maintenance expenses of, the covered products which are likely to result from the imposition of the standard;

(3) The total projected amount of energy, or as applicable, wa ter, savings likely to result directly from the imposition of the standard;

(4) Any lessening of the utility or the performance of the covered products likely to result from the imposition of the standard;

(5) The impact of any lessening of competition, as determ ined in writing by the Attorney General, that is likely to result from the imposition of the standard;

(6) The need for national energy and water conservation; and

(7) Other factors the Secretary considers relevant. (42 U.S.C. 6295(o)(2)(B)(i)(I)

- (VII))

The analys es performed to consider the above 7 factors are the focus of the energy conservation standard rulemaking process and are described in sections 5 through 20

. The typi cal process of developing conservation standards involves analyses , public notice, and consultation with interested parties. Such interested parties generally include manufacturers, consumers, energy conservation and environmental advocates, s tate and f ede ral agencies, and any other groups or individuals with an interest in energy conservation standards and test procedures. DOE considers participation of interested parties to be a very important part of the rulemaking process. Accordingly, DOE actively enco urages the participation and interaction of all interested parties during the comment period provided at each stage of the rulemaking. The broad array of interested parties who routinely provide comments promotes a balanced discussion of critical informati on required to conduct the standards rulemaking, beginning with public comment on the framework document.

In conducting the test procedure rulemakings and the energy (and water) conservation standards rulemakings, DOE involves interested parties through a variety of means. As discussed in further detail below, the standards rulemaking process involves two to three public notices in addition to the notice of availability of the framework document. All of these notices are published in the Federal Register

. Publication of the framework document, preliminary analysis, and NOPR are typically accompanied by public meetings to solicit comment from interested parties to enhance the rulemaking process.9

Briefly, these steps include :

 Preliminary a nalysis (section 2.2.1 ). The preliminary analysis presents a discussion of comments received on the framework document and is designed to solicit public feedback on the models and tools that DOE intends to use in the rulemaking. Us ing these models and tools, DOE performs preliminary analyses to assess candidate standard levels (CSLs), which span the range of efficiencies from baseline product to the most efficient technology.

 Notice of p roposed r ulemaking (section 2.2.2 ). The NOPR presents a discussion of comments received in response to the preliminary analysis ; DOE’s analys e s of the impacts of potential standards on consumers, manufacturers, and the nation ; DOE’s weighting of these impa cts, and any proposed standard levels for public comment.

 Final r ule (section 2.2.3 ). The final rule presents a discussion of comments received in response to the NOPR, revised analys e s, as appropriate, of the impacts of any standards, DOE’s weighting of those impacts, and the standard levels, if any, that DOE is adopting. The final rule also establishes the date by which manufacturers must comply with any standards.

2.2.1 Preliminary Analysis

As part of its energy c onservation standards rulemaking activity, DOE typically identifies product technology options and makes a preliminary determination as to whether to retain each option for detailed analysis or to eliminate it from further consideration. This process inclu des a market and technology assessment (section 6 ) and a screening analysis (section 7 ). DOE applies four screening criteria in the screening analysis to determine wh ich technology options to eliminate from further consideration: (1) technological feasibility; (2) practicability to manufacture, install, and service; (3) adverse impacts on product utility or availability; and (4) adverse impacts on health or safety. Tec hnologies that pass through the screening analysis are evaluated, and referred to as design options, in the engineering analysis (section 8 ).

DOE consults with interested parties and researches industry literatu re to identify the design options or efficiency levels that DOE will consider in the rulemaking. DOE considers design options or efficiency levels for each product class. DOE uses these design options or efficiency levels to collect manufacturer cost data, historical shipment data, shipment

- weighted average efficiency data, and preliminary manufacturer impact data ( e.g. , capital conversion expenditures, marketing costs, and research and development (R&D) costs). As part of the preliminary analysis, DOE also conducts other principal analyses, including:

(1) e ngineering analysis (section 8 );

(2) m arkups analysis (section 9 );

(3) e nergy use analysis (section 10 );

(4) c onsumer life

- cycle cost (LCC) and payback period (PBP) analysis (section 11 );10

(5) s hipments analysis (section 12 );

(6) n ational impact analysis (NIA ), which considers national energy savings (NES) and consumer net present value (NPV) (section 13 ); and

(7) p reliminary manufacturer impact analysis (MIA) (section 15 ).

Based on the preliminary results of these analyses, DOE selects CSLs from the energy efficiency levels considered in the preliminary analysis. In addition to the efficiency level corresponding to the maximum technologically feasible (max

- tech) efficiency l evel, DOE generally considers efficiency levels that span the full range of technologically achievable efficiencies. The range of efficiency levels that DOE typically analyzes includes:

 The baseline efficiency level, which typically represents products wit h the lowest energy efficiency on the market. For products that already have energy conservation standards, DOE typically defines the baseline efficiency level by the existing energy conservation standard.

 The highest energy efficiency level or lowest ener gy consumption level that is technologically feasible and satisfies the screening criteria ( i.e. , max

- tech).

 Levels that incorporate noteworthy technologies or fill large gaps between other efficiency levels being considered.

DOE uses analytical models and tools to assess the different product classes at each efficiency or energy use level analyzed. Many of these analytical models and tools are in the form of spreadsheets, used to conduct the LCC and PBP analys e s and to determine the NES and NPV of prospect ive standards. Discussion of various CSLs in the preliminary analysis helps interested parties review the spreadsheet models that underpin the analyses. DOE uses comments from interested parties to refine the models for the next stage of the rulemaking ana lyses.

2.2.2 Notice of Proposed Rulemaking

In developing any NOPR, DOE considers the comments received during the comment period of the prior phase . This process can result in revisions to the analyses conducted during the preliminary analysis stage; DOE conduct s additional economic and environmental impact analyses for the NOPR. These analyses generally include:

(1) c onsumer LCC subgroup analysis (section 14 );

(2) c omplete MIA (section 15 );

(3) emissions analysis (section 16 );

(4) monetization of emissions (section 17 );

(5) u tility impact analysis (section 18 ) ;11

(6) e mployment impact analysis (section 19 ); and

(7) r egulatory impact analysis (RIA) (section 20 ).

On its website docket, DOE describes the methodology used and makes th e results of all the analyses available for review. This analytical process results in the selection of proposed standard levels, if any, that DOE presents in the NOPR. DOE selects the proposed standard levels from the trial standard levels (TSLs) analyzed during the NOPR phase of the rulemaking

. 10 The NOPR is published in the Federal Register and describes the evaluation and selection of any proposed standards levels, along with a discussion of other TSLs considered but not selected and the reasons DOE did not select them. For each product class, DOE identifies the

max

- tech efficiency level. If DOE proposes a lower level, DOE explains the reasons for eliminating higher levels, beginning with the highest level considered. DOE presents the analytical results i n the NOPR and provides the details of the analysis in an accompanying technical support document ( TSD )

. DOE considers many factors in selecting proposed standards. These factors are prescribed by EPCA and take into consideration the benefits and costs of energy conservation standards.

When DOE publishes the NOPR, it provides the U.S. Department of Justice (DOJ) with copies of the NOPR and TSD to solicit feedback on the impact of any proposed standard levels on competition in the market of the product tha t is the subject of the rulemaking. DOJ reviews standard levels to assess the impacts from any lessening of competition likely to result from the imposition of such standards. (42 U.S.C. 6295(o)(2)(B)(i)(V) and (B)(ii)) Publication of the NOPR is followed by a public comment period that includes a public meeting.

2.2.3 Final Rule

After publication of any NOPR, DOE considers public comments received on the proposal and accompanying analyses. DOE reviews the engineering and economic impact analyses and any proposed standards based on these comments and considers modifications where necessary. DOE also considers DOJ’s comments on the NOPR relating to the impacts of any proposed standard levels on competition to determine whether changes to these standard levels are n eeded. DOE publishes the DOJ comments and DOE’s response as part of any final rule.

In the final rule, DOE sets final standard levels and the compliance date and also explain s the basis for the selection of such standard levels. The final rule is accompani ed by a final TSD.

10 TSLs are assembled from the C SLs analyzed for the individual product classes based on a set of criteria from the analysis results.12

2.2.4 Overview of Analyses for Rulemaking

The purpose of the analyses conducted in support of the standards rulemaking is to ensure that DOE selects energy conservation standards that achieve the maximum improvement in energy efficiency that i s technologically feasible and economically justified, and will result in significant energy savings. Economic justification includes the consideration of economic impacts on domestic manufacturers and consumers, national benefits including environmental i mpacts, issues of consumer utility, and impacts from any lessening of competition. DOE expects the selection of such standards to achieve the maximum energy savings that are economically justified without imposing excessive financial burden on any particul ar party.

Figure 2

- 1 summarizes the analytical components of the standards

- setting process. The “analyses” are presented in the center column. Each analysis has a set of “key inputs,” which are data and informatio n required for the analysis. “Approaches” are the methods that DOE will use to obtain key inputs, which may vary depending on the information in question. For example, some key inputs exist in public databases; DOE will collect other information from inter ested parties or experts with special knowledge, and DOE will gather other information in support of this rulemaking. The results of each analysis are “key outputs,” which feed directly into the rulemaking. Arrows indicate the flow of information between t he various analyses. DOE ensures a consistent approach to its analyses throughout the rulemaking by considering each analysis as a part of the overall standards

- setting framework.13

Figure 2

- 1 : Flow Diagram of Analyses for a Traditional Standards Rulemaking Process14

3. SCOPE OF COVERAGE

In the February 2014 NOPD, DOE proposed the following definition for computer systems:

“ A consumer product whose primary function is to perform logical operations and process dat a, or equipment whose primary function is to maintain continuity of load power for such products in case of input power failure. ” 79 FR 11346.

While this definition may be broad and include several products, DOE intends to narrow the scope of this rulemaki ng

. A s discussed in the February 2014 NOPD, DOE would consider consumer products such as computers, computer servers, and UPSs, to be within the scope of coverage of computer systems.

DOE is considering including definitions for computers, computer server s, and UPSs to establish the scope of coverage for the computer systems test procedure and standards rulemakings. These are discussed in sections 3.1

, 3.2 , and 3.3 , respectively. The proposed definitions for these types o f consumer products will be the starting point to establish the scope of this rulemaking. DOE is considering additional criteria to further identify the typ es of consumer products that should be included i n the scope of coverage, as discussed in section 3.4

3.1 Definition of Computers

DOE is considering the following definition for a computer.

“Computer means a consumer product powered by mains power with the p rimary function of performing logical operations and processing data. At a minimum, a computer is composed of the following:

(1) A central processing unit (CPU) to perform operations, or the ability to function as a client gateway to a server that acts as a co mputational CPU;

(2) User input devices such as a keyboard, mouse or touchpad; and

(3) An integrated display and/or the ability to support an external display screen to output information.

This definition excludes products that may perform similar operations but h ave different primary functions

, including but not limited to: playing video games, displaying television signals, making phone calls, taking pictures, or outputting audio signals.”

This definition is based on the definition in ENERGY STAR Computers V. 6.0 with the exception that DOE’s proposed definition is simplified by excluding examples of specific products and features included in the ENERGY STAR Computers V. 6.0 definition. Further, DOE’s proposed definition specifies that products that have different primary functions are excluded . DOE is proposing this specificity to exclude products such as game consoles, digital cameras, smartphones, etc. from the computers definition.15

Item 3

- 1 DOE requests comment on the definition of a computer or alternate approaches tha t should be considered. Specifically, DOE requests suggestions of characteristics that may be used in the definition to distinguish general consumer electronics from computers.

3.2 Definition of Computer Servers

DOE is considering the following definition for computer servers.

“ Computer server means a computer that provides services and manages networked resources for client devices (e.g., desktop computers, notebook computers, thin clients, wireless devices, personal digital assistants ( PDAs ) , IP telephones, other computer servers, or other network devices). A computer server is primarily accessed via network connections, versus directly connected user input devices such as a keyboard or mouse. Additionally, a computer server must meet the following criteria:

(1) Provides support for error

- correcting code (ECC) and/or buffered memory (including both buffered dual in

- line memory modules (DIMMs) and buffered on board (BOB) configurations).

(2) Is designed such that all processors have access to shared system memory and a re visible to a single operating system ( OS ) or hypervisor.”

This definition is based on the computer servers’ definition specified in ENERGY STAR Version 2.0, ENERGY STAR Program Requirement for Computer Servers , Rev. October 2013 ( ENERGY STAR Computer Se rvers V. 2.0 )

, except DOE’s proposed definition does not include language relating to whether a computer server is sold primarily to commercial customers through enterprise channels. Computer servers are not always sold through enterprise channels and are often sold for use in multiple environments in addition to office/corporate locations or data centers. Moreover, u nder EPCA, the fact that a computer server is sold only or primarily to commercial/industrial customers does not , alone, make it a commercial product

. DOE’s proposed definition also does not include the requirement from the ENERGY STAR Computer Servers V. 2.0 definition that a computer server “is designed for and listed as supporting one or more computer server OS and/or hypervisors”

, because it may be difficult to create a quantitative distinction between a computer OS and a computer server OS

. Additionally

, DOE’s proposed definition does not include the requirement that a computer server “is packaged and sold with one or more AC

- DC (alternat e current

- direct current) or DC

- DC (direct current

direct current) power supplies”, since the inclusion of a power supply does not provide a meaningful distinction between a computer and a computer server.

Although the currently proposed definition provide s a functional foundation, it may not sufficiently distinguish between client computers
, which are typically intended for single

- user operation, and computer servers, which are designed to handle multiple simultaneous users and service requ ests sharing sys tem resources. DOE intends to investigate further factors and criteria which could be used to clearly distinguish between computer servers and client computers.16

Item 3

- 2 DOE requests feedback and information on additional factors and criteria that could be used to distinguish clearly between computer servers and client computers, other than those based on point

- of

- sale or end

- use.

3.3 Definition of Uninterruptible Power Supplies

DOE is considering a definition for UPSs that is based on that of International Electrotech nical Commission ( IEC ) standard 62040

- 3 Edition 2.0, Uninterruptible power systems (UPS)

– Method of specifying the performance and test requirements , March 2011 (IEC 62040

- 3, Ed. 2.0) and ENERGY STAR Version 1.0, ENERGY STAR Program Requirements for Unint erruptible Power Supplies , Rev. July 2012 (ENERGY STAR UPS V. 1.0). As such, DOE proposes to define a UPS as “ a combination of convertors, switches and energy storage devices (such as batteries) constituting a power system for maintaining continuity of loa d power in case of primary input power failure. ”

Supplementary external circuits and components such as isolation transformers and

e lectromagnetic interference (EMI) filters may be needed depending on the topology of the UPS, the requirements of the load and the AC power distribution system. 11 These external components provide additional utility and do not contribute to the power conversion efficiency of the UPS. DOE therefore intends to exclude such external components and its impact on overall efficiency from its analysis.

3.4 Scope of Computer Systems Test Procedure and Standards Rulemakings

The proposed scope of coverage for the computers systems test procedure and standards rulemakings relates only to consumer products. EPCA defines “consumer product” as a ny article of a type that consumes or is designed to consume energy , and , to any significant extent, is distributed in commerce for personal use or consumption by individuals without regard to whether such article of such type is in fact distributed in com merce for personal use or consumption by an individual. ( 42 U.S.C. 6291 (1)) Therefore, only those computer systems that

are of a type which , to any significant extent, are distributed into commerce for personal use or consumption would be considered in the scope of this rulemaking

. DOE received comments in response to the February 2014 NOPD regarding the distinction between consumer and commercial computer systems. The Telecommunications Industry Association (TIA) agreed with DOE’s clarification that this r ulemaking should cover consumer products only, because regulating commercial products is contrary to EPCA and would have severe negative consequences. (TIA, No. 0023 at p. 6) The National Electrical Manufacturers Association (NEMA) requested DOE to identif y better indicators of consumer versus commercial products since assumptions regarding covered versus non

- covered products can result in millions of dollars wasted on redesigning non

- covered equipment or result in significant fines for failing to

11 IEC standard 62040

- 3 Edition 2.0, Uninterruptible power systems (UPS)

– Method of specifying the performance and test requirements (IEC 62040

- 3, Ed. 2.0 )17

redesign products mistakenly thought to be non

- covered. (NEMA, No. 0025 at p. 6) The Appliance Standards Awareness Project (ASAP), Natural Resources Defense Council (NRDC), Alliance to Save Energy, American Council for an Energy

- Efficient Economy (ACEEE), Northeast Energy Efficiency Partnerships (NEEP), Northwest Energy Efficiency Alliance (NEEA) and Northwest Power and Conservation Council (hereafter referred to as Joint Responders) commented that in the absence of a clear and lasting distinction, DOE must conclude that all computers are of the same type from a regulatory perspective, and therefore covered by the standards, irrespective of whether they are marketed to, and operated in, commercial settings. (Joint Responders, No. 0024 at p. 3)

DOE is working to iden tify factors that can distinguish between consumer and commercial products so that only computer systems which are consumer products are included in
scope. The Information Technology Industry Council (ITI) commented that residential products have electrica l capacity limits and many computer servers and UPSs are not designed for residential AC mains. (ITI, No. 0026 at p. 5) Finally, Schneider Electric recommended DOE to refer to its White Paper on different AC power connectors for distinguishing consumer fro m commercial products. (Schneider Electric, No. 0019 at p. 8) DOE is considering using the criterion mentioned by ITI to distinguish between consumer and commercial products as discussed in further detail in sections 3.4.1

, 3.4.2 , and 3.4.3

. DOE will also review Schneider Electric’s White Paper on AC power connectors. DOE is additionally considering whether specific types of computers , such as tablets, should be considered in scope as discussed in section 3.4.1

.
3.4.1 Computers

In response to the February 2014 NOPD, ITI commented that with respect to personal computers, the basic design is similar to devices sold to commercial customers. (ITI, No. 0026 at p. 6) ITI specified that commercial products are differentiated from consumer products in one o r more of the following areas: remote management capabilities; availability and serviceabil ity; expandability; and longer warranty periods. However, these differences are not clear delineators of the two end use markets. (ITI, No. 0026, at p. 6)

Accordingly, at this initial stage, DOE is not aware of any computer s that would be considered commer cial/industrial equipment only. 42 U.S.C. 6311(2)(A) Therefore, DOE is considering including all computers within scope except as discussed below.

DOE evaluated industry, regulatory, and voluntary standards for computers to determine their scope (discussed in section 4.1.1 )

. The scope of these industry standards are detailed in Appendix A

. Based on its initial review of industry and regulatory energy programs for
compu ters, DOE is considering including desktop, integrated desktop, notebook, thin client, mobile thin client, and integrated thin client computers in the scope of this rulemaking. DOE is still evaluating the impact of including workstations, small

- scale serve rs, and tablet computers in the scope of coverage.

ENERGY STAR Computers V. 6.0 specifies definitions for all these product types, except tablets , and uses these definitions to define its scope . DOE is considering the definitions specified in ENERGY STAR Computer s V. 6.0 to define the scope for computer product types

.18

Further, the U.S. Environmental Protection Agency ( EPA ) is currently revising the ENERGY STAR Computers V. 6.0 specification and published the ENERGY STAR Version 6.1 Final Draft Computers Sp ecification (ENERGY STAR Computers Final Draft V. 6.1) on June 23

, 2014. In this revision, EPA is updating definitions for some products, such as integrated desktop and DOE will consider the updated definitions, once the specification is final. While DOE m ay consider excluding some of these products from scope, clear product definitions will help avoid product overlap and confusion

. While a definition for tablet computers is excluded from ENERGY STAR Computers V. 6.0, EPA recognizes the need for its definit ion and is considering includ ing slates/tablets in the ENERGY STAR Computers Final Draft V. 6.1 revision

. The draft specification proposes a definition for slates/tablets and revises the scope to exclude handheld computers with cellular voice capability.

D OE believes that a definition for tablet computers may be necessary to distinguish them from similar products like notebook and integrated desktop computers. These products share many physical similarities like integrated touch screens and main batteries, but tablet computers are designed for increased portability making them ideal for usage while disconnected from mains power . This difference in usage can impact the overall usage profile and energy consumption of the product, reinforcing the need to separa te these products. Therefore, DOE will consider the definition for slates/tablets that is included in the ENERGY STAR Computers Final Draft V. 6.1 once the specification is final

.

Item 3

- 3 DOE requests comment on using ENERGY STAR Computers V. 6.0 and ENERGY STAR C omputers Final Draft V. 6.1 as the basis for computer product definitions. DOE also requests comment on any additional computer product definitions that should be included.

Item 3

- 4 DOE requests comment on the need for a tablet computer definition. DOE also request s comment on the criteria used to distinguish tablet computers from other computers as well as any suggestions for the definition.

While DOE is considering using the definitions of desktops, notebooks, and other products to establish the scope of included computer product types, it is also considering defining the scope without using these product definitions. In the latter scenario, DOE would establish bounds in scope through product features and technical specifications. With the rapidly changing form fa ctor of computers, this may be a more accurate method to ensure that only the intended product characteristics are included in the scope.
Specifically , DOE is considering certain product characteristics for scope criteria such as product weight, screen si ze, integrated mechanical keyboards, touch screen sensitivity, main batteries, battery capacity, power supply size, and internal storage. For example, DOE may decide that notebooks under a certain screen size do not need to be included in the scope or tabl ets with screens greater than a certain size should be included. Or DOE may decide to19

exclude smaller products that are already energy efficient and face design constraints due to their size.

Item 3

- 5 DOE requests comment on the types of computer s that should be

e xcluded from the scope.

Item 3

- 6 DOE requests comment on using computer product characteristics to narrow the scope of coverage or more accurately define products. In particular, what design characteristics would best be used to separate out tablets?

3.4.2 Computer Ser vers
DOE evaluated regulatory and voluntary standards for computer servers to determine the types of servers that should be included in scope (discussed in section 4.2.1 )

. The scope of these industry standards a re detailed in Appendix A

. Of these standards, DOE primarily reviewed the
scope requirements in ENERGY STAR Computer Servers V. 2.0. The scope of this program includes b lade, m ulti

- node, r ack

- mounted, and p edest al form factor computer servers with no more than four processor sockets in the computer server (or per blade or node in the case of blade or multi

- node servers)

. As discussed previously, DOE is considering only computer server s that are consumer products for the scope of this rulemaking

. Although the scope of ENERGY STAR Computer Servers V. 2.0 targets products that are “sold through enterprise channels for use in data centers and office/corporate environments”, DOE believes that many of the products with in the ENERGY STAR scope are also purchased and used by consumers. Computer servers that are used for these household purposes are available to consumers through retail outlets 12

, 13

, 14 and are typically sold alongside computer servers that are targeted more towards home office and small business applications.

However, s ince certain products that are included in the scope of ENERGY STAR Computer Servers V. 2.0, such as blade systems or resilient servers , might not be considered

consumer

- type products, DOE i s consider ing excluding such items from the scope.

In response to the February 2014 NOPD, DOE received several comments regarding the distinction between consumer and commercial servers. International Business Machines Corporation (IBM) commented that com puter servers are wholly unlike personal computing equipment and they are not used in a residential environment; therefore, they should be excluded

12 http://www.amazon.com/

13 http://www.tigerdirect.com/

14 http://www.newegg.com/20

from the regulation. (IBM, No. 0021 at p. 2) ITI commented that the subset of computer servers that may be u sed in both a home and commercial environment are limited and can be defined based on sales, ability to be powered by residential circuits, and by the fact that they are configured to be installed and used in a residential setting. (ITI, No. 0026 at p. 5) ITI also included an Appendix that contained comments from Cisco. T h e comments described distinguishing features and characteristics of commercial servers compared to servers sold for personal use or consumption. Cisco commented that servers used in data c enters have enormously large memory stores, are maintained by advanced cooling systems, are connected to very powerful processors, and are powered by energy supplies that are meant to stay on for years at a time. Whereas, home servers are used to manage an d stream video and music content, share photos, store emails and backup copies of files, remotely control computers and local area network applications, automate home functions, and potentially host small business websites. That is, the extent to which a d ata center server or a large enterprise server can be used in a residential application is near zero. (ITI Appendix 3, No. 0023 at p. 8

- 10 , 14 ) Cisco further commented that data center and network servers operate in an entirely different manner to home

ser vers. Further, while some components are similar, the processes for storing and moving data are differen t , as is the typical usage actively needed to generate data, where they are placed, what they connect to, and the amount of energy they consume. (ITI Ap pendix 3, No. 0023 at p. 12) Finally, Cisco commented that while a home server can operate on any flat surface in a house in any climate, commercial

- grade servers typically require a temperature between 65

– 75 degrees Fahrenheit and a monitoring system wi th temperature sensors and responsive cooling systems. (ITI Appendix 3, No. 0023 at p. 13

- 1 4)

While DOE is not considering using point of sale or configurability as a method to distinguish between commercial and consumer computer servers , it may consider I TI’s recommendation of qualifying computer servers based on ability to be powered by residential circuits. Accordingly, DOE will consider limiting the scope to computer servers that can be powered using 120 Volts ( V ) input or a standard wall plug receptacl e. Further, while DOE is consider ing physical design and hardware features as a basis for distinguishing between commercial and consumer computer servers

, certain other features are not being considered. For example, although computer servers designed for a commercial deployment may be capable of providing longer periods of reliable and uninterrupted service than those designed for consumer

use , such a characteristic may be difficult to quantify and verify. Additionally

, there is often overlap between the a pplications performed by commercial and consumer computer servers ( e.g., serving multimedia, storing files, hosting websites), with the difference between the two types being performance requirements and scale of operation. DOE believes that it may be chal lenging
to distinguish between commercial and consumer products based on such nuances , whereas the scale and performance capability of a computer server might be strongly correlated with its hardware and physical design characteristics. Finally, if certain commercial computer servers require external hardware or system infrastructure to function properly, such criteria may be considered as a method to distinguish from consumer computer servers

. Currently, DOE believes that of the three market segments of c omputer servers shown in Table 1

- 1 (volume, mid

- range, and high

- end)

, the volume computer servers category would primarily be considered a consumer product

. However, t his market segmentation of computer servers is ba sed on cost, which DOE will likely not use to determine the scope , as that may change over time . Therefore, DOE is investigating other methods by which to define the scope to21

include only computer servers that are consumer products

. An option that DOE is c onsidering is based on the distinction used in ENERGY STAR Computer Servers V. 2.0 , which includes a computer server’s form

- factor as a basis for determining whether it is included within the scope of coverage. DOE is also investigating alternative strateg ies that focus on a computer server’s quantifiable characteristics ( e.g. , number of processor sockets, memory capacity, maximum theoretical performance, etc.).

Item 3

- 7 Based on DOE’s definition of a consumer product, DOE requests

comment on additional methods (be sides ability to operate on a residential circuit) to identify computer servers that are consumer products . Are there alternative strategies that can be used to create a scope of coverage which distinguishes consumer computer servers from those that are ex clusively used in commercial/data

- center environments ?

3.4.3 Uninterruptible Power Supplies

A UPS has two primary functions. The first is to provide an instantaneous and uninterrupted source of emergency power in the event of a mains power failure. The second is to monitor and condition the mains power to protect sensitive electronic equipment against voltage surges, sags, switching transients, line noise and harmonic distortion. UPS applications can therefore extend from typical consumer use among households whe re there is a need to protect vulnerable loads such as personal computers and home entertainment systems to commercial applications such as at datacenters, public utiliti es, telecommunications, medical institutions and manufacturing environments.

As menti oned previously , DOE ’s intention is to only develop standards and test procedures for consumer products

. Thus, t he scope of this rulemaking will be limited to UPSs that fall within EPCA’s definition of a consumer product

. DOE reviewed the scope of the ENER GY STAR UPS V. 1.0 specification in consideration for the scope of this rulemaking. Of the products that are in scope for ENERGY STAR UPS V. 1.0, DOE is considering including

consumer UPSs that are intended to protect desktop computers and related peripher als, and/or home entertainment devices such as TVs, set top boxes, digital video recorders ( DVRs ) , Blu

- ray and digital video disc ( DVD ) players

. ENERGY STAR UPS V. 1.0 also includes several commercial UPSs in scope, that DOE is considering excluding. Furth er, DOE is considering excluding the following products from the scope of this rulemaking

, despite meeting the definition of a UPS :

(1) UPSs designed to comply with specific UL safety standards for safety

- related applications, such as emergency lighting, oper ations or egress, or medical diagnostic equipment. (2) UPSs designed for mobile, ship board, marine or airborne applications.

DOE received input from stakeholders to identify consumer UPSs from commercial UPSs in response to the February 2014 NOPD. IBM commen ted that DOE should remove22

battery backup systems from the proposed determination because they do not meet the EPCA definition of a consumer product nor are they a product “of a type” under DOE’s FA Q “several factors” test

. 15 (IBM, No. 0021 at p. 2) NEMA co mmented that if there is a need to regulate UPS products under EPCA, the definition should include mention of standard two and three prong power cords and that these systems should not draw more than 7 amps of power. (NEMA, No. 0025 at p. 5) Further, all r ack mounted or rack mountable devices and equipment requiring multiphase power or other than 120 V AC should be clearly excluded from scope since these items would not be consumer devices. (NEMA, No. 0025 at p. 5 ) NEMA also commented that to avoid regulato ry ambiguity, DOE should avoid definitions that capture a much broader range of products during certification and enforcement unless additional qualifications are set to clarify the determination of consumer products. (NEMA, No. 0025 at p. 5) Schneider Ele ctric commented that consumer UPSs are defined as voltage and frequency dependent (VFD), which have a different architecture compared to business class UPSs that are defined by IEC 62040, Ed. 2.0 as voltage and frequency independent (VFI) and voltage indep endent (VI). (Schneider Electric, No. 0019 at p. 3) Schneider Electric further commented that

, for the purposes of UPSs supporting consumer products

, the voltage is 120 V AC exclusively, connected to a 15 amp multi outlet residential branch circuit. Schnei der Electric utilizes several technical characteristics for defining their consumer marketplace and recommended the following: pluggable Type A equipment (as defined by IEC 60950

- 1); products marked as compliant with class B emissions limits (47 CFR 15, or EN 55022); and VFD type UPSs. (Schneider Electric, No. 0019 at p. 6

– 7) Further, commercial and industrial UPSs can be identified using the following characteristics: Products marked as compliant with class A emissions limits (47 CFR 15 or EN 55022);
equ ipment requiring multiphase power input or power input other than 120 V AC; computers and UPSs with greater than 12 amps power draw, at 120 V; computers and UPSs with voltage input other than 120 V AC; and, any rack mounted system

– the 19 inch rack mount systems are indicative of commercial applications. (Schneider Electric, No. 0019 at p. 7)

DOE is considering identifying consumer type UPSs as those operated at 120 V AC on a standard wall plug receptacle as commented by NEMA and Schneider Electric. In ord er to give manufacturers freedom to deploy any technology necessary when meeting standards, DOE will not use product architecture to distinguish between consumer and commercial UPSs unless certain architectures are associated with customer utility that are not offered otherwise. DOE is investigating alternative methods and will attempt to harmonize with current definitions for consumer UPSs as defined in IEC 62040, Ed. 2.0.

Item 3

- 8 DOE requests feedback on the proposed scope for UPSs. In particular, whether or no t industry believes a particular UPS type should be included within the scope.

15 http://www1.eere.energy.gov/buildings/appliance_standards/pdfs/cce_faq.pdf23

DOE is also considering the use of product characteristics such as overall capacity (in VA) to limit the scope of coverage. DOE believes a cut

- off capacity will allow consumer U PSs to be regulated without impacting those used in an industrial or commercial setting.

Item 3

- 9 DOE requests feedback on using UPS product characteristics to narrow the scope of coverage. DOE further requests feedback on whether capacity is a proper differentiat or between consumer and commercial UPSs and what constitutes a proper cut

- off capacity.

4. TEST PROCEDURES

DOE is consider ing a test procedure rulemaking for computer systems

. In prescribing new test procedures, DOE will take into account relevant informatio n including technological developments relating to energy use of computer systems. DOE plans to include the required definitions, test conditions, and setup requirements for computer systems in the test procedure

. Because of the complexity of the computer systems products, the test procedure text may be split into different sections to account for different product classes (e.g. notebooks vs rack

- servers) and t he modal energy consumption or efficiency values will be combined in a single metric for the purpo ses of determining compliance with energy conservation standards. Additionally, d ue to the varied interests of stakeholders, DOE will consider scheduling separate public meetings to discuss the different sections of the test method

. The following sections discuss the methods of energy consumption measurement for computer systems in further detail.

4.1 Methods of Measurement for Computers

4.1.1 Existing Industry and Regulatory Test Procedures

As an initial step to develop a test method for computers, DOE evaluated the following existing industry and regulatory programs:

(1) Australian/New Zealand Standard (AS/NZS):2012, Information Technology Equipment

- Energy Performance of Computers , July 2012 (AS/NZS 5813:2012) ;

(2) European Union (EU) No. 617/2013, Implementing Directive 20 09/125/EC of the European Parliament and the Council with regard to Ecodesign requirements for computers and computer servers , June 2013 (EU No. 617/2013) ;

(3) IEC 62623 Ed. 1.0, Desktop and Notebook Computers

– Measurement of Energy Consumption , October 2012 (IEC 62623 Ed. 1.0) ;

(4) Ecma International ECMA

- 383 Ed. 3: 2010

- 12, Measuring the Energy Consumption of Personal Computing Products , December 2010 (ECMA

- 383 Ed. 3.0) ;

(5) ENERGY STAR Computers V. 5.2;

(6) ENERGY STAR Computers V. 6.0; and24

(7) Japan’s Computer and Hard D isk Drive Judging Standards Subcommittee Final Report

, General Resources Energy Investigation Committee, Energy Savings Standards Section, Rev. Dec ember 2009 (Japanese Top Runner Program).

While ENERGY STAR Computers V. 5.2 was effective until June 1, 2014 , EPA released ENERGY STAR Computers V. 6.0 as an updated version that went into effect on June 2, 2014. Further, the Final Draft version of ENERGY STAR Computers V. 6.1 was published recently and will supersede ENERGY STAR Computers V. 6.0 once it goes in to effect. DOE has primarily evaluat ed ENERGY STAR Computers V. 6.0 for the computers test method in advance of the publication of this framework document, but will consider any additional requirements specified in ENERGY STAR Computers V. 6.1 once the fin al version is published

.

4.1.2 Proposed DOE Test Method for Computers

Of the computer standards DOE evaluated, the Japanese Top Runner Program has the most notable differences compared to the other standards . While the other procedures closely align with the me asurement practices of IEC 62623 Ed. 1.0, the Japanese Top Runner Program uses a unique procedure to determine an efficiency level for computers. Additionally, its power measurements are vague in comparison to the other industry procedures. Therefore, DOE did not consider the Japanese Top Runner Program to propose a test method for measuring computer energy consumption.

Of the other standards evaluated, a lthough ENERGY STAR Computers V. 5.2 and EU No. 617/2013 follow the same procedural style of IEC 62623 E d. 1.0, they only measure one idle mode of operation. Whereas, ENERGY STAR Computers V. 6.0, ECMA

- 383 Ed. 3.0, AS/NZS 5813:2012, and IEC 62623 Ed. 1.0, measure idle mode in two parts, short and long idle, because it’s believed to be a more typical represen tation of the computer’s idle mode power consumption. DOE agrees with this approach and is considering a short and long idle mode power measurement. DOE is therefore considering IEC 62623 Ed. 1.0 as the basis for its computers test procedure.

The IEC 626 23 Ed. 1.0 t est procedure defines methods for determining the power consumption of computers in the o ff, s leep, l ong i dle, and s hort i dle m odes. The test procedure includes definitions for different modes of operation and test setup instructions in additio n to the power consumption test methods. DOE supports these procedural methods and may consider the IEC 62623 Ed. 1.0 t est procedure as a basis for the computers test method

. Additionally, DOE observes that ENERGY STAR Computers V. 6.0 provides additional guidance for the power
measurements and for setting the luminance of integrated displays to a predetermined value. DOE will consider this guidance while developing the computer test method as well.

Item 4

- 1 DOE requests comment on the use of IEC 62623 Ed. 1.0 as th e bas is for the development of the computers test method

.25

Item 4

- 2 DOE requests comment on providing additional guidance as provided in ENERGY STAR Computers V. 6.0. Specifically, DOE requests comment on the luminance values specified in ENERGY STAR Computers V. 6 .0 for integrated desktops and notebooks. Are these values sufficient or does the luminance need to be higher for integrated displays?

4.1.3 Annual Energy Consumption Metric

Test procedure output metrics are used in the energy conservation standard to determine if the product meets the standard level. When considering this metric , DOE reviewed output metrics and implementation methods from regulatory and voluntary programs. Most standards that measur e the energy use of computers use a weighted average of modal p ower consumption values to determine an AEC value

, in kWh per year . ENERGY STAR, AS/NZS , and EU all use this method, while the Japanese Top Runner Program uses a watts

- per

- operation metric. Due to the substantial difference between the watts

- per

- operation metric used by Japan and an AEC metric , DOE is considering a n AEC metric which harmonizes with ENERGY STAR

.

T he weighting values associated with each measured mode of operation are necessary to create a representative AEC value

. A S /NZ S 5813:2012 and EU No. 617/2013 use the weightings specified by ENERGY STAR Computers V. 5.2, which are based upon a 2008 study by Microsoft 16 and do not distinguish between the s hort i dle and l ong i dle m odes. ENERGY STAR Computers V. 6.0 uses weightings based upon a 2010 study that was released along with ECMA

- 383 Ed. 3 . This study measures usage in both the s hort i dle and l ong i dle m odes, though it does not differ greatly from the Microsoft study in its weighting scheme. Table 4

- 1 lists t he mode weightings found in ENERGY STAR Computers V. 6.0 for comput ers without any network proxy functionality

. Table 4

- 1 : ENERGY STAR Computers V. 6.0 Modal Weightings, based on ECMA

- 383 Ed. 3

Mode Desktops * % Laptops

% Off 45 25 Sleep 5 35 Long Idle 15 10 Short Idle 35 30 Active 0 0 *Weightings for desktops also apply to integrated desktops and thin clients

The active mode of operation was assigned a 0% weighting because computers spend relatively lit tle time with significant CPU usage, and the ECMA

- 383 Ed. 3 study found that approximating active mode under short idle mode yielded accurate results for energy use

.

16 Microsoft Power Transition Report, 2008;

< www.energy star.gov/ia/partners/prod_development/revisions/downloads/computer/Microsoft_PowerTransitionRep ort.pdf?%%20f0fe

- 40d2 >26

Based on these reports, DOE is considering in cluding the A EC mode weightings and definitio ns based on ENERGY STAR Computers V. 6.0 for evaluating the energy consumption of computers

.

Item 4

- 3 DOE requests comment on the inclusion of ENERGY STAR Computers V. 6.0 mode weightings

.

4.1.4 Annual Energy Consumption Metric for Computers with a Network Proxy

N etwork proxy ing is a function that allows the computer to remain connected to a network through an intermediary while the computer is in a low power state such as sleep mode

. By giving the computer greater functionality in sleep mode, the network proxy may shift the amount of time spent in more energy consumptive operational mode s, such as long and short idle, to sleep mode. However, network proxying may also decrease the amount of time spent in off mode in exchange for time spent in sleep mode because of this add itional functionality.

The result of spending more time in sleep mode is that the computer may ultimately consume less energy. ENERGY STAR Computers V. 5.2 and V. 6.0 recognize the potential shift in mod al usage due to network proxy ing and off er different modal weightings based on the proxy’s functionality

. The ENERGY STAR Computers V. 6.0 weightings are shown in Table 4

- 2 and Table 4

- 3

. Table 4

- 2 : ENERGY STAR Computers V. 6.0 Modal Weightings with Proxy for Desktop,

Integrated Desktop and Thin Client Computers

Mode Conventional

% Base

Capability % Remote Wake

% Service/Name

Discovery % Full

Capability % Off 45 40 30 25 20 Sle ep 5 15 28 36 45 Long Idle 15 12 10 8 5 Short Idle 35 33 32 31 30

Table 4

- 3 : ENERGY STAR Computers V. 6.0 Modal Weightings with Proxy for Notebook Computers

Mode Conventional

% Base

Capability % Remote Wak e

% Service/Name

Discovery % Full

Capability % Off 25 25 25 25 25 Sleep 35 39 41 43 45 Long Idle 10 8 7 6 5 Short Idle 30 28 27 26 25

ENERGY STAR Computers V. 6.0 sets weightings based on four levels of proxy functionality

– base capability, remote wa ke, service/name discovery, and full capability . F or each successive level it increases the weight ing allocated to sleep mode and decreases the

we ight ing allocated to other mode s to compensate. The conventional weighting in ENERGY STAR Computers V. 6.0 is based on a robust study that was released along with ECMA

- 383 Ed. 3 in 2010.27

Item 4

- 4 DOE requests comment on adopting the ENERGY STAR Computers V

. 6.0 weightings for AEC based on network proxy functionality

. Specifically, DOE requests comment on the weighting valu es assigned to each proxy level.

While DOE is considering these network proxy modes for the DOE test procedure

, it is concerned that the difference in functionality may be difficult to discern. DOE requests comment on appropriate methods to identify a comp uter’s network proxy functionality that is not tied to the use of a specific software version

.

Item 4

- 5 DOE requests comment on a standardized and objective method to identify the level of proxy functionality on computers. Specifically, DOE welcomes information on steps that can objectively determine the proxy level on different OS s.

DOE is considering an alternate solution for network proxy functionality; a simplistic approach that only uses two network proxy modes, a conventional weighting for computers without an y network proxy functionality, and a weighting for computers with full network proxy functionality. DOE recognizes that this approach may not allow the computer’s network proxy functionality to be easily identified. Therefore, it is consider ing a weighting system without any network proxying , using only the conventional weightings specified in ENERGY STAR Computers V. 6.0

. DOE requests stakeholder feedback on an appropriate approach to address network proxying. DOE’s goal is to propose an approach that is r epresentative of the computer ’ s AEC

, yet simplistic enough so that network proxying can be easily identified.

Item 4

- 6 DOE requests comment on the best approach to address network proxying: (a) using four levels of weightings for proxy functionality as specified i n ENERGY STAR Computers V. 6.0 in addition to the conventional weightings; (b) using two levels of weightings, one for no network proxy functionality and the other for network proxy functionality; and, (c) using a single weighting for all computers.

Item 4

- 7 For ea ch of the approaches, DOE requests comment on the network proxy weighting that is representative of the computer ’ s AEC and is identifiable on all OS s.

4.2 Methods of Measurement for Computer Servers

4.2.1 Existing Regulatory and Voluntary Test Procedures

As an initi al step to develop a test method for computer servers, DOE evaluated the following existing programs:

(1) EU No. 617/2013 ;28

(2) Japanese Top Runner Program;

(3) South Korea Ministry of Knowledge Economy (MKE) Notification No. 2011

- 23, Regulation on Standby Power Redu ction Program

, e

- Standby program , February 2011 (Korea MKE No. 2011

- 23) ; and

(4) ENERGY STAR Computer Servers V. 2.0

. EPA collaborated with DOE to establish ENERGY STAR Computer Servers V. 2.0. This voluntary program targets blade, multi

- node, rack mounted, an d pedestal servers with four or fewer physical CPUs. It focuses on testing of idle and active states , but only sets levels for idle
state power measurements for qualification.

Of the other regulatory standards that DOE evaluated, EU No. 617/2013 does not include a test procedure

, and Korea MKE No. 2011

- 23 measures standby power of the products covered. T he most directly applicable standard for computer servers is ENERGY STAR Computer Servers V. 2.0 and the Japanese Top Runner Program

. The Japanese Top Runn er Program measures the energy consumption of the low power
state and idle mode

, but only provides general set

- up requirements like ambient temperature and supply voltage rather than specific measurement criteria. DOE is still considering these modes of
op eration for computer servers . However, due to the lack of detail in this procedure , DOE is not considering the Japanese Top Runner Program for the basis of its test procedure.

The ENERGY STAR Computer Servers V. 2.0 test procedure includes two distinct
tes ting paradigms: idle state and active state . The idle state test describes a methodology to determine a computer server ’ s power consumption while operating in an inactive state. The active state testing measures a computer server ’ s power consumption while it performs a variety of tasks that are representative of typical computer server applications. In the ENERGY STAR Computer Servers V. 2.0 test procedure , the active state test is performed using benchmarking software called Server Efficiency Rating Tool ( SERT), which is developed by Standard Performance Evaluation Corporation (SPEC). T he ENERGY STAR test method also provides comprehensive guidance for testing modern form

- factors such as blade and multi

- node computer servers. Because it is applicable to a w ide cross section of modern computer servers, and includes testing requirements for idle and active state power measurements, DOE is considering ENERGY STAR Computer Servers V. 2.0 as the basis for the computer servers test method

. Additionally, this prog ram has recently finished its second major version, which included a substantial level of stakeholder involvement during its development.

4.2.2 Proposed DOE Test Method for Computer Servers

To measure the energy consumption of computer servers, DOE is consideri ng measuring the power consumption only in active mode, which is defined in EPCA, as amended, as a condition in which an energy

- using product is connected to a mains power source, has been activated, and provides one or more main functions. (42 U.S.C. 6295 (gg)(1)(A)(i)29

A computer server would be considered to be in active mode when it is either in idle state or active state as defined in ENERGY STAR Computer Servers V. 2.0 . While ENERGY STAR Computer Servers V. 2.0 includes tests for both active and idle s tates, DOE is considering only the idle state energy consumption for the purposes of this rulemaking as discussed below

. DOE and EPA have worked closely with SPEC to aid in their development of an active state test, SERT, but because it is still in the ea rly stages of development, it may not be appropriate for DOE to incorporate this into a test procedure. The main disadvantage to the SERT workload is that it is currently not compatible with all computer servers. Additionally, it is unclear how an active s tate energy consumption value would be derived from the multiple output values of SERT. Further, DOE is not aware of any other active state test that can be performed on all computer servers that accounts for variation in product functionality.

Further, c omputer servers spend a considerable amount of time in idle state 17 and a study by Meisner, et al. 18 show s that deployed computer servers typically process workloads in bursts

– a brief period (few hundred milliseconds) of system activity

– which is followed by a comparably long period of inactivity. Based on DOE’s evaluation of the ENERGY STAR list of qualified products, Koomey’s analysis of product types 19 , and DOE’s assumptions on the utilization of consumer computer servers, DOE believes that the amount of energy observed by an idle state test represents a large portion of the total energy consumption of a computer se r ver. Therefore, DOE is considering adopting the idle state test method specified in ENERGY STAR Computer Servers V. 2.0 to determine the acti ve mode energy consumption of computer servers. The ENERGY STAR test method includes procedural and configuration requirements for determining the power consumption of computer servers while operating in idle state, which DOE is considering for this rulema king.

DOE is not considering energy consumption measurements in any other modes of operation for computer servers, including standby and off modes. EPCA, as amended, defines standby mode as the condition in which an energy

- using product is connected to the mains power source and offers one or more of the following functions: (a) to facilitate the activation or deactivation of other functions by remote switch, internal sensor, or timer; and (b) continuous functions, including information or status displays o r sensor based functions. (42 U.S.C. 6295(gg)(1)(A)(iii) With respect to computer servers, DOE believes that it would rarely be in standby mode. A computer server would be in standby mode after it is powered off and is capable of being powered on via a net work command using wake

- on

- LAN ( W O L ) . However, a computer server in such a state would be incapable of responding immediately to service requests or complete workload transactions. Being able to respond rapidly and reliably to requests at any time is one o f the computer server’s primary functions; it is designed to be on all

17 X. Fan, W.

- D. Weber, and L.A. Barroso, “Power Provisioning for a warehouse

- sized computer,” in Proc. of the 34 th Annual International S ymposium on Computer Architecture, 2007.

18 Meisner , D., Gold, B., Wenisch, T., PowerNap: Eliminating Server Idle Power . 2009. University of Michigan” Ann Arbor, MI.

19 Koomey, Jonathan. Growth in Data Center Electricity Use 2005

- 2010 . Analytics Press. 2011.30

the time. Therefore

, DOE expects that most computer servers rarely operate a standby mode, since it would take too long to respond to service requests.

A computer server would be consi dered in off mode if it has been powered off and can be powered on again only via a tactile switch or button on the computer server case. Many computer servers do not have such a switch to power off the computer server, therefore, DOE does not expect compu ter servers to have an off mode.

Item 4

- 8 DOE requests comment on the use of the idle state test from the ENERGY STAR Computer Servers V. 2.0 Test Method for computer servers as a base for the development of the computer servers test method

.

4.3 Methods of Measurement for Uninterruptible Power Supplies

4.3.1 Existing Industry Test Procedures

As an initial step to developing a test method for UPSs, DOE evaluated the following existing programs:

(1) IEC 62040

- 3 Ed. 2.0 ; and

(2) ENERGY STAR UPS V. 1.0

. Of these standards, the ENERGY STA R UPS V. 1.0 test method builds heavily on the IEC 62040

- 3 Ed. 2.0 standard, which has significant consensus among manufacturers in the industry. H owever, the ENERGY STAR test method offers additional guidance to implement IEC 62040

- 3 Ed. 2.0.

Both IEC 62 040

- 3 Ed. 2.0 and ENERGY STAR UPS V. 1.0 require the unit under test to achieve steady state before test measurements are made. ENERGY STAR UPS V. 1.0 further describes how to determine if steady state has been reached. IEC 62040

- 3 Ed. 2.0 does not explici tly provide any such instructions.

Further, ENERGY STAR UPS V. 1.0 requires input and output energies (in Wh) to be measured for a given interval. This measurement is then time averaged to obtain input and output power specification. The approach in IEC 6 2040

- 3 Ed. 2.0 is different and requires instantaneous and direct measurement of power using appropriate test equipment. The fundamental unit of measurement is therefore different.

Finally, IEC 62040

- 3 Ed. 2.0 provides efficiency allowances for external c omponents such as isolation transformers and input filters and provides detailed instructions on how to incorporate them into the test process. ENERGY STAR UPS V. 1.0 does not consider such external components as part of the system and therefore does not p rovide a lowered efficiency requirement to accommodate them.31

4.3.2 Proposed DOE Test Method for Uninterruptible Power Supplies

Of the standards DOE evaluated, the ENERGY STAR UPS V. 1.0 test method builds on that of IEC 62040

- 3 Ed. 2.0, but simplifies the qualif ication requirements using efficiency equations that extrapolate to UPSs of all power ranges. ENERGY STAR UPS V. 1.0 further simplifies the requirements by being voltage

- independent. DOE is considering referring to the IEC 62040

- 3 Ed. 2.0 test procedure fo r the purposes of the UPS test method

, with the inclusion of additional guidance outlined in ENERGY STAR V. 1.0 test method.

To analyze the energy efficiency of a UPS, both IEC 62040

- 3 Ed. 2.0 and ENERGY STAR UPS V. 1.0 require that power consumption be m easured with a reference test load that is 25%, 50%, 75% and 100% of the unit’s rated power. Each of these individual efficiency data point s is then weighted by a coefficient appropriate for that type of UPS and combined to determine the overall average ef ficiency of the unit. DOE will consider using a similar approach in its own test procedure rulemaking.

Item 4

- 9 DOE requests feedback on its adoption of the IEC 62040

- 3 Ed.2.0 standard as a basis for the development of the UPS test method, while considering additio nal guidance provided in ENERGY STAR UPS V. 1.0.

5. PRODUCT CLASSES

For the energy conservation standards rulemaking, DOE will consider efficiency standards for products that are within the scope of the test procedure rulemaking. However, DOE may or may not establish standards for all products that are in the test procedure scope.

As part of the analysis for developing an energy conservation standard, DOE is required by EPCA to achieve maximum energy efficiency improvements that are economically and technolog ically feasible. As part of this process

, when necessary, DOE establishes product classes that group products with similar characteristics together for the purpose of establishing appropriate standard levels for each product class

. DOE divides covered prod ucts into classes by: (a) the type of energy used; (b) the capacity of the product ; or (c) any other performance

- related feature that justifies different standard levels, such as features affecting consumer utility. (42 U.S.C. 6295(q))

For the computer sy stems energy conservation standards rulemaking, DOE proposes that product classes be determined on the basis of form factor and functionality delivered to the

consumer . Product classes are particularly effective for establishing energy conservation standar ds when the power consumption varies between different product types. For instance, there is considerable variation in the power consumption between desktop computers

, notebook computers, rack servers

, and blade servers, which requires different standard l evels. The following sections discuss some of the options for product classes for computers, computer servers, and UPSs.32

Item 5

- 1 DOE requests comment on the proposed approach for determining computer systems product classes

. DOE welcomes comments on any design cha racteristics that should be considered when establishing product classes.

5.1 Computer Product Classes

5.1.1 Existing Voluntary and Regulatory Standards

As part of the rulemaking process, DOE is evaluating product class structures in existing industry and regulatory programs. AS/NZS 5813:2012 and EU No. 617/2013 utilize a categorization for desktop, integrated desktop, and notebook computers that i s based on ENERGY STAR Computer s V. 5.2. However, these international standards also use the graphics AEC allowance struc ture from ENERGY STAR Computers V. 6.0

. This specification mirrors ECMA

- 383 Ed. 3 and offers seven different energy allowance levels based on graphics performance. All of these standards provide additional AEC allowances for other performance features. Alt hough there are some subtle differences between the classification systems in these standards , all use the same fundamental principles of establishing a base category , and further separating products based on performance and capabilities.

DOE also evaluat ed the Japanese Top Runner Program

, which uses a unique method of categorizing computer product classes. Japanese product classes for desktop and notebook computers are based on memory channels

, memory capacity, graphics cards, and screen size

. The program regulate s these classes based on a maximum watts

- per

- operation metric , compared
to the minimum AEC allowance used by other standards. Because this structure is so different from other existing standards, considering this methodology may confuse and hinder efforts to develop a US Federal standard. Therefore, DOE is considering a product class structure which build s upon ENERGY STAR Computers V. 5.2 and V. 6.0, due to their influence on multiple industry and regulatory programs

. While DOE is considering this structure, it will perform its own analyses to determine the minimum efficiency standards and will not directly use the standard specified in ENERGY STAR or other programs.

5.1.2 ENERGY STAR Computer s V. 5.2 Product Overview

ENERGY STAR Computers V. 5.2 separat es desktop, integrated desktop, and notebook computers into several categories based upon CPU performance, graphics processing unit (GPU) type, discrete graphics bandwidth, and system memory

. Table 5

- 1 shows these categories. Each category is associated with a base requirement value

, which is then subject to additional energy allowances for memory, graphics, and storage. Table 5

- 2 shows these allowance classifications for ea ch category

.33

Table 5

- 1 : ENERGY STAR Computers V. 5.2 Categories for Desktop, Integrated Desktop, and Notebook Computers

Cat egory Description

Desktops and Integrate d Desktops A Does not meet category B, C, or D

B CPU = 2 Physical Cores , and

Memory ≥ 2 gigabytes ( GB )

C CPU > 2 Physical Cores , and

(Memory ≥ 2 GB ) or (Discrete GPU)

D CPU ≥ 4 Physical Cores, and (Memory ≥ 2 GB) or (GPU bandwidth (BW) > 128 bits)

Notebooks A Does not meet category B or C

B Discrete GPU

C CPU ≥ 2 Physical Cores

, Memory ≥ 2 GB , and GPU BW > 128 bits34 Table 5

- 2 : ENERGY STAR Computers V. 5.2 Allowance Classification

Category Memory Allowance Graphics Allowance Storage Allowance

Descriptio n Allowance

kWh Description Allowance kWh Description Allowance kWh

Desktops and Integrated Desktops A Memory ≤ 2 GB 0 GPU BW ≤ 128 bits 35 Hard drive ≤ 1 0
Memory > 2 GB 1. 0*(Mem

– 2) GPU BW > 128 bits 50 Hard drive > 1 25

B Memory ≤

2 GB 0 GPU BW ≤ 128 bits 35 Hard drive ≤ 1 0
Memory > 2 GB 1. 0*(Mem

– 2) GPU BW > 128 bits 50 Hard drive > 1 25

C Memory ≤

2 GB 0 GPU BW ≤ 128 bits 0 Hard drive ≤ 1 0
Memory > 2 GB 1. 0*(Mem

– 2) GPU BW > 128 bits 50 Hard drive > 1 25

D Memory ≤

4 GB 0 GPU BW ≤ 128 bits 0 Hard drive ≤ 1 0
Memory > 4 GB 1. 0*(Mem

– 4) GPU BW > 128 bits 50 Hard drive > 1 25

Notebooks A Memory ≤ 4 GB 0 Hard drive ≤ 1 0
Memory > 4 GB 0.4*(Mem

– 4) Hard drive > 1 3

B Memory ≤

4 GB 0 GPU BW ≤ 64 bits 0 Hard drive ≤ 1 0

Mem ory > 4 GB 0.4*(Mem

– 4) GPU BW > 64 bits 3 Hard drive > 1 3

C Memory ≤

4 GB 0 Hard drive ≤ 1 0
Memory > 4 GB 0.4*(Mem

– 4) Hard drive > 1 3

DOE is evaluating the potential impact of ENER G Y STAR Computers V. 5.2’s categorization structure. Category A is treated as a catch

- all for products that do not meet the criteria for other categories , and can include great variation among products. Although DOE is considering this classification system, DOE may need to add specificity to avoid such large variat ion within Category A. The additional criteria may also need clarification to avoid product class overlap. Although the intention is that a product qualifies in one category only , it may be confusing if they meet the criteria for multiple categories. DOE t ypically implements product classes which are mutually exclusive of one another to set clear boundaries between included and excluded products. For example, this could be done by stating a computer meeting multiple categories would be only included in the highest letter category it can meet.

Implementing a similar structure in a rulemaking using all combinations of categories and additional product features (such as, graphics processing unit, storage, memory, etc.) could result in more than 50 product clas ses, so it is imperative that the classification system is well organized and each class is clearly defined. DOE is evaluating different methods of organizing these products to ensure that all necessary features are accounted for, and that product utility is not penalized by a more rigorous standard level.35

In addition to categories for desktop, integrated desktop, and notebook computers, ENERGY STAR Computers V. 5.2 also includes categories for small

- scale servers and thin clients (as shown in Table 5

- 3 )

. These products utilize a more simpl e structure
, which has two categories and an energy allowance for WOL. This is further refined for w orkstations , which only have a base category and obtain an energy allowance for additional hard drives. DOE sees value in a simplistic approach and may consider a similar structure when developing product classes for small

- scale servers and workstations , if these products are included in scope

. Table 5

- 3 : ENERGY STAR Computers V. 5.2 Categories for Small

- scale Servers and Thin Clients

Cat egory Description

Small

- Scale Servers A Does not meet category B

B Memory ≥ 1 GB, and

CPU ≥ 1 Physical Cores or CPU ≥ 1 discrete processor

Thin Clients A Does not meet category B

B Supports local multimedia encoding/decoding

Item 5

- 2 DOE requests comment on the categorization criteria for the ENERGY STAR Computers V. 5.2 product categories

.

Item 5

- 3 DOE requests comment on the memory, graphics, and storage sub

categorization and energy allowances from ENERGY STAR Computers V. 5.2

.

5.1.3 ENERGY STAR Computers V. 6.0

ENERGY STAR Computers V. 6.0 contains six categories for desktop, integrated desktop, and notebook computers

, shown in Table 5

- 4 and Table 5

- 5 . Additionally, each product with discrete graphics is eligible for one of seven different graphics allowances based on its bandwidth speed

, as shown in Table 5

- 6 . Allowances are also added for computers with switchable graphics processors, E nergy

- E fficient Ethernet ( EEE )

, high

- efficiency power supplies, WOL, integrated displays, enhanced performance displays , additional storage, and
memory

.36

Table 5

- 4 : ENERGY STAR Computers V. 6.0 Base Categories for Desktop and Integrated Desktop Computers

Graphics Type Base Category Performance Score* Allowance kWh
Any 0 P ≤ 3 69

Integrated I1 3 < P ≤ 6 112

I2 6 < P ≤ 7 120

I3 P > 7 135

Discrete D1 3 < P ≤ 9 115

D2 P > 9 135

* Performance score (P) = (# CPU cores) × (CPU clock speed in gigahertz )

Table 5

- 5 : ENERGY STAR Computers V. 6.0 Base Cate gories for Notebook Computers

Graphics Type Base Category Performance Score* Allowance kWh
Any 0 P ≤ 2 14

Integrated I1 2 < P ≤ 5.2 22

I2 5.2 < P ≤ 8 24

I3 P > 8 28

Discrete D1 2 < P ≤ 9 16

D2 P > 9 18

* Performance score (P) = (# CPU cores) × ( CPU clock speed in gigahertz)

Table 5

- 6 : ENERGY STAR Computers V. 6.0 Discrete Graphics Allowance

Graphics Category GPU Bandwidth (BW) Desktops Allowance kWh Notebooks

Allowance kWh

G1 BW ≤ 16 36 14

G2 16 < BW ≤ 32 51 20

G3 32 < BW ≤ 64 64 26

G4 64 < BW ≤ 96 83 32

G5 96 < BW ≤ 128 105 42

G6 BW > 128 (Data Width < 192) 115 48

G7 BW > 128 (Data Width ≥ 192) 130 60

DOE evaluated the ENERGY STAR Computers V. 6.0 product classification structure. Th e perfor mance score (number of cores times clock frequency) is used along with the graphics37

capability to determine the category, as seen in Table 5

- 4 . Additionally, DOE is considering the expanded graphics categories in Table 5

- 6 in comparison to the graphics allowances in ENERGY STAR Computers V. 5.2. DOE is seeking input on the most appropriate way to characterize commercially available GPUs and their associated power consumption

. Typically

, ENER G Y STAR grants energy allowances based on product features that consume more energy while simultaneously increasing functionality. However, EEE , high

efficiency power supplies, and switchable graphics processors, are incentivized by offeri ng such energy allowances even though they do not increase the energy consumption of the product, and in some cases, reduce the energy consumption. DOE will evaluate these features in more detail, to determine whether they warrant separate product classes.

In addition to storage and memory

, DOE is considering integrated displays and enhanced performance displays as features that may merit separate product classes

, because these features offer an additional utility to the consumer . The display

- related featu res are scaled with the screen size in ENERGY STAR Computers V. 6.0 because larger screens typically require more energy. DOE is also open to considering other classification criteria and product features which have utility to the consumer such that an add itional p roduct class should be established

.

Item 5

- 4 DOE requests comment on whether the CPU performance metric effectively classif

ies the performance of a CPU

.

Item 5

- 5 DOE requests comment on the granularity of seven graphics categories consistent with the market of ava ilable GPUs

.

Item 5

- 6 DOE requests comment on the enhanced performance display and integrated display performance features

.

Item 5

- 7 DOE requests comment on the absence of product categories for thin clients and small

- scale servers

.

5.2 Computer Server Product Classes

ENERGY S TAR Computer Servers V. 2.0 defines product categories based on form factor, creating different classes for pedestal s ervers, rack servers, blade s ystems
, and multi

node servers. Within each of these product categories , ENERGY STAR Computer Servers V. 2.0
account s for variation in energy consumption and additional functionality by dividing them into sub

- categories (see Table 5

- 7 ). Sub

- categories are distinguished by the number of physical CPUs as well as criteria f

or a managed server. Further, ENERGY STAR grants allowances based on certain product features such as number of power supplies, additional memory and hard drives, and input/output devices. DOE recognizes that using sub

- categories is necessary to account fo r variations in power consumption and product features, but may decide to use additional criteria for such categories

. DOE will perform its own analyses to determine the standard. DOE’s criteria to distinguish consumer computer servers will also be conside red when determining product classes.38 Table 5

- 7 : ENERGY STAR Computer Servers V. 2.0 Categories

Category Max Number of

Installed Processors Managed Server Base Power Allowance (W)

A 1 No Max Power A

B 1 Yes Max Power B

C 2 No Max Power C

D 2 Yes Max Power D

Resilient 2 Yes Max Power Resilient
Other possible strategies could include product classes based on application types or hardware features such as number of processors, redundancy features or storage capacity. DOE may also consider a metric

- score based approach, similar to the performance score used in ENERGY STAR Computers V. 6.0.

Item 5

- 8 DOE requests comment on possible strategies for computer server product classes. DOE requests comment on possible advanta ges and shortcomings of using the ENERGY STAR Computer Server s V. 2.0 classification criteria for the purpose of this rulemaking

.

5.3 Uninterruptible Power Supplies Product Classes

DOE is considering the adoption of ENERGY STAR UPS V. 1.0’s classification for UPSs but will perform its own analyses to determine the standard . The ENERGY STAR UPS V. 1.0 program sets minimum average efficiency requirements based on the following characteristics:

(1) UPS topology: A variety of UPS technologies exist to satisfy user requ irements for continuity and quality of power. Most consumer UPSs can be classified into three basic topologies: VFD, VI and VFI. Each topology offers improved efficiency and protection against input power variation respectively. The following are brief def initions of these three topologies that DOE is considering to use as the basis for UPS prod uct classes in this rulemaking.

(a) A VFD topology, also known as a standby/offline UPS, provides the most basic of features such as protection against an input power ou tage. Because this internal power conversion takes place only in the event of an outage, a standby UPS is also considered the most efficient. However, a standby UPS is unable to protect against sustained dips or surges i n input voltage and frequency.

(b) A VI topology , also known as a line interactive UPS, performs all the functions of a standby/offline UPS with the added capability of maintaining output power in the event of a prolonged under or over

- voltage condition in input power. A line interactive UPS is unable to correct against variations in input frequency.39 (c) A VFI topology, also known as an online or double

- conversion UPS, is capable of protecting a connected device not only against power outages but also against all voltage and frequency fluctuations. T he topology does this by converting input AC power to DC in order to charge the internal battery and then re

converting the battery’s DC voltage to AC using an inverter. Because this double

- conversion takes place continuously, a VFI UPS is inherently less efficient than a VFD or VI unit but provides electrical isolation.

(2) UPS rated output power: Efficiency of a UPS decreases with increasing rated output power. ENERGY STAR UPS V. 1.0 therefore provides efficiency allowances for UPS i n three distinct power rat ings:

(a) P ≤ 1500W

(b) 1500W < P ≤ 10,000W

(c) P > 10,000W

(3) UPS output type: UPSs that output DC power replace the output inverter with a power supply to achieve the desired DC voltage. As such, different efficiency allowances may be required for a DC

- output UPS as co mpared to one with an AC output.

(4) Additional Features: Additional features such as metering and communication capability may warrant different product classes. DOE will investigate the energy consumption of units with and without these additional features to understand the marginal impact on efficiency.

Table 5

- 8 and Table 5

- 9 show ENERGY STAR’s minimum average efficiency requirement based on the above product classificatio n for AC and DC output UPSs, respectively. DOE will not directly use the standard specified in ENERGY STAR, but will consider the criteria and classification requirements for its analyses.

Table 5

- 8 : ENERGY ST AR UPS V . 1.0 Efficiency Levels for AC

- Output UPS

Input Dependency
Rated Output Power VFD VI VFI

P<1500W 0.967
1500W<P<10,000W 0.97 0.967 0.0099 x ln(P) + 0.815
P>10,000W 0.97 0.95 0.0099 x ln(P) + 0.805
P>10,000W
(with Metering and Communication) 0 .96 0.94 0.0099 x ln(P) + 0.79540

Table 5

- 9 : ENERGY STAR UPS V. 1.0 Efficiency Levels for D C

- Output UPS

Without Metering and Communication 0.955
With Metering and Communication 0.945

Item 5

- 9 DOE requests comment on possible advantages and shortcomings of using the ENERGY STAR UPS V. 1.0 product classification criteria for the purpose of this rulemaking.

6. MARKET AND TECHNOLOG Y ASSESSMENT

The market and technology assessment provides information about the computer syst ems industry and the performance attributes of this product . DOE uses this assessment to determine product classes and identify potential design options or efficiency levels for each product class.

6.1 Market Assessment

The market assessment identifies compute r systems manufacturers, estimates market shares and trends, and addresses regulatory and non

- regulatory initiatives intended to improve the energy efficiency or reduce the energy consumption of computer s ystems

. This allows DOE to gather data that can hel p identify important issues in other phases of its analysis ( e.g. , potential small business impacts, competitive disruptions, and other factors that may arise from enacting standards). The market structure data may also be used in the manufacturer impact a nalysis to

assess the competitive impact by products and manufacturers

. DOE recognizes that there may be limited market information regarding recent trends of national shipments, manufacturing costs, channels of distribution, and manufacturers’ market sha res of computer

, computer servers
, and UPSs , and t herefore encourages interested parties to submit data that pertains to these issues and would aid DOE’s understanding of trends in the se market s

. This data is important for analyses that determine if energy conservation standards are economically justified or will result in significant energy savings.

Stakeholders may submit confidential data to DOE, indicating in writing which data should remain confidential. To prevent public disclosure of the data due to actions taken by a third party, interested parties providing confidential information to DOE must submit that data according to 10 CFR 1004.11. Under 10 CFR 1004.11, any person submitting information that he or she believes to be confidential and exempt by law from public disclosure should submit two copies. One copy of the document shall include all the information believed to be confidential, and the other copy of the document shall have the information believed to be confidential deleted. DOE will make i ts own determination about the confidential status of the information and treat it according to its determination. DOE prepares aggregated results from the data submitted for use in DOE’s analyses. These aggregated results do not divulge the sensitive
natu re of the individual raw data, but enable other interested partie s to review and comment on the aggregated dataset.41

Item 6

- 1 DOE requests information that would contribute to the market assessment for computers , computer servers , and UPSs that would be covered in this rulemaking

. DOE particularly seeks information on shipments, trends in product feature and efficiency, distribution channels and estimates of market shares for the computers

, computer servers , and UPSs considered in this rulemaking.

6.1.1 Market Assessment for Computers

DOE performed a n initial analysis of computer market data to evaluate the number of products shipped annually and their market share. DOE’s initial analysis suggests that the overall number of desktop, laptop, and tablet computer shipments is expected to experience significant growth in the coming years 20 (see Figure 6

- 1 ). However, a majority of the expected growth is due to the increase in tablet computer shipments while desktop and laptop computer shi pments are expected to level off and experience a slight decrease. However, the U

. S

. market has maintained consistent shipment levels since the emergence of tablet computers in the recent
years 21

, and still represent s a large energy use based on their volum e.

Figure 6

- 1 : Current and Projected Device Shipments by Year

Source: Arthur, Charles. Microsoft threatened as smartphones and table t s rise, Garner warns. The Guardian. 2013.

6.1.2 Market Assessment for Computer Servers

Similarly, DOE analyzed market data for computer se r vers . This analysis revealed a slight global decline in both shipments and revenues between the third quarters of 2012 and

20 Arthur, Charles. Microsoft threatened as smartphones and tables rise, Garner warns

. The Guardian. 2013.

< http://www.theguardian.com/technology/2013/apr/04/mic rosoft

- smartphones

- tablets >

21 Gartner Says Worldwide PC Shipments in the Third Quarter of 2013 Decline 8.6 Percent. Gartner. 9 October 2013. < http://www.gartner.com/newsroom/id/2604616 >42

2013. Between these periods, worldwide shipments of computer servers dec lined by only 0.4 percent (from 2.27 million to 2.26 million) as illustrated in Figure 6

- 2 , whereas global revenues declined by 3. 7 percent (from $12,559 million to $12,085 million) 22 marking the third consecutive q uarter of year

- over

- year revenue decline

. The International Data Corporation ( IDC ) attributes this decline in part to the anticipation of a forthcoming platform refresh in early 2014

, but also cites the continued focus of enterprise server customers to use virtualization, consolidation and migration alternatives to increase efficiency and lower infrastructure costs as a

cause of contraction in the market for computer servers

. 23

Figure 6

- 2 : Worldwide Quarterl y Server Shipments (3Q12 to 3Q13)

Source : IDC Worldwide Quarterly Server Tracker, December 2013.

6.1.3 Market Assessment for Uninterruptible Power Supplies

DOE also analyzed market data for UPS

. In 2005, the market value for UPS was estimated to be worth $5 bill ion with the United States comprising half of the total market value

. 24 T he global market for UPS grew to over $8 billion in 2008 led by growth in Asia Pacific markets of between 15 percent and 20 percent annually

. 25 In contrast, the US market was forecast t o grow at a rate of only 4 percent annually through 2010 24

. As of 2011 , the global UPS market was expected to rebound to 2008 levels by as soon as 2012 25 , and to gr ow to $14 billion

22 Eastwood, M., Scaramella, J., Stalarski, K., and Shirer, M. Worldwide Server Market Revenues Decline

- 3.7% in the Third Quarter as Weak Unix Server Demand Weights on the Market, According to IDC

.
23 Worldwide Server Market Revenue Decline

- 6.2% in Second Quarter as M arket Demand Remains Weak, According to IDC. IDC. 2013 < http://www.idc.com/getdoc.jsp?containerId=prUS24285213 >

24 Trends in UPS Systems , Electrical Contractor Magazine, November 2005 ( h ttp://www.ecmag.com/section/your

business/trends

- ups

- systems ).

25 UPS Revenues top $7 billion... again , IHS, March 2011 ( https://technology.ihs.com/479736/ups

- revenues

- top

- 7

- billion

- again ).43

by 2017 26

. However, a slowdown in fourth quarter sales of UPS in 2011(as illustrated in Figure 6

- 3 ) led into flat performance in 2012 27 , casting doubt on the market reaching the levels previously fo recast.

Figure 6

- 3 : World UPS Market Development

Source : IMS Research, February 2012
Growth in the global UPS market is driven in part by increasing virtualization and the convergence of voice and data netw orks

. Additionally, recognition of the cost of not protecting communications infrastructure and IT systems when utility outages do occur are fueling additional growth in areas with otherwise unreliable power systems. 24

, 25

6.2 Technology Assessment for Computers

The technology assessment evaluates all available technology options that may be capable of reducing the power consumption of computers. DOE works with stakehold ers and industry affiliates to develop a comprehensive list of options that include commercially available technologies as well as working prototypes. DOE also evaluates manufacturer websites, trade publications, and technical journals for additional optio ns. The technology options are used as examples of energy saving techniques in the screening and engineering analysis. They provide an

26 Global Uninterruptible Power Supply (UPS) Systems Market to Reach U S$14 Billion by 2017

, Global Industry Analysts, Inc., November 2011 (http://www.prweb.com/releases/uninterruptible_power/supply_UPS_systems/prweb8953934.htm)

.
27 UPS Service Market Flat in 2012; First Quarter Indicates a Better 2013 , IHS, June 2013 ( https:/ /technology.ihs.com/479688/ups

- service

- market

- flat

- in

- 2012

- first

- quarter

- indicates

- a

- better

- 2013 ).44

optional avenue to achieve certain energy saving levels but are not mandatory to implement. The engineering analysis of t hese technology options also helps to justif y the CSLs which DOE has selected.

Based on an initial review of hardware and software options for computers

, DOE has identified the following technology options as having potential to improve the efficiency of computers

.

6.2.1 Efficient Power Supplies

The i nternal and external power supply unit (PSU) can consume a significant amount of
energy as a result of efficiency losses and a low power factor. Efficient PSU designs and power factor correction reduce the overall energy consumption of the computer. V oluntary power supply standards like ENERGY STAR and the 80 PLUS program 28 aim at improving PSU
energy efficiency by setting voluntary standard limits

. The Federal external power supply standard implemented by DOE in Feb ruary 2014 will also contribute to efficiency gains for PSUs of notebooks and other computers with external supplies. See 79 FR 7846 (February 10, 2014).

6.2.2 Efficient Hard Drive s
The power consumption of a computer hard drive can be decreased in different way s. One option is a hard disk drive (HDD) that has fewer rotations per minute (RPM) than a standard HDD. Low RPM HDDs typically sacrifice performance for lower power consumption. This type of HDD may also have variable RPM, allowing high

- performance tasks t o increase the RPM (and power consumption) of the drive.

A nother method is to replace or supplement the traditional HDD with a solid

- state drive (SSD). SSDs operate using flash memory instead of a spinning hard disk and require significantly less power. I n addition to increases in efficiency, SSDs are faster, more durable, and are available in smaller form factors

. SSDs can be used as the sole hard drive or in conjunction with an HDD for storing the computer OS while the HDD handles other data storage. A s ystem with both an SSD and HDD can achieve some of the performance and power savings of SSD systems at a lower cost. The difference in cost has prevented SSDs from becoming standard in computers, though as technology advances and prices come down they are becom ing increasingly common

. There are also hybrid approaches where the portion of the drive accessed more frequently is stored as an SSD, and the rest of the drive is stored as an HDD. This allows for some energy savings at reduced costs.

28 80 PLUS Certified Power Supplies and manufacturers. < www.plugloadsolutions.com/80P lusPowerSupplies.aspx >45

6.2.3 Energy

- Efficien t Ethernet

EEE can be used as a method of decreasing the power consumption of Ethernet ports on a computer , and is standardized by the Institute of Electrical and Electronics Engineers (IEEE) Standard 802.3az

. 29 EEE saves energy over standard Ethernet by pl acing the Ethernet port into a low

- power state when not in use. EEE also allows energy to be saved by detecting the cable length to vary the signal power transmitted over the cable, instead of simply transmitting a signal for the maximum rated Ethernet cab le length.

6.2.4 Passive Cooling

Cooling is a necessary part of the computer architecture and without an adequate cooling system , CPUs and other core components can experience damage from overheating. Lowe r power CPUs and SSDs can alleviate the need for high pow er fans making way for passive cooling systems. Splitted

- Desktop Systems has demonstrated a technology prototype for cooling a CPU using convection airflow with no moving parts, saving energy from fans while maintaining comparable cooling performance

. 30 Thi s design has form

- factor restrictions that may limit it to desktop computers.

6.2.5 ACPI

- Compatible Devices

Advanced Configuration and Power Interface ( ACPI ) is a specification for the power management of a computer by introducing low power states to the system as a whole, the processor, and individual components . While most modern OS s support ACPI functionality, the computer ’s basic input/output system (BIOS) must be ACPI

- compliant in order to experience
any power reduction . In addition, individual components mu st be ACPI

- compatible to benefit from software and firmware power regulat ion . Manufacturers may therefore decrease the power consumption of computers by choosing ACPI

- compatible components

.
6.2.6 Switchable Graphics

Computers with a discrete GPU devote significa ntly more power to graphics processing than those with a graphics card integrated onto the motherboard. However, discrete graphics have higher performance and may be necessary for the computer application. In these cases, power can be saved by implementing switchable graphics. During low graphic demand

, the computer use s the integrated graphics processor to reduce power demands , and switch to the discrete graphics card under high graphic demands

.

29 Institute of Electrical and Electronics Engineers (IEEE) 802.3az

- 2010

- Standard for Information technology

— Local and metropolitan area networks

— Specific requirements

— Part 3: CSMA/CD Access Method and Physical Layer Specifications Amendment 5: Media Access Control Parameters, Physical Layers, and Management Parameters for Energy

- Efficient Ethernet.

30 Kirsch, N. Splitted

- Desktop Shows Fanless Sandy Bridge Cooling At IDF 2011. Legit Reviews. September 2011.

< www.legitreview s.com/splitted

- desktop

- shows

- fanless

- sandy

- bridge

- cooling

- at

- idf

- 2011_1710 >46

6.2.7 Dynamic Voltage and Frequency Scaling

A transistor is the fu ndamental element in the circuitry of a computer, allowing components to switch between high and low logic states for computation and memory

. The switching power of a transistor is proportional to both the clock frequency and the square of the supply volta ge at the gate. Correspondingly, one method to decrease power consumption in the transistor circuitry is to decrease the supply voltage of the chip and the clock speed. An additional benefit of decreasing the supply voltage is a decrease in the amount of h eat generated by the chip, keeping the computer at a more efficient lower temperature. Lowering the voltage does not necessarily affect performance on its own, as long as the transistor can handle the lower voltage, but oftentimes it can decrease the relia bility of the circuit as the gate voltage may change between levels at a slower rate

. To mitigate the reliability risks, the switching frequency of the circuit may be lowered. While a decrease in frequency also decreases power consumption, it slows the pr ocessing speed for lower performance and is generally only used when high performance tasks are not being run. This can be done in a dynamic way depending on the processing task at hand. Overall, v oltage and frequency scaling may be used in any circuitry o f the computer, though it is most often implemented on the CPU.

6.2.8 Resilient Circuitry

Similar to the reasoning behind dynamic voltage and frequency scaling, the power of transistors can be reduced by decreasing the buffer between the supply voltage and the m inimum voltage for a high logic state . Decreasing this safety band also decreases reliability as it increases the possibility for the transistor voltage to be indistinguishable, neither high nor low. Intel has designed a method for circuit error correction that recalculates a flagged operation with a slight delay

. 31 Th e circuit resiliency allow s a smaller voltage buffer margin and lower power consumption. This technology may still be in prototype phase.

Item 6

- 2 DOE requests comment and/or information on the current technological status of error

- resilient circuitry.

6.2.9 Clock Gating

Clock gating is a method in which the clock signal is deliberately withheld from certain components when they are not in use. In a traditional circuit, the clock signal would be received by ev ery component regardless of whether a change in state was needed, causing the component status to refresh and consume switching power. However, a component with a gated clock do es not receive a signal instructing them to refresh and the refore the transisto r remain s at the same

31 Hachman, M. Intel’s Power Research: ‘Resilient Circuits’, ‘ProxZzzy’. PCMag.com. March 2010.

< www.pcmag.com/ar ticle2/0,2817,2361563,00.asp >47

status and does not draw additional power . Depending on the computer’s activity and the required componentry

, clock gating can have a n impact on power consumption.

6.2.10 CPU Utilization Management

When a CPU is not performing any active tas ks it is considered to be idle. Generally, the more time a CPU spends in idle mode the less power it consumes. To optimize the time spent in idle, the CPU may decide to run the clock faster during a task to finish it more quickly and return to the idle sta te. However, the processor will be consuming more power than it would have been otherwise while performing the task. This “race

- to

- sleep” approach may only decrease power consumption if the time spent in idle counteracts the additional power used to run th e processor at a higher voltage and faster frequency, requiring proper utilization management for effective implementation

.

6.2.11 Suspended State to Flash

Both Intel and Advanced Micro Devices (AMD) have developed technolog ies to quickly

resume a computer’s on m ode from a low power state. While sleep mode keeps the computer state suspended to the memory for quick wake, a lower power hibernation state can be achieved by suspending the computer state to the hard drive and powering down the memory. A typical hiberna tion state requires a longer time to resume than a sleep state, but this flash storage quick start technology involves s uspending the computer state to a high speed SSD, decreasing this latency. The SSD does not have to be the main hard drive and may be a small drive working in conjunction with a large HDD. This technology allows the compute r to be placed in a lower
power hibernation state with a latency that is less than or equal to a higher power sleep mode. It also benefits performance by protecting the computer state in the event of a power failure during

non

- operation and allowing faster resume while using sleep mode.

6.2.12 Internal Network Proxy

As discussed in section 4.1.4 , a network proxy allows a computer’s ne twork functions to be operated in low power modes. This allows the computer to be put into a low

- power state even when the computer needs to stay online . It also prevents the computer from being unnecessarily woken up in response to a network request that can be handled by the proxy. Overall, the activity of an internal network proxy allows the computer to save power by spending a greater amount of time in sleep mode instead of on or idle modes.

6.3 Technology Assessment for Computer Servers

Personal c omputers and computer servers are very similar products because they share similar architecture, componentry, and only differ in the ir intended application s. Computer servers are designed for high performance applications and reliability but still require the same core componentry as their multi

- media based counterpart s . Because of these inherent similarities, computer servers can benefit from the same technology options as personal computers including: (1) Efficient power supply unit (section 6.2.1 ) (2) Variable speed HDDs and SSDs ( section 6.2.2 )48

(3) Dynamic voltage and frequency scaling (section 6.2.7 ) (4) Clock gating ( s ection 6.2.9 )

In addition to these shared technology options, computer servers can also benefit from the following design options

.
6.3.1 Fan Speed Control Algorithms

Equation 6

- 1 : Relationshi p between power consumed by fan and fan speed

Where:

: Power consumed by fan

: : Instantaneous speed of fan

The power consumed by fans has a cubic relationship with fan speed. Therefore, a creative fan speed control scheme 32 can save a significant amount of energy consump tion by lowering the fan speed. 33

6.3.2 Management Interface Low

- Power States

When not in active use, the server management interface card can be induced to a lower power state through power an d/or clock gating non

- essential components of the management interface, similar to the C

- states in the microprocessor

.
6.4 Technology Assessment for Uninterruptible Power Supplies

6.4.1 Semiconductor Improvements

DOE’s preliminary review of existing and forthcoming UPS technologies has shown improved energy consumption levels compared to traditional designs. Customer demand for increased reliability and reduced total cost of ownership (TCO) has led manufacturers to design efficient UPSs with more robust components. I mprovements in semiconductor technology has paved the way for insulated gate bipolar transistors (IGBT) that offer increased current carrying

32 Kim, J., et al. Global Fan Speed control considering Non

- Ideal Temperature Measurements in Enterprise Servers

. EDAA. 2014.

33 Shin, D., et al.

, Energy

- optimal dynamic thermal management for green computing in Proc . ICCAD, 20 09

.49

capability, faster switching speeds, smaller footprint and reduced overall cost. This technology is poised to repl ace inefficient silicon controlled rectifier (SCR) switches traditionally used. 34

6.4.2 Digital Signal Processing and Space Vector Modulation

Digital signal processing (DSP), space vector modulation (SVM) and fast switching transistors in UPSs now allow for int elligent switching that can adapt faster to changing input and output conditions. 35 This allows UPSs to reduce inefficient switching modes with lighter loads

– an operating point where UPSs are known to be sub

- optimal.

6.4.3 Transformer

- less UPS Topologies

Trans former

- less UPS topologies which are now possible also due to DSP and IGBT, reduce these harmonic distortions further while improving overall UPS energy consumption by removing the line

- frequency transformer popular in conventional designs. Additionally,
t ransformer

- less UPS designs improve input power factor and reduce weight and overall footprint

– all of which may be a cost burden for consumers. 36

Powering a device using a UPS is inherently less efficient when compared to running the same product directly from AC mains. This is primarily due to the additional power conversion processes involved. However, most UPSs, depending on their construction, will condition, isolate and filter adverse currents which reduce the burden on the AC mains network. 37 This add itional utility may outweigh the inefficiencies of a UPS by reducing the cost burden of conditioning a noisy power line for sensitive digital electronics in the vicinity.

Item 6

- 3 DOE welcomes comments on the preliminary technology options for computer systems iden tified in this section and whether there are other technology options it should consider. In commenting on technology options, please discuss their impacts, if any, on safety, performance, and user utility, as well as cost of the technology options.

7. SCREEN ING ANALYSIS

The purpose of the screening analysis is to screen out technology options that DOE will not consider in its potential energy conservation standard for computer s ystems . At the outset, DOE develops a list of technology options for consideration through its own research and in consultation with interested parties. Development of the list is based on the technologies

34 Richard L. Sawyer, Making Large UPS Systems More Efficient , APC White Paper #108, 2006.

35 Trends in UPS Systems , Electrical Contractor Magazine, November 2005.

36 Ian F Bitterlin, Benefits of transformer

- free UPS topology: myth or reality? , Chloride U PS Systems, July 2010.

37 Yam Hong, Future Trends: The Transformerless UPS , Schneider Electric.50

described in section s 6.2 and 6.3 . The ide ntified candidate technology options encompass all those technologies that may improve energy efficiency.

DOE then reviews each technology option considering the following four criteria, as provided in sections 4(a)(4) and 5(b) of Procedures, Interpretati ons, and Policies for Consideration of New or Revised Energy Conservation Standards for Consumer Products (see 10 CFR part 430, subpart C, appendix A):

(1) Technological feasibility. DOE does not further consider technologies that are not incorporated in comme rcially available product or in working prototypes.

(2) Practicability to manufacture, install, and service. If DOE determines that mass production of a technology and reliable installation and servicing of the technology could not be achieved on the scale nec essary to serve the relevant market by the time of the effective date of the standard, then it does not consider that technology further.

(3) Adverse impacts on product or equipment utility or availability. If DOE determines that a technology will have a signi ficant adverse impact on the utility of the product to significant subgroups of consumers, or result in the unavailability of any covered product type with performance characteristics (including reliability), features, size, capacities, and volumes that ar e substantially the same as product s generally available in the United States at the time, it does not consider that technology further.

(4) Adverse impacts on health or safety. If DOE determines that a technology will have significant adverse impacts on healt h or safety, it does not consider that technology further.

DOE will fully document the reasons for eliminating any technology options during the screening analysis and solicit interested parties’ comment. The remaining design options are considered further in the engineering analysis (section 8 )

.

Item 7

- 1 Are there any technologies, including those listed in section s 6.2

, 6.3

, and 6.4 that DOE should not consider because of any of the four screening criteria? If so, which screening criteria apply to the cited technology or technologies?

8. ENGINEERING ANALYSIS

After conducting the screening a nalysis, DOE performs an engineering analysis b ased on the remaining design options that would improve the efficiency of computer systems . This section provides an overview of the engineering analysis, and discusses baseline models, DOE’s proposed approach for determining the cost

- efficiency relationship, efficiency levels, proprietary designs, and cumulative regulatory burdens that might affect the engineering analysis.51

8.1 Engineering Analysis Overview

The purpose of the engineering analysis is to determine the relationship between manufacturer selling price (MSP) and the product’s energy efficiency ( power consumption ) . In determining the cost

- efficiency relationship, DOE estimates the increase in MSP ( which includes manufacturing cost and manufacturer markup s) associated with design changes that increase the efficiency (decrease power consumption) of computer systems relative to the baseline models.

As a preliminary step in this analysis, DOE may determine an appropriate subset of representative product clas ses to analyze. DOE will extrapolate the results of this analysis to the remaining product classes. Typically, each representative product class would represent the majority of the shipments in its category. The number of representative product classes dep end s on the availability of data that allow s for developing appropriate relationships between the engineering analysis results of the representative product class and the other product classes not directly analyzed. For each representative product class, D OE may analyze a subset of representative units.

For the engineering analysis, DOE examine s incremental changes in MSP associated with increases in the product’s efficiency. DOE intends to use publicly available data from manufacturer websites and catalogs for computer s ystems’ in the market to categorize relationships between efficiency and technological options. DOE also use s this information to select representative units in each product class. DOE focus es its analyses on these representative units.

Item 8

- 1 DOE encourages interested parties to submit data that will improve

DOE’s understanding of computer systems’ performance and associated

costs

.

DOE has two options for conducting the engineering analysis:

(1) Design

- option approach. Report the incremental costs of a dding design options or combinations of design options to a baseline model

. 38 This cost includes but is not limited to incremental cost of changes in material, labor, shipping, and overhead from the baseline

(2) Efficiency level approach. Report relative costs of achieving improvements in energy efficiency at incremental efficiency levels over baseline

, including those efficiency levels that include the maximum efficiency improvements that are technologically feasible (max

- tech). All models of varying efficiency for a given representative unit should be as similar as possible to be comparable

, and ideally differ only in efficiency.

38 Typically represents products with the lowest efficiency on the market.52

For each representative unit, DOE identif ies and evaluate s commercially available products that incorporate design options that impr ove efficiency. The engineering analysis will also identify the highest efficiency that is technologically feasible ( i.e., the max

- tech model). DOE may determine the max

- tech model by investigating the existence of any working computer system prototypes wi th higher efficiency than those commercially available. DOE examines only commercially available products; therefore, this approach may not provide information about the most efficient designs.

8.2 Engineering Analysis Methodology

DOE plans to purchase, test, and reverse engineer the representative units within each representative produc t class. DOE will conduct testing according to the appropriate DOE test procedure

, which it will be developing concurrently (see section 4 )

. The reverse engineering will include a physical teardown of the representative unit in which DOE will disassemble and inventory the product , identify the design options and technology changes, and construct a bill of materials (BOM) and labor cost estimate for each computer system

. DOE may supplement the findings from its tests and teardowns through:

(1) A review of data collected from manufacturers about prices, efficiencies, and other features of various computer system models, and

(2) Interviews with manufacturers about the techniques and associated costs used to improve efficiency.

In addition, DOE will use the cost data generated by the engineering analysis in the manufacturer impact analysis (see section 15 ).

DOE will also develop a cost model as part of the engineering analysis. The cost model will use the BOM generated from either a design

- option or an efficiency level approach to estimate the product costs ( i.e. , MSP) for each representative unit at each efficiency level considered. The proposed approach will enable DOE to characterize the cost

- efficiency relationship for computer systems across the entire efficiency range for all product classes. DOE will maintain the confidentiality of proprietary d ata while allowing the public to examine the cost and design assumptions that underlie the cost

- efficiency estimates.

The proposed approach will enable DOE to characterize the cost

- efficiency relationship for computer systems across the entire efficiency r ange for all product classes. DOE will maintain the confidentiality of proprietary data while allowing the public to examine the cost and design assumptions that underlie the cost

- efficiency estimates.

8.2.1 Representative Unit s and Baseline Models

The computer systems product classes cover a range of form factors and performance capabilities . To evaluate the efficiency and design within product class es , DOE will select representative models for each product class for the engineering analysis. These models may

re present common performance characteristics and through this analysis may be related to other models on the market.53

To analyze technology options for energy efficiency improvements, DOE will define a representative baseline model for each representative uni t. The baseline model should represent the characteristics of computer systems for their respective product class. DOE will evaluate selection of the baseline model at the bottom

- of

- market efficiency level or the minimum level commonly available for comput er systems . Selection of the baseline model for each representative unit will consider the product ’s features and performance characteristics.

8.3 Proprietary Designs

DOE will consider in its engineering and economic analyses all design options that are

comme rcially available or present in a working prototype, including proprietary designs and technologies. However, DOE will consider a proprietary design in the subsequent analyses only if the achieved efficiency level can also be reached using other non

- propri etary design options. If the proprietary design is the only approach available to achieve a given efficiency level, then DOE will reject that efficiency level, as the analytical results would appear to favor one manufacturer over others.

DOE is sensitive t o manufacturer concerns regarding proprietary designs and will make provisions to maintain the confidentiality of proprietary data submitted by manufacturers or discussed during manufacturer interviews. Materials provided to Lawrence Berkeley National Labo ratory (LBNL) or Navigant Consulting, Inc. (NCI), DOE contractors for this rulemaking, are generally subject to the terms of the applicable agreement under which those materials are submitted. In the case of materials provided to LBNL or NCI in the context of a DOE rulemaking and subject to a non

- disclosure agreement, those materials are generally not shared with DOE, apart from aggregated data that do not identify particular submitters. These materials may also be subject to a variety of laws and regulatio ns governing the disclosure of federal agency information. Information submitted to DOE will be protected in accordance with all applicable federal laws, rules, or regulations, including but not limited to the Trade Secrets Act, 18 U.S.C. 1905, and the Fre edom of Information Act (FOIA), 5 U.S.C. 552, and DOE’s implementing regulations at 10 CFR 1004.

8.4 Efficiency Levels

For each of the representative units, DOE will undertake analyses to determine potential efficiency levels relative to the baseline case and seek to develop incremental cost data at each of these levels.

To establish the efficiency levels DOE intends to consider, DOE will analyze the design changes and costs associated with improving efficiency from the baseline through the max

- tech model. Th is will include considering the design options identified in the screening analysis. DOE also intends to establish the range of efficiencies currently available on the market. DOE will use these data to categorize relationships between efficiency and techn ological options where the technological options used can be identified

. DOE notes that some of the design options that have met the screening criteria ( i.e.

, passed the screening analysis) may be working prototypes that are not yet commercially available and, therefore, would not be found in today’s available maximum efficiency products

.54

8.5 Outside Regulatory Changes Affecting the Engineering Analysis

In conducting an engineering analysis, DOE takes into consideration the effects of other DOE energy conserva tion standards and regulatory changes outside DOE’s statutory energy conservation standards rulemaking process that can affect the manufacturers of the covered product. Some regulatory changes can also affect the efficiency or energy consumption of compute r system s covered in this rulemaking. DOE will attempt to identify all such outside engineering issues that could affect the engineering analysis. The consideration of these issues is closely related to the cumulative regulatory burden assessment that DOE will carry out as part of the manufacturer impact analysis (see section 15 ).

9. MARKUPS ANALYSIS

DOE uses manufacturer

- to

- consumer markups to convert the MSP values, obtained from the engineering analysis, to consu mer purchase prices, which are then used in the later analyses

. The manufacturer

- to

- consumer markups are in addition to the markups on production costs that DOE uses in estimating manufacturer selling price in the engineering analysis. C onsumer purchase pr ices are needed for the baseline efficiency level and all other efficiency levels under consideration. To quantify these markups, DOE will collect data on existing prices in the market ( e.g. , purchased data sets or distributor Internet sites), where collec ting such data is possible and produces meaningful results.

To develop markups, DOE must identify distribution channels ( i.e. , how the product is distributed from the manufacturer to the user). Once it establishes proper distribution channels for each of t he product classes, DOE will estimate how products are marked up in the distribution chain from the manufacturer to the user.

DOE will determine an average manufacturer markup by examining the annual U.S. Securities and Exchange Commission (SEC) 10

- K repor ts 39 filed by publicly traded manufacturers of appliances whose product range includes computer systems . DOE will determine an average retailer markup by analyzing both economic Census data from the U.S. Census Bureau 40 and the annual SEC 10

- K reports filed by publicly traded retailers.

In addition to developing manufacturer and retailer markups, DOE will develop and include sales taxes to calculate appliance retail prices. DOE will use an Internet source, the Sales Tax Clearinghouse 41 , to calculate applicabl e sales taxes.

DOE intends to develop baseline and incremental markups for computer systems

. Baseline markups are cost multipliers applied to the MSP of baseline product, while the

39 10

- K reports are available at: < http://w ww.sec.gov/index.htm >

40 U.S. Census Bureau < http://www.census.gov/econ/census/ >

41 Sales Tax Clearinghouse < http://www.thestc.com/ >55

incremental markups are cost multipliers applied to the incremental cost ch ange in the MSP of the higher

- efficiency product. Through the markups analysis, DOE will generate end

- user prices for each product efficiency level that DOE considers , assuming that each level represents a new minimum efficiency standard. DOE will make thi s assumption to capture the effect on retail prices that may be produced by manufacturers’ higher production volumes of more efficient products as required by the standard . DOE’s approach for estimating the mar k up multipliers will depend on the specific di stribution channel traced by the product (from the manufacturer to the end user).

Item 9

- 1 DOE seeks suggestions and comments concerning its proposed approach to developing estimates of markups.

10. E NERGY USE ANALYSIS

The purpose of the energy

- use analysis is to ident ify how products are used by consumers, and thereby determine the energy savings potential of energy efficiency improvements. DOE determines the energy consumption of computer systems through the rated power and the way consumers use the products ( i.e., op erating hours per year in various modes of operation ). This analysis, which is meant to represent typical energy consumption in the field, is an input to future analyses to establish the savings in consumer operating costs at various product efficiency lev els

.

As discussed in section 3 , ENERGY STAR Computers V. 6.0 uses an AEC metric that estimates the amount of energy a computer will use in one year based on a weighted average of measured power consumption valu es in each mode of operation. It includes mode weightings based on a 2010 usage profile study by E cma International. DOE is considering a test procedure with a similar metric. For computer servers, DOE is considering an idle mode power test only, which can be converted to an annual energy consumption based on assumed product utilization. For UPS, DOE is considering a similar metric to ENERGY STAR UPS V. 1.0. The metric s proposed for development as part of the test procedure s in this rulemaking will contribu te to the energy use analysis by characterizing the yearly amount of energy consumed by a given unit. In addition to characterizing the energy use of individual models for this energy use analysis, DOE plans to investigate the average AEC for different pro duct classes and estimate the share of each product class in the current market and installed base. Because the energy use of computer systems can vary greatly based on different usage patterns, DOE will conduct further research and utilize additional data to establish a range of energy use for computer systems

. The energy use analysis will allow DOE to correlate the price distribution from the engineering and markups analyses with an annual energy usage distribution for different product classes , as well a s to support characterization of the impacts of more efficient designs. The results of this analysis are used as inputs to the LCC, PBP, NIA, and other downstream analyses.56

Item 10

- 1 DOE seeks comments on its proposed approach for specifying typical annual energy co nsumption. Most importantly, DOE is interested in sources of data that can assist in characterizing the annual energy consumption of computer systems

.

Item 10

- 2 DOE welcomes input on data sources that it can use to characterize the variability in annual energy consu mption for computer systems in the field. DOE is particularly interested in field monitoring studies and data.

11. LIFE

- CYCLE COST AND PAYBA CK PERIOD ANALYSES

DOE will conduct an LCC analysis to evaluate the economic impacts of energy conservation standards de veloped for computer systems on users. The effect of standards includes a change in operating cost (usually decreased) and a change in purchase cost (usually increased). The analysis uses two metrics, LCC and PBP, for each representative unit to determine the effect of the standards on consumers:

 Life

- cycle cost . The total consumer cost over the life of the product is the sum of installed costs (purchase and installation costs) and operating costs (energy, maintenance, and repair costs as applicable). Futur e operating costs are discounted to the time of purchase and summed over the lifetime of the product.

 Payback period

. Payback period is the estimated amount of time (in years) it would take consumers to recover the higher purchase price of a more efficient product through lower operating costs.

11.1 Approach

Inputs for the LCC analysis are estimated from the best available data for the market. Where possible, DOE uses a range of values for each input (for example, the product lifetime, which can vary over a wide range). 42 DOE will perform the LCC analysis in the form of Monte Carlo simulations in which certain inputs are provided as a range of values and probability distributions to model both the uncertainty and variability in the inputs. The Monte Carlo approach provides a significant advantage over alternative approaches ( e.g. , an approach using typical or average values to characterize inputs) because it identifies the percentages of consumers benefiting from or being impacted by a prospective standard . The res ults of the LCC analysis are presented in the form of:

(1) Mean LCC savings;

42 DOE notes that in some cases, data are available for generally accepted representative values within the industry rather than a range of values. Calculations based on representative values yield average or representative values for the LCC and PBP outputs

.57

(2) Percentages of consumers experiencing net savings, net cost, and no impact in LCC; and

(3) Median PBP.

For each representative unit, DOE develops an LCC and PBP model that incorporates b oth Monte Carlo simulation and probability distributions

. Each Monte Carlo simulation would typically consist of 10,000 LCC and PBP calculations. 43 The model will perform each calculation using input values sampled from probability distributions where possi ble, or characterized using single

- point values in other cases. The analysis results are a distribution of 10,000 data points showing the range of LCC savings and PBPs for a given efficiency level relative to the baseline level.

DOE expects to use probabi lity distributions to characterize most of the operating cost inputs to the LCC and PBP analyses, including product lifetime and consumer discount rates. DOE expects to use a combination of data to establish the annual energy consumption of each product cl ass, characterized using sales

- weighted probability distributions. The LCC and PBP analysis will capture the regional variability in electricity prices and sales taxes. Depending on the available data, DOE expects to use point values to characterize other LCC inputs, such as the manufacturer markup. To estimate the percentage of users that would be affected by a particular standard level, DOE takes into account the full range of product efficiencies that users purchase under the base case ( i.e., the case wi thout new energy conservation standards). By accounting for users who already purchase more efficient products, DOE avoids overstating the potential benefits from standards.

In addition to the aforementioned cost inputs, DOE will use the cost

- efficiency

re lationships obtained from the engineering analysis and the energy consumption values obtained from the energy use analysis.

DOE will determine as part of the LCC and PBP analyses whether there may be a rebound (or “take back”) effect associated with more efficient computer systems . The “take

back” in energy consumption associated with the rebound effect typically involves greater use that can result from increases in energy efficiency and the associated reduction in operating costs. The rebound effect assu mes that consumers will increase their overall annual usage of a more efficient product, thereby decreasing their overall annual savings.

Based on the results of the LCC analysis, DOE would select candidate standard levels (CSLs) for the Preliminary Analys is. The range of CSLs typically includes the efficiency level with the minimum LCC, the highest efficiency level that is technologically feasible, and other intermediate levels.

43 DOE typically chooses 10,000 iterations to ensure the LCC results are representative of the input probability distributions.58

The following sections discuss the methodologies DOE plans to use to develop s everal of the inputs to the LCC and PBP analysis, including (1) electricity prices; (2) maintenance, repair, and installation costs; (3) product lifetimes; and (4) discount rates. Other inputs to the LCC and PBP analysis (manufacturer costs, annual energy consumption, and markups for the determination of consumer retail prices) were discussed previously.

DOE also perform s an analysis to determine whether the 3

- year rebuttable presumption of economic justification applies ( i.e., , whether the additional cost of purchasing a product that meets the standard level would be less than three times the value of the energy savings in the first year.). (42 U.S.C. 6295(o)(2)(B)(iii)) To determine the rebuttable

- presumption PBP, DOE would determine the value of the first year’s energy savings by calculating the quantity of those savings in accordance with DOE’s test procedure. DOE determines whether selected CSLs are economically justified through an analysis of the economic impacts of increased efficiency pursuant to sec tion 325(o)(2)(B)(i) of EPCA. (42 U.S.C. 6295(o)(2)(B)(i))

In preparing a NOPR, DOE carefully reviews all the comments it receives on the Preliminary Analysis LCC analysis, makes any necessary revisions to the analysis, and if necessary evaluates additiona l parameters not included in the Preliminary Analysis.

Item 11

- 1 DOE seeks comments on its proposed approach of using probability distributions and Monte Carlo simulation to conduct the LCC and PBP analysis.

Item 11

- 2 DOE requests data from stakeholders to characterize the cu rrent mix of computer system efficiencies in the market.

11.2 Electricity Prices

DOE expects to estimate average electricity prices using Energy Information Administration (EIA) data covering the geographic areas outlined in EIA’s Residential Energy Consumption Survey. To calculate electricity prices for residential and commercial consumers in each of the se geographic areas, DOE will use information provided by electric utilities as summarized in the most recent EIA Form 861 data. 44 These data, which cover the re sidential, commercial, and industrial sectors for every utility serving final customers, are published annually and include annual electricity sales in kWh, revenues from electricity sales, and number of customers. DOE’s calculation of an average electrici ty price proceeds in two steps: (1) for each utility, estimate an average residential and commercial price by dividing revenues by sales; and (2) calculate a regional average price, weighting each utility that has customers in a region by the number of res idential and commercial customers served in that region.

44 EIA Form 861 data available at < www.eia.doe.gov/cne af/electricity/page/eia861.html >59

In its LCC analysis DOE uses projections of national average electricity prices to residential and commercial consumers to estimate future energy prices. DOE uses the most recently available edition of EIA’s Annual Energy Outlook ( AEO ) as the default source of projections for future energy prices.

Item 11

- 3 DOE seeks comments on the planned approach for estimating current and forecasted energy prices.

11.3 Maintenance, Repair, and Installation Costs

DOE will conside r any expected changes to maintenance, repair, and installation costs for computer systems subject to new standards. Typically, small incremental changes in product efficiency incur little or no change in repair and maintenance costs over baseline products

. Products having efficiencies that are significantly higher than the baseline are more likely to incur increased repair and maintenance costs, because such products are more likely to incorporate technologies that are not widely available. DOE will use in put from manufacturers and other stakeholders to develop appropriate repair and maintenance cost estimates, as
necessary.
With regard to installation costs, unless the increased efficiency levels considered for this rulemaking result in significantly large r or heavier products, DOE expects that more efficient computer systems will incur no increased installation costs.

Item 11

- 4 DOE seeks comments on the merits of its proposed analytical assumption that changes in maintenance, repair, and installation costs will be

n egligible for more

- efficient computer systems . If that assumption is incorrect, DOE is interested in the reasons why this is so and in specific ways to correct that assumption.

11.4 Product Lifetimes

The product lifetime is the age at which a product is retired from service. DOE will characterize computer system survival functions using Weibull distributions. In addition, DOE plans to use literature sources, industry experts, and input from manufacturers and other interested parties to determine a range for the lifetime of computer systems

.

Item 11

- 5 DOE seeks comments on appropriate product lifetimes for computer systems . Specifically, DOE seeks data sources for establishing product lifetimes.

11.5 Discount Rates

The calculation of LCC requires the use of an appropriate discou nt rate. DOE uses a discount rate to determine the present value of lifetime operating expenses. The discount rate60

used in the LCC analysis represents the rate from an individual consumer’s perspective. For both residential and commercial consumers of comp uter systems , DOE plans to use estimates of the interest or “finance cost” to purchase residential or commercial products. For residential consumers, the finance cost of raising funds to purchase products can be interpreted as (1) the financial cost of any debt incurred to purchase products (principally interest charges on debt), or (2) the opportunity cost of any equity used to purchase products (principally interest earnings on household equity). Household equity is represented by holdings in assets such as stocks and bonds, as well as the return on homeowner equity. Much of the data required for determining the cost of debt and equity comes from the Federal Reserve Board’s triennial Survey of Consumer Finances

. 45 For commercial consumers, DOE will derive t he discount rates by estimating the capital costs for companies that purchase computer systems . The cost of capital is commonly used to estimate the present value of cash flows to be derived from a typical company project or investment. Most companies use both debt and equity capital to fund investments, so the cost of capital is the weighted

- average cost of equity and debt financing, which is referred to as the weighted

- average cost of capital.

Item 11

- 6 DOE seeks comments on its planned approach for estimating disc ount rates for residential and commercial consumers.

11.6 Energy Efficiency in the Base Case

To estimate the share of consumers affected by a standard at a particular efficiency level, DOE’s LCC and PBP analysis considers the projected distribution ( i.e. , mark et shares) of product efficiencies that consumers will purchase in the first compliance year under the base case (the case without amended energy conservation standards). DOE requests market

- share efficiency data ( i.e. , data on the distribution of shipment s by efficiency) for the product classes of computer systems

. Forecasted market shares will use available data on recent market trends in computer system efficiency and will take into account the potential impacts of other programs or policies (such as ENE RGY STAR, consumer rebate programs or State tax credits to consumers for the purchase more efficient products, and manufacturer tax credits that encourage the production of more efficient products) that may affect the demand for more efficient computer sys tems

.

Item 11

- 7 DOE seeks comments on computer system efficiency in the base case, historical efficiency data on computer systems , and projected trends in computer system efficiency.

45 Board of Governors of the Federal Reserve System: Survey of Consumer Finances

< http://www.federalreserve.gov/econresdata/scf/scfindex.htm >61

12. SHIPMENTS ANALYSIS

DOE forecasts product shipments to calculate the national impact s of standards on energy consumption, NPV, and future manufacturer cash flows. DOE plans to develop shipments projections based on analysis of the key market drivers for computer systems . DOE typically projects shipments for a 30

- year period beginning with the expected compliance date of any standards.

12.1 Base

- Case Forecast

To evaluate the various impacts of standards, DOE must develop a base

- case projection against which to compare projections for higher efficiency levels. The base

- case projection is designed to depict what will happen to energy consumption and energy costs over time if DOE does not adopt new energy conservation standards for the product covered under this rulemaking. In determining the base

- case projection, DOE will consider historical shipme nts, the mix of efficiencies sold in the absence of standards, and how that mix might change over time, for instance in response to known voluntary or incentive

- based programs such as ENERGY STAR. For these purposes, DOE needs data on historical shipments and the market shares of the different efficiency levels offered in each product class. Furthermore, DOE also looks at market and industry reports on expected market trends to better understand future product shipments.

Item 12

- 1 DOE seeks historical shipments data and reports on future market trends from stakeholders. If such data are provided, DOE requests market share data showing the percentage of computer system shipments of different efficiencies and product classes.

12.2 Impact of Standards on Product Shipments

Af ter developing the base

- case projection, DOE will develop a set of shipment projections for each product class and each set of standards analyzed, also known as standards

case projections. Standards

- case projections are derived using the same datasets as b ase

- case projections; however, because the standards

- case projections take into account the increase in purchase price and the decrease in operating costs caused by standards, projected shipments may deviate from the base case. The magnitude of the differe nce between the standards

- case and base

- case shipment projections depends on the estimated purchase price increase as well as the operating cost savings caused by the standard. DOE plans to assess whether the purchase price or the operating cost will have a greater impact on computer system purchase decisions; therefore, standards case projections may show a change in shipments relative to the base case. These standards

- case projections will be used to evaluate the impacts of standards on shipments.

DOE’s p ast standards analyses have attempted to quantify the sensitivity of shipments to increased purchase price and operating cost savings, as well as to changes in household income. DOE has conducted literature reviews and analyses of historical appliance pric e and efficiency data to develop sensitivities. DOE will attempt to develop purchase price and operating cost sensitivities for computer systems . If the data required to develop those sensitivities are62

unavailable, DOE will consider modeling standards

- case shipments forecasts using scenarios ( i.e. , specified impacts to product shipments).

Market

- pull programs, such as ENERGY STAR, consumer rebate programs that encourage the purchase of more efficient products, and manufacturer tax credits that encourage the production of more efficient products, also affect forecasts of standards

- case shipments. To the extent that such programs exist, DOE will consider their impact on the forecast of both base

case and standards

- case shipments.

Item 12

- 2 As part of the preliminary man ufacturer impact analysis, DOE seeks input from manufacturers on the potential impact of new energy conservation standards on computer system shipments. DOE also seeks input from other stakeholders on the potential impact of standards on product shipments.

Item 12

- 3 DOE also requests input on any current market

- pull programs that promote the adoption of more efficient computer systems

.

13. NATIONAL IMPACT ANAL YSIS

The NIA assesses the aggregate impacts of potential conservation standards at the national level. Impacts th at DOE will report include the NES from potential computer systems standards ( i.e. , the cumulative incremental energy savings from computer system efficiency standards) and the NPV of the total user benefits.

13.1 Energy Efficiency Trends

A key component of DOE ’s estimates of NES and NPV are the product energy efficiencies projected over time, for the base case (without new standards) and for each of the standards cases. To develop the various standards cases, DOE plans to develop market

- share efficiency data ( i .e. , data on the distribution of product shipments by efficiency) for the computer system product classes DOE is considering. To estimate the impact that standards may have in the year compliance becomes required, DOE ha s used “roll

- up” and/or “ shift” scen arios in its past standards rulemakings. DOE will evaluate whether one of these approaches is more reasonable for computer systems.

Under the roll

- up scenario, DOE assumes (1) product efficiencies in the base case that do not meet the standard level under consideration would roll up to meet the new standard level; and (2) product shipments at efficiencies above the standard level under consideration would not be affected.

Under the shift scenario, DOE retains the pattern of the base

- case efficiency distri bution but re

- orients the distribution at and above the new energy conservation standard. After DOE establishes the average efficiency for the assumed effective date of a standard, it can estimate future efficiency by using the same rate of projected effic iency growth as for the base

- case efficiency trend.63

Item 13

- 1 DOE seeks comments on the use of the “roll

- up” and “shift” efficiency scenarios to characterize the impact that potential standards would have on the product efficiency distributions.

13.2 National Energy Sa vings

DOE intends to calculate national computer system energy consumption for each year beginning with the expected compliance date of any standards. It will calculate national computer system energy consumption for the base cases and each standard level analyzed, and the energy savings will be calculated as the difference in energy consumption between the base case and the standards cases. DOE plans to perform this calculation through the use of a spreadsheet model that effectively accounts for the stock of products affected by standards. 46 The energy savings are measured over the entire lifetime of products purchased in the 30

- year projection period. 47

DOE intends to consider whether there may be a rebound effect associated with more efficient computer syst ems in its determination of NES. Increased equipment utilization may result from an increase in energy efficiency. If data indicate that there may be a rebound effect and the data are sufficient to allow quantification of this effect for computer systems
, DOE will account for the rebound effect in its calculation of NES.

DOE has historically presented NES in terms of primary energy savings. In response to the recommendations of a committee on “Point

- of

- Use and Full

- Fuel

- Cycle Measurement Approaches to Energ y Efficiency Standards” appointed by the National Academy of Science, DOE announced its intention to use full

- fuel

- cycle (FFC) measures of energy use and greenhouse gas and other emissions in the national impact analyses and emissions analyses included in future energy conservation standards rulemakings. 76 FR 51281 (August 18, 2011). After evaluating the approaches discussed in the August 18, 2011 notice, DOE published a statement of amended policy in the Federal Register in which DOE explained its determi nation that NEMS is the most appropriate tool for its FFC analysis and its intention to use NEMS for that purpose. 77 FR 49701 (August 17, 2012). The method used to derive the FFC multipliers will be described in the preliminary TSD.

13.3 Net Present Value

To develop the national NPV of user benefits from potential standards, DOE must calculate annual energy expenditures and annual product expenditures for the base case and the

46 Sever al examples of NES spreadsheet models from previous rulemakings can be found on DOE’s website at:

< http://www.eere.energy.gov/buildings/appliance_standards/ >

47 In the past DOE prese nted energy savings results for only the 30

- year period that begins in the year of compliance . In the calculation of economic impacts, however, DOE considered operating cost savings measured over the entire lifetime of products purchased in the 30

- year per iod. DOE has chosen to modify its presentation of national energy savings to be consistent with the approach used for its national economic analysis.64

standards cases. DOE calculates annual energy expenditures based on AEC by incorpora ting projected energy prices, using the projections of shipments and average energy efficiency described in section 12 . DOE calculates annual product expenditures by multiplying the price per unit by the number of projected shipments. The difference each year between energy bill savings and increased product expenditures is the net savings (if positive) or net costs (if negative). DOE discounts those annual values to the present time and sums them to obtain a NPV

. Consistent with guidelines set by the U.S. Office of Management and Budget (OMB), DOE will conduct two NPV calculations, one using a real discount rate of 3

- percent and the other using a real discount rate of 7

- percent (OMB, Circular A

- 4: Regulatory Anal ysis) (September 17, 2003). The discount rates for the determination of NPV differ from the discount rates used in the LCC analysis (which are developed from a customer’s perspective). The 7

- percent real value is an estimate of the average before

- tax rate of return on private capital in the U.S. economy. The 3

- percent real value represents the “societal rate of time preference,” which is the rate at which society discounts future consumption flows to their present value.

14. CONSUMER SUBGROUP AN ALYSIS

The LCC a nalysis described in section 11 analyzes the impacts of energy conservation standards on all consumers for computer systems . For the subgroup analysis, DOE divides consumers into subgroups, which comprise a subs et of the population that is likely, for one reason or another, to be affected disproportionately by new or revised energy conservation standards ( e.g. , small businesses or firms that use computer systems in particular applications where energy savings are likely to differ from the mean ) . The purpose of a subgroup analysis is to determine the extent of this disproportional impact. DOE will work with interested parties to identify any subgroups for this consideration and will conduct a subgroup analysis for any NOPR developed for this rulemaking.

In comparing potential impacts on the different consumer subgroups, DOE will evaluate variations in regional energy prices, variations in energy use, and variations in installation costs that might affect the LCC sav ings and PBP of a standard to consumer subgroups. To the extent possible, DOE may obtain estimates of the variability in each input variable and consider this variability in its calculation of consumer impacts. It will discuss the variability in each input variable and likely sources of information with interested parties

.

Item 14

- 1 DOE welcomes comment on what, if any, consumer subgroups are appropriate in considering standards for computer systems

.

15. MANUFACTURER IMPACT ANALYSIS

The MIA provides an assessment of the potential impacts of energy conservation standards on manufacturers of computer systems . A wide range of quantitative and qualitative effects may occur following the adoption of a standard that may require changes to manufacturing practices. DOE will ident ify these potential effects through interviews with manufacturers and other interested parties.65

DOE will conduct an industry

- wide cash

- flow analysis using the Government Regulatory Impact Model (GRIM), identify and analyze subgroups of manufacturers whose businesses vary significantly from the industry as a whole, perform a competitive impacts assessment, and review the cumulative regulatory burden for the industry.

15.1 Sources of Information for the Manufacturer Impact Analysis

Many of the analyses described e arlier provide information that DOE will use as inputs for the MIA. Such information includes financial parameters developed in the market assessment (section 5.2 ), cost data developed in the engineering analysi s (section 8 ), and shipments projections (section 12 ). DOE will supplement this information with information gathered during manufacturer interviews, as discussed bel ow.
During any preliminary analysis phase, DOE will conduct interviews with manufacturers to gain insight into the range of possible impacts resulting from potential energy conservation standards. These interviews will coincide with preliminary technical i nterviews for the engineering analysis.

During any NOPR phase, DOE will conduct more detailed MIA interviews with manufacturers. The interview process plays a key role in the MIA, because it provides an opportunity for directly affected parties to express their views on important issues. During the interviews, DOE will solicit information on the possible impacts of potential standards on manufacturing costs, product prices, sales, direct employment (meaning employment for the manufacturer only), capital ass ets, and industry competitiveness. Both qualitative and quantitative information are valuable in this analysis. DOE prefers an interactive interview process because it helps to clarify manufacturer input and provides the opportunity to identify additional issues.

DOE asks interview participants to identify confidential information and protects the confidentiality of the information provided as explained in section 8.3 . DOE also asks participants to identify any i nformation they wish to have included in the public record, but do not want to have associated with their interview (thereby identifying that particular manufacturer). DOE incorporates this information into the public record without attribution.

DOE collat es the interview results and prepares a summary of the major issues and outcomes. This summary becomes part of the technical support document for this rulemaking.

15.2 Industry Cash Flow Analysis

The industry cash

- flow analysis will rely primarily on the GRIM. DOE uses the GRIM to analyze the financial impacts of new energy conservation standards on the computer system industry.

The GRIM uses a number of factors

— annual expected revenues; manufacturer costs such as costs of goods sold; selling, general, and admin istrative (SG&A) costs; R&D costs; product conversion costs; taxes; capital expenditures (both ordinary capital expenditures and those related to standards); and working capital requirements

— to determine annual cash flows associated with a new standard, be ginning with the announcement of the standard and continuing66

for several years after its implementation. DOE compares the results against base

- case projections that involve no new standards. The financial impact of new standards is the difference between t he two sets of discounted annual cash flows, or the differences between the base

- case and standards

- case industry net present values. Other performance metrics, such as return on invested capital, are also available from the GRIM.

DOE gathers the inputs ne eded for the GRIM from two primary sources: (1) the analyses conducted to this point; and (2) interviews with manufacturers and other interested parties. As discussed above, information gathered from previous analyses will include financial parameters,

man ufacturing costs, price projections, and shipment projections. Interviews with manufacturers and other interested parties will supplement this information.

15.3 Manufacturer Subgroup Analysis

Average industry cost values may not reveal differential impacts amon g computer system manufacturer subgroups. Smaller manufacturers, niche players, and manufacturers exhibiting a cost structure that differs significantly from the industry average may be affected differently by standards. Ideally, DOE would consider the imp act on every firm individually. In highly concentrated industries, this may be possible. In industries having numerous participants, however, DOE uses the results of the market and technology assessment to group manufacturers into subgroups, as appropriate . For computer systems , DOE is interested in feedback about potential subgroups, including small businesses. DOE conducts a Regulatory Flexibility Act analysis to determine the impacts of any standards on small businesses consistent with the Regulatory Fle xibility Act. (5 U.S.C. 601

- 612)

Item 15

- 1 DOE seeks comments on any subgroups of computer system manufacturers that it should consider in a manufacturer subgroup analysis.

15.4 Competitive Impacts Assessment

EPCA directs DOE to consider any lessening of competition like ly to result from the imposition of standards. (42 U.S.C. 6295(o)(2)(B)(i)(V)) It further directs the Attorney General to determine in writing the impacts, if any, of any lessening of competition likely to result from standards. (42 U.S.C. 6295(o)(2)(B)(ii ))

DOE gathers firm

- specific financial information and impacts and reports the aggregated impact of the proposed standard on manufacturers. The competitive impacts analysis will focus on assessing the impacts on smaller manufacturers. DOE bases the assessm ent on manufacturing cost data and information collected from interviews with manufacturers. The manufacturer interviews focus on gathering information that would help in assessing asymmetrical cost increases to some manufacturers, increased proportion of fixed costs potentially increasing business risks, and potential barriers to market entry ( e.g. , proprietary technologies). DOE provides the Attorney General with a copy of any NOPR for consideration in evaluating the impact of standards on the lessening o f competition. DOE will publish the Attorney General’s letter and address any related comments in any final rule.67

15.5 Cumulative Regulatory Burden

Other regulations (federal, state, local, or international) may apply to manufacturers of computer systems covere d under this rulemaking as well as to other products made by these manufacturers. Multiple regulations may result in a significant, cumulative regulatory burden on these manufacturers. DOE considers the impact on these manufacturers of multiple, product

sp ecific regulatory actions.

Item 15

- 2 DOE welcomes comments on other existing regulations or pending regulations it should consider in examining cumulative regulatory burden.

16. E MISSIONS A NALYSIS

In the emissions analysis, conducted in the NOPR phase, DOE will estima te the reduction in power sector emissions of carbon dioxide (CO 2 ), nitrogen oxides (NOx), sulfur dioxide (SO 2 ), and mercury (Hg) from potential energy conservation standards for computer systems. In addition, DOE will estimate emissions impacts in product ion activities (extracting, processing, and transporting fuels) that provide the energy inputs to power plants. These are referred to as “upstream” emissions. Together, these emissions account for the FFC discussed in section 14.2. In accordance with DOE’s FFC Statement of Policy (76 FR 51281;Aug. 18, 2011), the FFC analysis also includes impacts on emissions of methane (CH 4 ) and nitrous oxide (NO X ), both of which are recognized as greenhouse gases.

DOE primarily conducts the emissions analysis using emiss ions factors for CO 2 and most of the other gases derived from data in EIA’s most recent AEO . Combustion emissions of CH 4 and N 2 O are estimated using emissions intensity factors published by the Environmental Protection Agency (EPA), GHG Emissions Factors H ub. 48

EIA prepares the AEO using NEMS. Each annual version of NEMS incorporates the projected impacts of existing air quality regulations on emissions. The text below refers to AEO 2013 , which generally represents current legislation and environmental regu lations, including recent government actions, for which implementing regulations were available as of December 31, 2012.

SO 2 emissions from affected electric generating units (EGUs) are subject to nationwide and regional emissions cap

- and

- trade programs. T itle IV of the Clean Air Act sets an annual emissions cap on SO 2 for affected EGUs in the 48 contiguous States and the District of Columbia (D.C.). SO 2 emissions from 28 eastern States and D.C. were also limited under the Clean Air Interstate Rule (CAIR), which created an allowance

- based trading program that operates along with the Title IV program in those States and D.C. 70 FR 25162 (May 12, 2005). CAIR was remanded to the U.S. Environmental Protection Agency (EPA) by the U.S. Court of Appeals for

48 http://www.epa.gov/climateleadership/guidance/ghg

- emissions.html68

the Dis trict of Columbia Circuit ( D.C. Circuit), but it remained in effect. 49 On July 6, 2011, EPA issued a replacement for CAIR, the Cross

- State Air Pollution Rule (CSAPR). 76 FR 48208 (August 8, 2011). On August 21, 2012, the D.C. Circuit issued a decision to va cate CSAPR. 50 The court ordered EPA to continue administering CAIR. AEO 2013 assumes that CAIR remains a binding regulation through 2040. 51

The attainment of emissions caps is typically flexible among EGUs and is enforced through the use of emissions allowa nces and tradable permits. Under existing EPA regulations, any excess SO 2 emissions allowances resulting from the lower electricity demand caused by the adoption of an energy conservation standard could be used to permit offsetting increases in SO 2 emissio ns by any regulated EGU. In past rulemaking efforts, DOE recognized that there was uncertainty about the effects of conservation standards on SO 2 emissions covered by the existing
cap

- and

- trade system, but it concluded that no reductions in power sector SO 2 emissions would occur for SO 2 as a result of standards.

Beginning in 2016, however, SO 2 emissions will fall as a result of the Mercury and Air Toxics Standards (MATS) for power plants, which were announced by EPA on December 21, 2011. 77 FR 9304 (Februar y 16, 2012). In the final MATS rule, EPA established a standard for hydrogen chloride as a surrogate for acid gas hazardous air pollutants (HAP), and also established a standard for SO 2 (a non

- HAP acid gas) as an alternative equivalent surrogate standard f or acid gas HAP. The same controls are used to reduce HAP and non

- HAP acid gas; thus, SO 2 emissions will be reduced as a result of the control technologies installed on coal

- fired power plants to comply with the MATS requirements for acid gas. AEO 2013 ass umes that, in order to continue operating, coal plants must have either flue gas desulfurization or dry sorbent injection systems installed by 2016. Both technologies, which are used to reduce acid gas emissions, also reduce SO 2 emissions. Under the MATS, emissions will be far below the cap that would be established by CAIR, so it is unlikely that excess SO 2 emissions allowances resulting from the lower electricity demand would be needed or used to permit offsetting increases in SO 2 emissions by any regulat ed EGU. Therefore, DOE believes that energy efficiency standards will reduce SO 2 emissions in 2016 and beyond.

CAIR established a cap on NOx emissions in the 28 eastern states and the District of Colombia. Energy conservation standards are expected to have little or no physical effect on

49 See North Carolina v. EPA, 550 F.3d 1 176 (D.C. Cir. 2008); North Carolina v. EPA, 531 F.3d 896 (D.C. Cir. 2008).

50 See EME Homer City Generation, LP v. EPA, 696 F.3d 7, 38 (D.C. Cir. 2012).

51 On April 29, 2014, the U.S. Supreme Court reversed the judgment of the D.C. Circuit. The case will no w return to the D.C. Circuit for further proceedings consistent with the Supreme Court's opinion. The Supreme Court held in part that EPA's methodology for quantifying emissions that must be eliminated in certain states due to their impacts in other downwi nd states was based on a permissible, workable, and equitable interpretation of the Clean Air Act provision that provides statutory authority for CSAPR. See EPA v. EME Homer City Generation, Slip. Op. No 12

- 1182, *32 s lip o p. at 32 ( U.S. April 29, 2014). B ecause DOE would be using emissions factors based on AEO 2013 for the NOPR phase of this rulemaking, this document assumes that CAIR, not CSAPR, is the regulation in force. The difference between CAIR and CSAPR is not relevant for the purpose of DOE's anal ysis of SO 2 emissions.69

these emissions in those states covered by CAIR because excess NOx emissions allowances resulting from the lower electricity demand could be used to permit offsetting increases in NO x emissions. However, standards would be expected to reduce NOx emissions in the states not affected by CSAPR the caps, so DOE estimates NOx emissions reductions from potential standards in the States where emissions are not capped for these states.

The MATS limit mercury emissions from power pla nts, but they do not include emissions caps and, as such, DOE’s energy conservation standards would likely reduce Hg emissions. DOE will estimate mercury emissions reduction using emissions factors based on AEO 2013 , which incorporates the MATS.

Power pla nts may emit particulates from the smoke stack, which are known as direct particulate matter (PM) emissions. NEMS does not account for direct PM emissions from power plants. DOE is investigating the possibility of using other methods to estimate reduction in PM emissions due to standards. The great majority of ambient PM associated with power plants is in the form of secondary sulfates and nitrates, which are produced at a significant distance from power plants by complex atmospheric chemical reactions that often involve the gaseous emissions of power plants, mainly SO 2 and NOx . The monetary benefits that DOE estimates for reductions in SO 2 and NOx emissions resulting from standards are in fact primarily related to the health benefits of reduced ambient PM.

Item 16

- 1 DOE seeks comments on its approach to conduct the emissions analysis for the products that would be covered by any proposed rulemaking that would regulate computer system efficiency.

17. MONETIZING REDUCED CARBON DIOXIDE AND O THER EMISSIONS

DOE plans to consi der the estimated monetary benefits likely to result from the reduced emissions of CO 2 and NOx that are expected to result from each of the standard levels considered.

To estimate the monetary value of benefits resulting from reduced emissions of CO 2 , DOE plans to use the most current Social Cost of Carbon (SCC) values developed and/or agreed to by an interagency process. The SCC is intended to be a monetary measure of the incremental damage resulting from greenhouse gas (GHG) emissions, including, but not limited to, net agricultural productivity loss, human health effects, property damage from sea level rise, and changes in ecosystem services. Any effort to quantify and to monetize the harms associated with climate change will raise serious questions of s cience, economics, and ethics. But with full regard for the limits of both quantification and monetization, the SCC can be used to provide estimates of the social benefits of reductions in GHG emissions.70

The Interagency Working Group on Social Cost of Car bon released in 2013 an update of its previous report in 2013. 52 The most recent estimates of the SCC in 2015, expressed in 2013$,

are $12.0, $40.5, $62.4, and $119 per metric ton of CO 2 avoided. For emissions reductions that occur in later years, these val ues grow in real terms over time. Additionally, the interagency group determined that a range of values from 7

- percent to 23

- percent should be used to adjust the global SCC to calculate domestic effects, although DOE will give preference to consideration o f the global benefits of reducing CO 2 emissions.

DOE multiplies the CO 2 emissions reduction estimated for each year by the SCC value for that year in each of the four cases. To calculate a present value of the stream of monetary values, DOE discounts the values in each of the four cases using the discount rates that had been used to obtain the SCC values in each case.

DOE recognizes that scientific and economic knowledge continues to evolve rapidly as to the contribution of CO 2 and other GHG to changes in the future global climate and the potential resulting damages to the world economy. Thus, these values are subject to change.

DOE also estimates the potential monetary benefit of reduced NOx emissions resulting from the standard levels it considers. For N Ox emissions, estimates suggest a very wide range of monetary values, ranging from $476 to $4,893 per ton in 2013$. 53 DOE calculates monetary benefits using a medium value for NO X emissions of $2,684 per short ton (2013$), and real discount rates of 3 perce nt and 7 percent.

DOE is evaluating the appropriate valuation of avoided SO 2 and Hg emissions. Whether monetization of reduced SO 2 and Hg emissions will occur as part of any proposed rule that DOE issues for computer systems is yet to be determined

.

Item 17

- 1 DOE r equests comments on the approach it plans to use for estimating monetary benefits associated with emissions reductions.

18. UTLITY IMPACT ANALYS IS

To estimate the effects of energy conservation standards for computer systems on the electric utility industry, D OE plans to use a variant of EIA’s NEMS, called NEMS

- BT. NEMS is a large, multi

- sectoral partial equilibrium model of the U.S. energy sector, used primarily for the

52 Technical Update of the Social Cost of Carbon for Regulatory Impact Analysis Under Executive Ord er 12866

. Interagency Working Group on Social Cost of Carbon, U

. S

. Government , revised November 2013. http://www.whitehouse.gov/sites/ default/files/omb/assets/inforeg/technical

- update

- social

- cost

- of

- carbon

- for

regulator

- impact

- analysis.pdf

53 U.S. Office of Management and Budget , Office of Information and Regulatory Affairs, 2006 Report to Congress on the Costs and Benefits of Federal Reg ulations and Unfunded Mandates on State, Local, and Tribal Entities

, Washington, DC

.71

purpose of preparing EIA’s AEO . NEMS produces a widely recognized reference case forecast f or the United States through 2040 and is available in the public domain.

The effect of reducing site energy use is modeled by making NEMS runs that deviate from the most recent AEO Reference case

. Each year, DOE develops response coefficients using the NE MS

- BT which give changes in capacity and generation by fuel type for a given quantity of site energy use reduction to a particular energy end use

. DOE develops response coefficients for several different energy end uses

. To model the impact of this standar d on the electric utility industry, the response coefficients will be weighted by end use, and then they will be applied to the site energy savings for computer systems which is generated from the NIA analysis.

Item 18

- 1 DOE seeks input from stakeholders on its prop osed use of NEMS

- BT to conduct the utility impact analysis.

19. EMPLOYMENT IMPACT AN ALYSIS

The employment impact analysis examines indirect employment impacts from standards, which consist of the net jobs created or eliminated in the national economy, other th an in the manufacturing sector being regulated, caused by: (1) reduced spending by end users on energy; (2) reduced spending on new energy supply by the utility industry; (3) increased spending on new equipment to which the new standards apply; and (4) the effects of those three factors throughout the economy

. ( D irect employment impacts are any changes in the number of employees of manufacturers of the equipment subject to standards , their suppliers, and related service firms. The MIA will address impacts o n the number of employees working for the manufacturers ).

One method for assessing the possible effects on the demand for labor of such shifts in economic activity is to compare sector employment statistics developed by the Labor Department’s Bureau of La bor Statistics (BLS). The BLS regularly publishes its estimates of the number of jobs per million dollars of economic activity in different sectors of the economy, as well as the jobs created elsewhere in the economy by this same economic activity. Data fr om BLS indicate that expenditures in the utility sector generally create fewer jobs (both directly and indirectly) than expenditures in other sectors of the economy. 54 There are many reasons for these differences, including wage differences and the fact tha t the utility sector is more capital

intensive and less labor

- intensive than other sectors. Energy conservation standards have the effect of reducing consumer utility bills. Because reduced consumer expenditures for energy likely lead to increased expendit ures in other sectors of the economy, the general effect of efficiency standards is to shift economic activity from a less labor

- intensive sector ( i.e. , the utility sector) to more labor

- intensive sectors ( e.g. , the retail and service sectors).

54 See Bureau of Economic Analysis, Regional Multipliers: A User Handbook for the Regional Input

- Output Modeling System (RIMS II )

. Washington, DC. U.S. Department of Commer ce, 1992.72

Once DOE i ssues a NOPR, DOE plans to estimate indirect national employment impacts using an input/output model of the U.S. economy called Impact of Sector Energy Technologies version 3.1.1 (ImSET). 55 ImSET is a special

- purpose version of the “U.S. Benchmark National Input

- Output” (I

– O) model, which was designed to estimate the national employment and income effects of energy

- saving technologies. The ImSET software includes a computer

- based I

– O model having structural coefficients that characterize economic flows among 187 sectors most relevant to industrial, commercial, and residential building energy use.

DOE notes that ImSET is not a general equilibrium forecasting model and understands the uncertainties involved in projecting employment impacts, especially changes in the later years of the analysis. Because ImSET does not incorporate price changes, the employment effects predicted by ImSET may over

- estimate actual job impacts over the long run. DOE may consider the use of other modeling approaches for examining long

- run employment impacts.

Item 19

- 1 DOE seeks feedback on its proposed approach to assessing national employment impacts.

20. REGULATORY IMPACT AN ALYSIS

If DOE issues a proposal to set standards for computer systems , it will prepare a regulatory impact analysis to addres s the potential for non

- regulatory approaches to supplant or augment energy conservation standards to improve the efficiency of computer systems . DOE recognizes that voluntary or other non

- regulatory efforts by manufacturers, utilities, and other intereste d parties can result in substantial improvements in efficiency. DOE intends to analyze the likely effects of non

- regulatory initiatives on equipment energy use, customer utility, and LCC. DOE will attempt to base its assessment on the impacts of any such i nitiatives to date, but will also consider information presented regarding the impacts that an initiative might have in the future.

55 J. M. Roop, M. J. Scott, and R. W. Schultz, ImSET 3.1: Impact of Sector Energy Technologies

, PNNL

- 1 8412, Pacific Northwest National Laboratory

, 200 9

. < www.pnl.gov/main/publications/external/technical_reports/PNNL

18412.pdf

>73

APPENDIX A. SCOPE OF INDUSTRY ST ANDARDS

A.1 Scope of Existing Computer Standards

DOE evaluated several industry, regulatory, and voluntary standards for computers in consideration for the scope of this rulemaking. The following sections discuss the scope of the computer industry standards.

A.1.1 ENERGY STAR Program Scope for Computers

ENERGY STAR Computers V. 5.2 and V. 6.0 require that all produc ts covered under the scope of coverage must meet the definition of a computer as well as one of the included product’s definitions such as a desktop or notebook computer. ENERGY STAR also includes a list of products that are excluded from this program. A l ist of included and excluded products for ENERGY STAR Computers V. 5.2 is specified in Table A

- 1

.

Table A

- 1 : ENERGY STAR Computers V. 5.2 Scope of Coverage

Included P roducts Excluded Products Desktop computers Integrated desktop computers Notebook computers Workstations Small

- scale servers Thin clients Computer servers Handheld computers Game consoles Personal Digital Assistant devices (PDAs)

Smartphones Handheld gami ng devices

ENERGY STAR Computers V. 6.0 adds definitions for mobile thin clients and ultra

- thin clients to distinguish them from notebook computers and thin clients respectively. Additionally, point of sale (POS) systems, tablet computers, and ultra

- thin clients were added to the list of excluded products under the scope of coverage. These changes are specified in Table A

- 2

. Table A

- 2 : Scope Updates in ENERGY STAR Com puters V. 6.0 from V. 5.2

Included Products Excluded Products

Mobile thin clients Point of sale systems Tablet computers Ultra

- thin clients

A.1.2 Scope of Industry and Regulatory Programs for Computers

While EU No. 617/2013 and AS/NZS 5813:2012 closely align with ENERGY STAR Computers V. 5.2’s testing requirements, there are some differences in scope between these
programs

. Table A

- 3 highlights only the differences between ENERGY STAR Computers V. 6.0, AS/NZS 5813:2012 , and EU No. 617/2013, and omits consistencies with ENERGY STAR Computers V. 6.0. Additionally, IEC 62623 Ed. 1.0 and ECMA

- 383 Ed. 3 are not included in this comparison because they only cover desktop, integrated desktop, and notebook computers in their sc ope of coverage.74 Table A

- 3 : Differences in Scope of Coverage for Regulatory Programs

Included Excluded ENERGY STAR Computers V.

6.0 Thin clients Workstations Tablet computers

AS/NZS 5813:2012 Thin clients Workstations

EU No. 617/2013 Tablet computers Docking stations Thin clients* Workstations* Small

- scale servers*

* EU does not measure the power consumption of these products. They are technically in scope but only to measure the internal power supply ef ficiency.

A.2 Scope of Existing Computer Server Standards

DOE evaluated several regulatory and voluntary standards for computers in consideration for the scope of this rulemaking. The following sections discuss the scope of the computer server industry standar ds.

A.2.1 ENERGY STAR Program Scope for Computer Servers

ENERGY STAR Computer Servers V. 2.0 includes blade, multi

- node, rack mounted, and pedestal servers with four or fewer physical CPUs in its scope. The products included and excluded from the ENERGY STAR Com puter Servers V. 2.0 scope as specified in Table A

- 4

. Table A

- 4 : ENERYGY STAR Computer Servers V. 2.0 Scope of Coverage

Included Products Excluded Products

Rack serv ers Multi

- node servers Pedestal servers Microservers/cloud servers Blade systems Fully fault tolerant servers Server appliances High performance computing systems

Large servers Storage products including blade storage

Network equipment

A.2.2 Scope of Regulatory Programs for Computer Servers

Of the other regulatory programs that DOE evaluated, EU’s EC Regulation No. 617/2013 (Lot 3) also targets rack and pedestal servers with four or fewer physical CPUs but, these regulations do not include a test procedure. Inst ead, requirements are provided for the minimum power supply efficiency and power factor.

The Japanese Ministry of Economy, Trade and Industry’s Top Runner Program for Computers & Hard Disks targets computer servers, defined as “a computer that is designed to operate 24 hours a day and provide services on a network, and which can be accessed only via the network”, but excludes very high and very low performance systems. The test procedure in the program includes an idle state power measurement test, which i s then compared to the maximum theoretical performance to obtain an efficiency figure. This program uses different compliance standards for each product class, which are determined based on a product’s hardware characteristics.75

The Korean Ministry of Trade , Industry and Energy works with the Korea Energy Management Corporation (KEMCO) to develop the E

- Standby Program. This targets computer servers with two or fewer physical CPUs and a power supply rating of less than 3,000 watts, but excludes blade and mult i

- node servers. A test procedure is defined for measuring the standby power of covered products, there is a different compliance standard for each product class, which is determined based on a product’s hardware characteristics.76

APPENDIX B. LIST OF ITEMS FOR CO MMENT

Item 3

- 1 DOE requests comment on the definition of a computer or alternate approaches that should be considered. Specifically, DOE requests suggestions of characteristics that may be used in the definition to distinguish general consumer electronics from computers.

........................... 15 Item 3

- 2 DOE requests feedback and information on additional factors and criteria that could be used to distinguish clearly between computer servers and client computers, other than those based on point

- of

- sale or end

- use.

................................ ................................ ................................ 16 Item 3

- 3 DOE requests comment on using ENERGY STAR Computers V. 6.0 and ENERGY STA R Computers Final Draft V. 6.1 as the basis for computer product definitions. DOE also requests comment on any additional computer product definitions that should be included.

...... 18 Item 3

- 4 DOE r equests comment on the need for a tablet computer definition. DOE also requests comment on the criteria used to distinguish tablet computers from other computers as well as any suggestions for the definition.

................................ ................................ .................... 18 Item 3

- 5 DOE requests comment on the types of computers that should be excluded from the
scope.

................................ ................................ ................................ ................................ .... 19 Item 3

- 6 DOE requests comment on using computer product characteristics to narrow the scope of coverage or more accurately define products. In particular, what design characteristics would best be used to separate out tablets?

................................ ................................ .................. 19 Item 3

- 7 Based on DOE’s definition of a consumer product, DOE requests comment on additional methods (besides ability to operate on a residential circuit) to identify computer servers that are consumer products. Are there alternative strategies that can be used to create a scope of coverage w hich distinguishes consumer computer servers from those that are exclusively used in commercial/data

- center environments?

................................ ......................... 21 Item 3

- 8 DOE requests feedback on the proposed scope for UPSs. In pa rticular, whether or not industry believes a particular UPS type should be included within the scope.

............................. 22 Item 3

- 9 DOE requests feedback on using UPS product characteristics to narrow the scope of coverage. DOE further requests feedback on whether capacity is a proper differentiator between consumer and commercial UPSs and what constitutes a proper cut

- off capacity.

....................... 23 Item 4

- 1 DOE re quests comment on the use of IEC 62623 Ed. 1.0 as the basis for the development of the computers test method.

................................ ................................ ................. 24 Item 4

- 2 DOE requests comment on providing additional guidance as provided in EN ERGY STAR Computers V. 6.0. Specifically, DOE requests comment on the luminance values specified in ENERGY STAR Computers V. 6.0 for integrated desktops and notebooks. Are these values sufficient or does the luminance need to be higher for integrated displ ays?

..................... 25 Item 4

- 3 DOE requests comment on the inclusion of ENERGY STAR Computers V. 6.0 mode weightings.

................................ ................................ ................................ ................................ .... 26 Item 4

- 4 DOE requests c omment on adopting the ENERGY STAR Computers V. 6.0 weightings for AEC based on network proxy functionality. Specifically, DOE requests comment on the weighting values assigned to each proxy level.

................................ ................................ . 27 Item 4

- 5 DOE requests comment on a standardized and objective method to identify the level of proxy functionality on computers. Specifically, DOE welcomes information on steps that can objectively determine the proxy level on different OSs.

................................ .............................. 27 Item 4

- 6 DOE requests comment on the best approach to address network proxying: (a) using four levels of weightings for proxy functionality as specified in ENERGY STAR Computers V. 6.0 in addition to the conventional weightings; (b) using two levels of weightings, one for no77

network proxy functionality and the other for network proxy functionality; and, (c) using a single weighting for all computers.

................................ ................................ ................................ ......... 27 Item 4

- 7 For each of the approaches, DOE requests comment on the network proxy weighting that is representative of the computer’s AEC and is identifiable on all OSs.

............................... 27 Item 4

- 8 DOE requests comment on the use of the idle state test from the ENERGY STAR Computer Servers V. 2.0 Test Method for computer servers as a base for the development of the computer servers test method.

................................ ................................ ................................ ....... 30 Item 4

- 9 DOE requests feedback on its adoption of the IEC 62040

- 3 Ed.2.0 standard as a basis for the development of the UPS test method, while considering additional guidance provided in ENERGY STAR UPS V. 1.0.

................................ ................................ ................................ ....... 31 Item 5

- 1 DOE requests comment on the proposed approach for determining computer systems product classes. DOE welcomes comments on any design characteristics that should be considered when establishing product classes.

................................ ................................ ............. 32 Item 5

- 2 DOE requests comment on the categorization criteria for the ENERGY STAR Computers V. 5.2 product categories.

................................ ................................ ........................... 35 Item 5

- 3 DO E requests comment on the memory, graphics, and storage sub

- categorization and energy allowances from ENERGY STAR Computers V. 5.2.

................................ ..................... 35 Item 5

- 4 DOE requests comment on whether the CPU performa nce metric effectively classifies the performance of a CPU.

................................ ................................ ............................ 37 Item 5

- 5 DOE requests comment on the granularity of seven graphics categories consistent with the market of available GPUs.

................................ ................................ .............................. 37 Item 5

- 6 DOE requests comment on the enhanced performance display and integrated display performance features.

................................ ................................ ................................ .................... 37 Item 5

- 7 DOE reques ts comment on the absence of product categories for thin clients and small

- scale servers.

................................ ................................ ................................ ....................... 37 Item 5

- 8 DOE requests comment on possible strategies for computer server product classes. DOE reques ts comment on possible advantages and shortcomings of using the ENERGY STAR Computer Servers V. 2.0 classification criteria for the purpose of this rulemaking.

.................... 38 Item 5

- 9 DOE requests comment on possible advantages and shortcomings of using the ENERGY STAR UPS V. 1.0 product classification criteria for the purpose of this rulemaking. 40 Item 6

- 1 DOE requests information that would c ontribute to the market assessment for computers, computer servers, and UPSs that would be covered in this rulemaking. DOE particularly seeks information on shipments, trends in product feature and efficiency, distribution channels and estimates of market shares for the computers, computer servers, and UPSs considered in this rulemaking.

................................ ................................ ................................ ...... 41 Item 6

- 2 DOE requests comment and/or information on the current technological status of

error

- resilient ci rcuitry.

................................ ................................ ................................ ................. 46 Item 6

- 3 DOE welcomes comments on the preliminary technology options for computer systems identified in this section and whether there are other technology options it should conside r. In commenting on technology options, please discuss their impacts, if any, on safety, performance, and user utility, as well as cost of the technology options.

................................ ..... 49 Item 7

- 1 Are there any tech nologies, including those listed in sections 6.2, 6.3, and 6.4 that DOE should not consider because of any of the four screening criteria? If so, which screening criteria apply to the cited technology or technologies?

................................ ................................ 50 Item 8

- 1 DOE encourages interested parties to submit data that will improve DOE’s understanding of computer systems’ performance and associated costs.

................................ ..... 5178

Item 9

- 1 DO E seeks suggestions and comments concerning its proposed approach to developing estimates of markups.

................................ ................................ ................................ . 55 Item 10

- 1 DOE seeks comments on its proposed approach for specifying typical annual

ener gy consumption. Most importantly, DOE is interested in sources of data that can assist in characterizing the annual energy consumption of computer systems.

................................ .......... 56 Item 10

- 2 DOE welcomes input on da ta sources that it can use to characterize the variability in annual energy consumption for computer systems in the field. DOE is particularly interested in field monitoring studies and data.

................................ ................................ ............................. 56 Item 11

- 1 DOE seeks comments on its proposed approach of using probability distributions and Monte Carlo simulation to conduct the LCC and PBP analysis.

................................ ........... 58 Item 11

- 2 DOE requests data from st akeholders to characterize the current mix of computer system efficiencies in the market.

................................ ................................ ................................ . 58 Item 11

- 3 DOE seeks comments on the planned approach for estimating current and forecasted energy pr ices.

................................ ................................ ................................ ............... 59 Item 11

- 4 DOE seeks comments on the merits of its proposed analytical assumption that changes in maintenance, repair, and installation costs will be negligible for more

- efficient
compu ter systems. If that assumption is incorrect, DOE is interested in the reasons why this is so and in specific ways to correct that assumption.

................................ ................................ ........... 59 Item 11

- 5 DOE seeks comments on appropriate pro duct lifetimes for computer systems. Specifically, DOE seeks data sources for establishing product lifetimes.

................................ .... 59 Item 11

- 6 DOE seeks comments on its planned approach for estimating discount rat es for residential and commercial consumers.

................................ ................................ ........................ 60 Item 11

- 7 DOE seeks comments on computer system efficiency in the base case, historical efficiency data on computer systems, and projected trends in computer system efficiency.

....... 60 Item 12

- 1 DOE seeks historical shipments data and reports on future market trends from stakeholders. If such data are provided, DOE requests market share data showing the percentage of computer system shipments of different efficiencies and product classes.

.............................. 61 Item 12

- 2 As part of the preliminary manufacturer impact analysis, DOE seeks input from

ma nufacturers on the potential impact of new energy conservation standards on computer system shipments. DOE also seeks input from other stakeholders on the potential impact of standards on product shipments.

................................ ................................ ................................ ........................ 62 Item 12

- 3 DOE also requests input on any current market

- pull programs that promote the adoption of more efficient computer systems.

................................ ................................ .............. 62 Item 13

- 1 DOE seeks comments on the use o f the “roll

- up” and “shift” efficiency scenarios to characterize the impact that potential standards would have on the product efficiency distributions.

................................ ................................ ................................ ................................ . 63 Item 14

- 1 DOE welcomes comment on wh at, if any, consumer subgroups are appropriate in considering standards for computer systems.

................................ ................................ ............... 64 Item 15

- 1 DOE seeks comments on any subgroups of computer system manufacturers that it should co nsider in a manufacturer subgroup analysis.

................................ ................................ . 66 Item 15

- 2 DOE welcomes comments on other existing regulations or pending regulations it should consider in examining cumulative regulatory burden.

................................ ...................... 67 Item 16

- 1 DOE seeks comments on its approach to conduct the emissions analysis for the products that would be covered by any proposed rulemaking that would regulate computer system efficien cy.

................................ ................................ ................................ ......................... 6979

Item 17

- 1 DOE requests comments on the approach it plans to use for estimating monetary benefits associated with emissions reductions.

................................ ................................ ............. 70 Item 18

- 1 DOE seeks input from stakeholders on its proposed use of NEMS

- BT to conduct the utility impact analysis.

................................ ................................ ................................ ............ 71 Item 19

- 1 DOE seeks feedback on its proposed approach to ass essing national employment impacts.

................................ ................................ ................................ ................................ . 72