# N ATURAL 

# R ESOURCES 

# D EFENSE 

# C OUNCIL



# 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-T op 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 co mments 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. Thes e 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 anal ysis previously performed by NRDC

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

installed in the US. Nationally, as of 2010, STBs 1 

# consume an estimated 27 billion

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

this energy consumption occurs while the us er 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, 20 th 

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# 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 c onnected to. Also the

STBs in homes that have a DVR and a dditional 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 ve rsion of ENERGY STAR (Version 3) went

into effect and new boxes are entering the ma rket 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 thes e new more efficient boxe s 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 commitment 2 

# in a letter to Senator Feinst ein: 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 majo r providers of service – cable,

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

access to pay TV and video content. In almo st all cases, the serv ice 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 somewh at 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 s hould create separate

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

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

allowances due to additional features/f unctionality (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 cla ss/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 ea ch, often 24/7, and th eir 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 te lco 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 l onger 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 c over these products.

 TiVo Boxes – TiVo produces a standal one 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 pro cedures 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 essentia lly 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 defi nition 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 dow n 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 w ould most likely not en ter deep sleep and

would consume significantly higher am ounts of power when not in use.

Other high level input on test procedures include:

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

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

different daily energy use levels when c onnected 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 serv ice provider or via an equivalent

simulation.

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

STB prior to testing. For example, ar e 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 th at has speculative recording?

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

major operating modes ( record ing, 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 cons ider 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 earlie r 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 mean ingful DOE standard would include this

requirement as the foundation of its require ments. 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 exam ples of products on the market today that

offer exactly this functionality. These in clude smart phones and IP ads, 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 mu ltiple chip vendors that can develop/provide

the needed technology for STBs.

As the DOE standard will not lik ely 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 esta blish 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 impr ovement 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 incrementa l improvements in on mode power.

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

recently on energy efficient Ethernet standard s which essentially require the equipment

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

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

power state.

Respectfully Submitted,

Noah D. Horowitz

Senior Scientist

Natural Resources Defense Council

nhorowitz@nrdc.org

NRDC Comments 5Initial NRDC Comments on Set TopBoxes and Network EquipmentDocket: EERE-2011-BT-NOA-0067/ RIN: 1904-AC52Noah Horowitz – Senior ScientistNatural Resources Defense Council (NRDC)nhorowitz@nrdc.orgJanuary 26, 2011NRDC-Ecos STB 2010 Study Findings•> 80% of US households subscribe to pay TV•Installed base - 160 million STBs•Many homes have 2 or more STBs•Little to no difference in power use when“turned off”•Per home STB energy use increasing due togrowth of DVRs23NRDCS2010SURVEYOFENERGYCONSUMEDBYU.S.SET-TOPBOXESOnModePower6051M d PeepoeowerlJStreamingStandardOefinitionHighOefinitionHO-OVROevices(SO)Receiver(HO)ReceiverSO-OVR•3models26models2models14models15models•-VI50........ro••-•"'0c:40roEQ)••••0...••Q)300•-II••••IIc..•:..•"'0Q)...•I•II::l20VIroQ)I,••....,•••••10..f-J--•ot-ocUnitsTestedNRDCS2010SURVEYOFENERGYCONSUMEDBYU.S.SET-TOPBOXESOnModePower6051M d PeepoeowerLJStreamingStandardDefinitionHighDefinitionHD-DVRDevices(SD)Receiver(HD)ReceiverSD-DVR•3models26models2models14models15models•-VI+-'50,+-'ro••-•"'0!::40roE(lJ0...••••••(lJ300•I•••c..••••"'0(lJ••...::l20VIro(lJ,••....,•••••10..f-t-•ot-ocUnitsTested2010 Study Results for All ServiceProvidersNRDC'S 2010 SURVEY OF ENERGY CONSUMED BY SET-TOP BOXESCableIPTVSatellite700High Definition(HD) Receivern = 15HD Receiverwith DVRn = 26StandardReceiver w/DVR3StandardReceivern = 146005004003002001000Units TestedSource: Ecos/NRDC 2010

Estimated Unit Energy Consumption (kWh per year) .4NRDC-Ecos STB Study Findings II•DVR STB may use more electricity/yr thanthe big screen TV its connected to•DVR STB + regular STB = Annualelectricity use of new refrigerator•Americans spend $2 billion/yr to powertheir STBs when they are NOT in use.56NearlyTwo-ThirdsofAnnualU.S.Set-TopBoxEnergyUseOccursWhenViewersareNotWatchingorRecordingContentNotInUseRESULTSIN..•ElectricityConsumption:JPowerPlants(500MWeach)Emissions:5MillionMetricTonsC02!'yearCosttoConsumers:$1Billion/yearRESULTSIN..ElectricityConsumption:6PowerPlants(500MWeach)Emissions:11MillionMetricTonsCO,.JyearCosttoConsumers:52Billion/yearInUse"watchingorrecordingashowNolinUse"notwatchingorrecordingashowNearlyTwo-ThirdsofAnnualU.S.Set-TopBoxEnergyUseOccursWhenViewersareNotWatchingorRecordingContentRESULTSIN..•ElectricityConsumption:JPowerPlants(500MWeach)Emissions:5MillionMetricTonsCOiyearCOSttoConsumers:51Billion/vearRESULT"IElectricityConsumption:6PowerPlants(500MWeach)Emissions:11MillionMetricTonsCO;.JyearCosttoConsumers:52Billion/yearInUse",watchingorrecordingashowNotInUse",notwatchin9orrecordingashowRecent STB Developments•EPA updated ENERGY STAR specification forset top boxes (STBs)•E-Star 3.0 specification is live and with ~40qualified models. Two positive developments:–On mode power reduction ~30%–37 watt savings between on and sleep modes•Major service providers shifting to E-Star 3.0 innext 12-24 months. Good first step but does NOTaddress need for deep sleep.7Desired STB Outcomes•Low power consumption (<5W for main box)when STB is not actively used•Ability to wake quickly when user returns torecord pre-programmed show, or receiveupdatesLearn from excellent power management alreadyin place for IPads, smart phones, etc.8Desired STB Outcomes (II)•Significantly reduce STB energy used for 2nd,3rdTVs•Encourage “thin client”, multi-room approach.Eliminate need to maintain connection to“head end”9Other Input•Standard not likely to go into effect for 6+years from today•Changes may be required at both STB andservice provider (head end) level•Standard should establish power targets fornext generation STBs– new silica, software,better power scaling, etc10Test Method Issues•Critical for testing to be done on live network.Results may vary by service provider•How to address frequent wake events•What else to include:–Satellite – LNBs–Telco – Optical Network Terminal (ONT) (~15 W,24/7131 kWh/yr)11Networking Equipment•Many homes have:A.High-speed internet – cable/DSL modemB.Wireless network – router•It adds up –6 W x 2 x 24/7 = 105 kWh/yr•Need good definition, data, test method•Have energy use scale to amount of data beingtransferred12For More InfoNRDC Report :http://www.nrdc.org/energy/files/settopboxes.pdf1314EnergyUseofSet-TopBoxesandOtherAppliancesTypicalHouseholdSet-TopConfiguration(1HO-OVR,1HOSet-TopNewENERGYSTARRefrigerator(21cubicfeet,topfreezer)RecentModelHO-OVRSet-TopENERGYSTARVersion4.14TLCDTVModelRecentModelHoSet-TopCompactfluorescentLightBulbICFL)200500AverageEnergyUse(kWh/year)EnergyUseofSet-TopBoxesandOtherAppliancesTypicalHouseholdSet-TopConfiguration(1HO·OVR,1HOSet·TopNewENERGYSTARRefrigera!Or(21cubicfeet,!Opfreezer)RecentModelHO-OVRSet-TopBoxENERGYSTARVersion4.14TLCDTVModelRecentModelHOSel-TopCompactfluorescentLightBulbICFl)17200500t:DCAverageEnergyUse(kWh/year)15PawerMeasurement.ofCobif>,SatelliteandIPTV5et-TopBoxe._.......................----ecos--____-....._u..PowerMf'<1Sur..mentsof[obit>,Sat..l/it..andIPTVSet-TopBox",--ecos---.--........._...-"'"