NATURAL RESOURCES DEFENSE COUNCIL 

January 19, 2012 

Ms. Brenda Edwards 

U.S. Department of Energy 

Building Technologies Program 

Mailstop EE-2J 

1000 Independence Avenue, SW 

Washington, DC 20585-0121 

Re: Preliminary NRDC Comments – RFI Covering Test Procedure and Energy 

Conservation Standard for Set-Top Boxes and Network Equipment 

Docket Number: EERE-2011-BT-NOA-0067 

RIN: 1904-AC52 

On behalf of NRDC and its more than 1.3 million members and electronic activists we 

respectfully submit these preliminary comments in advance of the January 26, 2012 

DOE meeting on the test procedure and energy efficiency standards for set-top boxes 

(STBs) and networking equipment. These comments are meant to inform the 

proceeding DOE is initiating and builds off of the written comments NRDC previously 

submitted on September 29, 2011. Our comments cover the following topics: 

background, product classes, test procedures, and efficiency targets for the rulemaking. 

Background: Per field measurements and analysis previously performed by NRDC 

and its consultant Ecos, there are approximately 160 million pay TV set top boxes 

installed in the US. Nationally, as of 2010, STBs1

 consume an estimated 27 billion 

kWh/yr and cost consumers more than $3 billion per year in electric bills. The bulk of 

this energy consumption occurs while the user is neither is watching or recording a 

show. This is because STBs as currently designed consume near full power levels even 

when they are “turned off”. Figure 1 below provides a graphical summary of the 

national impacts of set top box use. 

1

 A copy of NRDC’s report can be downloaded at: http://www.nrdc.org/energy/files/settopboxes.pdf. 

 Note, our analysis only focused on set top boxes provided by cable, satellite and telco service providers 

and does NOT include the power consumed by networking equipment such as cable/DSL modems or 

routers. 

www.nrdc.org 111 Sutter Street, 20th Floor NEW YORK  WASHINGTON, DC  LOS ANGELES  BEIJING  CHICAGO 

San Francisco, CA 94104 

TEL 415 875-6100 

FAX 415 875-6161 
Figure 1– National Energy Use and Operating Costs of STBs 

It should also be noted that in many cases a high definition DVR may use more 

electricity per year to operate than the new big screen TV it’s connected to. Also the 

STBs in homes that have a DVR and additional basic boxes hooked up to their other 

TV(s) will consume more electricity per year than a new refrigerator. (See Figure 2 

below.) 

Figure 2 – Annual Energy Use of STBs and Other Appliances (Note: The top entry 

is for a common set-up found in the market – an HD-DVR STB on the main TV and a 

basic STB on the second TV.) 

NRDC Comments 2 
 

Since we completed our study, an updated version of ENERGY STAR (Version 3) went 

into effect and new boxes are entering the market that meet these requirements and use 

roughly 30% less energy. While there are approximately 30 or so qualified models on 

the market, it is often difficult for a consumer to access one of these new models for 

their home. Over time, availability of these new more efficient boxes will increase and 

national STB energy use will begin to decline. (Note as a typical STB lasts 6 years or 

so, it will take many years for the installed base of less efficient legacy boxes to be 

replaced). We also want to point out that the leading cable companies have made the 

following public commitment2

 in a letter to Senator Feinstein: 90% of new STBs they 

purchase and deploy will meet or exceed ENERGY STAR 3.0 standards by the end of 

2013. 

Based on informal conversations we have had with service providers from the satellite 

and Telco companies, the vast majority of new STBs deployed in the near future will 

meet ENERGY STAR Version 3. 

Product Classes/Scope – There are currently three major providers of service – cable, 

satellite and telephone company (Telco for short). Each provides consumers with 

access to pay TV and video content. In almost all cases, the service provider either 

loans the box to the customer without charge or leases it to them for a monthly fee. The 

boxes that are deployed differ somewhat between service providers. 

We do not yet have an opinion whether DOE should simply set one set of standards for 

STBs that offer similar functionality (e.g., one size fits all) or should create separate 

product classes for cable, satellite and Telco STBs. In either case, DOE can consider 

establishing power use adders, where appropriate, to provide additional power 

allowances due to additional features/functionality (e.g., a STB with a DVR would 

warrant additional on mode power compared to a basic box). 

Other points tied to the issue of product class/scope that we wish to bring to DOE’s 

attention include: 

	 LNBs – satellite systems deploy one or more LNBs (low noise block). Their 

power use is typically 2 to 4 Watts each, often 24/7, and their power use should 

be included in power measurements made under the final DOE test procedure. 

	 Auxiliary Boxes – Many of the systems deployed by the Telco providers include 

a gateway or optical network terminal (ONT) box that is placed in the garage, 

basement or exterior of the home. Incoming data, video and phone service may 

be routed through this box. Little is publicly known about these boxes but they 

are believed to consume around 16 or more Watts continuously. That translates 

to 140 kWh/yr and some portion of this power should be assigned to the STB. 

This energy use needs to be accounted for in DOE policies or little attention will 

be paid to this sizable energy use and telco providers will be provided with an 

2

 http://energy.gov/sites/prod/files/120511_DOE%20Ltr.pdf 

NRDC Comments 3 
unfair advantage. We also understand that when a consumer switches service 

providers, typically after the favorable initial rate expires after the first year, that 

the ONT may remain at the customer’s home and continue to consume power 

even when the user is no longer receiving service from it. 

	 Network Equipment – We encourage DOE to continue to include cable and DSL 

modems, and routers as part of this rulemaking and to develop one or more 

product classes to cover these products. 

	 TiVo Boxes – TiVo produces a standalone DVR that consumers purchase at 

retail. To receive pay TV content, the user signs up with a service provider and 

inserts a cable card into the back of the box. We recommend these types of 

boxes be covered by the test procedure and standard. 

Test Procedures – ENERGY STAR and CEA test procedures provide two excellent 

starting points for measuring the energy use of STBs. The main area where additional 

improvement is needed is on the topic of “deep sleep”. The CEA document has only 

one sleep state in its document and essentially measures how much power a connected 

box uses when it is turned “off”. It does not provide the ability to distinguish between a 

light or deep sleep state. While ENERGY STAR does include deep sleep in Version 4 

of its specification, their definition and test method lack sufficient clarity on what is an 

acceptable implementation. For example, one could conceivably design a box that 

requires the user to hold down the power button for 10 seconds or more for it to enter a 

deep sleep state, instead of light sleep. As few consumers would know about this 

option or remember to do this, the box would most likely not enter deep sleep and 

would consume significantly higher amounts of power when not in use. 

Other high level input on test procedures include: 

	 Test on live system – Set top power use is highly dependent upon the service 

provider the box is connected to. For example, the same box may produce very 

different daily energy use levels when connected to Comcast vs Time Warner. 

This is because STB power use is tied to the hardware and software used by the 

service provider, and how the service provider deploys the box. We recommend 

STB testing for each box is done with live network testing. This can be done by 

actually connecting the box to the service provider or via an equivalent 

simulation. 

	 Set up conditions – DOE needs to include sufficient clarity on how to set up the 

STB prior to testing. For example, are the LNBs hooked up during the test, if 

the box has an auto power down feature as an option should it be on during 

testing, and how to handle a box that has speculative recording? 

	 DVRs – we concur with DOE that these devices should be tested in each of their 

major operating modes ( recording, playback, sleep, etc). 

NRDC Comments 4 
	 24 Hour Testing – In addition to testing a STB’s power use in the key operating 

modes, the testing should also consider the STB’s behavior and power 

consumption throughout the day. For example while a box might have a low 

power deep sleep state, it is less useful if the STB is constantly being awakened 

by the head end or other STBs in the home network and spending most of its 

time in a much higher power state. 

	 Networking Equipment – Separate test methods from STBs will be needed for 

this product class. 

Stringency – As stated in our earlier comments, the big savings opportunity for STBs is 

to reduce the power consumption when the box is not in use. None of the boxes on the 

market today meet this target. A meaningful DOE standard would include this 

requirement as the foundation of its requirements. Although today’s STB are not able 

to meet a low power deep sleep requirement ( approx 3 to 5 W) and quickly wake when 

the consumer returns, there are numerous examples of products on the market today that 

offer exactly this functionality. These include smart phones and IPads, both of which 

have similar user security and billing needs, use very low levels of power when not in 

use and wake almost instantly to receive or make a call, or return to view a video. 

While each product has its unique requirements, the general principles of power scaling 

are universally applicable and there are multiple chip vendors that can develop/provide 

the needed technology for STBs. 

As the DOE standard will not likely take effect for 5 years or so, it’s critical for the 

efficiency standard DOE issues to be forward looking and embrace the energy saving 

opportunities that exist. It is not sufficient to merely establish a standard at the same 

levels as ENERGY STAR Version 3, which the industry is likely to move to by the end 

of 2013 on its own. While it reflects an improvement over the installed base, it does not 

achieve the 75% or so level of savings that are achievable via incorporation of low 

power deep sleep and incremental improvements in on mode power. 

For networking equipment we encourage DOE to review the work that has been done 

recently on energy efficient Ethernet standards which essentially require the equipment 

to scale power use to the amount of data being transmitted. Thus a router or modem at 

2 am which is not actively receiving data would automatically throttle down to a lower 

power state. 

Respectfully Submitted, 

Noah D. Horowitz 

Senior Scientist 

Natural Resources Defense Council 

nhorowitz@nrdc.org 

NRDC Comments 5 
Initial NRDC Comments on Set 

Boxes and Network Equipme

Docket: EERE-2011-BT-NOA-0067/ RIN: 1904-AC52 

Noah Horowitz – Senior Scie

Natural Resources Defense Counci

nhorowitz@nrdc.org

January 26, 2011
NRDC-Ecos STB 2010 Study Fin

• > 80% of US households subscribe to p• Installed base - 160 million STBs • Many homes have 2 or more STBs • Little to no difference in power use w

“turned off” 

• Per home STB energy use increasing du

growth of DVRs 
NRDCS 2010 SURVEY OF ENERGY CONSUMED BY U.S. SET-TOP BOXES 

On Mode Power 

60 51 eep M d P o e ower 

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NRDCS 2010 SURVEY OF ENERGY CONSUMED BY U.S. SET-TOP BOXES 

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2010 Study Results for All Se

Providers

NRDC'S 2010 SURVEY OF ENERGY CONSUMED BY SET-TOP BOXES Cable S

700 High Definition 

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n = 15 

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with DVR 

n = 26 

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Units Tested Source: Ecos/NR

Estimated Unit Energy Consumption (kWh per year) . 
NRDC-Ecos STB Study Findin

• DVR STB may use more electricity/yr 

the big screen TV its connected to 

• DVR STB + regular STB = Annual 

electricity use of new refrigerator

• Americans spend $2 billion/yr to pow

their STBs when they are NOT in use
Nearly Two-Thirds of Annual U.S. Set-Top Box 

Energy Use Occurs When Viewers are Not 

Watching or Recording Content 

Not In Use 

RESULTS IN ..• 

Electricity Consumption: 

J Power Plants (500 MW each) 

Emissions: 

5 Million Metric Tons C02!'year 

Cost to Consumers: 

$1 Billion/year 

RESULTS IN .. 

Electricity Consumption: 

6 Power Plants (500 MW each) 

Emissions: 

11 Million Metric Tons CO,.Jyear 

Cost to Consumers: 

52 Billion/year 

In Use " watching or recording a show 

Nolin Use " not watching or recording a show 

Nearly Two-Thirds of Annual U.S. Set-Top Box 

Energy Use Occurs When Viewers are Not 

Watching or Recording Content 

RESULTS IN ..• 

Electricity Consumption: 

J Power Plants (500 MW each) 

Emissions: 

5 Million Metric Tons COiyear 

COSt to Consumers: 

51 Billion/vear 

RESULT" I 

Electricity Consumption: 

6 Power Plants (500 MW each) 

Emission s: 

11 Million Metric Tons CO;.Jyear 

Cost to Consumers: 

52 Billion/year 

In Use ", watching or recording a show 

Not In Use ", not watchin9 or recording a show 
Recent STB Developmen

• EPA updated ENERGY STAR specificatio

set top boxes (STBs) 

• E-Star 3.0 specification is live and with ~4

qualified models. Two positive developme

– On mode power reduction ~30% –

3

7 watt savings between on and sleep mode

• Major service providers shifting to E-Star 

next 12-24 months. Good first step but doaddress need for deep sleep. 
Desired STB Outcomes

• Low power consumption (<5W for main 

when STB is not actively used 

• Ability to wake quickly when user retur

record pre-programmed show, or receivupdates 

Learn from excellent power management in place for IPads, smart phones, etc. 
Desired STB Outcomes (

• Significantly reduce STB energy used f

3rd TVs 

• Encourage “thin client”, multi-room app

Eliminate need to maintain connection t“head end” 
Other Input

• Standard not likely to go into effect for 

years from today 

• Changes may be required at both STB a

service provider (head end) level 

• Standard should establish power targets 

next generation STBs– new silica, softwbetter power scaling, etc 
Test Method Issues

• Critical for testing to be done on live ne

Results may vary by service provider 

• How to address frequent wake events • What else to include: 

– Satellite – LNBs – Telco – Optical Network Terminal (ONT) 

24/7 

 131 kWh/yr) 
Networking Equipment

• Many homes have: 

A. High-speed internet – cable/DSL modem B. Wireless network – router 

• It adds up – 6 W x 2 x 24/7 = 105 kWh

• Need good definition, data, test method • Have energy use scale to amount of data 

transferred 
For More Info

NRDC Report : http://www.nrdc.org/energy/files/settopbo
Energy Use of Set-Top Boxes and Other 

Appliances 

Typical Household Set-Top 

Configuration 

(1 HO-OVR, 1 HO Set-Top 

New ENERGY 

STAR Refrigerator 

(21 cubic feet, top freezer) 

Re cent Model HO-OVR 

Set-Top 

ENERGY STAR Version 4.1 

4T LCD TV Model 

Recent Model 

Ho Set-Top 

Compact f luorescent 

Light Bulb ICFL) 

200 50

Average Energy Use (kWh/ year) 

Energy Use of Set-Top Boxes and Other 

Appliances 

Typical Household Set-Top 

Configurati on 

(1 HO·OVR, 1 HO Set·Top 

New ENERGY 

STAR Refrigera!Or 

(21 cubic feet,!Op freezer) 

Recent Model HO-OVR 

Set-Top Box 

ENERGY STAR Version 4.1 

4T LCD TV Mode l 

Recent Model 

HO Sel-Top 

Compact fluorescent 

Light Bulb ICFl) 17 

200 50

t:DC Average Energy Use (kWh/ year) 
Pawer Measurement. of Cobif>, Satellite and IPTV 5et-Top Boxe. 

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