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UNITED STATES OF AMERICA 

DEPARTMENT OF ENERGY 

U.S. DEPARTMENT OF ENERGY 

NOTICE OF PROPOSED RULEMAKING PUBLIC MEETING ON 

TEST PROCEDURE FOR SET-TOP BOXES

 

U.S. Department of Energy 

1000 Independence Avenue, SW 

Washington, DC 20585 

Room 8E-089 

Wednesday 

February 27, 2013 

 

Facilitator: 

Doug Brookman 

Public Solutions 

Baltimore, MD 
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Participants Identified: 

Jennifer Amann 

ACEEE 

Joseph Andersen 

TIA 

Tim Ballo 

Earth Justice 

Tom Eckman 

Northwest Power and Conservation Council 

Kuriacose Joseph 

Director of Engineering 

DIRECTV 

Gregg Hardy 

ECOVA 

Noah Horowitz 

NRDC, the Natural Resources Defense Council 

David Hungerford 

California Energy Commission 

Adam Goldberg 

Consultant, Representing TiVo 

Neal Goldberg 

General Counsel 

National Cable and Telecommunications Association 

Paul Glist 

Davis Wright 

Representing NCTA 

Stephen Jeong 

UL LLC 

Katherine Kaplan 

EPA 

EnergyStar Program 

 

Gary Langille 

Echostar Technologies 

Representing Dish Network 
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Mark Levine 

Consumer Electronics Association 

Jonathan Make 

Communications Daily 

Mateusz (Matt) Malinowski 

ICF International 

Joshua S. Parker 

Willkie Farr & Gallaher, LLP 

Chuck Samuels 

CEA 

Jennifer Sanford 

Cisco Systems 

Charlie Stephens 

Northwest Energy Efficiency Alliance 

Rachel Unger 

ICF International 

Robert Turner 

Pace 

Webinar Participants (Identified): 

Antonio Figueiredo 

Ken Rider 

Roger Goodner 
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Participants from DOE:

Jeremy Dommu 

Project Manager for Rulemaking 

Francine Pinto 

General Counsel’s Office 

Ashley Armstrong 

Participants from Navigant/LBL:

Allen Tsao (presenter) 

Navigant Consulting 

Mansi Thakkar (presenter) 

Navigant Consulting 

Mike Rivest 

Navigant Consulting 

Debra Brunk 

Navigant Consulting 

Louis-Benoit Desroches 

Lawrence Berkeley National Laboratory 

Stephanie Gupana 

Navigant Consulting 

Anthony Rotolo 

Navigant Consulting 
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AGENDA

 ITEM PAGE 

 

Opening Statements 6 

Further Introductions 9 

Rulemaking Process, Mr. Dommu 17 

Scope, Mr. Dommu 22 

Summary of the NOPR, Mr. Dommu 55 

Navigant Presentation, Ms. Thakkar 

 Definitions 60 

 Test Conditions and Setup 95 

 On, Sleep and Off Mode Tests 110 

Navigant Presentation, Mr. Tsao 

 Calculation of AEC Metric 186 

 

 Estimated Burden to Small Businesses 190 

 
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1 P R O C E E D I N G S

2 MODERATOR: (meeting in progress at start of 

3 audio.) 

4 Opening Statements 

5 MR. SAMUELS: ... standard 2043. However, for 

6 the reasons I’m going to briefly explain, we oppose 

7 the promulgation of a federal test procedure for set 

8 top boxes. It’s unnecessary and would be detrimental 

9 both to innovation and to the existence of an up-to10 date, technology relevant national test procedure. 

11 First let me announce, for those who don’t 

12 know it, that with support from CEA and NCTA, 15 

13 industry-leading multi-channel video providers and 

14 device manufacturers announced a voluntary agreement 

15 in December, which is a major step forward in 

16 increasing the deployment of energy efficient set top 

17 boxes. A corporate entity is being formed and the 

18 companies and associations have met to develop a 

19 comprehensive and rigorous program for determining 

20 compliance with the commitments of the voluntary 

21 agreement, as well as to set future goals. 

22 We will be glad to provide for the 

23 administrative record, information on this agreement 

24 as well as our future activities. 
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1 We would have hoped that the efficiency 

2 advocates would have been parties to this agreement 

3 and we’re disappointed that they’re not. Nonetheless, 

4 we are committed to continue to discuss with them the 

5 implementation of the agreement and what can be done 

6 in the future to extend it. 

7 Because of this agreement, and for the 

8 reasons that we stated in the pending proceeding on 

9 whether or not set top boxes should be a covered 

10 product, we don’t think a federal test procedure is 

11 necessary because there’s no justification for federal 

12 standards. And the set top boxes should not be 

13 designated as a covered product. Now curiously, this 

14 proceeding has been commenced even though the question 

15 of whether or not set top boxes should be a covered 

16 product has not been resolved. 

17 As DOE and other stakeholders know, CEA has 

18 a very active process to develop a national consensus 

19 test procedure which is close to finalization, CEA 

20 2043. In fact, we have taken the comments, the 

21 variations in this proposed test procedure as comments 

22 to our consensus test procedure and will attempt to 

23 integrate as many of them as possible. DOE, NRDC, and 

24 other parties here have been part of that process and 

25 we think that that is going to work out quite 
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1 satisfactorily and ensure that our country has a 

2 uniform, national test procedure. Please keep in mind 

3 that federal test procedures historically have 

4 remained stagnant for many years and have not kept up 

5 with technological developments. This is only going 

6 to be exacerbated by actions like the sequestration 

7 and future budget constraints. A consensus standard 

8 like CEA 2043, on the other hand, can be revised 

9 relatively quickly for relevance and incorporation of 

10 developments in the design and use of set top boxes. 

11 In contrast, a federal test procedure will only have 

12 the effect of inhibiting innovation since it will be 

13 illegal to make energy claims outside of the scope of 

14 the test procedure, at least without obtaining a 

15 waiver which is an uncertain process. 

16 Since there’s no FTC labeling, since the CEA 

17 process already has a relationship with EPA and with 

18 EnergyStar, we don’t see any reason why there needs to 

19 be a federal test procedure. We’re glad to 

20 participate. The technical minded among us, like the 

21 chairman of our committee, Gary Langille will make 

22 technical comments today, but we do want to make clear 

23 that we don’t think it’s necessary for the Department 

24 to promulgate a test procedure. 

25 MR. BROOKMAN: Thank you. A few individuals 
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1 have joined us and they didn’t get a chance to 

2 introduce themselves, so we’ll do that now. Your name 

3 and organizational affiliation? 

4 Further Introductions 

5 MR. JOSEPH: I’m Kuriacose Joseph 

6 from DIRECTV. 

7 MR. TURNER: Robert Turner from Pace in the 

8 UK, manufacturer. 

9 MR. BROOKMAN: Yes, please. 

10 MS. SANFORD: Jennifer Sanford with Cisco 

11 Systems. 

12 MS. AMANN: Jennifer Amann with ACEEE. 

13 MR. BROOKMAN: Thank you. Any other 

14 individuals that wish to make opening remarks? Yes. 

15 Neal first. 

16 MR. N. GOLDBERG: Thank you. Neal Goldberg 

17 from National Cable Telecommunications Association. 

18 First of all, thank you for inviting us and letting us 

19 come. And a particular thank you to you, Doug, 

20 because at least as we understood it at the last 

21 meeting, last public meeting, we took a suggestion 

22 from you to try and negotiate a voluntary agreement 

23 that obviates a need for regulation, and Chuck stole 

24 my thunder but basically that’s what we did and the 

25 companies involved are the six largest cable 
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1 companies, Comcast, Time Warner Cable, Fox, Charter, 

2 Cablevision, Brighthouse Networks, along with AT&T, 

3 Verizon, Century Link and Motorola, Cisco, Arris, and 

4 Echostar Technologies. 

5 That agreement, when announced, received 

6 bipartisan support, particularly from Senators 

7 Feinstein and Murkowski, and as recently as yesterday 

8 on the Hill, House Energy Subcommittee hearing, 

9 although it wasn’t the subject of that hearing, there 

10 were statements with respect to the agreement by 

11 Congressman Dingell and Markey. 

12 I will yield the rest of my time to my 

13 counsel who will be more diplomatic than I would be, 

14 but I would like to say that the agreement is being 

15 implemented now, and as Chuck suggested, it’s open to 

16 other parties, my friend Noah and his colleagues, 

17 particularly, to have further discussions with us. 

18 MR. BROOKMAN: Thank you. 

19 MR. P. GLIST: I also appreciate the growing 

20 insights that are reflected in the NOPR, but we oppose 

21 the adoption of federal test procedure. I’m not going 

22 to repeat what Mr. Samuels has said, although I agree 

23 with everything that he stated. I will supplement it 

24 in this way. 

25 You know from the record that we have 
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1 submitted in the prior chapters of this saga, that we 

2 do not believe that the Department has jurisdiction or 

3 the need to set the different set top boxes as a 

4 covered product, or to set a testing method for it. 

5 To my understanding, testing is normally explained as 

6 providing consistency for the market or as a basis for 

7 a standard, and we don’t have a requirement for 

8 standardized testing to be promulgated by the 

9 Department. We have, under the voluntary agreement, 

10 adopted uniform testing procedures. All agreed to 

11 follow it. There’s not a problem of misrepresentation 

12 in the market. Everyone recognizes that this is a 

13 market in which consumers are not buying individual 

14 boxes off the shelf. Under the VA, we’ll be following 

15 a uniform method, informed a great deal by 2043, and 

16 we’ll be posting the results publicly. It is curious 

17 to me at the least that there’s no mention of the 

18 voluntary agreement at all in the NOPR. 

19 The other justification often given for a 

20 procedure like this is to set the basis for a 

21 standard, and in fact, many aspects of the NOPR signal 

22 that a standard is in the work. We have previously 

23 raised the point that DOE standards would not result 

24 in a significantly better energy conservation result 

25 than non-regulatory approaches. And through the 
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1 voluntary agreement we already have up and running, an 

2 organized, rapid, flexible structure to conserve 

3 energy, which includes standards. It’s now already 

4 achieving dramatic market place improvements that are 

5 superior, faster, and more flexible than a regulatory 

6 approach and has, as Mr. Goldberg explained, it has 

7 already received repeated bipartisan endorsement as 

8 the appropriate way for industry to address a 

9 complicated technology such as this. 

10 We urge the Department to give the voluntary 

11 agreement an opportunity to work, to collect from us 

12 reports which we are happy to share, and not try to 

13 supplant the good work that the voluntary agreement 

14 reflects. 

15 I’d also suggest, and we can explore this in 

16 more detail as the slides progress, that the specific 

17 way that the NOPR is framing out the issues is 

18 creating disincentives for energy efficiency and it is 

19 introducing competitive disparities that should be 

20 troubling to the Department. 

21 To illustrate it very briefly. It would 

22 make it unlawful, to my understanding, for somebody to 

23 market a device that is a more efficient DVR because 

24 the recording capability is housed in the network 

25 instead of the device, which does not make sense from 
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1 a conservation point of view. 

2 As another example, the NOPR basically lumps 

3 a set of service provider devices, regardless of the 

4 characteristics of the individual combinations of 

5 hardware and software into a class of set top boxes 

6 subject to this regulation, while it excludes 

7 categorically hundreds of millions of devices that are 

8 currently being used for video viewing. It is 

9 attributing the video viewing to the set top box. At 

10 the very time that Nielsen has embraced these other 

11 devices as part of the measured television universe, 

12 at the very time that the makers of XBox have said 

13 these are intended to be video devices, and so we 

14 submit that that is an arbitrary distinction that will 

15 cause great competitive disparity in the market. 

16 I would add that in addition to the parties 

17 that Mr. Goldberg named, the parties to the voluntary 

18 agreement transect the entire industry and include 

19 DirecTV and Dish, and not simply Cable, telephone and 

20 the equipment suppliers -- very broad support, very 

21 broad base. It covers 90 million households, better 

22 than 90 percent of the devices out there, and we’re 

23 already achieving results. 

24 MR. BROOKMAN: Thank you. Other comments at 

25 the outset? Noah. 
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1 MR. HOROWITZ: Noah Horowitz with NRDC. 

2 Three brief comments. We, NRDC, do support DOE moving 

3 forward with the development of a test method for set 

4 top boxes. We agree with the use of CEA 2043 as a 

5 starting point, and then making modifications on top 

6 of that. And we agree with many of those changes or 

7 modifications contained in the draft by DOE, and then 

8 there’s some other points that will come up today that 

9 we’ll be providing input on. 

10 I want to point out the voluntary agreement 

11 has been referred to several times today -- that’s an 

12 agreement solely written by industry and only signed 

13 by industry members. It’s non-binding, and the reason 

14 advocates -- I can speak for our organization -- 

15 haven’t signed, it’s due to the lack of specificity 

16 and stringency within the current draft. We’re open to 

17 ongoing conversations with the group, but we don’t see 

18 that as a substitute for DOE action. Thank you. 

19 MR. BROOKMAN: Thank you. Yes, Gary. 

20 MR. LANGILLE: Hi. My name’s Gary Langille 

21 and I’m speaking on behalf of both Dish Network, third 

22 largest video provider in the US, and also Echostar 

23 Technologies, which is a set top box manufacturer. 

24 Our belief is that a test procedure rulemaking is not 

25 required. We believe that the current CEA standard 
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1 that’s in process and is attempting to incorporate any 

2 issues raised as part of the DOE NOPR, is sufficient. 

3 We also believe that it’s a mechanism that can be 

4 adapted very quickly by either issuance of errata or 

5 revision as new capabilities and functionalities are 

6 introduced by companies. We believe it’s fully 

7 sufficient for use by the EPA in their EnergyStar 

8 program. It certainly -- it’s already been adopted as 

9 a reference point for the industry voluntary 

10 agreement. And we also believe that if DOE does elect 

11 to continue the process of issuing a test procedure 

12 that it should be referenced as is, without 

13 modification. 

14 We believe that if DOE moves forward with a 

15 rulemaking around a test procedure that we do 

16 understand that additional information is required, 

17 you know, perhaps which devices are included or not 

18 included, what combinations and configurations need to 

19 be tested, and also how data may have to be reported. 

20 But we believe that all of that kind of information 

21 should be handled as supplemental information, as part 

22 of a rulemaking, as opposed to sort of a rewrite of 

23 the actual test procedure. 

24 I did want to point out that we’re very much 

25 committed to the industry voluntary agreement. Our 
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1 two companies. In fact, the agreement, in essence -- 

2 its really first deliverables are at the end of this 

3 year, but the fact of the matter is that if you 

4 actually look at the current EnergyStar set top box 

5 qualified product list, over 50 percent of the 

6 products on that list do not meet the minimum required 

7 level for regulation under EPCA, that is, therefore 

8 far less than 100 kilowatts per year per device. To 

9 me, that means that DOE should really stop, reexamine 

10 whether these products even qualify under EPCA. 

11 The average DVR, which has been cited by 

12 advocates as being basically the cause for rapid and 

13 future increases in energy consumption, is now 

14 averaged at 145 kilowatt hours per year. This is 

15 almost -- this is 48 percent reduction over advocates’ 

16 estimates of what a DVR consumption is, in less than a 

17 year’s time. So industry has delivered over 50 

18 percent -- almost 50 percent savings in its most 

19 energy-consuming product in a year’s time. We expect 

20 that trend to continue as we install systems. 

21 I’d also like to point out that even though 

22 the voluntary agreement hasn’t even begun, Dish alone 

23 has delivered over two million thin client set top 

24 boxes, resulting in a savings of almost 400 -- 

25 approximately 400 kilowatt hours over delivering 
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1 equivalent DVRs, and savings of almost 50 million. 

2 Complementing that with introductions by the cable 

3 industry of a light sleep mode, we already have saved 

4 over $100 million dollars per year on a running rate, 

5 and almost a billion kilowatt hours. And the 

6 voluntary agreement hasn’t even started yet. 

7 So just to summarize. We do believe that 

8 DOE should reexamine the justification for regulation 

9 and issuance of a test procedure, and thank you. 

10 MR. BROOKMAN: Thank you. Other comments 

11 here at the outset? No additional comments. Okay. 

12 So then we’re going to proceed with the content. All 

13 of you received a packet of information as you checked 

14 in this morning. These colorful PowerPoint slides 

15 will be the basis for both discussion and question and 

16 answer as we proceed today. Jeremy, I turn it over to 

17 you. 

18 Rulemaking Process 

19 MR. DOMMU: Hello everyone. This is Jeremy 

20 Dommu again, Department of Energy. I’m going to begin 

21 with a presentation now. I believe the first couple 

22 slides that I’m going to bring up on the screen have 

23 already been covered, the welcome, the agenda, the 

24 webcast instructions. 

25 The purpose of today’s public meeting is to 
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1 present DOE’s proposed test procedure for set-top 

2 boxes, and we will be inviting comment on the test 

3 procedure notice of the proposed rulemaking document 

4 throughout the day and with subsequent written 

comments that -- to be submitted by April 8th 5 . We’ll 

6 also discuss the next steps in this specific 

7 rulemaking related to the proposed test procedure and 

8 again, invite participants to provide summary comments 

9 or statements and raise additional issues for 

10 discussion. So that’s going to be the focus of 

11 today’s meeting. 

12 Throughout the presentation we’ll have issue 

13 boxes and the issue boxes bring up specific issues in 

14 which we’re seeking comment. When we see them we’ll 

15 be able to pause in the presentation to allow all 

16 stakeholders an opportunity to provide their oral 

17 comments today. Also on these issue boxes is a 

18 reference, a footnote reference, to the corresponding 

19 issue number as it had appeared originally in the 

20 Notice of Proposed Rulemaking document that was 

published in the Federal Register on January 23rd 21 . 

22 Here’s the opening remarks slide, which we 

23 obviously just had and now I am going to begin today’s 

24 public meeting first with the rulemaking process 

25 agenda item. 
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1 So for the regulatory history, Part A of the 

2 Energy Policy and Conservation Act, established energy 

3 conservation program for consumer products other than 

4 automobiles, and subsequent amendments to EPCA gave 

5 DOE the authority to regulate the efficiency of 

6 several types of equipment. It also provided DOE the 

7 authority to classify additional types of consumer 

8 products as covered products. 

9 In June 2011, DOE preliminarily determined 

10 that set-top boxes and network equipment meet the 

11 criteria for covered products. At this time we have 

12 not yet finalized that coverage determination. 

13 So for the test procedure rulemaking 

14 process, we began this process with the publication of 

15 a Request for Information in December 2011. That 

16 asked specific questions on the rulemaking process as 

17 it related to test procedures and also efficiency 

18 standards. We received written comments and we held a 

19 public meeting and provided an overview of that 

20 rulemaking process during the RFI and that public 

21 meeting. 

22 In January of this year we published the 

23 Notice of Proposed Rulemaking test procedure for set24 top boxes. Today we are holding a public meeting, and 

the comment period ends on April 8th 25 . The next step 
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1 after the comment period ends would be a final rule 

2 publication. The timeline of that is to be 

3 determined. Our rulemaking process could take one of 

4 two directions, of either based on the nature of 

5 comments that are submitted to DOE, DOE may opt to 

6 make any changes to our proposal, and if those changes 

7 are significant enough, we may issue a Supplemental 

8 Notice of Proposed Rulemaking to allow stakeholders an 

9 additional opportunity to provide comments to us. If 

10 there aren’t sufficient comments or DOE opts to move 

11 forward, the next step could be the publication of the 

12 final rule. 

13 So when we start out to establish a test 

14 procedure, we look for a number of objectives to be 

15 met by the test procedure. 

16 • We want to look for a test procedure that is 

17 repeatable, meaning that the test procedure outputs 

18 similar results when the laboratory conducts multiple 

19 tests on the same unit; 

20 • That is reproducible, that similar results are 

21 achieved when various persons or laboratories perform 

22 the test; 

23 • That it’s representative; 

24 • That’s consistent with the typical energy 
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1 consumed by the products in the field; 

2 • It’s not overly burdensome to conduct, meaning 

3 that the test burden is justified to achieve the 

4 necessary accuracy, repeatability of the overall 

5 measurement; 

6 • That it’s applicable to anticipated future 

7 technologies to the best of our ability; 

8 • That it discourages circumvention; 

9 • That it cannot be easily gamed; 

10 • That it’s unambiguous, that it’s clear enough 

11 that there are no questions or items in the test 

12 procedure that are open to interpretation. 

13 • We also would like to harmonize with related test 

14 procedures, and finally, 

15 • We want to ensure that the test procedure is 

16 consistent with our legal authority. 

17 So the other thing that we do when we begin 

18 the test procedure is we first look to other test 

19 procedures that already exist. So this slide here 

20 kind of shows what test procedures for set-top boxes 

21 already exist and fade into our proposed regulatory 

22 test procedure. So we looked at the draft CEA 2043, 

23 which itself is based on the ANSI CEA 2022 test 

24 procedure and ANSI 2013A test procedure. And we also 
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1 looked to the most recent specification for set-top 

2 boxes from EnergyStar -- that was version 3.0, and 

3 that itself was based on the IEC 62087 and the 

4 Canadian standard CE 380-08. 

5 So when we did this process we identified 

6 that the draft CEA 2043 test procedure was an 

7 appropriate basis to establish our DOE proposed test 

8 procedure. However, there were quite a -- there are 

9 several changes that DOE proposed that were different 

10 from draft CEA 2043. Those changes were discussed in 

11 the Federal Register publication, and actually 

12 throughout today’s public meeting we will also be 

13 identifying what some of those differences are. 

14 The other thing that I would note is that 

15 that draft CEA 2043 is currently in development and is 

16 not yet been final. The version that was distributed 

to the CEA working group on November 27th 17 was the 

18 version that we based our comparison on. Since that 

19 time, DOE is aware that there have been some 

20 supplemental changes to draft CEA 2043, but for the 

21 purposes of today’s meeting, we’re going to be 

22 comparing it back to that draft version that was 

submitted to vote on November 27th 23 . 

24 So that’s the overview of our rulemaking 

25 process. 
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1 Scope 

2 I am now going to get into scope questions 

3 of what products are covered within our scope. So, I 

4 think to begin the scope conversation, it’s important 

5 to begin with our proposed definition of a set-top 

6 box, and that is, “A set-top box means a device 

7 combining hardware components with software 

8 programming designed for the primary purpose of 

9 receiving television and related services from 

10 terrestrial, cable, satellite, broadband, or local 

11 networks, providing video output using at least one 

12 direct video connection.” 

13 And because of that requirement to provide 

14 output using at least one direct video connection, we 

15 also are proposing a definition for a direct video 

16 connection, which is, “Any connection type that is one 

17 of the following: high definition multimedia 

18 interface, HDMI; component video; S-video; composite 

19 video; or any other video interface that may be used 

20 to output video content.” We’re also specifying and 

21 proposing to add a definition for those specific 

22 direct video types, and I think these are relatively 

23 standardized definitions or references for HDMI, 

24 component video, S-video, and composite video. 

25 So to compare our definition of a set-top 
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1 box, and anything that meets this definition would be 

2 in the scope of today’s rule, to the draft CEA 2043 

3 definition of a set-top box, I think you note that 

4 overall ours is a little bit more specific. We 

5 specify the primary purpose. We use the term “primary 

6 purpose” in our definition, and that primary purpose 

7 is to receive television and related services. We 

8 also include specifications of the networks for 

9 receiving content, that it would be from terrestrial, 

10 cable, satellite, broadband, or local networks. And 

11 we specify the video connections where are we are 

12 requiring at least one direct video connection, 

13 whereas the draft CEA 2043 definition specifies 

14 devices -- display device, recording device, or 

15 clients. 

16 Finally, our definition specifies that the 

17 device contains both hardware and software as 

18 components, whereas CEA draft 2043 does not specify 

19 hardware or software as components. 

20 In a couple slides we are having several 

21 issue boxes and that will provide an opportunity for 

22 comments, so let me just continue going through our 

23 proposed scope, and we are going to open it up to the 

24 floor. 

25 So the reason for our proposed definition -- 
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1 the reason that we used the term “primary purpose” is 

2 it’s DOE intent to exclude products like smart phones 

3 and game consoles from the scope. So those devices 

4 might otherwise meet the definition, but our intention 

5 is that their primary purpose is something other than 

6 receiving video signals and providing video output. 

7 We certainly recognize that some of these devices are 

8 trending to be more home entertainment centers, that 

9 people are using smart phones in different ways, but 

10 our intention for using the word “primary purpose” was 

11 for these to be excluded from the scope. And we’ll 

12 certainly be welcoming comment on that. 

13 The other reason for our proposed definition 

14 was to exclude devices that do not provide for direct 

15 video output. So in order to be in scope, a device 

16 needs to be capable of actually taking a video stream, 

17 decoding that stream into raw video data and then 

18 being able to send that data to a display device. 

19 It’s not -- if it does not have at least one video 

20 connection, then it’s not within the scope. 

21 Obviously, if it does have one video connection, then 

22 it is considered a set-top box. The reason for this 

23 is to clearly separate a set-top box from other 

24 devices that simply pass internet protocol traffic 

25 between various devices. 
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1 So, furthermore -- so the scope of coverage, 

2 included products, set-top boxes, things that are 

3 excluded from scope based on our definition or 

4 proposed definition of set-top boxes include network 

5 equipment, other infrastructure devices which include 

6 optical network terminals (ONTs), low-noise block 

7 downconverters, (LNBs), outdoor units (ODUs). 

8 So in the preliminary coverage 

9 determination, we covered set-top boxes and network 

10 equipment. With this proposed rule, we are proposing 

11 to exclude network equipment from the scope because of 

12 differences in functionality and use of network 

13 equipment as compared to set-top box, and we recognize 

14 that to have a representative test for network 

15 equipment, it would essentially take a completely 

16 different set of procedures to establish a test since 

17 they are used in such different ways. However, I do 

18 want to stress that DOE will continue to evaluate that 

19 need for a test procedure for network equipment 

20 separately. 

21 Again, the definition of a set-top box, and 

22 just thus the scope of our proposed test procedure. 

23 It’s just a proposal at this time, and we are urging 

24 stakeholders to submit comments, and where 

25 appropriate, suggest new definitions if they disagree 
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1 with our proposed definition and scope. Furthermore, 

2 we are proposing to exclude infrastructure devices -- 

3 LNBs, ONTs, ODUs, because of the complexity associated 

4 with these equipment and significant operational 

5 differences from set-top boxes, we’re proposing not to 

6 include them. However, within the test procedure we 

7 are providing setup requirements for these 

8 infrastructure devices in order to test set-top boxes 

9 that require the use of them. 

10 So that is the overview of our scope, and at 

11 this time we have several slides with issues for 

12 discussion. We will begin with this issue A and you 

13 could comment on any of these bullets, 

14 • requesting comment on the proposed definition, in 

15 particular, 

16 • comment on whether the proposed definition is 

17 specific enough to exclude non-set-top box devices 

18 such as gaming consoles and smart phones, yet broad 

19 enough to cover traditional set-top boxes and newer 

20 devices, meaning devices based on current technology 

21 or anticipated future technologies, 

22 • and we’re also requesting comment on the proposed 

23 definition for direct video connection, HDMI, 

24 composite video, S-video and component video. 
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1 MR. BROOKMAN: I saw Gary first. Gary. 

2 MR. LANGILLE: Hi this is Gary from -- who 

3 am I from? Echostar. I just wanted to make the 

4 general comment that clearly the current definition in 

5 CEA 2043 most likely had an error that it did not 

6 identify the primary purpose, and we think that’s an 

7 extremely valid point that DOE’s making and in fact I 

8 believe that the review of the NOPR comments as part 

9 of the CEA process has already incorporated some 

10 aspects of the proposed definition by DOE. 

11 I do want to raise just one question, it 

12 doesn’t have to be answered now, just to put on the 

13 list, that the current definition, by indicating that 

14 the -- it has to provide video using at least one of 

15 these direct video connection interfaces will exclude 

16 what the industry would call a headless device, and I 

17 just wanted to raise that so DOE can assess did they 

18 mean to do that or do they need to think about further 

19 modification. Currently as written, it would exclude 

20 the headless device. 

21 MR. BROOKMAN: What is that? 

22 MR. LANGILLE: What I would mean by that is, 

23 for instance, I could build a whole household system 

24 that connects to the TVs by way of -- very common on 

25 new TVs, internet connection or Ethernet connection, 
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1 and I’d never have to fall under this. 

2 MR. BROOKMAN: Okay. Adam. 

3 MR. A. GOLDBERG: Adam Goldberg for TiVo. 

4 So, I have two comments, but first and primarily to 

5 follow up on what Gary said. The proposed definition 

6 for the direct video output says any other video 

7 interface. And it strikes me that either says 

8 nothing, or includes everything. What I’m trying to 

9 get at is, for example, DIRECTV is espousing a system 

10 called RVU, R-V-U, which is essentially a video 

11 interface over IP. And I think the similar sort of 

12 system used by my friends at Dish and Echostar is 

13 different, but similar enough. And there’s probably a 

14 handful of ways to do this, and I expect that either 

15 Kuriacose or Gary, either one would be very happy if 

16 TVs typically had an interface that directly supported 

17 those connections which would -- I mean this is how 

18 things like HDMI come about, is people start including 

19 it and then everybody includes it, and then it’s 

20 commonly used by consumers. 

21 So either “any other video interface” is 

22 going to include things like RVU, or it’s not. And if 

23 it doesn’t, then I’m not sure what it does rope in. 

24 And if it does, then I think it ropes in everything. 

25 So perhaps some additional thought needs to be put on 
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1 the catch-all at the end of the definition. 

2 And then second, and maybe a little less 

3 vital from my perspective, is some guidance on what 

4 primary purpose is, you know, 51 percent? 80 percent? 

5 At some point, somebody’s going to have to make a 

6 judgment about whether, for example, a play station, 

7 is primarily video or not. And, you know, I point you 

8 to the press releases about the press reports on PS4, 

9 which may be a streaming video player with a remote 

10 control. Thank you. 

11 MR. BROOKMAN: As we go along today, it 

12 would be helpful if, in addition to citing what you 

13 object to that’s being presented, you could also 

14 describe what the solution is, what the fix is. That 

15 would be helpful. So for that one? 

16 MR. A. GOLDBERG: Well, we haven’t had a 

17 long time to think about this. I’ll be glad to 

18 provide that in our comments. 

19 MR. BROOKMAN: Okay. That’s great. That’s 

20 very useful. Noah. 

21 MR. HOROWITZ: Sure. I’d like to address 

22 the part in the comment box here about whether or not 

23 the proposed test method, the scope, would work 

24 sufficiently looking forward towards newer boxes. And 

25 I want to echo what Gary said. These headless -- the 
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1 term headless gateways -- imagine you have a whole 

2 home set-top box that may include additional 

3 functionality, whether it’s a TV, a modem, or a router 

4 -- all that will be in one box servicing the home. 

5 These were prominently shown at the recent Consumer 

6 Electronic Show and may well be the main type of box 

7 deployed within the next few years which would well be 

8 within the life of this test method. So we want to 

9 make sure those type of set-top boxes would be 

10 included. As we understand the current definition and 

11 scope, they would not be included because they do not 

12 have a video output. These would probably have some 

13 sort of home network interface, whether it’s through a 

14 Ethernet cable, wireless, or something we haven’t even 

15 thought about today. So we think the scope and 

16 definition needs to include those boxes. And we think 

17 there is a way, we don’t have it today, but we’ll work 

18 with others to develop it, to modify the definition at 

19 the end of this in such a way that those would be 

20 covered, but we still think there’s a way to do it 

21 without unintended consequences of pulling in smart 

22 phones and tablets and things like that which are 

23 clearly not set-top boxes the way DOE intends. Thank 

24 you. 

25 MR. BROOKMAN: Thank you. Yes, Paul. 
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1 MR. GLIST: Paul Glist. On the same theme 

2 of the gateway devices without a direct video 

3 connection. Although you know that we’re not keen on 

4 this proceeding, we think that you actually got it 

5 right in taking out what we would call the gateway 

6 that doesn’t happen to video connect, for many of the 

7 same reasons that you have excluded a number of other 

8 pieces of network equipment due to their complexity 

9 and variation and the like. I would add a supportive 

10 reason for maintaining that course, that I know that 

11 the Department has never wanted its rules to interfere 

12 with the very rapid innovation in this space. I can’t 

13 say that Noah is right, that these are going to take 

14 over the world in the next year or two. I don’t think 

15 so, but I do know that there’s a great degree of 

16 variation in the R&D going in to that right now, and 

17 it would add infinitely to the complexity of this test 

18 method to include them. 

19 What I would suggest as a concrete 

20 suggestion is that the language is very clear in 

21 saying what is included, and I take Adam’s point that 

22 the vague “any other video connect” should be 

23 clarified away. But if you just say a gateway that 

24 doesn’t have HDMI, Component, Composite, S-video, 

25 you’re out. It would add a lot of clarity because our 
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1 technical people working with this document are 

2 looking for that level of clarity. 

3 MR. BROOKMAN: Okay. Thank you. Robert. 

4 MR. TURNER: I would tend to again agree 

5 that the -- same remark as the definition of headless 

6 gateways which are becoming prevalent in industry, to 

7 add something on the lines of HDMI, et cetera, or a 

8 recorded stream to a client which feeds out HDMI, et 

9 cetera, would probably cover it. Otherwise, you’ll 

10 end up with a document that’s a dinosaur, it’s 

11 obsolete by the time it’s enforced, and that’s not 

12 going to help. So I’m keen that we all have a level 

13 playing field, and we all are under the same rules, 

14 that we do need to include new technologies. 

15 MR. BROOKMAN: Thank you. Yes, Gregg. 

16 MR. HARDY: Gregg Hardy, California IOUs. I 

17 did want to throw out a possible solution for how to 

18 exclude products that we don’t want to include, DOE 

19 doesn’t want included, which is to list defining 

20 elements of the products that should be excluded, for 

21 example, you know, set-top box cannot have a cell 

22 phone antenna, and we can define with some specificity 

23 what a cell phone antenna is. Or, set-top box cannot 

24 run a desktop operating system, like Windows, MacOS, 

25 or Linux, and so on down the list of items that we 
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1 want to exclude. Just a proposal. 

2 MR. BROOKMAN: Thank you. You can see the 

3 comment boxes there. 

4 MR. DOMMU: And we actually on this next 

5 slide we have a couple additional issue boxes, and I 

6 think some of these do overlap with the prior issue 

7 boxes, but I’ll read through them in case there are 

8 any additional comments on issue B or C here. And 

9 that is requesting comment on 

10 • narrowing the scope of today’s rulemaking to 

11 exclude, to set-top boxes and excluding network 

12 equipment, and also 

13 • requesting comment on narrowing the scope of 

14 today’s rulemaking to set-top boxes and excluding 

15 infrastructure devices. 

16 And again, going back to Doug’s comment, if 

17 you do support developing a test procedure for other 

18 infrastructure devices, it would be very helpful if 

19 you could provide additional information or comment on 

20 what test procedures and standard configurations 

21 should be used on how those types of devices should be 

22 tested. So is there any other comments related to 

23 these issue boxes? 

24 MR. BROOKMAN: Yes, Noah. 
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1 MR. HOROWITZ: Noah Horowitz, NRDC. We’re 

2 in agreement with DOE’s proposal to not include small 

3 network equipment at this time. However, we think DOE 

4 should move forward on set-top boxes in an expeditious 

5 way, so do that first and then revisit small network 

6 equipment, not close the door on that for the future. 

7 Keep it as part of the scope. 

8 And the conversation we had a moment ago, to 

9 the extent that a box is a set-top box and it has 

10 small network equipment functionality, that box should 

11 be covered. So that’s kind of a hybrid approach here. 

12 Thank you. 

13 MR. DOMMU: Okay. Thank you. And I would 

14 state, as I said before, that we will continue to 

15 evaluate the need for a test procedure for network 

16 equipment. 

17 MR. BROOKMAN: Robert. 

18 MR. TURNER: Just to come back to Noah. If 

19 we start saying a box with networking is included, 

20 then we’re going to have unintended consequences of 

21 making two products with higher energy consumption to 

22 keep -- because one product by itself can’t make the 

23 limits. So if there’s exclusions or extra functions 

24 included, they need to have some sort of allowance to 

25 make sure that we still drive the power consumption of 
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1 the whole home downwards. 

2 MR. BROOKMAN: Yes, Noah. 

3 MR. HOROWITZ: Just a quick clarification. 

4 I agree with Robert that we want to be able to measure 

5 these devices and to the extent additional allowances 

6 are warranted, that’s an open discussion. Here we’re 

7 just trying to figure out how to measure things. So 

8 I’m not in disagreement with you, and we do want to 

9 move to whole home if it can save energy. 

10 MR. BROOKMAN: Final comments on this series 

11 of boxes. Okay. 

12 MR. DOMMU: Okay. So the next topic is the 

13 definition of a basic model for the set-top box. So 

14 according to our Code of Federal Regulations, a basic 

15 model means all units of a given type of covered 

16 products or class thereof, manufactured by one 

17 manufacturer, having the same principal energy source 

18 and which have essentially identical electrical, 

19 physical, and functional or hydraulic characteristics 

20 and affects energy consumption, energy efficiency, 

21 water consumption, or water efficiency. 

22 So obviously, this is a broad definition in 

23 scope, but as this definition applies to what is a 

24 basic model for a set-top box, the identical 

25 electrical, physical and functional characteristics 
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1 would include software download and hardware 

2 integration for the proposed definition of a set-top 

3 box. It also would mean that the same multi-streaming 

4 and DVR functionality would constitute a basic model. 

5 So -- this is because the hardware components and 

6 software programming can change the functional or 

7 physical characteristics of the box that affect energy 

8 consumption and energy efficiency. Thus, in order for 

9 multiple set-top boxes to be in the same basic model, 

10 they must have essentially the same software download 

11 and hardware integration. 

12 So at this point we would identify comment 

13 and discussion of basic model as it pertains to set14 top boxes. 

15 MR. BROOKMAN: Gregg. 

16 MR. HARDY: Gregg Hardy. I would propose 

17 that -- I have a concern that say a Motorola box 

18 running Motorola test software might be considered a 

19 basic model, even though downstream from that in the 

20 supply chain, it would be loaded with say, Comcast 

21 software or Time Warner Application software. Then I 

22 know later on in the NOPR it articulates that to do 

23 the testing you have to configure the box in the field 

24 per the service provider’s instructions. So I don’t 

25 think there’s a risk with the test procedure not 
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1 testing with that final software, but I think that 

2 maybe there’s just a little bit of ambiguity that 

3 could be clarified here today that a basic model has 

4 the same hardware and field-deployable software, or 

5 something like that. 

6 MR. BROOKMAN: Okay. Paul. 

7 MR. GLIST: Paul Glist. Do you have a sense 

8 -- given that you tend to treat as different basic 

9 models each different combination of hardware and 

10 software. Is it your intention, then, to distinguish 

11 boxes by not just service provider who has a different 

12 guide, but also with applications that are 

13 subsequently downloaded to the box as those service 

14 providers innovate in services? And if that’s the 

15 level of precision that you’re looking for, how many 

16 models are you estimating are out there in scope for 

17 this approach? 

18 MR. DOMMU: Yeah, well, I would put it back 

19 on you and certainly suggest that you provide comment 

20 if the definition of a basic model is ambiguous. But 

21 we welcome your recommendations. 

22 MR. GLIST: I understand you welcome 

23 recommendations and I aim to give you comments. I’m 

24 asking for the Department’s understanding of this 

25 approach. Are you saying we are slicing the market 
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1 into all of the permutations and combinations of 

2 hardware and software. Each one is a distinct model. 

3 And so in the world of standards that you allude to in 

4 this NOPR, each one would be subject to a different 

5 standard. Is that what you’re seeing in this 

6 document? 

7 MR. DOMMU: Well, I think what we’re saying 

8 is that we recognize that software is a component of 

9 set-top boxes, and that software loaded onto the set10 top box could affect the energy consumption or energy 

11 efficiency of that box, so to the extent that the 

12 energy consumption or efficiency changes, then that 

13 could have impact on whether or not it’s a basic 

14 model. 

15 MR. BROOKMAN: Adam. 

16 MR. A. GOLDBERG: So -- Adam Goldberg for 

17 TiVo. I’m a little confused how a retail device would 

18 do this. For example, if I build a box with version 

19 one of the software, and I advertise it as consuming a 

20 certain amount of power, but it’s version one of the 

21 software. I make these -- I print up these boxes to 

22 box up the devices and it’s months and months in the 

23 supply chain and sitting on the shelf and eventually 

24 making it to somebody’s house and then they connect it 

25 up to the internet and it gets version three of the 
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1 software. What -- how -- I mean, so the box -- the 

2 set-top box in the cardboard box on the shelf may have 

3 a power number attached to it, but as soon as you plug 

4 it in, it’s going to have a different power number, 

5 and I wonder how -- am I going to need to be, a, 

6 changing the printed box, the cardboard box and 

7 literature every time I update the software, number 

8 one? And number two, how do I advise -- how would I 

9 need to advise the consumer that the power consumed is 

10 going to have a slightly different number when it gets 

11 updated software? 

12 MR. BROOKMAN: Ashley. 

13 MS. ARMSTRONG: So can I ask a question of 

14 you before we attempt to potentially answer the 

15 question? 

16 MR. A. GOLDBERG: Yes. 

17 MS. ARMSTRONG: Right now if you were to 

18 say, like in your scenario where you said you had 

19 boxes on the shelf at a retailer, and they have 

20 version one software, as you know, a certain energy 

21 consumption with the given software you loaded it from 

22 the point of manufacture. Say that inventory was 

23 depleted and when you guys came out with a version 

24 3.0, the new ones you were shipping from the point of 

25 manufacture, not the ones that were sitting on the 
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1 shelf that may now be deployed, but wouldn’t the new 

2 ones coming from your factory have the version three 

3 with the latest software that you also intend to 

4 download in the house? 

5 MR. A. GOLDBERG: So there are sort of two 

6 scenarios. One is that we ship -- that one would ship 

7 boxes with what amounts to boot loader software, 

8 something that’s enough to have it be alive and 

9 download whatever the latest version is. So in that 

10 case, the box on the shelf, you know, shrug about what 

11 its power consumption would be. But second, yeah, 

12 okay, well, I mean when new software gets released, 

13 maybe there’s a change made in the manufacturing of 

14 the boxes so that they would get the latest software. 

15 That’s not always the case. But whichever happens, 

16 how do I deal with the fact that if I want to put a 

17 power number on the box, and the power number depends 

18 on the software version -- we’ve disconnected the 

19 model from the power consumption. Because -- because, 

20 you know, the cardboard gets printed in large volumes 

21 well in advance, essentially. 

22 MS. ARMSTRONG: This is Ashley from DOE. I 

23 think we -- I see where the need for clarity is, or at 

24 least where the questions arise. I mean, ultimately, 

25 you’ll see when we go through the setup that the 
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1 testing has to be run more or less with the software 

2 as installed as it would be in the field. So if 

3 you’re just loading bootup software or some bare 

4 minimum of software with the acknowledgement that that 

5 software will get automatically updated in the field, 

6 the test number is going to be representative of the 

7 field software. 

8 Now, the question becomes that is ever9 changing, and where do you draw the line for the 

10 number on the box, so I get that part. But I don’t 

11 think it’s an issue of what software is sitting on the 

12 floor at the point of manufacture, it’s going to be at 

13 what point, you know, do we draw the line for the 

14 number on the box. So I get your point that we need 

15 to provide clarity, but I think it can be done. 

16 MR. A. GOLDBERG: It’s -- sorry, it’s a bit 

17 of a different question like how -- like a service 

18 provider would operate, you know, because I mean 

19 Comcast has Comcast software, and that’s fine. But in 

20 a retail environment, if I’m selling a box at retail 

21 that works nationwide, it’s dependent on the software 

22 it’s got, sure, but it’s not dependent on which 

23 network it’s installed on. 

24 MR. BROOKMAN: Gregg. 

25 MR. HARDY: This raises an important 
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1 question and I think it’s going to be very difficult 

2 to grapple with, which is, is it DOE’s intent to 

3 provide a regulation that ensures that boxes will be 

4 maintained in a configuration that meets the 

5 regulation, or just that initial deployment of that 

6 box? And if that is the case, then, you know, DOE has 

7 to look at and see which entities out there -- service 

8 providers, manufacturers -- can be responsible for 

9 that credibly, and so that’s a question that I either 

10 raise here for discussion or for consideration. 

11 MR. BROOKMAN: Neal. 

12 MR. N. GOLDBERG: Neal Goldberg, NCTA. Do 

13 you have a position on that? I’m not sure from your 

14 question? Are you advocating one way or the other? 

15 MR. HARDY: I don’t have a position. I 

16 think it’s going to be very difficult. I’ll just say 

17 a few examples where I do have a thought. One is, so 

18 for a major service provider, like Comcast, who writes 

19 the application software for their box, it seems to me 

20 that Comcast ought to be responsible for the initial 

21 deployment of that box meeting the regulation, or 

22 continued. I’d like to explore ways that Comcast 

23 could have continued responsibility for ensuring that 

24 the box meet the regulation. 

25 Just one more point. I think it gets more 
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1 complicated when you consider scenarios where you’ve 

2 got a bunch of small service providers, say small 

3 telcos that are buying a standard configuration of a 

4 Cisco IPTV box with media room loaded on it, that 

5 those small service providers sort of can’t possibly 

6 be responsible for -- they’re not actually dictating 

7 the configuration of that box. And there are many out 

8 there. So there may be situations where the 

9 responsible party is say the hardware manufacturer or 

10 even the software manufacturer like Microsoft. I’m 

11 raising a complexity here without knowing -- 

12 MR. N. GOLDBERG: There’s no question -- 

13 MR. BROOKMAN: Use the microphone. 

14 MR. N. GOLDBERG: There’s no question this 

15 is a complex area. This is Neal Goldberg, NCTA. But 

16 -- and whether the provider is large or small, don’t 

17 you think that would have an inhibiting effect on 

18 innovation? You’ve got these boxes in the field and 

19 they could be downloaded with various program guides 

20 or who knows what’s going to happen in the future. 

21 MR. HARDY: I’m sure concerned that that 

22 would limit innovation. I think there are a bunch of 

23 constraints here that we’re trying to grapple with and 

24 that’s one of them. 

25 MR. BROOKMAN: Gary. 
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1 MR. LANGILLE: I just wanted to ask a 

2 clarifying question, is, because I’m not sure how to 

3 advise or construct a comment on this definition. 

4 What’s this going to be used for? I don’t understand 

5 the reason for defining a basic model. So if you 

6 could help us understand that, we might be able to 

7 give you better comments. 

8 MS. ARMSTRONG: So the way we -- this is 

9 Ashley from DOE. The way regulations are currently 

10 constructed is we define a basic model for the 

11 purposes of manufacturers to determine what needs to 

12 be tested and what needs to be -- what can be grouped 

13 together for the purposes of ratings. So what it 

14 allows you to do is give you some flexibility in not 

15 testing every single different model that you may 

16 have. If you have multiple models, say one is -- I 

17 mean I’ll use the simplest example -- one is black, 

18 one is silver, but all the functional characteristics 

19 are the same, the rating would be the same coming out 

20 of the test procedure, you don’t have to test the 

21 black model, you don’t have to test the silver model. 

22 Group them together and call them the basic model. 

23 Obviously, the definition provides a little 

24 bit more leeway than just something as simple as that. 

25 But you could group together multiple individual 
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1 models for the purposes of reducing your testing 

2 burden. But they would have to have the same rating 

3 coming out of the test procedure. That’s the idea. 

4 Now, how it translates to the set-top box 

5 world is the issue at hand. This was our shot at it, 

6 and we obviously welcome feedback from you guys since 

7 you know best on how you do your models and software 

8 and all the variations that are out there that there 

9 may be. 

10 MR. BROOKMAN: Pardon me, Chuck, you’re 

11 next. 

12 MR. SAMUELS: Chuck Samuels, CEA. The 

13 preceding conversation I just think points out the 

14 slippery slope that any discussion of test procedures 

15 immediately gets you into how it will be implemented 

16 in standards. And although it’s quite troubling that 

17 the Department has not been transparent about this, it 

18 hasn’t even today explained why it’s proceeding with 

19 the test procedure rulemaking, I think it’s pretty 

20 obvious it’s because it, although it’s unannounced, it 

21 has an intent to move forward on standards, even 

22 though the many, many comments that were received in 

23 the covered product proceeding have not yet been 

24 resolved or even responded to by the Department. So I 

25 just -- I just want to point out that the technical 
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1 discussion is fine, but from my point of view, it 

2 seems pretty obvious where this is heading, and I 

3 think it’s quite troubling. 

4 MR. BROOKMAN: Thank you. Gary. 

5 MR. LANGILLE: Just one last, I guess, 

6 comment now. So I -- you know, even with the iPhone, 

7 I mean, like I think the last update I got was because 

8 it was a quick update from Apple because the last one 

9 caused the power consumption to go up excessively and 

10 was running everyone’s battery down. So is it that 

11 we’re trying to rate -- is it that we’re trying to 

12 rate it initially with an as shipped set of 

13 applications or something? Because I fully expect, in 

14 fact our current set-top box has a whole applications 

15 environment. It has Facebook. It has, you know, it’s 

16 going to have all the applications I have on my 

17 iPhone. We haven’t quite released yet the tool kit 

18 and opened it up to thousands of developers, but 

19 that’s just because we haven’t had enough time. But 

20 it will happen. So I think that we’ll all have to 

21 think about, you know, what is a rating mean? I’m not 

22 sure. 

23 MS. SANFORD: This is Jen Sanford with 

24 Cisco. Does a rating mean max power that the device 

25 is capable of? So regardless -- I just -- I don’t 
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1 know where this is heading or how meaningful it is to 

2 provide that information. 

3 MS. ARMSTRONG: The rating would be the 

4 number that’s coming out of the test procedure. To 

5 the extent that corresponds with max power, you know, 

6 it’s probably not going to, right, because we do a 

7 variety of different things. I’m not arguing it 

8 should or shouldn’t, but I’m just saying the rating’s 

9 going to be based on the test procedure and the 

10 several units that you would have to test to come up 

11 with an individual rating. And it should be 

12 representative of what we would say a consumer used in 

13 the field. 

14 MR. BROOKMAN: Robert first. 

15 MR. TURNER: The max power is for safety 

16 reasons, the absolute maximum loading which includes 

17 any peripherals attached, so USB ports, you load 

18 those, LNB you load, so it’s going to be much, much 

19 higher than your test procedure. 

20 Second point, in Europe, the way we’ve 

21 tackled it in the European Voluntary Agreement and in 

22 the Code of Conduct which has been around for ten 

23 years, we express the manufacturer declares based on 

24 the first deployed software in the field. If the 

25 service provider changes the software, then he has to 
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1 make a separate declaration based on new software. We 

2 don’t expect every single iteration of software to be 

3 changed, just if major functionalities change. 

4 MR. BROOKMAN: Noah. 

5 MR. HOROWITZ: This is Noah Horowitz. I 

6 want to echo the comment made by Gregg Hardy in terms 

7 of need for field deployable software. So this 

8 particular box might come out of a set-top box 

9 manufacturer’s factory and then either at that factory 

10 or at the service provider, additional software may be 

11 installed prior to deployment. We want to make sure 

12 that’s captured. And then when we’re talking setup 

13 conditions, which I understand is separate but related 

14 to this point, this box on service provider A might 

15 give 20 watts and may or may not go to sleep or fast 

16 resume, and if it’s tested on a different service 

17 provider, it would get -- you could potentially get a 

18 different answer. So we would think those are 

19 different models and how this relates to the 

20 definition of basic model, I think we need to take a 

21 look at. Thank you. 

22 MR. BROOKMAN: Okay. Matt. 

23 MR. MALINOWSKI: Just one more comment. I 

24 think there’s a question about basic model and how 

25 that relates to everything in this matter, so I think 
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1 it needs to tie into the sampling plan. I think, in 

2 particular, what was proposed was that a higher value 

3 be reported so perhaps the issue is not having to 

4 report the same value as the software is upgraded, but 

5 making sure that the measure -- the AEC does not 

6 increase past what was initially reported. I don’t 

7 know if that’s -- that’s something that will be 

8 discussed later in the day, but may play into it. 

9 MR. BROOKMAN: Paul. 

10 MR. GLIST: I’m not sure I understood your 

11 point, Matt. Are you putting forward the idea that 

12 the initial test results serve as a cap on the total 

13 consumption of any subsequent software download? Or 

14 are you saying something else? 

15 MR. MALINOWSKI: That’s how I, at least, 

16 read the sampling plan, the portion of the NOPR. So I 

17 guess I welcome maybe some discussion or clarification 

18 on that. 

19 MR. GLIST: So if it reads that way to you, 

20 it illustrates Mr. Samuels’ point that we have rapidly 

21 progressed from something that is advertising itself 

22 as agnostic to standards and caps and has power and 

23 all the rest. We’re just doing this to be uniform in 

24 measurement into something that is actually a cap on 

25 software upgrades and downloading software for whole 
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1 home energy management or anything else. Where is 

2 this going? Ashley? 

3 MS. ARMSTRONG: This is Ashley from DOE. I 

4 actually disagree with you because, you know, what the 

5 sampling plan is supposed to do is provide a rating 

6 for a given box. And I get there’s questions around 

7 what does that really represent? Is it the initial 

8 software download? Is it the software download over 

9 the lifetime of the box? And these are the issues the 

10 Department is grappling with, hopefully with your 

11 input. But what it does make you do is put a rating 

12 on the box, but we are not specific as to whether 

13 that’s the initial rating or a lifetime rating -- so 

14 that issue is open, obviously. But what it doesn’t do 

15 is set a hard cap period. There is no mention of a 

16 level or a cap in the document. 

17 MR. BROOKMAN: Gary. 

18 MR. LANGILLE: Yeah, I was just going to 

19 mention that to a certain extent, all us manufacturers 

20 are struggling with this right now with the EnergyStar 

21 program, because, you know, we have to test the 

22 product, but when you actually list it, everyone 

23 actually fudges the numbers because there is an audit 

24 done, independent audit by a certification lab, and if 

25 you fail, you lose your listing. And no one wants to 
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1 risk that. So it sort of brings into, you know, you 

2 do a test procedure but then you sort of just guess at 

3 how much you should increment it so that you don’t -- 

4 maybe you’re below the EPA limit, but you’re above 

5 what it actually uses, so you don’t get caught in the 

6 field and in some kind of an audit problem or 

7 something. So, it would be nice if we could come up 

8 with a method that takes the guesswork out of all that 

9 so we all know how to approach it. 

10 MR. BROOKMAN: You want to respond first, 

11 Ashley? 

12 MS. ARMSTRONG: No, that’s okay. 

13 MR. BROOKMAN: Gregg first, and then Jeff. 

14 MR. HARDY: I just wanted to express support 

15 for the approach that Robert mentioned as being taken 

16 in Europe, where you test with the initial software 

17 and for major updates, you retest. I think that’s 

18 sort of a practical approach to this. 

19 MR. BROOKMAN: Thank you. Jeff. 

20 MR. SAMUELS: I just wanted to clarify that 

21 when Gary uses the term fudge, I think what he means 

22 is conservative rating. 

23 MS. SANFORD: This is Jen with Cisco. 

24 MR. BROOKMAN: Jen, please. Go ahead. 

25 MS. SANFORD: I would also support the 
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1 approach that Europe took in both the voluntary 

2 agreement and a code of conduct by industry, which was 

3 industry-led in concert with energy stakeholders and 

4 the government, and the government ended up 

5 recognizing the leadership that industry provided in 

6 that area. I’d like to see a similar type of dynamic 

7 here. 

8 MS. ARMSTRONG: To Robert’s point, your 

9 general description of how Europe does it in terms of 

10 re-rating and based on major changes that would be 

11 more consumptive is DOE’s general position for most 

12 consumer appliances is that -- and commercial 

13 appliances -- it’s much easier to see changes in a 

14 refrigerator as compared to software. So I guess the 

15 question to all of you when you write your comments 

16 is, you know, how does that concept really translate 

17 to your world? 

18 MS. SANFORD: We’re supporting it. 

19 MR. BROOKMAN: Charlie Stephens. 

20 MR. STEPHENS: Charlie Stephens. I just -- 

21 I think it’s possible to actually arrive at a 

22 definition of a basic model and a test methodology 

23 that covers first deployments when they’re first put 

24 in the field, but I’m fairly certain that most of the 

25 appliances in my house are using more energy than they 
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1 did when they were first deployed. The reasons vary 

2 for that, of course. But one of the most important 

3 things you can do, based on some old research I did, 

4 is to have a piece of equipment that’s continually 

5 upgradable, forever. From a resource perspective, 

6 that’s a really good thing even if some of those 

7 upgrades do result in a modest increase in energy use 

8 in the field, not replacing the box is a huge thing. 

9 There are energy and other resource savings in not 

10 having to do that. So it doesn’t bother me that there 

11 might be modest increases in energy use from software 

12 upgrades down the road. But I would like to know when 

13 it’s first deployed, in comparison to other devices 

14 that are first deployed, what does it look like? What 

15 is its energy use? So I think there’s a way to do 

16 this, and I’m confident the Department can do this 

17 without wandering off into the weeds over what happens 

18 five years down the road. 

19 MR. BROOKMAN: Thank you. I think we’ve 

20 covered this now, right? We’re going to move on. 

21 MR. DOMMU: Okay. So the next topic we want 

22 to discuss is the definition of a manufacturer in 

23 terms of set-top boxes. So, the Energy Policy and 

24 Conservation Act defines the term “manufacture” as “to 

25 manufacturer, produce, assemble, or import.” And 
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1 furthermore, any person that manufactures a device 

2 that meets the proposed definition of a set-top box 

3 would be considered a manufacturer under DOE’s 

4 regulation. So if you’re a person or an entity that 

5 manufactures a device that combines hardware 

6 components with software programming designed for the 

7 primary purpose of receiving television or related 

8 services, from terrestrial, cable, satellite, 

9 broadband, or local networks, providing video output 

10 using at least one direct video connection, then you 

11 would be considered a manufacturer of a set-top box. 

12 So that concludes conversation around scope, 

13 and now I’m going to move into a summary of the 

14 proposed test procedure and then we will get into more 

15 of the details. 

16 Summary of NOPR 

17 So this chart here shows kind of the summary 

18 of everything that we’re proposing today. I’m going 

19 to provide a high level overview of our test 

20 procedure, and then I will hand it over to Mansi 

21 Thakkar and Allen Tsao will be providing more details, 

22 and I suggest I’m just going to go through this 

23 quickly, but I encourage you to reserve your comments 

24 and some discussion for the detailed conversation 

25 that’s to follow. 
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1 So the first thing that we do in 

2 establishing the test procedure is identify the scope 

3 and propose the definitions. Obviously, we just had 

4 the entire scope conversation, and we will begin by 

5 proposing which definitions we’ll be proposing to add 

6 to the regulation. 

7 We then go into the test conditions and 

8 measurement criteria, that specifies the required test 

9 conditions and measurement capabilities specifically. 

10 Video subscription, installation of the set-top box, 

11 room conditions, power requirements, test equipment 

12 and measurement accuracy. We also provide 

13 instructions on how to set up the room conditions and 

14 test units, so we’ll probably get into all of that. 

15 The next step is to connect, display devices 

16 and clients. So based on the capabilities or 

17 functionality of the set-top box, we are proposing to 

18 hook up display devices or clients -- and we will get 

19 into a proposal of exactly how we’re proposing to do 

20 that. 

21 We then get into, once the test setup and 

22 connections are all made, then we’ll get into on, 

23 sleep, and off mode test. The on mode test, we are 

24 proposing two tests, an on watch TV test, which 

25 essentially is measuring the power consumption when 
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1 the set-top box is in a state that’s watching TV, and 

2 we also have a multi-stream on mode test. And again 

3 based on the capabilities of the set-top box, we are 

4 proposing to use multiple streams at once based on 

5 that functionality of the set-top box and record its 

6 power consumption. That’s a single multi-stream test 

7 and there’s a table that has an order of priority that 

8 we will get into on exactly which streams should be 

9 enabled for that test. 

10 We then have two sleep mode tests, a manual 

11 sleep mode test where you simply turn the set-top box 

12 into sleep mode using the remote control or external 

13 signal and measure the power consumption. And we also 

14 are proposing an auto power down test for set-top box 

15 that is capable of automatically powering down and 

16 that test would measure the power consumption in that 

17 mode. 

18 We finally have an off mode test then. The 

19 Energy Policy and Conservation Act requires that we 

20 have an off mode test so that we recognize that not 

21 all set-top boxes are capable of entering that mode, 

22 and then those are all of our power consumption tests. 

23 We then, on this last line here, we go into 

24 the different calculations, so first we provide 

25 instructions on how to calculate the rated power 
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1 consumption, and this is the mathematical formula and 

2 description of how to convert the data of the power 

3 consumption into the required test results. Testing 

4 has to be performed at least twice and so to calculate 

5 the representative power consumption, you either take 

6 the mean of the test performed, or calculate the upper 

7 confidence limit, which is the representative power, 

8 or whichever is higher. So we will get into that 

9 later on. 

10 Once you have calculated the rated power 

11 consumption in each mode of operation, we provide 

12 instructions on how to calculate the annual energy 

13 consumption. So you’re taking the rated power 

14 consumption and you are applying usage profile which 

15 we will get into in order to calculate what the 

16 anticipated or estimate annual energy consumption is, 

17 and we’re calling that metric the AEC. 

18 Finally, we are including a test which is 

19 called the sleep to on mode transition time test, and 

20 the reason we’re doing that is because our sleep mode 

21 test or definition of sleep mode requires the set-top 

22 box to be capable of transitioning from sleep to on 

23 within 30 seconds, so that test is provided in order 

24 to ensure that that 30 second requirement is met, 

25 although there’s not a required output of the time 
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1 that it takes, it’s rather a function of that mode. 

2 So again, that is the high level summary and 

3 overview of our test procedure and we are going 

4 through, throughout the remainder of the day, get into 

5 a lot more detail, starting with definitions and 

6 working our way through all of these aspects of the 

7 test. 

8 MR. BROOKMAN: A few individuals have 

9 indicated that maybe we should take a short break. So 

10 I’d suggest we do that now. There’s a lot of rather 

11 detailed content for us to cover here. It’s now 

12 10:25. Let’s take a 15 minute break which means we’ll 

13 resume at 10:40. You must wear this badge if you’re 

14 going to walk around the Forrestal Building. There 

15 are restrooms at both ends of the hall. There’s a 

16 coffee shop down on the ground floor about directly 

17 underneath us. Go to the elevator bank, go down to 

18 the ground floor, hang a left and go quickly so we can 

19 resume at 10:40. 

20 (Whereupon, at 10:25 a.m., the meeting was 

21 recessed for a 15 minute period, and reconvened at 

22 10:40 a.m.) 

23 MR. BROOKMAN: We’re going to start back up 

24 and we’re going to hear from Mansi. 

25 MS. THAKKAR: Thanks, Doug. Good morning, 

26 everyone. I’m Mansi Thakkar from Navigant, and I’ll 
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1 be presenting the next three sections. I’ll discuss 

2 the definitions proposed in the test procedure, the 

3 test conditions and set up for performing the test, and 

4 the test methods for measuring power consumption in the 

5 on, sleep and off modes. 

6 Definitions 

7 Starting with the definitions, DOE proposes 

8 to adopt definitions for all the terms listed on this 

9 slide verbatim from the draft CEA standard. 

10 Additionally, DOE’s also proposing to adopt definitions 

11 for digital video recorder or DVR, display device, and 

12 home network interface or HNI, from CEA standard. 

13 We’re drafting information beyond what is specified in 

14 the standard. DOE is also proposing new definitions 

15 for two terms, content provider and multi-stream. 

16 We look at each of these five terms in more 

17 detail now. 

18 For the definition of DVR, DOE is proposing 

19 to adopt the CEA definition and is proposing to include 

20 the requirement that the hard disk drive must be 

21 integrated into the set-top box. This is not 

22 explicitly stated in the definition specified in the 

23 CEA standard. DOE is proposing this to explicitly 

24 state that if the hard disk drive is not integrated 

25 into the set-top box it is not considered a DVR capable 

26 set-top box for the purposes of this rulemaking. And 

27 it should not be tested as a set-top box with DVR 

28 capability. This requirement is also consistent with 
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1 what was specified in version 3.0 of the EnergyStar 

2 specification. 

3 We are proposing this requirement for a few 

4 reasons. 

5 • First, the power consumption of the set-top box 

6 will vary based on the hard disk drive that is 

7 used for testing such boxes. 

8 • External storage devices are generally optional 

9 and are therefore are not always provided with the 

10 set-top box. 

11 • Finally, standard hard disk drives for testing 

12 such set-top boxes are not defined and so 

13 repeatability of the test is a concern when 

14 testing with an external hard disk. 

15 If DOE tests set-top boxes with external hard 

16 disks as DVR set-top boxes, it will either consider 

17 specifying a standard storage device that should be 

18 used for testing, or it would specify that the set-top 

19 box should be tested with an external hard disk that it 

20 is shipped with. 

21 So at this time, DOE requests comment on the 

22 proposed requirement that set-top boxes with external 

23 storage devices should not be tested as DVR capable 

24 set-top boxes. Also, if stakeholders indicate, that 

25 such set-top boxes should be tested as DVR set-top 

26 boxes, then DOE requests comment on the proper external 

27 storage device that should be used for testing. 
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1 MR. BROOKMAN: Which of you two wants to go 

2 first? Gary, go ahead. 

3 MR. LANGILLE: Just a general comment that I 

4 think that -- I’m predicting that industry won’t accept 

5 text as DOE has proposed. If the intent for DOE to 

6 insert integrated into the STB as a means to trigger 

7 certain tests to be done and, you know, behavior and 

8 measurement, I think maybe there’s a better way to do 

9 that, because whether a device is actually integrated 

10 in or shipped in the box with the device and you’re 

11 told to plug it in when it gets there, to me that’s all 

12 irrelevant. So I think we’ll submit some comments and 

13 try to suggest some language that accomplishes similar 

14 goals perhaps. 

15 We also, I think, don’t want to define -- by 

16 mistake define a DVR as having to have a disk inside 

17 the box or it can’t be called a DVR, because there’s 

18 lots of technology on the way where you may not have a 

19 disk and still get the same functionality. 

20 MR. BROOKMAN: Okay. Noah. Actually --

21 pardon me -- Paul was next in the queue. Paul. 

22 Please. 

23 MR. GLIST: I would observe for you that 

24 there is no other functionality that you have required 

25 to be resident in the box in order for the box to be 

26 meeting various primary functions -- navigation, guide, 

27 tuning, all of those things could be in the network, 

28 they could be in the cloud, and they could still meet 
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1 the definition of a box. And so I question in the 

2 context of real set-top boxes on a real service 

3 provider networks, where the recording functionality is 

4 in the network and can be tested in a repeatable 

5 fashion, why you would set up a structural disincentive 

6 for energy efficiencies where you can save the consumer 

7 residential power and you would be able to market it as 

8 a better solution than something with a spinning disk. 

9 So we would also be submitting comments, 

10 questioning this approach. But I would raise this to a 

11 higher level, that this is one of many illustrations of 

12 why a DOE testing method which edges into a standards13 making, is not the right approach for this very 

14 complicated, rapidly changing, industry. 

15 MR. BROOKMAN: Thank you. Noah. 

16 MR. HOROWITZ: This is Noah Horowitz. I 

17 agree with a lot of what my colleague, Paul, has just 

18 mentioned. There may be content stored in the cloud 

19 that might be referred to as a network DVR, so you 

20 don’t need the hard drive, or in some cases, some of 

21 your content may come from the network and some might 

22 be recorded on what we currently think of as a spinning 

23 hard drive. Bottom line, we think whether the DVR has 

24 the disk in it or not, if you have the play and record 

25 capability, we need to include those, not exclude them 

26 from the scope. And in terms of hours of use, whether 

27 the content resides in the box or in the cloud, we need 

28 to capture that. 
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1 MR. BROOKMAN: So regardless of whether you 

2 agree with this specific definition, you understand why 

3 DOE needs to have these definitions, correct? So in 

4 your comments, tell them -- give them your best advice. 

5 MR. HOROWITZ: Yes, so our advice that will 

6 amplify in written comments is, we think it’s a DVR 

7 whether or not it has a hard disk drive in it. Thank 

8 you. 

9 MR. BROOKMAN: Okay. 

10 MS. THAKKAR: I’d like to clarify and say 

11 that the CEA definition on this point does include that 

12 “set-top boxes that support a service provider 

13 delivering network-based DVR service, are not 

14 considered DVR set-top boxes.” So that is something 

15 that’s not currently part of the CEA standard also. 

16 MR. BROOKMAN: It seems like, Allen, do you 

17 wish to make a comment. 

18 MR. TSAO: Yeah, this is Allen with Navigant. 

19 I just wanted to, I guess, ask -- I understand that 

20 maybe it’s still called a DVR if it can record and do 

21 all this stuff over the cloud, but would there be a 

22 need to test it differently than, you know, so if I’m 

23 just receiving video and it’s live or I’m receiving a 

24 prerecorded content, I mean, would that mean to be 

25 tested actually differently? I mean that’s kind of 

26 where the notion of how the DVR is defined. We know 

27 that because it has a disk, the energy consumption 

28 increases, so you would test that to cover that case. 
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1 But when it’s in the cloud, then I don’t know, maybe 

2 it’s all the same, the power is the same. 

3 MR. BROOKMAN: I guess we’ll start with Gary 

4 first. 

5 MR. LANGILLE: Well, a couple things. One is 

6 that CEA standard does indicate what you said, but it 

7 also adds at the end of that sentence you just 

8 repeated, “for the purposes of this testing.” 

9 MS. THAKKAR: Right. 

10 MR. LANGILLE: So the idea was it was just a 

11 qualifier as a trigger for which test would apply to a 

12 particular device. Whereas if DOE actually defines 

13 what a DVR is, that it must include an internal drive, 

14 that could limit market issues that Paul has raised. 

15 So I think -- we just need to talk about the language. 

16 And in answer to your question, I think the 

17 answer is maybe. I’ve got to think about it some more. 

18 There might be multiple processes running when you’re 

19 pulling in content from a network DVR that aren’t 

20 running when you’re not. We have to all think about 

21 it. 

22 MR. BROOKMAN: Gregg. 

23 MR. HARDY: Building on Gary’s point, I think 

24 that one potential solution would be to define a 

25 capability called integrated DVR capability, and not to 

26 define the box as a DVR and then say if you have 

27 integrated DVR capability, you do the following test. 

28 MR. DOMMU: Another follow up question is, 
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1 with some of this information you’re providing, if 

2 there is a box that’s potentially, say, capable of -- 

3 has an integrated DVhard disk but also is capable of 

4 receiving DVR content from a cloud as you’re 

5 suggesting, would there be reason to have an order of 

6 specificity of how you record that content or how you 

7 play it back within the test procedure? Would there be 

8 differences in power consumption based on where that 

9 DVR content is coming from? 

10 MR. BROOKMAN: Gary. 

11 MR. LANGILLE: This is Gary. Again, we’ll 

12 have to spend some more time thinking about it. I mean 

13 you raise a valid point that we need to make sure that 

14 the definition tree is the right test to be run on a 

15 device and I think we just have to figure out how to 

16 properly word that. 

17 MR. BROOKMAN: Okay. We’re going to move on 

18 then. 

19 MS. THAKKAR: Thank you. So further 

20 definition of display device. DOE is proposing to add 

21 the clarification that the content that is received 

22 through a video interface must be displayed for 

23 viewing. The CEA standard does not explicitly state 

24 that the content is displayed for viewing. DOE is 

25 proposing to include this clarification to say that the 

26 intent is also to display the device and not just 

27 receive it. 

28 The next definition is for home-network 
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1 interface. DOE proposes to adopt the CEA definition 

2 but add the clarification that a home-network interface 

3 is capable of transmitting video content. DOE is 

4 proposing to include this clarification because today’s 

5 proposed rule defines set-top boxes as a device that 

6 must provide video output. And so a home-network 

7 interface should be capable of transmitting video 

8 content, which will require a high bandwidth 

9 connection. The clarification ensures that low 

10 bandwidth interfaces that will not be capable of 

11 translating the video content and therefore would not 

12 be applicable for connecting with the set-top box, are 

13 excluded. 

14 Finally, DOE is proposing to include 

15 definitions for content provider and multi-stream. The 

16 proposed definition for content provider is an entity 

17 that provides video programming content. DOE is 

18 proposing this term because the term content provider 

19 is used in the proposed rule to explain the type of 

20 content that should be streamed to a connected display 

21 device or client. 

22 For multi-stream, the proposed definition is 

23 that a set-top box feature that may provide independent 

24 video content to one or more clients, one or more 

25 directly connected TVs, or a DVR. Again, DOE is 

26 including this definition because the term is used in 

27 the proposed rule extensively. In fact, DOE is using 

28 it to describe set-top boxes that have multi-streaming 
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1 capability and should be tested in accordance with the 

2 multi-stream test which we will discuss later in the 

3 day. 

4 MR. BROOKMAN: Adam. 

5 MR. A. GOLDBERG: I guess this relates to the 

6 other direct video connection. If -- I mean you may be 

7 reading that in context with the HNI definition, it 

8 would seem to say that a direct video connection is -- 

9 a direct video connection in that it will -- excluding 

10 anything over the home networking interface and it 

11 lists some things here. But I mean, still, I’m not 

12 entirely sure that this is as forward-thinking as it 

13 might be. But if the definition for -- if we talk 

14 about other video device in terms of -- sorry, other 

15 video interface as being other video interface not HNI, 

16 then that might give clarity. I don’t know if it’s the 

17 right answer or not, but it might make it clearer. 

18 MR. BROOKMAN: Okay. Gary. 

19 MR. LANGILLE: Just a general comment that -- 

20 on HNI, that the addition of the qualification that 

21 it’s capable of transmitting video -- we’ll suggest 

22 some language that will try to, I guess, get at the 

23 intent. But we think that isn’t sufficient because 

24 basically every home network interface is capable of 

25 transmitting video. May not be much video, may not be 

26 very viewable, but they’re all going to transmit video 

27 at some level. So we think that possibly the 

28 definition of what a home network interface maybe 
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1 should stay similar to what’s already in the CEA 

2 standard, but that separately from that there should be 

3 just a qualification list of what DOE will accept as an 

4 acceptable home network interface to use for the test -

5 - processors or something to that effect. 

6 MR. BROOKMAN: Okay. Yes. 

7 MR. TSAO: I think the point of that too is 

8 for testing purpose use the home network interface to 

9 maybe stream video and it may be possible that there 

10 may be products that have this interface and it’s used 

11 for some other purpose besides the video. So I agree 

12 to suggest some language there, but that’s going to be 

13 the test. 

14 MR. BROOKMAN: Thank you, Allen. Back to 

15 you, Mansi. 

16 MS. THAKKAR: So moving right along. The 

17 definitions of power modes. DOE is proposing to adopt 

18 definitions specified in the CEA standard for on, 

19 sleep, and off power modes. But DOE is proposing to 

20 include additional information to the sleep mode 

21 definition. So for the sleep mode definition, DOE is 

22 proposing to include “the set-top box shall be able to 

23 transition from sleep mode to on mode within 30 seconds 

24 to be considered in sleep mode. That is, if the set25 top box cannot transition from sleep to on mode within 

26 30 seconds, then it is not considered to have sleep 

27 mode capability for the purposes of today’s rule, and 

28 the set-top box should not be tested for the sleep mode 
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1 energy consumption.” 

2 DOE is proposing to include the 30 second 

3 requirement as an upper bound for the transition time 

4 to ensure that full functionality resumes in a 

5 reasonable period of time. DOE is including this 

6 because in response to the RFI that was published in 

7 2011, it received a stakeholder comment which 

8 referenced consumer studies to indicate that consumers 

9 have a strong resistance to adopt lower power modes if 

10 the recovery time, which is the transition time from 

11 sleep to on mode, is longer than one minute. Such a 

12 long recovery time is likely a barrier to adoption 

13 because it negatively impacts the user’s experience 

14 such that they may not use the sleep mode functionality 

15 of the set-top box. And if consumers disable sleep 

16 mode on the set-top box, this test procedure will 

17 likely not be representative. 

18 So at this time, DOE invites comment on the 

19 definitions of all three power modes, and specifically 

20 about the requirement to transition from sleep to on 

21 mode within 30 seconds. 

22 MR. BROOKMAN: Paul. 

23 MR. GLIST: Paul Glist. I am capable, and 

24 MVPDs generally are very supportive of the idea that 

25 the sleep modes should give a very good consumer 

26 experience. So I’m not taking issue with that. I am 

27 confused as to why a performance metric is in what is 

28 supposed to be a testing method that is not 
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1 establishing a standard. It would seems to be mixing 

2 two different things together and I’m, you know, Ashley 

3 told me we’re not doing standards here, we’re just 

4 saying how to test. Why wouldn’t you just say you test 

5 it, you measure the results, and you get a number? 

6 MR. BROOKMAN: Allen. 

7 MR. TSAO: This is Allen with Navigant. So, 

8 the goal is to have sort of the apples to apples 

9 comparison. When we talk about the sleep of one 

10 product that we’re talking about the same thing. If 

11 one set-top box just shuts it off and takes ten minutes 

12 to resume, and another -- and that’s like less than a 

13 watt, and another set-top box resumes very quickly and 

14 that takes eight watts, and we call those the same 

15 things, then there may be some mismatch, right, between 

16 -- well, someone’s going to say well this box may be a 

17 lot better at sleep mode because it can go down to .01. 

18 So I think there’s some notion of parity that we’re 

19 trying to get out with the definition of the sleep 

20 mode. 

21 MR. BROOKMAN: Adam. 

22 MR. A. GOLDBERG: Yes, so this is Adam for 

23 TiVo. So the -- what we’re talking about now is on, 

24 sleep, and off, and I think that the current discussion 

25 has been is 30 seconds a good number for describing 

26 sleep mode. And maybe a better time to talk about what 

27 I’m getting at here is in a discussion of what the duty 

28 cycle calculation is. But it’s true, I think, that, as 
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1 Allen was saying, that it’s something if the device 

2 takes ten minutes to come out of sleep then it’s going 

3 to be a poor experience. But even in the case where -- 

4 let me put it this way -- we’re talking about sleep 

5 mode here seems to be automatic power down sleep, that 

6 is, either the box after a period of time puts it in a 

7 lower power state or the user pushes a power button and 

8 after a period of time it goes into a lower power state 

9 and will wake up when someone wants to use it. And I 

10 think one interesting aspect of this that’s missing is 

11 not an automatic power down in terms of little use, but 

12 rather a scheduled power down state. 

13 You know, there can be times when a device is 

14 going to be at a higher power consuming standby mode 

15 and things like automatic power down or automatic power 

16 down sleep do what they do. For example, in the middle 

17 of the night, when few people watch TV, it could do 

18 other things like put itself into a much deeper sleep 

19 that takes longer to come out of. But so long as the 

20 user experience isn’t affected, that shouldn’t matter. 

21 For example, I mean if I made software in a 

22 box say between two and six a.m. it went into a low 

23 power mode where it took a minute to come out of it, 

24 then few people are even going to notice that ever 

25 happens. And in a discussion of duty cycle, I mean, 

26 right now we make assumptions about how much time per 

27 day is spent in various states. And for something like 

28 a scheduled power down, I mean we can measure exactly 
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1 what the power consumption is during that state and we 

2 can know as shipped, exactly how much time per day it’s 

3 going to spend in that state. And there’s -- we’d like 

4 to see an accommodation for that sort of operating mode 

5 included in the test procedure and in particular, the 

6 TEC calculation. 

7 MR. BROOKMAN: Jeremy. 

8 MR. DOMMU: So this requirement for the 30 

9 second from sleep to on applies to the two sleep tests 

10 that we are proposing in the test procedure. One is 

11 this the normal sleep mode test and the other is the 

12 auto power down. So it’s within those two specific 

13 tests that the 30 second requirement would apply to. As 

14 we get into the sleep tests later today, we’ll explain 

15 our proposal to ensuring that none of those automatic 

16 downloads occur during the performance of the test. 

17 MR. A. GOLDBERG: Yeah, I’m sorry, that’s not 

18 what I was -- that’s not what I was getting at. I’m 

19 saying there’s a missing sleep state from the -- 

20 downloads being a wholly separate discussion. 

21 MR. BROOKMAN: Okay. Gary. 

22 MR. LANGILLE: I was just going to comment 

23 that I totally understand the challenge and I think 

24 what DOE is trying to get to as far as comparing apples 

25 to apples and whether a sleep mode would actually get 

26 used or not by users. But I think that defining the 

27 sleep mode with a specific time, it might be an error 

28 in that it may be better to define sleep mode as 
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1 whatever it happens to be, but put the time limits in a 

2 different section where you’re figuring out where the 

3 rating is for a device. For instance, you could say, 

4 when you figure out the rating for a device and how you 

5 have to label it for sleep mode, you may say you can 

6 only count the level of sleep it was able to obtain 

7 with a 30 second recovery. But don’t change the 

8 definition of sleep mode. 

9 The other comment I’d like to make is that I 

10 think that for a test standard, it’s really important 

11 that we keep as much of the sort of behavioral times 

12 out of the actual testing if we can. Like for 

13 instance, I can tell you that if I lived in Hawaii and 

14 I’m paying 40 cents per kilowatt hour, I’d probably be 

15 perfectly happy to take a minute for it to turn on, 

16 given that I could save a significant amount of money 

17 every night. You know, I live in Colorado. It’s ten 

18 cents a kilowatt hour, I probably don’t care too much. 

19 So I think that even where the 30 seconds is 

20 acceptable, it depends to whom, to where, the 

21 geography, and I think that somehow we’re going to have 

22 to move that to a different part of the calculation. 

23 MR. BROOKMAN: Noah. 

24 MR. HOROWITZ: Noah Horowitz with NRDC. To 

25 be responsive to your question up there, is 30 seconds 

26 appropriate, we think that’s an appropriate middle 

27 ground. If it’s longer than that, consumers are 

28 frustrated. If it’s shorter than that, it might be 
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1 difficult to achieve, and many TVs take 15-plus seconds 

2 to turn on, so it won’t be that much longer than the 

3 consumer is already experiencing. 

4 A couple of finer points. We have the new 

5 term, transition from sleep to on within 30 seconds. 

6 We’d like to see some more clarity of what do we mean 

7 to transition to on. Does that mean I can go to the 

8 last channel I selected? Can I go to any channel? Or 

9 is my program guide supposed to be fully populated 

10 within those 30 seconds? So how far do you need to -- 

11 how much of the full functionality do you need? 

12 Another example would be, can I pull up my list of 

13 prerecorded shows and get to them after the 30 seconds, 

14 or might that take another two minutes? I don’t know 

15 what that point is, but we need to define it through 

16 more conversation. 

17 We also think this transition time should be 

18 reported as part of the output from the test method, 

19 and I agree with Gary and other -- and Adam here -- 

20 that DOE might want to include a deep sleep, and by a 

21 deep sleep, that’s where it has less power than on 

22 mode, but would have a resume time greater than 30 

23 seconds, for example. And there may be some consumers, 

24 this could be optional, and we’ll figure out how or 

25 whether to include it in the TEC, but those 

26 manufacturers that want to provide a deep sleep in the 

27 interim, should be able to do so. Some people might be 

28 off the grid or have time of use pricing and they might 
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1 be okay certain times of the day want their device to 

2 go into a truly low power state without much user 

3 inconvenience, especially if it’s implemented wisely. 

4 Long term, I think the industry has a goal of 

5 having one simple sleep state. You hit the on/off 

6 button, it uses very little power. You hit the button 

7 again and it resumes quickly. We’re not there yet so 

8 there might be an interim time period where having this 

9 second deep sleep, whatever we call it, might be 

10 warranted. Thank you. 

11 MR. BROOKMAN: Thank you. Gregg. 

12 MR. HARDY: Gregg Hardy. I think that the 

13 apples and oranges comment that Allen you made, is an 

14 important one. I think DOE’s approach is sort of a 

15 simple approach that makes sense. It does not factor 

16 in the possibility of scheduled sleep. I think that 

17 DOE, given what Gary said, I think DOE ought to 

18 consider what it would look like if they just measured 

19 sleep states and then wait times for each of those 

20 sleep states, and somehow you would define what it 

21 means to go to a new sleep state and then you would 

22 measure the sleep time for that sleep state, so that 

23 the test procedure truly is just testing the boxes and 

24 not specifying limits. 

25 And I’m not sure how that would all play out 

26 in the whole ecosystem of what this test procedure is 

27 about. You might then have situations where different 

28 organizations have different energy calculations 
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1 because they might come on different uses of these 

2 sleep levels or have different specifications, so that 

3 would -- the downside of that would be that you might 

4 not have consistent reporting of total energy 

5 calculation. 

6 MR. BROOKMAN: Which they’re trying to avoid. 

7 MR. HARDY: Right. Understand. 

8 MR. BROOKMAN: So additional comments before 

9 we move on? Okay. 

10 Test Conditions and Set Up

11 MS. THAKKAR: Okay. Thank you. So moving on 

12 to test conditions and set ups. For the set-top box, 

13 DOE is proposing that for set-top boxes that require 

14 subscription to a service, the simplest video 

15 subscription that supports all the functionality 

16 proposed in the test procedure should be selected. 

17 Supporting the required functionality here would mean 

18 functionality such as high definition streaming, multi19 streaming, or DVR, which are functionality that are 

20 being tested according to today’s proposed rule. 

21 Once the subscription has been selected, the 

22 set-top box will be installed. If the set-top box can 

23 be installed and set up according to the instructions 

24 provided in the user manual, then it must be installed 

25 according to those instructions. On the other hand, if 

26 the set-top box must be installed by a manufacturer’s 

27 technician, per the instructions provided by the 

28 manufacturer, then it shall be set up and installed by 
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1 that technician. All the steps that the manufacturer’s 

2 technician would follow to install the set-top box in a 

3 consumer household must be followed and these 

4 instructions must be recorded and maintained by the 

5 set-top box manufacturer. 

6 DOE is proposing this requirement to ensure 

7 the set-top boxes are tested in the same set up as they 

8 would be when installed in a consumer’s home, and to 

9 ensure that the test is representative. The CEA 

10 standard does not specify this requirement. The 

11 requirements that DOE is proposing are to ensure that 

12 non-tested features are set up in the default setting, 

13 that is, they are set up in the settings as they would 

14 be when first installed in a user’s home. 

15 While the language for these requirements is 

16 not exactly the same, these requirements were adopted 

17 from the CEA standard, which optionally specifies that 

18 non-tested features should be left in the default 

19 setting. 

20 At this time, DOE requests comment on the 

21 proposed requirements for setting up set-top boxes as 

22 installed in the consumer’s home for testing. 

23 MR. BROOKMAN: Gregg. 

24 MR. HARDY: Gregg Hardy. So two things. The 

25 NOPR says that the manufacturer’s technician will -- 

26 should configure the box, and I think there are other 

27 policy tools where this test procedure would be used 

28 where there’s going to be a third party doing the 
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1 testing so that wouldn’t be relevant in those 

2 situations. And I forget the other point. 

3 MR. DOMMU: Yeah, I don’t think that’s what 

4 we’re proposing in the test procedure. We’re just 

5 talking more generally about the technician who is 

6 performing the test, not necessarily the manufacturer’s 

7 technician. 

8 MR. HARDY: Okay. 

9 MR. BROOKMAN: Okay. Gary. 

10 MR. LANGILLE: Echostar’s just generally 

11 supportive of improving the clarification of the 

12 initial set up of the test condition. In fact, I think 

13 we got something in there in our previous draft, but I 

14 don’t know how it got taken out. 

15 MR. BROOKMAN: Okay. Additional comments on 

16 that in writing. Adam. 

17 MR. A. GOLDBERG: Yes, so I don’t -- I’m just 

18 looking at the slide and not the text in the NOPR, but 

19 when the -- for a user installed device, maybe you can 

20 go back to that slide? Yes. So it says installed 

21 according to the instructions in the user manual. Does 

22 the NOPR say or certainly the regulation, I think 

23 should, that according to the instructions in the user 

24 manual selecting all the defaults -- right? 

25 MS. THAKKAR: Right. I believe that the way 

26 it’s specified is that you follow the steps in the user 

27 manual and you set it up so the non-tested features are 

28 in the default condition. 
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1 MR. A. GOLDBERG: I’m not talking about non2 tested features. 

3 MS. THAKKAR: Okay, so -- 

4 MS. ARMSTRONG: So go back -- this is Ashley 

5 from DOE. Check the language in the notice. The idea 

6 -- the premise behind it was that each step a user 

7 would go through if it’s articulated in your user 

8 manual, we will go through for testing. Same thing as 

9 what we tried to do with the technician is saying the 

10 test technician would emulate anything a manufacturer’s 

11 technician would do in the field. The language doesn’t 

12 accurately capture all that, let us know. 

13 MR. A. GOLDBERG: What I’m trying to say is, 

14 is for example, there’s like a guided set up, and 

15 there’s -- it asks a series of questions and say one of 

16 the questions is, consume extra ten watts? And the 

17 default is no. Well -- 

18 MS. ARMSTRONG: We would go with no. 

19 MR. A. GOLDBERG: I’m just asking. The 

20 procedure should say, select the default. 

21 MS. ARMSTRONG: Okay. And that’s fine, as 

22 long as the default clearly -- what the default option 

23 is clearly labeled in your installation manual because 

24 you guys can do it pretty differently depending on who 

25 we’re talking about. Thank you. 

26 MR. BROOKMAN: Gregg. 

27 MR. HARDY: Gregg Hardy. So for gateway 
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1 boxes, I think the definition says that you’ll set up a 

2 box for the most basic service, and for a gateway box 

3 we recommend that it be tested with telephony active 

4 and broadband active, if that’s capable -- if the box 

5 is capable of that, but not in use. Otherwise you 

6 don’t capture the power -- potential power consumption 

7 of those capabilities, so that would not be the most 

8 basic package, it would be the most basic triple play 

9 package that exercises capability. 

10 MR. BROOKMAN: Noah. 

11 MR. HOROWITZ: Noah Horowitz with NRDC. We 

12 support the added clause by DOE of always keeping 

13 untested features in default setting, and I agree with 

14 the comment my colleague, Gregg, just made. To the 

15 extent there are other features, it’s Gregg, not Craig, 

16 just for you, Doug -- 

17 MR. BROOKMAN: Thank you. Thank you. I 

18 apologize. 

19 MR. HARDY: I was going to slip you a note 

20 under the table on that. 

21 MR. HOROWITZ: So if it’s provided -- if it 

22 has the capability of providing internet, you know, 

23 high speed data or telephony, you connect all those 

24 cables, but during the test you’re not activating them, 

25 so you’re not making a call or you’re not streaming 

26 data. So we’re focusing on the primary use, but to the 

27 extent that there’s a lot of unnecessary overhead 

28 energy, it would be captured there. 
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1 One other piece in all of this. It’s often 

2 the service provider that is deploying the box, not the 

3 manufacturer. So we say a set-top box must be 

4 installed by technician per manufacturer’s 

5 instructions, the technician from the service provider 

6 can make some decisions to turn certain things on or 

7 off, which have a dramatic impact on the energy use. 

8 So when we get into the set up conditions and 

9 throughout, I think we need to be clear on that. 

10 MR. BROOKMAN: Okay. Thank you. Paul, and 

11 then to Gary. 

12 MR. GLIST: Two points. I may have been 

13 confused by Mr. Hardy’s comment about gateways being 

14 turned on and measured with multiple services running, 

15 when I thought we had just got through a discussion 

16 that gateways without direct video connect would be out 

17 of scope. And so that may be my own confusion about 

18 what was going on there, but that didn’t connect for 

19 me. 

20 MR. BROOKMAN: You want to let -- go on 

21 Gregg, follow on. 

22 MR. HARDY: Sure, specifically, currently 

23 headless gateways are out of scope, but certainly there 

24 are other gateways that could be in scope, ones that 

25 have a direct video connection. 

26 MR. BROOKMAN: Now back to Paul. 

27 MR. GLIST: So I understand his comment 

28 although I may disagree with it as we get into the 
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1 written record. 

2 The other point that I have raised repeatedly 

3 in prior chapters and the Department has never engaged 

4 with us on is to consider the effect on innovation of 

5 new features that may have minimal market share, they 

6 might be out there in trials, they might be deployed in 

7 a box even making use of existing silicon which is an 

8 energy efficient way of trying it out. And the test 

9 procedure makes no accommodation for that path to 

10 innovation. It’s addressed in the NOPR. It’s not 

11 addressed so much in the test procedures. I renew that 

12 and I will explore it again in the written comments, 

13 because as I said it’s been represented to me 

14 repeatedly that the Department does not want to stand 

15 in the way of innovation and I think there are finer 

16 ways to cut this to allow the industry to continue to 

17 innovate and compete and still do it in an energy 

18 efficient way. 

19 MR. BROOKMAN: Gary -- actually let Ashley 

20 slip in here. 

21 MS. ARMSTRONG: I’m just going to follow on, 

22 and perhaps it’s a bit of my background appreciation 

23 for the types of innovation you’re doing. But I’m not 

24 understanding what the language is that precludes you. 

25 Is it that certain modes won’t be -- I mean I don’t get 

26 that incorporating a certain type of silicon or 

27 whatever you’re explaining won’t -- can’t be tested in 

28 accordance and won’t give you a credit. We’re asking 
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1 you to take the wattage values. 

2 MR. GLIST: And I think to try to put a finer 

3 point on it so that you understand the issue -- this 

4 proceeding is morphing into standards and caps, 

5 regardless of representations to the contrary. If 

6 we’re just measuring and it’s just going to be posted 

7 and nothing else happens, then I don’t have a problem 

8 on the innovation cycle. 

9 MS. ARMSTRONG: So I think I’m trying to 

10 distinguish, because what this proceeding is trying to 

11 do is set up a test method, and so when you make 

12 comments -- and while we appreciate everyone’s 

13 comments, we’re trying to understand what exact 

14 language is precluding innovation. So that’s why, you 

15 know, I don’t -- standards aside, a different issue for 

16 another day. But if you would tell us exactly what 

17 language is precluding innovation as part of the actual 

18 testing procedure, that is of great concern to the 

19 Department, as you said. 

20 MR. GLIST: Yea, and we’ll do that. 

21 MS. ARMSTRONG: Great. 

22 MR. GLIST: You engage quite well in the 

23 NOPR, and you said we disagree with you, so I don’t 

24 think the issue is vague, but I will clarify it in 

25 written comments. 

26 MR. BROOKMAN: Thank you. Gary. 

27 MR. LANGILLE: I was just going to make a 

28 general comment that my reading of the NOPR and also 
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1 the CEA 2043 standard is that the -- both of these test 

2 procedures as written or as referenced to each other, 

3 don’t support the testing of non-set-top box -- non4 video functions, let’s put it that way. So if you do 

5 have a broadband service or a telephone service 

6 resident in the same box, there’s nothing in these 

7 standards that tell you how to configure, what to do 

8 with those while you’re testing the video portion. So 

9 I think we have to either define set-top box to exclude 

10 devices that contain more than just video service 

11 capabilities, or if we’re going to include devices that 

12 include, you know, more than video services -- 

13 broadband, telephone, security, whatever -- then we 

14 have to update the test procedure to tell you how to 

15 set those up and how they should be configured. The 

16 statements in CEA 2043 where it says, optionally, you 

17 know, keeps non-tested features in default setting, it 

18 was meant to say sort of, non-tested set-top box video 

19 features, meaning, you know, for instance, trying to 

20 think what CEA -- ultra high definition is 

21 theoretically on the way. We’re all going to have 

22 these 4K TVs in another five years. Well, I’m not 

23 because they cost 12 grand, but -- so there’s a feature 

24 that may show up in a set-top box. For those ten 

25 people that can afford that TV and the reason for that 

26 is so that we can innovate, we can experiment, we can 

27 see what it takes to deliver that kind of quality, 

28 whether the customers are accepting of the quality we 
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1 deliver or what technical issues are there. 

2 So to me, that’s the kind of feature that 

3 statement was aimed at, is that, you know, don’t turn 

4 that on when you do the test. It’s not a whole other 

5 service delivery system or a whole other huge energy 

6 consuming section. It’s just sort of a small feature 

7 you can keep off. 

8 MR. BROOKMAN: Robert. 

9 MR. TURNER: I think Gary has covered a lot 

10 of what I was thinking, but the way we tackled it in 

11 Europe is we have, which is another step further, a 

12 sort of limits on the test method, and the test method 

13 specifically says, if you have a feature that doesn’t 

14 have an allowance, you specifically exclude it, 

15 disabling it, so you’re measuring what you intend to 

16 measure, not unintended extras. 

17 MR. BROOKMAN: Okay. Thank you. Gregg. 

18 MR. HARDY: Is someone else first? Okay. 

19 Gregg Hardy. So thinking, you know, sometimes it’s 

20 hard not to think ahead to whatever we do in the spec, 

21 right, but in a scenario where you test the other 

22 triple play functions, broadband, telephony, then you 

23 might have functional adders for those, per Robert’s 

24 comment and if you come up with a new feature that 

25 doesn’t have a functional adder, that you would not 

26 have to test that. So with a scenario like that, I’m 

27 just envisioning a world where telephony and broadband, 

28 you know, if gateways are going to become very common 
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1 devices, those would be very common features. So it’s 

2 a scenario where if you didn’t have functional adders 

3 for those and you didn’t test for them, then those 

4 would sort of be unregulated capabilities within 

5 gateways. 

6 MR. BROOKMAN: Jennifer. 

7 MS. SANFORD: This is Jennifer Sanford with 

8 Cisco. I think Gregg’s point proves the point that 

9 this is a fishing expedition. And if we’re focusing on 

10 set-top boxes and measuring set-top boxes, let’s focus 

11 on that. And if we’re not, then let’s include 

12 everything else and make sure we’re representing 

13 everything else. And I’ll say for the record I think 

14 that the voluntary agreement and the EnergyStar program 

15 and other voluntarily led programs by industry have 

16 this covered, and I think we should take that into 

17 account. 

18 MR. BROOKMAN: Gregg, follow on. 

19 MR. HARDY: Sure. I just want to disagree 

20 with the point that this -- that proves it’s a fishing 

21 expedition, and just say that I think there’s a real 

22 debate that needs to happen about when you have a box 

23 with multiple capabilities and it’s primarily a set-top 

24 box, do you want to know how much energy that device 

25 uses in its most common usage. If we take all the 

26 energy calculations of all these set-top boxes and we 

27 add up a national energy sum, you might want to have 

28 the broadband and the telephone capabilities as part of 
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1 that energy. But when we get the boxes that are 

2 primarily game consoles, we might want to test out the 

3 video streaming functions of those also and include 

4 that energy in that box. 

5 So it’s more of a philosophical point about 

6 what are you measuring. Are you measuring the energy 

7 use in its most common usage? 

8 MR. BROOKMAN: Chuck Samuels. 

9 MR. SAMUELS: It sounds like Gregg’s view, 

10 philosophical view, is just regulate everything that 

11 has an electron moving, even if you can’t define it. 

12 But more specifically, and to Ashley’s point about 

13 what’s the inhibition on innovation. This question 

14 about functional adders, which is what would normally 

15 happen in a test procedure, makes sense when you have 

16 relatively static technology and designs, and fairly 

17 slow pace of change. Here, where you’re having changes 

18 throughout the year and every year, it’s inevitable 

19 that companies are going to need to come to DOE to seek 

20 waivers from the test procedure, and in and of itself, 

21 that will be an inhibition on innovation. You’re going 

22 to have all kinds of complicated issues about 

23 disclosure of confidential information. You don’t 

24 really address this within the test procedure, because 

25 you think of it as sort of separate as the waiver 

26 process. But frankly, you have to integrate thinking 

27 about what are you going to do as your test procedure 

28 becomes more and more irrelevant every year, and how 
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1 are you going to keep up with that? And I think it’s a 

2 fundamental problem, basically a law written in the 

3 1970s and 1980s didn’t contemplate this scenario, and 

4 it just doesn’t work. But whether you agree with that 

5 or not, I think the Department has to consider how it 

6 is going to use the waiver or other process to keep up 

7 with changes that are not going to make sense in terms 

8 of a static test procedure. 

9 MR. BROOKMAN: Thank you. Charlie Stephens. 

10 MR. STEPHENS: Charlie Stephens. I just 

11 wanted to add a little perspective. A couple of us 

12 here in the room are representing people who pay our 

13 salaries who have an obligation to keep the lights on, 

14 no matter what wonderful innovations everybody sitting 

15 around the table comes up with and attaches to that 

16 grid by the millions. If it were a few ten thousands 

17 of these things, it would be one thing, but these 

18 things run in the millions, and there actually is a 

19 need for us to understand exactly how much energy they 

20 use and will use, because somebody has to go out and 

21 invest the multimillions of dollars that it takes to 

22 serve these new loads. 

23 So I am interested in how much it uses, and I 

24 am interested in all those other functionalities that 

25 might come along with it, because they’re adding up 

26 into very large numbers. And my own preliminary field 

27 research kind of shows that. So I’m sure we can do it. 

28 I’d rather argue about how to do it well than argue 
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1 about whether we should do it at all. Thank you. 

2 MR. BROOKMAN: Thank you. Paul. 

3 MR. GLIST: I would just like to address Mr. 

4 Stephens’ point because one of the things that we 

5 learned in developing the voluntary agreement was the 

6 importance of trying to come up with aggregate 

7 footprints and trends in the industry so that people in 

8 Charlie’s position and the IOUs and the energy 

9 advocates and the DOE could see where things were going 

10 in this very rapidly changing complex environment. So 

11 we’ve put those kinds of annual reporting metrics into 

12 the voluntary agreement in a way that I think is very 

13 helpful and has the advantage of flexibility that does 

14 not interfere with innovation. 

15 By contrast, by singling out a class of 

16 defined set-top boxes in the way that you have and 

17 saying that we really need to know what the plug load 

18 is associated with that, and saying but for those 200 

19 million video devices that we call gaming consoles, 

20 ignore that. Nothing to see here, has no impact on 

21 IOUs or DOE or consumers or anything, just ignore that. 

22 Or give them an incentive, you know, get an EPA merit 

23 badge and plus, we’ll give you 40 watts for active mode 

24 and no ceiling on anything that you can dump into the 

25 device. That is a competitive disparity that makes no 

26 sense. 

27 And so I challenge the Department again to 

28 compare the relative benefits of something that works 
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1 well with rapid innovation in the market and one that 

2 has broadly segmented the market and is running the 

3 risk of handicapping the innovation of just a select 

4 few. 

5 MR. BROOKMAN: Okay. I think we’re going to 

6 move on now. 

7 Test Conditions and Setup 

8 MS. THAKKAR: So the next requirement is for 

9 the test room and these requirements have been adopted 

10 as specified in the CEA standard. DOE proposes that 

11 the air speed surrounding the set-top box shall be less 

12 than or equal to 0.5 meters per second. The ambient 

13 temperature should be maintained at 23 degrees Celsius, 

14 with a tolerance of five degrees Celsius throughout 

15 testing. And the set-top box should be tested on a 

16 thermally non-conductive surface. 

17 While DOE is proposing these requirements, it 

18 believes that it may be difficult to maintain the 

19 required air temperature of 23 degrees Celsius at such 

20 a low air speed. This is because the heat generated 

21 from the set-top box would likely heat up the 

22 surrounding air and at such a low air speed, the air 

23 temperature will not be maintained. DOE believes that 

24 the air speed requirement may be stringent in 

25 conjunction with the temperature requirement, 

26 particularly because it is likely that the power 

27 consumption of the set-top box does not really vary 

28 significantly at a moderately higher air speed. 
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1 So at this time, DOE requests comment on the 

2 proposed test room conditions and also with respect to 

3 air speed, DOE request comment on whether the 0.5 

4 meters per second requirement is fine or if it should 

5 be relaxed to a higher value, or removed all together. 

6 MR. BROOKMAN: Gary. No? No comment. Yes, 

7 Robert. 

8 MR. TURNER: Happy with it. It’s the same 

9 basic criteria as in 62301, which is the main standard 

10 for measuring essential standby power. If you go for 

11 higher temperature ambience, then you’re going to get 

12 some different results because particularly for DVRs, 

13 we have the fan working, and that changes the answer. 

14 Keeping a standard room ambient and a nominal still air 

15 will give repeatable answers. 

16 MR. BROOKMAN: Okay. Thank you. Additional 

17 comments? 

18 MS. THAKKAR: So the next subject we will 

19 discuss is test set up. For the proposed test 

20 procedure, DOE is proposing test set up requirements 

21 for input power, measurement accuracy, test equipment, 

22 true power watt meter, and instrument calibration. 

23 These requirements have been specified according to the 

24 requirements in the CEA standard, and are discussed in 

25 detail in the NOPR. 

26 DOE requests comment on each of these 

27 proposed test set up requirements. 

28 Okay. Moving on to the network set up. 
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1 MR. BROOKMAN: Noah has a comment. 

2 MR. HOROWITZ: A question -- Noah Horowitz 

3 from NRDC. I don’t know whether we could here or it’s 

4 covered later in the day. Your talk about the accuracy 

5 of the meters. Another important point is the 

6 allowable tolerance. So the meter might be plus or 

7 minus a tenth of a watt, but in terms of the reported 

8 value, does that need to be within a certain threshold 

9 as well? Is it plus or minus one percent, three 

10 percent? 

11 MS. THAKKAR: We do discuss rounding 

12 requirements later on. 

13 MR. BROOKMAN: Someone on the webinar has a 

14 question, Antonio Figueiredo. Antonio, if you speak 

15 clearly and loudly we ought to be able to hear you. 

16 Why don’t you try it. 

17 MR. Figueiredo: Yeah, Tony Figueiredo from 

18 Cisco Systems. The question I had was the definition 

19 of a non-conductive surface. I’d like to know what is 

20 a non-conductive surface. Even air is conductive, so I 

21 need clarification on what you guys are referring to. 

22 MR. BROOKMAN: Jeremy first. 

23 MR. DOMMU: Yeah, thank you, and I do believe 

24 you’ve already submitted this comment writtenly for the 

25 record, and it’s something that we will certainly 

26 consider. I mean I think that the intent here was that 

27 it’s tested on a wood or a glass surface, not 

28 necessarily a metal surface. But if that language is 
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1 not specific enough to get to that requirement, we will 

2 certainly look for feedback from stakeholders on how to 

3 make it more specific to meet your expectational 

4 question that you have. 

5 MR. BROOKMAN: Gary, you want to -- 

6 MR. LANGILLE: I was just going to add that 

7 as cochair of the standards group, we’ll also take that 

8 in consideration. I mean clearly that’s an error that 

9 needs to be fixed. 

10 MR. BROOKMAN: Okay. Thank you. Keep going. 

11 MS. THAKKAR: Okay. So for the service 

12 provider network connection, DOE is proposing that for 

13 set-top boxes that require a service provider 

14 connection, the set-top box shall be tested with a 

15 specific service provider network or in an environment 

16 that’s simulates a subscriber operating environment and 

17 is verified by the service provider. These 

18 requirements are as specified in the CEA standard. 

19 At this time, DOE requests comment on the 

20 proposed requirements for the service provider 

21 connection. DOE particularly requests comment about 

22 whether the power consumption of the set-top box is 

23 similar on the live network versus the simulated 

24 environment. 

25 No comments? 

26 MR. BROOKMAN: No comment here? We’ll come 

27 back to it. Okay. 

28 MS. THAKKAR: Okay. So the next network 
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1 requirement is for the home network connection. DOE is 

2 proposing requirements that are specified in the CEA 

3 standard with one key addition. The CEA standard says 

4 that the entity specifying the use of the standard 

5 should provide the home network connections. So DOE is 

6 proposing that for set-top boxes that require home 

7 network connection, the order in which the connection 

8 is selected should be MoCA, followed by HPNA, followed 

9 by Wi-Fi, and finally if none of these connections are 

10 available, then any other connection. The order of 

11 these connections is being proposed based on the most 

12 common to least common home network interface 

13 connections that are known as of today. These 

14 requirements are again consistent with the requirements 

15 in version 3.0 of the EnergyStar specification. 

16 At this time, DOE requests comment on a few 

17 issues. First, we’re requesting comment on the 

18 proposed requirements for the home network connection. 

19 We are also requesting comment on the proposed order 

20 which is MoCA, followed by HPNA, followed by Wi-Fi. 

21 And finally, DOE requests comment about whether there 

22 are any additional home network interface connections 

23 that should be included and order of preference in 

24 which they should be included. 

25 MR. BROOKMAN: Adam. 

26 MR. A. GOLDBERG: I think Gary was in first. 

27 MR. BROOKMAN: Gary, go ahead. 

28 MR. LANGILLE: I was just going to comment 
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1 that I think specifying the preference for usage of the 

2 home networks is fine as part of requirements before 

3 you run a test procedure. I do think that DOE should 

4 make sure that they put this in a place that it can be 

5 updated frequently. For instance, 802.11 WiFi, you 

6 know, there’s already a whole bunch of versions and the 

7 most recent one, AC, really draws a lot of power for 

8 itself. That may end up being more than MoCA by the 

9 time it’s done. 

10 MR. BROOKMAN: So thank you. Adam. 

11 MR. A. GOLDBERG: So just to be clear, 

12 without a TiVo hat on, I find it curious that 802.11 is 

13 behind the HPNA, and it might even be that WiFi is more 

14 popular than MoCA for these devices. And then 

15 finally, that 802.3, which is just a wired Ethernet, 

16 isn’t in here at all, having just completed building a 

17 house, I can tell you that I’m not going to be using 

18 MoCA to connect my devices. 

19 MR. BROOKMAN: Thank you. Additional 

20 comments? Robert? 

21 MR. TURNER: I wasn’t going to -- 

22 MR. BROOKMAN: You looked like you were 

23 ready. 

24 MR. TURNER: All I would say is I wouldn’t 

25 define a product list. I would leave it that each 

26 technology should be measured and the results recorded. 

27 So if you’ve got three network interfaces, measure each 

28 interface and record the results. 
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1 MR. BROOKMAN: Additional comments? Okay. 

2 MS. THAKKAR: For the broadband service 

3 connection, again, DOE is proposing requirements that 

4 are specified in the CEA standard. But DOE is also 

5 proposing an additional requirement. The requirement 

6 adopted from the CEA standard specifies that every set7 top box that includes a home network interface 

8 connection and requires that this connection be 

9 connected to broadband service for operation of 

10 principal set-top box functions, then the set-top box 

11 shall be tested while connected to a broadband network. 

12 The broadband performance criteria, such as download 

13 speed, and upload speed, should meet the specific 

14 requirements of the set-top box. 

15 Additionally, DOE is proposing that if a set16 top box operates with both broadband connection and 

17 service provider connection, then the service provider 

18 connection takes precedence. That is, a broadband 

19 connection is used only if the set-top box requires it 

20 for operating a principal function. 

21 DOE is proposing to include this 

22 clarification because there may be some set-top boxes 

23 that can operate on both networks. For such boxes, it 

24 is our understanding that the box typically operates on 

25 the service provider network connection, rather than 

26 the broadband connection. 

27 At this point, DOE invites comment on the 

28 proposed requirements for broadband connection. DOE 
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1 also requests comment on the clarification that a 

2 service provider connection should take precedence over 

3 a broadband connection. 

4 MR. BROOKMAN: Adam. 

5 MR. A. GOLDBERG: So I’m looking at the 

6 definition of principal STB function, and I’m not sure 

7 whether the program guide is included in that. I think 

8 it makes a difference, honestly, because I could -- 

9 looking at the word select, selecting -- that’s there 

10 for selecting. I can select a channel without having a 

11 guide. Right? 

12 MS. THAKKAR: Right. 

13 MR. BROOKMAN: Jeremy. 

14 MR. DOMMU: We do have a definition of 

15 principal set-top box function in section 2.18 of the 

16 test procedure. That means “a function necessary for 

17 selecting, receiving, decoding, decompressing or 

18 delivering video content to a display device, DVR, or 

19 client. Monitoring for user or network request is not 

20 considered a principal set-top box function.” So 

21 that’s a proposed definition that we have. 

22 MR. A. GOLDBERG: And that’s an issue I had a 

23 question about. Does that include a guide or not? 

24 MR. DOMMU: Ah, I mean, we don’t specifically 

25 mention that a guide is included in that definition I 

26 just read off. 

27 MR. BROOKMAN: Gary. 

28 MR. LANGILLE: I was just going to agree -- I 
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1 actually wrote that and when I wrote it I was thinking 

2 selecting that guide, but you point out a very valid 

3 point that it’s not clear at all. 

4 MR. BROOKMAN: Yes, Gregg. 

5 MR. HARDY: I’ll just finish the thought and 

6 say I think a guide should be in there. 

7 MR. BROOKMAN: That’s useful, thank you. 

8 Additional comments on this issue. Did they hit the 

9 second one? Mansi? Clarification service provider, 

10 network connection should take precedence over 

11 broadband connection? Comments? Additional comments? 

12 No additional comments. Okay. We’re moving on. 

13 MS. THAKKAR: Okay. The next is service 

14 provider network distribution equipment. This includes 

15 equipment such as network gateways, network routers, 

16 and other devices that are required for distribution of 

17 a service provider network to the set-top box. For 

18 such equipment, DOE is proposing that the power 

19 consumed by these equipment should be excluded from the 

20 power consumption of the set-top box. Again, this 

21 requirement is specified in the CEA standard. DOE is 

22 proposing to exclude the power consumption of these 

23 equipment because they do not meet the proposed 

24 definition of the set-top box. 

25 At this time, DOE requests comment about the 

26 proposed exclusion of the power consumption of such 

27 equipment from the power consumption of the set-top 

28 box. Also, if stakeholders indicate that the power 
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1 consumption of this equipment should be included, then 

2 DOE requests comment on the test method as well as 

3 standard configuration in which these equipment should 

4 be tested. 

5 MR. BROOKMAN: Gary. 

6 MR. LANGILLE: Echostar agrees that the way 

7 that the tests are currently written that, you know, 

8 we’re focused on testing a set-top box, then we agree 

9 that you should not include extraneous equipment to get 

10 the signal distributed around the home to the box. We 

11 believe that would be the subject of a different test 

12 procedure if it had to be done or included. 

13 MR. BROOKMAN: Other comments? Noah. 

14 MR. HOROWITZ: I agree, just like the outdoor 

15 unit, the ONT and other three letter acronyms, 

16 shouldn’t be part of this initial set-top box test 

17 method, but to the extent that DOE wants to, they 

18 should continue their evaluation of small network 

19 equipment and when they do, they should try and 

20 incorporate these other devices, some of which might 

21 even consume more energy than the set-top box itself. 

22 MR. BROOKMAN: Okay. Thank you. Robert. 

23 MR. TURNER: I would agree with what’s being 

24 proposed. The complication comes that you don’t want 

25 to end up with having a networking device and the set26 top box as two separate boxes to get around limitations 

27 of -- with any one of them, where you get a more energy 

28 efficient solution by combining them. That’s the 
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1 challenge that you’re going to struggle with. 

2 MR. BROOKMAN: Okay. Thank you. Next. 

3 MS. THAKKAR: Okay. The last network set up 

4 requirement is for input signal equipment. This 

5 includes equipment such as low noise block down 

6 converters, outdoor units, over the air antenna 

7 amplifiers, and other similar equipment that is 

8 required to operate the set-top box. For such 

9 equipment DOE is proposing that if the equipment cannot 

10 be powered from another source, then the power 

11 consumption of this equipment must be included in the 

12 power consumption of the set-top box. However, if the 

13 equipment can be powered from another source, then it 

14 must be powered from another source and such an 

15 external source should not deliver any power to the 

16 set-top box itself. 

17 This requirement has been adopted from the 

18 CEA standard, but there is a small difference. DOE is 

19 proposing that if the equipment cannot be powered from 

20 another source, then its power must be included. This 

21 is not specified in the CEA standard. DOE is also 

22 proposing that additional clarification that input 

23 signal equipment should not deliver any power to the 

24 set-top box if it is powered externally. CEA is not 

25 proposing specifying this requirement either. 

26 The second requirement is being proposed to 

27 avoid the possibility of circumvention when the set-top 

28 box receives some of its power from the external source 
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1 powering the equipment. For this requirement, DOE 

2 considered, but has not proposed at this time, 

3 specifying the use of a DC block, or a direct current 

4 block that will prevent power transfer to and from the 

5 input signal equipment. DOE has not proposed this 

6 requirement because a DC block could potentially impact 

7 the functionality of such equipment. 

8 So at this time, DOE requests comment on the 

9 proposed exclusion of input signal equipment if they 

10 can be powered from another source, and additional 

11 clarification that such equipment should not supply any 

12 power to the set-top box. 

13 MR. BROOKMAN: Gary, looks like you’re ready. 

14 MR. LANGILLE: I understand DOE’s concern 

15 that there isn't a way to sort of, you know, power 

16 parts of the set-top box that wouldn’t be counted as 

17 part of the set-top box. We are somewhat against with 

18 trying to come up with a specification for a DC block, 

19 just because there’s so many different systems. But 

20 maybe perhaps some language that we actually have to 

21 verify that there’s no current or power being delivered 

22 may be a better way to do it so that you don’t 

23 interfere with any signal issues. 

24 The other issue may be is that there may have 

25 to be some exception language. We’ve had some crazy 

26 thoughts that maybe you want to power part of the set27 top box from, for instance, an LNB power supply so 

28 that the set-top box could go to a much deeper sleep, 
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1 and then just have the smaller LNB power supply keep 

2 critical functions alive. So it could be that that 

3 actually supplying power to some small section of a 

4 set-top box could be a very innovative method to reduce 

5 overall power consumption. So there may just have to 

6 be some exception language added, but in general I 

7 understand the concern and it seems like a reasonable -

- 8 

9 MR. BROOKMAN: Yes, Charlie. 

10 MR. STEPHENS: Just a dumb question. Is 

11 there any reason why we just can’t measure it and net 

12 it out? 

13 MR. BROOKMAN: Gary, for the record, you’re 

14 saying no. 

15 MR. LANGILLE: That’s not what I’m proposing. 

16 It’s just to make sure that you measure that there’s in 

17 fact no power being transferred into the set-top box 

18 from an input signal system. So it wouldn’t alter the 

19 set-top box measurement. 

20 MR. BROOKMAN: Gregg. 

21 MR. HARDY: Gregg Hardy. I’d be interested 

22 in Gary’s opinion on this, but I would prefer an 

23 allowance, allowing test strips to subtract the power 

24 level of the ONT from the set-top box measurement in 

25 cases of ODU or LNB -- acronym soup here. And the 

26 reason why is that it may create an incentive to move 

27 to external power supplies which are often, my 

28 understanding is, left on when a service is terminated, 
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1 so there’s the risk that they consume power many years 

2 after service is terminated. And there are a couple of 

3 other reasons why. I don’t think we’d want to create 

4 an incentive to shift away from set-top box power to 

5 LNBs to externally powered LNBs. 

6 MR. BROOKMAN: Okay. Additional comments? 

7 On, Sleep and Off Mode Tests 

8 MS. THAKKAR: Okay. So the next section is 

9 the on, sleep, and off mode test. We begin with the 

10 test configuration, which describes how the set-top box 

11 must be configured for testing. 

12 For the test configuration, DOE is proposing 

13 that the set-top box should be connected to as many 

14 display devices and clients as possible, depending on 

15 the capabilities of the set-top box as described in the 

16 table on this slide. So the way this table works is 

17 the first three columns on the left ask whether the 

18 set-top box meets certain criteria. Such as, does it 

19 support connections to multiple display devices? Or 

20 does it support DVR functionality? Or does it support 

21 clients? 

22 Based on the answers to these three 

23 questions, you pick the row for which the set-top box 

24 meets the three criteria and then look at the last two 

25 columns to determine the connections to display devices 

26 and clients. We’ll look at specific examples, but an 

27 important thing to note here is that each of these rows 

28 are mutually exclusive. That is, any set-top box will 
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1 satisfy all three criteria in the three columns on the 

2 left, for only one of the rows. 

3 These requirements are not specified in the 

4 CEA standard but the standard requires that the entity 

5 specifying the use of CEA 2043 must provide the 

6 configuration in which the set-top box is connected to 

7 display devices and clients. 

8 So the first example here is a set-top box 

9 that has an integrated DVR and supports connections to 

10 multiple displays and clients. This set-top box meets 

11 the criteria specified in the first three columns only 

12 for the first row of the table. And therefore, 

13 according to the last two columns, it must be connected 

14 to one display device and one client as shown in this 

15 figure. 

16 The second example is a set-top box that does 

17 not have DVR functionality, but it supports multiple 

18 display devices and client connections. This 

19 particular set-top box meets the criteria for the three 

20 columns on the left for row three of the table. And so 

21 it is connected to two display devices and one client 

22 as shown in this image. 

23 So once we determine how many displays and 

24 clients need to be connected, we need to make the 

25 connections. For connecting a display device to the 

26 set-top box, DOE is proposing that the first preference 

27 should be to use an HDMI connection, followed by 

28 component video, s-video, composite video, and finally 
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1 if none of these connections are feasible, then any 

2 other video interface must be used. This order is 

3 proposed based on stakeholders’ feedback to the TV test 

4 procedure NOPR which was published in January last 

5 year. 

6 Again, for connecting the client, DOE is 

7 proposing to use an HNI connection in the order MoCA 

8 followed by HPNA, WiFi, and then another -- any other 

9 HNI connection. 

10 So at this time, DOE requests comment on the 

11 proposed test configuration which will be used 

12 throughout testing for the on, sleep, and off modes. 

13 DOE especially requests comment on the proposed 

14 connections for the test configuration, which is 

15 connecting to the multiple displays and clients. And 

16 DOE is also requesting comment on the proposed order 

17 for connecting a display device to the set-top box. 

18 MR. BROOKMAN: Adam. 

19 MR. A. GOLDBERG: So, can you go back to the 

20 table? Yeah, so this corresponds to, I think, table 

21 one in the NOPR, right? 

22 MS. THAKKAR: Right. 

23 MR. A. GOLDBERG: So, what happens if the 

24 device doesn’t fall into any of those columns? 

25 MS. THAKKAR: Well, then it falls in the last 

26 row where it’s just connected to one display device. 

27 MR. A. GOLDBERG: Well, I’m thinking of a DVR 

28 that supports one display device and clients -- I don’t 
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1 see where it fits in any row in that table. 

2 MR. DOMMU: Could you repeat that? You said 

3 how many clients would it support? 

4 MR. A. GOLDBERG: It supports one directly 

5 connected TV, not two. 

6 MR. DOMMU: Okay. Then it wouldn’t be an x 

7 in the first row. 

8 MR. A. GOLDBERG: Right. It has a DVR. 

9 MR. DOMMU: Okay. So that’s an x in the 

10 second one. 

11 MR. A. GOLDBERG: And it’s a multiroom 

12 device, so it supports clients. 

13 MR. DOMMU: So an x in the third, so it looks 

14 like the fourth line. 

15 MS. THAKKAR: Row four. 

16 MR. A. GOLDBERG: Which one? 

17 MS. THAKKAR: Row four. 

18 MR. A. GOLDBERG: Oh -- 

19 MR. DOMMU: So you just hook up one display 

20 device and one client. 

21 MR. A. GOLDBERG: Okay. Sorry. Thank you. 

22 MR. BROOKMAN: Gregg. 

23 MR. HARDY: Gregg Hardy. So two comments. 

24 My understanding, reading through the NOPR was that the 

25 intent was to connect to three devices because the 

26 average home has three TVs in it. But then this process 

27 results in DVRs only being connected to two devices, 

28 and that was confusing to me why you would sort of give 
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1 DVRs a break or different treatment from that regard. 

2 MS. THAKKAR: So the intent was to enable 

3 three streams when testing based on the data that there 

4 are three TVs generally in the household. So when you 

5 have DVR, as we’ll see later on in the presentation, 

6 you will have three streams enabled, one of which is 

7 going to a DVR -- 

8 MR. HARDY: Right, and so, just to respond, 

9 I would clearly distinguish between connected devices 

10 and number of streams, and I would define the number of 

11 streams in table two and keep the number of connected 

12 devices consistent in table one to be three across all 

13 product categories. 

14 MS. THAKKAR: Okay. 

15 MR. HARDY: And then my second comment is, it 

16 doesn’t appear to me that we’re defining what a client 

17 is, so a tester could hook up a smart TV or a thin 

18 client set-top box, or any number of other clients, and 

19 iPad, and it might make sense to define exactly what 

20 that client is. In the case of an implementation where 

21 there happens to be a thin client available, I’d 

22 probably recommend it be tested with the thin client 

23 that’s paired with that multiroom system. 

24 MS. THAKKAR: Yeah, you’re right that we 

25 don’t specify the client, but we do specify that the 

26 first connection that is supported by the set-top box 

27 in this list should be selected, so if the set-top box 

28 supports MoCA then the client invariably will be 
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1 something that can hook up to a MoCA connection. 

2 MR. BROOKMAN: Gary. 

3 MR. LANGILLE: Just a comment that -- more a 

4 question. When you say support multiple display 

5 devices, it occurred to me that I assume that you meant 

6 multiple display devices with independent video going 

7 to each one. But we need to put some language around 

8 that to clarify. Lots of devices will have, for 

9 instance, an HDMI and component, either one could be 

10 used to deliver high definition video. You could 

11 actually hook them both up at the same time and have 

12 two displays, but it’s the same video. So we should 

13 just clarify when you say multiple display devices, if 

14 it’s with independent video, or, you know, just some 

15 language. 

16 MR. BROOKMAN: Thank you. Additional 

17 comments? Yes, Gary. 

18 MR. LANGILLE: And one other comment. Dish 

19 Network happens to be one of the -- the only companies 

20 I was aware of that actually supported two directly 

21 connected display devices in the past. Since we’re not 

22 going to be selling -- since discontinued those models, 

23 so I’m not sure if multiple display devices exist any 

24 more. So if they don’t, we might be able to simplify 

25 the table. 

26 MR. DOMMU: Yeah, whether it supports 

27 multiple displays or not, you’re still going to get to 

28 the same answer on that table. 
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1 MR. LANGILLE: Certainly. 

2 MR. BROOKMAN: Jeremy, thank you. Okay. 

3 MS. THAKKAR: Okay. So for calculating the 

4 average power for all the tests that are performed, DOE 

5 is proposing two methods. The first is to record the 

6 accumulated energy consumed over the time period for 

7 each test and calculate the average power as the 

8 accumulated energy divided by the time. This method is 

9 as specified in the CEA standard. 

10 The second method is to calculate the 

11 arithmetic mean of all power samples measured over the 

12 time period for each test. The power consumption 

13 should be sampled at a rate of at least one sample per 

14 second. This second method is not specified in CEA 

15 2043 but DOE is proposing it because it is typical in 

16 laboratory set ups to use this method as well. 

17 So at this time, DOE requests comment on the 

18 two proposed methods to calculate the average power 

19 consumption. 

20 MR. BROOKMAN: Gary. 

21 MR. LANGILLE: Sounds like a reasonable 

22 request. 

23 MR. BROOKMAN: Additional thoughts? No 

24 additional thoughts. Okay. 

25 MS. THAKKAR: Okay. So moving on to the next 

26 section, which is on mode tests. So DOE is proposing 

27 two tests to measure the power consumption of the set28 top box in on mode. The first is an on-watch TV test, 
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1 which records power consumption while viewing SD and HD 

2 channels on the connected display device. The second 

3 test is called the multi-stream test, and it measures 

4 the power consumption of the set-top box when multiple 

5 principal functions, such as viewing the channel, 

6 recording content, and playing back recorded content, 

7 are performed simultaneously. 

8 We’ll discuss the details for each of these 

9 tests in a few minutes. But for both of these on mode 

10 tests, DOE is proposing that the average power 

11 consumption should be recorded over a period of two 

12 minutes. This is because internal testing showed that 

13 the average power consumption is generally stable 

14 within two minutes, and this duration is sufficient to 

15 produce repeatable results. This requirement is not 

16 specified in the CEA standard, but CEA does require 

17 that the entity specifying the use of the standard 

18 should provide the time duration. 

19 To perform the on-watch TV test, DOE is 

20 proposing that the test should be performed according 

21 to the steps listed here. So once the set-top box has 

22 been configured and connected to the display devices 

23 and clients, which we just discussed a few minutes ago, 

24 one SD stream is enabled to view on a single connected 

25 display device. That is, all the other connected 

26 displays and clients should not have any content 

27 streamed to them. The average power consumption should 

28 be recorded for two minutes. 
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1 For HD set-top boxes, the test should be 

2 repeated with an HD stream instead of an SD stream. 

3 So this test has been based off of CEA’s on4 Watch TV test, but there is a key difference. The CEA 

5 standard specifies that HD set-top boxes should be 

6 tested using an HD stream only, whereas DOE is 

7 proposing to test them using both HD and SD streams. 

8 The reason we’re doing this is because DOE does not 

9 expect all content to be available in HD in the future. 

10 That is, it is possible that some content is still 

11 streamed in SD even for boxes that have HD capability. 

12 This requirement, again, is consistent with that 

13 specified in version 3.0 of the EnergyStar 

14 specification. 

15 So to calculate the average power consumption 

16 for HD set-top boxes, DOE proposes that P-watch, which 

17 is the power consumption in on-Watch TV mode should be 

18 calculated as the average of the power consumption when 

19 using SD and HD streams. DOE did consider alternate 

20 weights for calculating P-watch for HD boxes, but it 

21 did not find any data to indicate what would be 

22 representative of consumer usage, or the percentage of 

23 content that would not be available in HD. 

24 So a few requests for comment. First, DOE 

25 requests comment on the proposed method for the on26 Watch TV test. DOE also requests comment on using both 

27 SD and HD streams for testing high definition boxes, 

28 and also the percentage of streams that are available 
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1 in SD and HD for HD set-top boxes and whether the 

2 proposed equation should be changed. 

3 MR. BROOKMAN: Adam. 

4 MR. A. GOLDBERG: I wonder if there was any 

5 testing done or evaluation done on whether power 

6 consumption does vary with an HD box given an SD and an 

7 HD signal. 

8 MR. BROOKMAN: Allen. 

9 MR. TSAO: Yes, Allen with Navigant. We did 

10 conduct some testing and there was -- some boxes had 

11 some difference, and it varied. It was not 

12 significant. Maybe it was less than a watt or so and I 

13 don’t remember the exact values, but there was a 

14 difference you could detect. 

15 MR. A. GOLDBERG: So, okay, without taking 

16 any position, it might be that testing once is 

17 sufficient and doing it twice might yield no additional 

18 value. And then second, was there any consideration of 

19 this case where you’ve got an HD stream, an HD box, and 

20 a SD output -- that is, I have an HD box with an HD 

21 signal connected to an older television. I mean maybe 

22 it’s irrelevant, based on the answer to the first 

23 question I asked, but I mean if we’re worried about 

24 fractions of a watt difference between HD and SD, there 

25 may be some difference in that form as well. I 

26 shouldn’t be suggesting that we cut the testing in half 

27 and at the same time add a third, but maybe I’ll just 

28 forget it all. 
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1 MR. BROOKMAN: Robert. 

2 MR. TURNER: There’s two things I’m not 

3 seeing included. One is the bit rate, so the type of 

4 content. I’ve suggested for my international sports 

5 channel will be chess, because it’s so slow moving. 

6 The other is the quality of the signal which can make 

7 quite a significant difference to the different type of 

8 performance. If you’ve got a poor signal quality, 

9 you’ve got a lot of error correction, and that 

10 increases the power. So the signal quality needs to be 

11 defined. 

12 MR. BROOKMAN: Gary. 

13 MR. LANGILLE: I guess my comment would be to 

14 endorse what Adam’s saying, is that if the difference 

15 through some sample measurement is fairly 

16 insignificant, which we believe it is, then we prefer 

17 just to simplify the test procedure and make the single 

18 measurement. And Robert has some good points, but I’m 

19 not sure how we could possibly address them. 

20 MR. TURNER: 62087 does define minimum signal 

21 strength requirements. And I think if you’re above 

22 those, then error correction things tend to help ease 

23 themselves out. EnergyStar does specify stream content 

24 from a sort of a talking head to sports content. 

25 Again, difficult to quantify exactly but it’s making an 

26 attempt at it. 

27 MR. BROOKMAN: Yes. Noah. 

28 MR. HOROWITZ: Noah Horowitz, NRDC. I think 
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1 that there’s probably consensus to the extent there is 

2 a power difference, HD would consume the same or a 

3 little bit more than SD. But I think many people 

4 believe SD content is decreasing in its percentage of 

5 time being used, and it’s a small difference. So one 

6 option, if you don’t want to change things would be to 

7 simply say, to allow the tester if they want, only test 

8 an HD and have 100 percent to that. If they want to go 

9 to the time to do the SD, they could do that as well, 

10 and if you do do that and if additional analysis shows 

11 there is a big difference, then probably the weighting 

12 of 50:50 is inappropriate. 

13 MR. BROOKMAN: Jennifer. 

14 MS. SANFORD: Quick question on multi-stream. 

15 Would that include picture in picture? 

16 MS. THAKKAR: No. 

17 MR. BROOKMAN: Allen. 

18 MR. TSAO: You can interpret the language as 

19 -- I don’t think it would include picture in picture 

20 based on the way the language is written. If you think 

21 it’s unclear, just put in a comment on that. 

22 MR. BROOKMAN: Robert. 

23 MR. TURNER: The other thing is when you talk 

24 about high definition, what do you mean? 1080p, 1080i? 

25 MR. BROOKMAN: Additional comments on this 

26 section? I’m going to propose we pause for lunch. 

27 It’s now almost 12:15. We’ve made very good progress 

28 this morning, covered a lot of ground. More to cover 
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1 as we return from lunch, we will return and start at 

2 1:15. 

3 Once again let me remind you, please wear 

4 this badge visible while you’re walking around the 

5 Forrestall building. For those of you that are new to 

6 the facility, you can go down to the ground floor go 

7 about 100 yards that way and then up two escalators and 

8 you’re in our rather large cafeteria. That’s the best 

9 place to eat around here. Don’t leave campus. This 

10 room will be locked. You can leave your stuff, it’ll 

11 be supervised, and see what else. You know where the 

12 restrooms are. You might need an ID to get back 

13 through the security portal. You can leave the rest of 

14 your stuff here, enjoy lunch. See you back here about 

15 1:15. 

16 (Whereupon, at 12:15 p.m., the meeting in 

17 the above captioned matter was adjourned for lunch 

18 recess, to reconvene at 1:15 p.m.) 

19 
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1 AFTERNOON SESSION

2 1:37 p.m. 

3 MR. BROOKMAN: Welcome back. Let’s resume. 

4 Before we broke for lunch, I neglected to recognize 

5 Ken Rider who’s joining us via the web. Ken, are you 

6 there? 

7 MR. RIDER: Here. 

8 MR. BROOKMAN: I’m sorry to leave you off. 

9 Do you wish to jump back in where we left off 

10 previously? 

11 MR. RIDER: I mean I’m following along the 

12 presentation on my -- I didn’t have any comments or 

13 anything. 

14 MR. BROOKMAN: Oh, okay. The moderator, the 

15 web master handed me a note suggesting you had a 

16 question or a comment. 

17 MR. RIDER: Not at this time. Thank you, 

18 though. 

19 MR. BROOKMAN: Okay. Thank you. So now 

20 we’re going to proceed where we left off with Mansi. 

21 MS. THAKKAR: Okay. Thanks, Doug. So, this 

22 is the second test for on mode and it’s called the 

23 multi-stream test. The multi-stream test has three 

24 steps as can be seen in these blue boxes on the left. 

25 The first step is to select the number of streams that 
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1 will be enabled to display devices and clients based on 

2 the priority listed in the table shown here. The 

3 second step, after the number of streams are selected, 

4 is to select the content that is streamed on each of 

5 the streams. And finally, once we have the number of 

6 streams and the content for each stream, the third step 

7 is to perform the test. 

8 So for the first step, which is to select the 

9 number of streams, the set-top box at this point will 

10 already be connected to the display devices and clients 

11 based on the configuration table we saw earlier. So 

12 once these connections are made, we need to select the 

13 number of streams and prioritize the selection. These 

14 are selected -- by using this table. So what this 

15 table says is that the highest priority that is 

16 supported by the set-top box for the connections that 

17 have been made must be selected for streaming content 

18 to output to a display device, record on a DVR, or 

19 stream to a client. So if the set-top box can stream 

20 to a display device, a DVR and a client, then priority 

21 one must be used and one stream should be enabled to 

22 each. 

23 So using the same example that we saw before. 

24 This is the set-top box that can be connected to 

25 multiple display devices and clients, and it has a DVR. 

26 So according to the multi-streaming table, this set-top 

27 box meets the requirement for priority one, and so to 

28 test it, I need to enable one stream to a display 
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1 device, one stream to record on a DVR, and one stream 

2 to a connected client. Do you have a question? 

3 PARTICIPANT: I’ll wait until the question 

4 period. 

5 MS. THAKKAR: Okay. So this is the second 

6 example that we’ve seen earlier. This is a set-top box 

7 that does not support DVR, but it does support 

8 connections to multiple displays and clients. This 

9 set-top box meets the requirement that’s listed in 

10 priority three in the table, which requires two streams 

11 to be enabled to display devices, and one stream 

12 enabled to a client. 

13 So the second step to perform the test, once 

14 we know the number of streams being enabled, is to 

15 select the content that will be streamed on each of 

16 these streams. For the content, DOE proposes that the 

17 content should be selected to output to a display 

18 device, record on a DVR, or streamed to a connected 

19 client. So to output to a display device, DOE’s 

20 proposed method is adopted from CEA on-Watch TV test. 

21 DOE proposes to select an SD stream for SD set-top 

22 boxes and HD stream for HD set-top boxes, and view the 

23 stream on the connected display device. That is, for 

24 the multi-stream test, HD set-top boxes are tested 

25 using an HD stream only, unlike the on-Watch TV test. 

26 Additionally, DOE is proposing when there is more than 

27 one display device that is connected, such as in the 

28 second example we saw, then the content stream to each 
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1 display should be different. This requirement is in 

2 addition to that specified in the CEA standard. 

3 Next, to record on the DVR, DOE’s proposed 

4 method is adopted from CEA’s on-Record Test. DOE 

5 proposes that a channel should be selected using the 

6 connected display device or client, and the program 

7 should be recorded. In addition, again DOE proposes 

8 that if more than one recording stream is enabled, then 

9 the content being recorded on each should be different. 

10 Finally, to stream content to a connected 

11 client, DOE proposes that the first priority should be 

12 to stream content that has been recorded previously, 

13 that it’s playing back recorded content. The second 

14 priority is to stream a channel. And finally, if the 

15 other two methods are not feasible, then any other 

16 streaming option should be selected. DOE selected this 

17 hierarchy to ensure consistency and repeatability 

18 between tests. 

19 DOE expects that the power consumption will 

20 be more when playing back content, because the hard 

21 disk would be engaged than when viewing a channel. 

22 For the first stream which requires playing 

23 back content, DOE’s proposed method is adopted from the 

24 on-Play test of the CEA standard. DOE proposes that a 

25 previously recorded program should be selected and 

26 viewed on a display device connected to the client. If 

27 the client does not support streaming of recorded 

28 content, then a channel should be streamed and viewed 
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1 on the connected display device. Again, this method is 

2 adopted from the on-Watch TV test. As with streaming 

3 to a display and recording on a DVR, DOE proposes that 

4 if more than one stream is enabled to a client, then 

5 the content on each stream should be different. 

6 Going back to the same two examples. This is 

7 the example that one stream is enabled to a display 

8 device, one to record to a DVR, and one to a client. 

9 So based on the proposed requirement for selecting 

10 content, in this case, one channel will be viewed on 

11 the display device connected to the set-top box. A 

12 different stream will be used to record content to the 

13 DVR. And, finally, a third stream will be used to 

14 playback content on the connected client. 

15 In the second example, which can stream to 

16 only two display devices and a client, two different 

17 channels should be selected and viewed on the two 

18 display devices. For the client, the first option is 

19 to playback content, but given the set-top box does not 

20 support DVR, we cannot play back content, and therefore 

21 we select the second option, which is to view a 

22 channel. Again, this channel should be different than 

23 the channel that is being viewed on the two display 

24 devices. 

25 So at this time, DOE requests comment on the 

26 proposed requirements for streaming content to a 

27 display device, recording content on a DVR, and 

28 streaming content to a client. Specifically, DOE 
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1 requests comment on its proposed hierarchy for 

2 streaming content to a client which is playing back 

3 previously recorded content or by viewing a channel. 

4 MR. BROOKMAN: Adam. 

5 MR. A. GOLDBERG: So let me see if I 

6 understand the way table two works. The highest 

7 priority selection, number one in the table, has a one 

8 for display devices, one for recording on DVR, one for 

9 connect to client. So if the device that we’re trying 

10 to test is a DVR that can record zero, one, or two 

11 programs at a time, and stream -- and output content to 

12 zero, one, or two devices, the way you would set that 

13 up would be to record one thing and play back one thing 

14 off disk to a local device, plus one thing off disk a 

15 remote device, right? 

16 MS. THAKKAR: Well, to the display device 

17 would be a channel. 

18 MR. A. GOLDBERG: So look, it says one, one, 

19 one. Right? 

20 MS. THAKKAR: Correct. 

21 MR. A. GOLDBERG: The first one is to a 

22 display device, okay, so that’s playback off the DVR. 

23 No? 

24 MS. THAKKAR: No, it’s a live channel. 

25 MR. A. GOLDBERG: Oh, sorry. I thought there 

26 was a preference to not -- to record a content and not 

27 tune content. 

28 MS. THAKKAR: The preference is only when 
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1 you’re streaming to the client. So when it’s streaming 

2 to a client, then you playback content. 

3 MR. A. GOLDBERG: So the first -- so to -- so 

4 going to a display device that’s got to be live content 

5 unless that’s not possible, right? 

6 MS. THAKKAR: Right. 

7 MR. A. GOLDBERG: And recording on the DVR, 

8 that’s recording a live content, but it’s got to be 

9 different content. 

10 MS. THAKKAR: Right. 

11 MR. A. GOLDBERG: Okay. And then what’s sent 

12 to a remote client is not live content, it’s got to be 

13 DVR. 

14 MR. A. GOLDBERG: I’m not sure I understand 

15 the justification for why the local device would be 

16 treated differently than the connected device. 

17 MS. THAKKAR: The goal was to engage all the 

18 different functionalities, so when you’re connecting a 

19 display device directly to the set-top box, you’ll be 

20 viewing a live channel, and when it’s streaming to a 

21 client, through a display device, you’re viewing 

22 playback, and that way you’re engaging the different 

23 functionalities that the set-top box can perform. 

24 MR. BROOKMAN: We have an additional comment 

25 from Allen. 

26 MR. TSAO: So, the reason is that with the 

27 multirooms, a lot of different options out there, and 

28 one of the common ones is that there are clients that 
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1 can just access the recorded content, but not the live 

2 content, so there’s thin clients out there that can 

3 access the content on the DVR, but not necessarily 

4 access the live content. And so at this point we 

5 thought the common case was that for the clients was to 

6 access recorded. 

7 MR. A. GOLDBERG: So without pointing 

8 fingers, really? 

9 MR. TSAO: The intention is that there are 

10 thin clients that are able to access recorded -- 

11 content that’s recorded on a DVR, but not live content. 

12 MR. A. GOLDBERG: I think we’re all looking 

13 surprised. 

14 MR. BROOKMAN: So can you describe how you 

15 make this so you’re not surprised? 

16 MR. A. GOLDBERG: Well, I expected you say, 

17 well, we believe that playing back off of a hard drive 

18 takes more power than tuning, and that you would -- 

19 that in this first round here, you would say playback 

20 one recorded piece of content to the local display, 

21 playback one recorded piece of content to a connected 

22 client, and record something out there. That would 

23 give you one tuner in use, one recorded stream and two 

24 playback streams, right? 

25 MR. A. GOLDBERG: But it seems like you’ve 

26 got different selection criteria for each of the 

27 columns, so display device should be live, but the 

28 client device should be recorded. 
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1 MR. BROOKMAN: And if you did it that way, 

2 would that engage, as Mansi was saying, the different 

3 potential modalities? Would it satisfy what they were 

4 trying to do here, which is to get -- to be able to 

5 demonstrate each case. 

6 MR. A. GOLDBERG: Yeah, I don’t think it’s 

7 possible to demonstrate each case. 

8 MR. BROOKMAN: Charles. 

9 MR. STEPHENS: Yeah, I think I understand 

10 what they want here and I think I approve of it. I’ll 

11 have to think about this more, but we do want to know 

12 how much power is used in the playback mode. I think, 

13 Adam, as you were proposing it, we wouldn’t know -- we 

14 would never measure that. 

15 MR. A. GOLDBERG: Well, to be clear, I wasn’t 

16 proposing anything, I’m just trying to understand what 

17 was written. 

18 MR. STEPHENS: With this lineup we get how 

19 much power is used when it’s not -- when it’s tuning 

20 and playing to a display device. We get how much it’s 

21 using when it’s recording a channel with another tuner. 

22 And we get how much it uses when it plays back to 

23 anything -- when it plays back to a client. 

24 Later, when I tried to understand in my 

25 position, how much energy is being used every day, or 

26 every week, or every year with this thing, I may have 

27 to figure out what fraction of the time it’s playing a 

28 channel, what fraction of the time it’s recording, and 
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1 what fraction of the time it’s playing back. But I 

2 wouldn’t even bother with any of that unless I knew 

3 what the power consumption was in each of those three 

4 modes. 

5 MR. A. GOLDBERG: But the way this is set up 

6 is for a multi-stream device. You’ll end up with one 

7 power number which is based on the sum of -- you know, 

8 the power consumption for a device which is recording 

9 one, watching one live and playing one back from disk. 

10 You’re not going to be able to know what the 

11 consumption is for playback. 

12 MR. STEPHENS: Except that, I think, to my 

13 comfort, I would probably assume that the power I would 

14 expect to be used by that device would generally be at 

15 that level or less than that. But I don’t know if it 

16 would be more than that, so in other words, I will end 

17 up with what a maximum power consumption would be, but 

18 it could be less than that. 

19 MR. BROOKMAN: Several individuals would like 

20 to speak. Jeremy, we’ll start with you. 

21 MR. DOMMU: Yeah, I just want to clarify what 

22 this test entails. So this is a single test, and in 

23 this single test we’re doing multiple things at once. 

24 We’re recording the energy consumption of that device. 

25 So for priority one, we are playing back content and 

26 displaying it on the client. We are recording content 

27 through the DVR. And we also are outputting live TV to 

28 a display. All those things are happening 
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1 simultaneously, and while those things are happening we 

2 are recording the power. 

3 MR. BROOKMAN: Robert. 

4 MR. TURNER: Just a comment, when you’re 

5 talking about power in playback versus watching live 

6 TV, when you’re watching live TV, every application I 

7 know records at the same time because you’ve got live 

8 pause, so you’re recording content to disk and 

9 potentially erasing it afterwards, so your playback 

10 will be a lower figure than -- because you don’t need 

11 the tuners. 

12 MR. BROOKMAN: Gary. 

13 MR. LANGILLE: I just wanted to comment that 

14 I think there’s a couple of approaches to measure this 

15 category, and I know in the CEA standard, we took the 

16 approach of just measuring each mode, you know, like 

17 how much in watching, how much recording, and how much 

18 playing. Now, the advantage to that is that -- one 

19 reason we did that is because that’s what I think EPA 

20 duty cycles were, how the program was run, so we wanted 

21 to make sure we supported that. But the disadvantage 

22 to that is you’re not testing it with multiple 

23 activities all at the same time. So I think what DOE 

24 is introducing is, as a substitute for measuring the 

25 modes, they are proposing that we measure a device 

26 doing multiple things at the same time, you know, 

27 recording, playing, tuning, it’s all happening. Which 

28 I think is valid. My only question would be is does 
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1 that support everyone’s need? Because like Charlie, 

2 you said, you won’t know the modal information the way 

3 this is set up right now. You will know what I think 

4 DOE is assuming is a more typical use of one of these 

5 devices, which is to do multiple things at the same 

6 time. Which is how they’re usually used. 

7 MR. BROOKMAN: Go ahead, Charlie. 

8 MR. STEPHENS: Yeah, to follow up on that, as 

9 was pointed out by Robert, I think the only worse case 

10 would be if everything was playback or recording. In 

11 other words, you’re playing back and the DVR is -- in 

12 other words, you’ve got three tuners going. So if you 

13 had three tuners going and the way I see it here, the 

14 way they’re prioritized, there’s only two. Right? 

15 We’re recording one and we’re playing one. 

16 MR. A. GOLDBERG: Or one if you can bring in 

17 more than one channel on one tuner. 

18 MR. STEPHENS: Okay. But in any case, can 

19 you bring in three on one tuner? And if you can, well, 

20 that’s great. But I guess what I’m saying is, if on 

21 average the situation out there for me, trying to 

22 understand the energy use of this thing over an hour or 

23 over a day, this represents a kind of a average family 

24 household case, then somebody on one television is 

25 watching one thing, but there’s something being 

26 recorded because somebody wants that recorded during 

27 that hour, and you’ve got somebody in a bedroom 

28 watching something on a client. Well, you know, that 
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1 tells me kind of what the average use of this thing 

2 might be during a certain period of a day, and that’s 

3 kind of what ultimately I want to get to, is how much 

4 is this thing, on average using during a certain period 

5 of the day when it’s in use. 

6 So I don’t know. I think it may -- I could 

7 go with any number of modifications, but I understand 

8 this and I think it might be useful. 

9 MR. BROOKMAN: Gary. 

10 MR. LANGILLE: So then I think this is 

11 generally acceptable. I mean, it’s just a different 

12 way of measuring, of kind of getting at the same 

13 result. But the one question would be then to EPA and 

14 the EnergyStar program is historically you’ve required 

15 a test procedure that measured each mode so then you 

16 could then multiply by duty cycling and get the 

17 results. So the question would be, can you -- with 

18 this -- so for the next version of EnergyStar, you 

19 wouldn’t be able to have modes. You’d have so many 

20 hours in this mode, basically. 

21 MR. BROOKMAN: Please say your name. 

22 MS. KAPLAN: Katherine Kaplan from EPA’s 

23 EnergyStar program, and we’ll align with DOE’s test 

24 procedure. 

25 MR. BROOKMAN: Thank you. Paul. 

26 MR. GLIST: I was only going to observe that 

27 for what Mr. Stephens is looking for, this may not 

28 capture it because there are different uses of second 
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1 and third televisions in the home than there are for 

2 the primary television, and this is working on the 

3 assumption, I believe, that they’re all running all the 

4 time on whatever hours you want to assign to the 

5 metric. And so if you’re actually trying to capture a 

6 metric that is more realistic than that, I’m not 

7 certain that this meets your need. 

8 MR. BROOKMAN: Okay. Thank you. Yes, 

9 Jeremy. 

10 MR. DOMMU: Just one comment on that. I mean 

11 -- I think we could all recognize that based on the 

12 functionality of a set-top box you could be performing 

13 thousands of different iterations of either playing or 

14 recording or streaming to a thin client. So really the 

15 purpose of this test is just to have one single test 

16 that reduces testing burden and best represents the 

17 energy consumption of the set-top box. 

18 MR. BROOKMAN: Gregg. 

19 MR. HARDY: Gregg Hardy. It also, I don’t 

20 think, assumes that these other TVs are running all the 

21 time. It assumes that they’re running during the five 

22 hours that are allocated to multi-streaming in the DOE 

23 duty cycle. 

24 The other thing I would say is I think that 

25 there are possibly some -- there are clients out there 

26 that look to the server for recorded content, to get 

27 live streams from the head end. I think those are the 

28 cable hybrid clients and maybe that’s why the DVR 
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1 assumption, you know, you assume that you would stream 

2 by hard drive to the -- that’s probably that cable 

3 hybrid client. 

4 MR. BROOKMAN: Okay. We’re about to move on. 

5 Final comments here? Okay. 

6 MR. A. GOLDBERG: Just one last thing. 

7 MR. BROOKMAN: Adam. 

8 MR. A. GOLDBERG: Thank you. This table of 

9 nine things in table two, it’s for a device that can do 

10 the one-one-and one? That’s the test you do and the 

11 rest of the tables are all ... right? 

12 MR. DOMMU: Right. 

13 MR. BROOKMAN: All right. Mansi. 

14 MS. THAKKAR: Okay. So the final step for 

15 the multi-stream test after determining the number of 

16 streams and the content for each stream is to perform 

17 the test. So to perform the test, enable the streams 

18 that are feasible based on the connections and the 

19 priority, and then record the average power consumption 

20 for two minutes. 

21 Comparing DOE’s multi-stream test to the CEA 

22 standard, we already touched on this a little bit, but 

23 DOE does not exclusively specify -- excuse me -- CEA 

24 does not explicitly specify a multi-stream test, but it 

25 does contain most of the information that DOE has 

26 combined for the multi-stream test. The CEA standard 

27 specifies individual tests for recording, playing back, 

28 and viewing a channel. It also provides 
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1 recommendations for concurrent testing of network set2 top boxes and the different tests that may be performed 

3 on different set-top boxes. 

4 Finally, CEA states that the entity requiring 

5 the use of the standard must provide the specific 

6 information about the configuration and the tests to be 

7 performed. 

8 So at this time DOE requests any further 

9 comment on the multistream test and the priority in 

10 table two that we saw a little while ago. 

11 MR. BROOKMAN: Additional comments? We’ve 

12 covered it. 

13 MS. THAKKAR: Okay. So the multistream test 

14 that DOE is proposing will enable a maximum of three 

15 streams at any given time. DOE proposed this based on 

16 data published by the Nielsen Company in January 2011 

17 which states that the average number of TVs per US 

18 household is 2.5. DOE rounded this value to three TVs 

19 per household and assumed that a set-top box may 

20 perform up to three functions at a time. 

21 At this time, DOE requests comment about 

22 whether it is reasonable to enable three streams for 

23 the multistream test, or whether a different number of 

24 streams should be enabled. 

25 MR. BROOKMAN: Comments on that? No comment. 

26 We also in this room accept affirmation. 

27 MS. SANFORD: This is Jen Sanford with Cisco. 

28 We’ll be providing you some written comments on that. 
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1 We’re not sure it matters. 

2 MR. BROOKMAN: Gary. 

3 MR. LANGILLE: Yeah, I look forward to 

4 Jennifer’s comments, but I mean it seems reasonable. 

5 MS. THAKKAR: Okay. Thank you. So DOE 

6 recognizes that there may be set-top boxes that are 

7 capable of streaming more than three streams at a time. 

8 DOE considered implementing a maximum power test. We 

9 have not proposed this in the NOPR. 

10 A maximum power test would test the set-top 

11 box at maximum functionality, that is in this test as 

12 many streams as supported by the set-top box would be 

13 enabled and would provide content to clients, display 

14 devices and DVR. Again, DOE has not proposed this test 

15 in the NOPR, but is requesting feedback on the 

16 possibility of including such a test at this time. 

17 MR. BROOKMAN: Gary. 

18 MR. LANGILLE: It’s our opinion that going 

19 into some kind of maximum configuration wouldn’t really 

20 change the results much. The drive may be accessing a 

21 little faster, but the fact that all the major 

22 subsystems are now active captures the majority of all 

23 power consumed, so I don’t see a need for it beyond 

24 what you have. 

25 MR. BROOKMAN: Additional thoughts? I see a 

26 few heads nodding. Robert. 

27 MR. TURNER: Depends on what you mean by 

28 maximum power test. This already requires pretty much 
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1 maximum power on the product, which includes any 

2 peripherals attached. So worst case, in operation plus 

3 worst case peripherals. You’re going to be 10, 20, 30 

4 watts below that in some cases. So it’s not a valued 

5 number. It’s more the size of the power cable than 

6 anything else. The test you’ve got is reasonable. 

7 MR. BROOKMAN: Charlie Stephens. 

8 MR. STEPHENS: Charlie Stephens. I guess 

9 unless I had some data that showed me what fraction of 

10 the time in the course of a year these things actually 

11 operated in that mode, I’m not sure I could comment on 

12 whether it would be useful. But the real answer, if I 

13 find out that the answer is it almost never operates in 

14 that mode, I don’t know why we’d bother to measure it. 

15 MR. BROOKMAN: Okay. Moving on. 

16 MS. THAKKAR: Okay. So before we leave the 

17 on mode test, one last opportunity to provide comment 

18 on anything that we may not have discussed already, 

19 including the two minute time period for the test 

20 itself. 

21 MR. BROOKMAN: No additional comments? 

22 MS. THAKKAR: So moving on to the test 

23 procedures in sleep mode. DOE is proposing to have two 

24 tests for testing in sleep mode only for those set-top 

25 boxes that support the sleep mode capability and can 

26 transition from sleep to on mode within 30 seconds. 

27 The two tests are a manual sleep test in 

28 which the set-top box enters sleep mode manually, 
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1 through a remote, and an auto power down test, or APD 

2 test, in which the set-top box enters sleep mode 

3 automatically after a period of user inaction. 

4 DOE is proposing the time period for each 

5 test in sleep mode should be between four to eight 

6 hours. DOE expects that this time duration will 

7 capture the reduced power consumption states such as 

8 deep sleep or special sleep modes as the set-top box 

9 powers down gradually over time. The proposed time 

10 duration is also approximately the half to full 

11 duration of an overnight time period. 

12 Again, similar to the on mode tests, the 

13 proposed time duration is not specified in the CEA 

14 standard, but it does require that the entities 

15 specifying the use of the standard should provide the 

16 time duration. 

17 At this time, DOE requests comment on the 

18 proposed duration for the sleep mode test and whether 

19 this duration should be increased or decreased to 

20 better represent the set-top box power consumption in 

21 sleep modes. 

22 MR. BROOKMAN: Yes, Noah. 

23 MR. HOROWITZ: Noah Horowitz, NRDC. We agree 

24 it shouldn’t be instantaneous measurement, but should 

25 be an average over a certain period of time, and four 

26 hours seems reasonable. 

27 One thing we need to think about is potential 

28 gaming of the system. So let’s say the manufacturer or 
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1 service provider might say between one and five in the 

2 morning, you go to a very deep sleep and if it’s 

3 between one and five, at 4:55 you ramp back up and you 

4 get a very good test reading, even though that’s not 

5 representative of what happens over the whole day. So 

6 maybe the test needs to be done between normal viewing 

7 hours, between eight in the morning and eight in the 

8 afternoon or something like that. Or there could be a 

9 caveat in terms of verification testing, the test could 

10 be done at any time of the day and you need to get the 

11 same answer. Thank you. 

12 MR. BROOKMAN: Okay. Thank you. Yes. Your 

13 name, please. 

14 MR. JOSEPH: Kuriacose Joseph of DirecTV. 

15 It’s a question for clarification. So if a set-top box 

16 has a sleep mode and doesn’t recover within 30 seconds, 

17 we will not measure a sleep mode for that set-top box, 

18 is that the proposal? 

19 MS. THAKKAR: Right. 

20 MR. JOSEPH: Okay. That’s -- 

21 MS. THAKKAR: So the set-top box has to meet 

22 the sleep mode definition to perform the sleep mode 

23 tests. 

24 MR. JOSEPH: Yes, so essentially, even if the 

25 box is capable of saving power in the house, we are 

26 saying we are not going to count that measurement? 

27 Right? 

28 MR. BROOKMAN: If it doesn’t qualify. 
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1 MR. JOSEPH: If it doesn’t qualify, even 

2 though it’s low power box. It seems to be an issue 

3 with the method. 

4 MR. BROOKMAN: Okay. Yes, Adam first. 

5 MR. A. GOLDBERG: So, just to be clear. In 

6 order for there to be H sleep manual, a non-zero value, 

7 it’s got to transition from that sleep mode to on in 

8 less than 30 seconds, and the same sort of test for H 

9 sleep APD, right? 

10 MS. THAKKAR: Yes. 

11 MR. A. GOLDBERG: So if a box takes 35 

12 seconds to go from sleep to not sleep, then the 

13 measurements, I think, are what, 24 hours on, right? 

14 MS. THAKKAR: Right. 

15 MR. A. GOLDBERG: Which doesn’t seem to be 

16 accommodated in table three. 

17 MR. DOMMU: I’m not sure -- 

18 MS. THAKKAR: Is that table three in the 

19 NOPR? 

20 MR. A. GOLDBERG: Yes. 

21 MS. THAKKAR: I believe those are EnergyStar 

22 rated. 

23 MR. A. GOLDBERG: Well, I don’t know, what 

24 I’m saying is there’s no entry in table three that has 

25 sleep set to zero. 

26 MR. DOMMU: No, the way it works is this. 

27 Our definition of sleep has that requirement that it 

28 must transition from sleep to on within 30 seconds, 
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1 otherwise it’s not considered sleep. It’s not 

2 considered sleep, there’s no point of doing the sleep 

3 tests. And the test procedure you would set, the power 

4 in sleep mode, equal to the power in on on those tests. 

5 So therefore, when you do those calculations with the 

6 AEC at the end, you would just substitute the on mode 

7 power consumption for those points where it requires a 

8 sleep mode power consumption. 

9 MR. BROOKMAN: Noah. 

10 MR. HOROWITZ: Noah with NRDC. A point 

11 raised earlier this morning, the transition to on mode. 

12 Does DOE have a proposed definition of what the box 

13 needs to be able to do to be considered on? Is it 

14 simply changing a channel? Is it accessing an updated 

15 program guide? I’m curious what your definition would 

16 be. 

17 MR. BROOKMAN: Allen. 

18 MR. TSAO: So we have -- at the end we’ll 

19 cover the verification test for the sleep to on mode 

20 transition, but it basically follows CEA 2043. I 

21 believe it is just viewing. 

22 MS. THAKKAR: Viewing a channel. 

23 MR. TSAO: I think that’s what the CEA 2043. 

24 MS. THAKKAR: Ensure it’s on when you can 

25 start viewing a channel. 

26 MR. HOROWITZ: So if it was the last channel 

27 selected, that’s different than if I get 438 and 72, 

28 I’m going to get the right channel, versus if there is 
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1 recorded content on the DVR, can I see the DVR menu? 

2 Hopefully it’s all of those, but it’s unclear to me. 

3 MR. BROOKMAN: Gary. 

4 MR. LANGILLE: I guess my only comment would 

5 be that we’ll try to provide some comments to this and 

6 the 30 seconds -- I think that we’re wrapped up in the 

7 30 second limit, and I haven’t figured it out yet, but 

8 I’m hoping some way we can accommodate both making 

9 these measurements, even if it takes longer than 30 

10 seconds, and then also somehow maybe during the -- 

11 later in the document or during a rating 30 seconds 

12 becomes some limit or something. I think -- I mean, 

13 like Adam said, if it takes 35 seconds, you could save 

14 an awful lot of energy if we allowed that to happen, 

15 even if a bunch of customers didn’t like it and turned 

16 it off, it’s still going to be that whole bunch that 

17 keep it on. So it could result in substantial energy 

18 savings. 

19 MR. BROOKMAN: Jeremy. 

20 MR. LANGILLE: I just hate to see a hard 

21 cutoff. 

22 MR. DOMMU: And I think that’s a good 

23 comment. We definitely encourage you to provide those 

24 comments or suggestions to us, and we’ll take them 

25 under consideration for sure. 

26 MR. BROOKMAN: Other comments before we move 

27 on? Okay. 

28 MS. THAKKAR: Okay. So to perform the sleep 
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1 mode test, first certain conditions need to be ensured 

2 while the set-top box is in the sleep mode. The first 

3 condition is that no recording events must be scheduled 

4 over the entire duration of the test. This requirement 

5 is slightly different from the CEA standard which 

6 specifies that no recording events should be scheduled 

7 while the set-top box is in the sleep mode. DOE is 

8 proposing that no events are scheduled over the entire 

9 duration, which will also include the time spent in on 

10 mode prior to transitioning to sleep mode, to ensure 

11 that the set-top box can transition to sleep mode when 

12 it has to do so. 

13 The second requirement that DOE is proposing 

14 is that if a recording can be scheduled, then it must 

15 be done 24 or more hours in the future. Again, this is 

16 a requirement specified in addition to that provided in 

17 the CEA standard. 

18 At this time, DOE requests comment on the 

19 proposed scheduled recording requirements. 

20 MR. BROOKMAN: Gary. 

21 MR. LANGILLE: Seems reasonable. 

22 MR. BROOKMAN: Okay. Thank you. Adam. 

23 MR. A. GOLDBERG: That’s the scheduled 

24 recording events. It doesn’t say anything about 

25 whether recording unscheduled events, right? 

26 MS. THAKKAR: So no recording should be 

27 scheduled for when the test is being performed. And a 

28 recording should be scheduled 24 or more hours in the 
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1 future. 

2 MR. A. GOLDBERG: Okay. Again, without 

3 respect to whether actual recording is happening? 

4 MS. THAKKAR: Yeah, at this time it’s not 

5 clear if a recording is already occurring. Is that 

6 your -- 

7 MR. A. GOLDBERG: Well, I’m saying, there are 

8 boxes that are always recording. 

9 MS. THAKKAR: Okay. 

10 MR. BROOKMAN: Gregg. 

11 MR. HARDY: This is Gregg. I think a 

12 clarification might be needed. These are sort of user13 programmed scheduling, as opposed to, you know, TiVo -- 

14 MR. A. GOLDBERG: That is what I expected 

15 someone to say. 

16 MR. HARDY: So maybe we can clarify by just 

17 saying scheduled recording or something like that. 

18 MR. BROOKMAN: Okay. Other thoughts on this 

19 subject? Yes, Noah. 

20 MR. HOROWITZ: I guess a global question is 

21 to the extent manufacturers have what’s called a 

22 speculative recording where it’s always recording even 

23 though the user might not ask for a particular show. 

24 How is that handled throughout the whole test method in 

25 terms of setup conditions and whether that’s considered 

26 a scheduled event or not, and how that plays into the 

27 TEC calculation. 

28 MR. BROOKMAN: Jennifer. 
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1 MS. SANFORD: I’d like to echo that comment 

2 because we’ve had a lot of questions from our engineers 

3 about buffering, and, you know, so-called live content 

4 that’s coming in, actually is getting recorded so that 

5 people can pause and rewind, and things -- is that 

6 considered recording? Is that live? What is that? So 

7 clarity around that question would be helpful. 

8 MS. THAKKAR: Right, and we can definitely 

9 provide that. 

10 MR. DOMMU: And I would put it back on you 

11 guys because it is relatively unclear in the NOPR. I 

12 think we’d agree, and if you have recommendations for 

13 how that should be handled, we’d very much appreciate 

14 that. 

15 MR. BROOKMAN: Gregg first. 

16 MR. HARDY: This is Gregg. I would just add 

17 that I think the test procedure actually works fairly 

18 well the way it is, which is that if you’re doing 

19 speculative recording after someone has powered the box 

20 down or it’s auto powerdown, you sort of, you know, 

21 your resulting power level is your resulting power 

22 level, which would be higher if you’re doing that. 

23 MR. BROOKMAN: Adam. 

24 MR. A. GOLDBERG: Just to make it clear, 

25 there’s often -- there’s a box maybe not recording, it 

26 may be just always recording, or it may find shows that 

27 it thinks you might want to watch and record those when 

28 they’re on and not record anything when they’re not, 
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1 which I think is what you mean when you say it’s 

2 speculative recording, I think. But -- whatever. I 

3 think that the way it’s written is clear enough that 

4 the box is doing what the box is doing, measure the 

5 power and move on, right. 

6 MR. BROOKMAN: Yes, Noah. 

7 MR. HOROWITZ: A minor quick comment. So 

8 that’s speculative -- generic term, speculative 

9 recording, that could probably be disabled during set 

10 up and is that allowed to be done? That’s the sort of 

11 clarification we’re looking for. 

12 MR. BROOKMAN: Can we just say what 

13 speculative recording is, just so we’re clear. Yes. 

14 MR. HARDY: Well, I think Adam stated it, 

15 which is when you -- if you have a show that you are 

16 watching regularly, it will automatically record that 

17 show. You’ll get unrepeatable results. The results 

18 will vary depending on your viewing pattern, so it’s 

19 actually an issue to just let the process play out and 

20 if a speculative recording happens, then it happens. 

21 So I think that’s something that needs careful 

22 consideration. If you’ve got some recommendations on 

23 how to get repeatable results and test results that 

24 mirror sort of the average consumption that people 

25 would normally see. That’s tricky. 

26 MR. A. GOLDBERG: I think that what you’re 

27 calling speculative we might think about in terms like 

28 a user agent or something -- user agent initiated 
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1 recording. Different from just always recording. I 

2 think you can do things where you’re always recording 

3 and sometimes what you’re recording is what it thinks 

4 you’re going to watch. Or you do things where if it 

5 thinks there’s something you’re going to watch and 

6 record it, otherwise not record it. 

7 I’m not aware of devices doing that, though. 

8 I mean they’re either recording always, I think, or 

9 only recording when something is manually scheduled. 

10 But maybe I could -- maybe in comments I’ll have some 

11 recommendation on that. 

12 MR. DOMMU: In a moment Mansi is going to 

13 speak about this requirement that there’s no network 

14 initiated activities that are occurring during the 

15 sleep mode test, and it’s potential that this issue of 

16 recordings of the non-user initiated recordings could 

17 be kind of covered and related to that, so that might 

18 help to form the conversation as well. 

19 MR. BROOKMAN: Gary. 

20 MR. LANGILLE: Speculative recording may be 

21 covered an if by the current language, because it does 

22 say that you must assure that there’s no recording 

23 events scheduled to occur during the test. Now, with 

24 speculative recording, it usually will continuously 

25 search what program’s going to be on, and when it sees 

26 one that it thinks you’re going to like it sets a 

27 recording for it. So if the user has -- or the tester 

28 has a way to see -- just check, you know, are there any 
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1 speculative recordings going to occur during the test 

2 and verify that there aren’t, then things could be 

3 okay. But if they don’t have access to that 

4 information and it just kind of happens, then I don’t 

5 see how they could accommodate it. So we’ll have to 

6 think through comments and some more discussion maybe, 

7 figure that out. 

8 MR. BROOKMAN: Okay. Any additional 

9 contributions at this point? Robert. 

10 MR. TURNER: I think that’s why you’re going 

11 to get a difference between testing at a manufacturer’s 

12 site and testing in the real world. The manufacturer’s 

13 site you won’t have speculative recordings because 

14 there’s no history to go on. In the real world, the 

15 viewer has built a period of history which that box has 

16 learned. 

17 MR. BROOKMAN: Okay. Gregg. 

18 MR. HARDY: This is Gregg. Per Jeremy’s 

19 comment, if we do treat speculative recording as a 

20 network initiated activity, there’s a mechanism in the 

21 test procedure that says if the power level jumps up, 

22 then that means that a network initiated event has 

23 happened and you either start over or -- I didn’t 

24 actually follow all the complexity there. But there is 

25 a mechanism for handling that, right, with the idea of 

26 pulling that out. 

27 MR. DOMMU: That’s right, and Mansi’s 

28 probably just about to speak on that very issue. 
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1 MR. BROOKMAN: So you want to add anything 

2 more at this point? 

3 MS. THAKKAR: I think if we discuss the next 

4 issue it might guide this conversation. 

5 MR. BROOKMAN: Okay. Let’s move on then. 

6 MS. THAKKAR: So the second condition that 

7 must be maintained while the sleep mode tests are being 

8 performed is that network activities should not occur, 

9 that is, service provider network initiated actions, 

10 such as content downloads or software updates that 

11 require transition to on mode should not occur for the 

12 four to eight hour test duration. And local network 

13 initiated actions, such as mobile applications that 

14 require transition to on mode should also not be 

15 scheduled over the test duration. 

16 These requirements are being proposed to 

17 ensure that the set-top box remains in sleep mode 

18 through testing -- while testing for the sleep mode. 

19 It might not always be possible to disable network 

20 initiated actions, especially the service provider 

21 network initiated activities. In the event that these 

22 activities cannot be disabled, DOE proposes a method to 

23 monitor for these activities. For input power less 

24 than or equal to one watt a linear regression through 

25 all power readings should have a slope less than ten 

26 milliwatts per hour. If this is not so, the test 

27 should be restarted or extended until this condition is 

28 achieved. 
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1 For input powers greater than one watt, the 

2 linear regression through all power readings should 

3 have a slope less than one percent of the measured 

4 input power per hour. Again, if this condition is not 

5 met, the test may be restarted or extended until this 

6 condition is achieved. If the test is extended beyond 

7 eight hours to achieve the desired condition, the 

8 average power consumption over the entire test duration 

9 should be measured and reported. 

10 So at this time, DOE requests comment on the 

11 proposed method to address network initiated 

12 activities. We also request comment on the proposed 

13 approach as well as any other approaches that may 

14 capture the transition of the set-top box from sleep to 

15 on mode when the occurrence of such activities cannot 

16 be disabled. 

17 MR. BROOKMAN: Why don’t you go back to the 

18 preceding slide. Okay. Comments. Yes, Adam. 

19 MR. A. GOLDBERG: So what I take from this is 

20 if the box has a spike in energy consumption of 

21 significance of any duration, then we restart or extend 

22 the test. And it strikes me that -- without speaking 

23 TiVo, it strikes me that it’s not at all unreasonable 

24 to think that there are boxes that are going to wake up 

25 every hour or two, look around, say nothing’s new, go 

26 back to sleep, and that’s their normal state. You 

27 can’t turn it off. You can’t not do that. So you 

28 wouldn’t be able to ever measure the power consumption 
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1 with this procedure. 

2 MR. BROOKMAN: Jeremy, do you want to -- 

3 MR. DOMMU: Sure. I would just say the 

4 intent here is, you know, we’ve heard from many service 

5 providers, many manufacturers, that box could wake up, 

6 download new on demand content, update the program. We 

7 don’t want to measure that during this sleep mode test. 

8 That’s why we’re including that. So if it’s not 

9 possible to disable that, or to prevent that from 

10 happening, we certainly welcome your comments on how we 

11 could test sleep mode and ensure that that condition 

12 doesn’t happen. 

13 MR. A. GOLDBERG: I think there’s a 

14 difference between waking up and spending a half hour 

15 downloading EPG data and stuff. And waking up and 

16 saying, oh, nothing’s new and going back to sleep. And 

17 so what I think is written here is, if I build a box so 

18 that every hour on the hour it wakes up, looks around 

19 the home network to see if anything’s new, takes it 

20 about ten seconds, and then it goes back into lowest 

21 power setting. It’s not downloading anything. Nothing 

22 new is happening. It’s entirely predictable. Every 

23 hour on the hour it spends ten seconds looking around. 

24 That seems like sleep mode. But I don’t think that 

25 using this process we would ever be able to measure 

26 sleep mode on that box. 

27 MR. BROOKMAN: Jeremy. 

28 MR. DOMMU: I mean it’s the slope that we’re 
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1 measuring here, right, so over an extended period of 

2 time of four to eight hours, if it’s doing what you 

3 described it to do of only waking up for a couple 

4 seconds, I don’t think -- and I want your input -- but 

5 it seems to me that that likely wouldn’t affect this 

6 slope that much that that would ultimately cancel out 

7 anyway. 

8 MR. A. GOLDBERG: I’m not understanding your 

9 slope then. If I have a box that’s drawing 500 

10 milliwatts and once an hour it draws 15 watts for ten 

11 seconds, what’s the slope. 

12 MR. DOMMU: I think the term power samples is 

13 not made clear. So what you have to do in this case is 

14 you have to sample the power once a second for the 

15 entire duration, and if it spikes in the middle there, 

16 what you’re doing is you’re doing a linear regression 

17 through all the samples. If it spikes for a very short 

18 amount of time, it’s likely it won’t affect your linear 

19 reggression of slope because it should be flat over 

20 that duration if it’s a short duration. 

21 Now, if it’s a long duration, then your 

22 regression line is probably going to have some kind of 

23 slant or tilt to it due to the -- when you calculate 

24 the regression. I don’t know if that makes -- it will 

25 affect the slope due to the duration of that spike and 

26 how large that spike is. 

27 MR. BROOKMAN: Gary, go ahead. 

28 MR. LANGILLE: Yeah, I was just going to say 
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1 that I agree with Adam that -- I mean, I understand the 

2 test. I think it’s a Baronian way to come up to see if 

3 anything’s happening, but we have to accommodate boxes 

4 that could be up for as much as five minutes every 

5 hour, you know, to do various updates. 

6 MR. BROOKMAN: You should be able to measure 

7 that though, yes? 

8 MR. LANGILLE: Yes, well, we just need to 

9 make sure that this method will allow for that somehow. 

10 And I don’t know. We have to do some analysis, I guess 

11 to figure that out. 

12 MR. BROOKMAN: Allen, and Charlie, please 

13 stand up. 

14 MR. TSAO: Yes, that’s the goal. I mean 

15 we’re trying to take an average measurement that 

16 probably excludes these minor events, because maybe the 

17 average power doesn’t really change by having these 

18 five minute interval increases for short period of 

19 time. So any method to factor that out or eliminate it 

20 is welcome, if you guys have a different suggestion. 

21 MR. LANGILLE: Yeah I guess the challenge is 

22 that, you know, every system’s different and one system 

23 could take -- let’s say it comes up during that five 

24 minutes or ten seconds, whatever that design supports, 

25 and it says, okay, there’s a movie for me to load and 

26 it takes an hour. Now obviously, you want to detect 

27 that. Or if it comes up and says, oh, new software 

28 available and it takes 30 minutes to download these 
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1 software. You want to check that. But, you know, the 

2 question is at what level do you not want to detect. 

3 In one system it could just update the changes to the 

4 guide in two minutes and 16 seconds, while -- we’ve got 

5 to make sure this algorithm works such that, you know, 

6 how do we not detect that but detect all the other 

7 things, so -- just got to figure out how to analyze 

8 that. 

9 MR. BROOKMAN: Charlie. 

10 MR. STEPHENS: To pick up where Gary just 

11 left off, Charlie Stephens, I think you also need to go 

12 back to the definition of sleep mode based on what Adam 

13 was saying, it sounds like he has a mode that’s non14 user selectable, it just is the nature of the beast, 

15 that its sleep mode looks like ten seconds per hour of 

16 15 watts, and the rest of the time it’s at 4 watts or 

17 whatever it sits at in its lower power state. The 

18 average power in that mode might be 4.7 watts or 

19 something. I mean it -- that sounds to me like a 

20 different kind of low power mode. If you can 

21 accommodate that in the definition of what this low 

22 power state is, then I would measure it and that would 

23 -- and 4.7 watts might be its answer for how -- but 

24 then you have to go to -- the next question is, how 

25 many hours a day does this machine do that? In other 

26 words, specifically, wake up, see nothing, and go back 

27 to sleep. Versus, wake up and oh, I need to record an 

28 hour long program in the next 30 minutes, starting in 
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1 30 minutes. Well, that’s a different -- that’s more 

2 like on mode by the time it starts recording the 

3 program. 

4 So it’s a combination of definition, how you 

5 measure whatever mode is defined as its low power 

6 stage, and then later deciding how many hours a day it 

7 spends in which state. But I think there ought to be -

8 - the test procedure needs to be able to accommodate 

9 all of this within its definitions, within its 

10 measurement protocols, and then later when we try to 

11 figure out how much time each of these things spend in 

12 what mode. 

13 MR. BROOKMAN: Adam. 

14 MR. A. GOLDBERG: Yeah, I might have been 

15 exactly wrong in my understanding of the way this 

16 works, because I went back and looked at the proposed 

17 language in the NOPR, and it just says, linear 

18 regression throughout power reading -- through all 

19 power readings. And I think that if we’re talking 

20 about taking readings of something that increases over 

21 time, you’d end up with a line with a slope. But 

22 that’s not what I was describing. You’ve got a system 

23 where it’s -- all your samples are going to be 500 

24 milliwatts, except for brief periods where it’s 15 

25 watts, and I guess -- I think you do a linear 

26 regression -- simple linear regression across that 

27 sample size, that’s the same as average power over that 

28 time. In which case, I’m not entirely sure that 
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1 catches the network initiated stuff or not. It kind of 

2 depends on, you know, what we’re trying to do is find a 

3 case where nothing untoward has happened and we’re 

4 actually measuring a typical case with no 

5 externalities. And if the average power over the eight 

6 hour time is -- I’m sorry, the slope is always going to 

7 be flat, it’s never going to be -- it’s never going to 

8 be -- it’s never going to be non-zero. Because you can 

9 have an average power. It’s not -- we’re not measuring 

10 an increasing thing, we’re measuring a flat line with 

11 occasional spikes. 

12 MR. BROOKMAN: Over to Gregg. 

13 MR. HARDY: I think there’s probably 

14 agreement in the room that the real unusual events that 

15 don’t happen multiple times a day, so if you’re pushing 

16 movies on to a box a couple of times a week or 

17 something, that could take an hour or two, but that’s 

18 not normally happening. We don’t want the sleep test 

19 to occur then. But on the other side, it could be that 

20 through the design, five minutes every hour the box is 

21 deliberately, without any user intervention, waking up 

22 to do something. It’s not to watch TV, it’s to check 

23 to see if you recorded something or if you have to go 

24 for an update or whatever, and we think those things, 

25 if they’re happening all the time, they should be 

26 included in the sleep, and that’s why we have a 

27 multiple hour sleep test. 

28 What I don’t understand, and I think we’re 
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1 hearing from the group, is is this proposal a way to 

2 address that thing we’re trying to capture, and I can’t 

3 get my arms around that. 

4 MR. BROOKMAN: Charlie, you want to follow up 

5 here. 

6 MR. STEPHENS: Yeah, Charlie Stephens. Just 

7 really quickly. I keep going back to the definition 

8 and it basically says that sleep mode is a mode where 

9 the thing is not providing any primary function. And 

10 by that I assume that means recording a show, playing 

11 back a show, but I don’t know whether it’s a primary 

12 function of a device that automatically wakes up every 

13 hour for ten seconds and looks around. Is that a 

14 primary function of this device or is it not? It seems 

15 like it would be helpful to define that. Somehow you 

16 have to take all these behaviors that we’re talking 

17 about and categorize them as sleep mode or low power 

18 mode or primary function, based on the definitions that 

19 we’re now working with. So I just reiterate that we 

20 need to go back and look at our definitions and make 

21 sure that what we -- we’re sure of what’s included and 

22 what isn’t, and then we’ll know what to do. 

23 MR. BROOKMAN: Gregg. 

24 MR. HARDY: This is Gregg. The current 

25 definitions of primary function sort of do work for me 

26 in this regard because I think the maintenance 

27 activities that we’re talking about doing at nighttime 

28 aren’t primary functions from my perspective. So the 
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1 way the spec is currently written sort of works for me. 

2 I echo Noah’s comments. I think that we all sort of 

3 agree with the intention that is here, to exclude the 

4 things that are once a month or once a week activities, 

5 include the sort of scheduled, periodic events that are 

6 part of sleep mode. 

7 And I have a second point that’s a slight 

8 shift in gears, if we’re ready to maybe move on from 

9 this a little bit -- 

10 MR. BROOKMAN: I think we’re ready. 

11 MR. HARDY: Okay. It’s related. It’s the 

12 fact that set-top boxes that when they wake for a 

13 maintenance event, either to download software or even 

14 to record a prescheduled show, if they auto powerdown 

15 so that you’re in a nighttime, the box is asleep, it 

16 wakes to record, or wakes to download software, if it 

17 quickly goes to sleep it’ll use less energy than a box 

18 that takes, say, four hours to go back to sleep again. 

19 And so if we could do some thinking about how we can 

20 capture that difference in the test procedure -- one 

21 way would be to just measure the amount of time it 

22 takes to return to sleep state from those various 

23 maintenance activities. There are probably other ways 

24 to do it as well. But it does seem to me to be 

25 important to capture that. 

26 MR. BROOKMAN: Okay. Any additional comments 

27 here? I guess not. Okay, moving on. 

28 MS. THAKKAR: Okay. So after the initial 
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1 conditions have been set up, to perform the sleep mode 

2 test itself, the first test is a manual sleep test. 

3 Again, if the set-top box cannot be placed in sleep 

4 mode or cannot transition from sleep to on mode within 

5 30 seconds, then the test should be skipped, and the 

6 power consumption in manual sleep, which is P-sleep 

7 manual, shall be set equal to the power consumption in 

8 the on-Watch TV test. 

9 If the set-top box can be placed in sleep 

10 mode, then it must be operated in the multi-stream 

11 configuration for at least five minutes if the set-top 

12 box supports multi-streaming, or it should be operated 

13 in the on-Watch TV configuration for at least five 

14 minutes. The power button on the remote for the set15 top box and all locally connected display devices or 

16 clients should be pressed to place all devices into 

17 sleep mode. At this point, the set-top box remote 

18 should not be used or moved at all. It must be ensured 

19 that the set-top box and clients are in sleep mode by 

20 verifying that no channel viewing is supported by the 

21 set-top box. 

22 Finally, record the average power consumption 

23 over the test duration of four to eight hours unless 

24 the test duration is extended for network activities as 

25 we just discussed. 

26 So DOE’s proposed test to measure power 

27 consumption for the manual sleep test is similar to the 

28 test specified in CEA for sleep mode. But there are 
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1 some differences. First, DOE is proposing to set P2 sleep manual equal to P-Watch if the test cannot be 

3 performed. The CEA standard does not specify this. 

4 Second, DOE proposes that the set-top box should be 

5 operated in on mode for at least five minutes prior to 

6 transitioning to sleep mode. CEA does not specify a 

7 standard period of time the set-top box is in on mode. 

8 Finally, DOE is proposing only one of the three methods 

9 that are specified in the CEA standard to ensure that 

10 the set-top box has entered sleep mode. This is that 

11 no channel be viewed or recording is supported on the 

12 set-top box. 

13 At this time, DOE requests comment on the 

14 proposed test method for the manual sleep test. 

15 MR. BROOKMAN: Gary. 

16 MR. LANGILLE: I just wanted to clarify that, 

17 I know our set-top boxes, I’m not sure about others, 

18 but when a customer actually turns it off, we have a 

19 pre -- like a graphic -- it’s like a screensaver, and 

20 it’s quite useful because it reminds the customer to 

21 turn off the TV. So, I’d like to make sure that if DOE 

22 agrees that that’s not considered channel viewing or 

23 video, but, you know, it does have the output stage on 

24 but -- 

25 MR. DOMMU: And I think that’s certainly a 

26 very good comment and one we will keep in consideration 

27 as we’re looking at the NOPR to ensure that that 

28 wouldn’t be considered channel viewing. 
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1 MR. BROOKMAN: Noah. 

2 MR. HOROWITZ: Noah, NRDC. I’d support 

3 Gary’s proposal as well, and one thing that we didn’t 

4 mention here that is in CEA test procedure and in the 

5 Federal Register is when you press the power button, 

6 you can only hold it one or two seconds -- I forgot 

7 what it said. We think that’s extremely important 

8 because there are some implementations if you do 

9 something heroic like hold it 15 seconds, or do some 

10 sort of Morse code, it will go into a much lower power 

11 state, but users would never really do that. So we 

12 want it to be a routine, and that’s less than one or 

13 two seconds. Thank you. 

14 MS. THAKKAR: That’s right, and the DOE test 

15 procedure specifies what’s in CEA, which is less than 

16 one second. 

17 MR. BROOKMAN: Thank you. Additional 

18 comments? Robert. 

19 MR. TURNER: Should we specify what’s being 

20 viewed before you’re going to sleep? If we think it’s 

21 important to differentiate between SD and HD viewing 

22 for recording purposes and the mode it’s in before 

23 sleep may also be important depending on power saved. 

24 MR. DOMMU: Are you suggesting that we have 

25 more specificity on what is being -- the requirement to 

26 operate the set-top box in on mode for at least five 

27 minutes? 

28 MR. TURNER: Yeah, if you think it’s 
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1 important to differentiate between SD and HD, there are 

2 products that that would make some difference, some 

3 don’t. Then you need to define what you’re -- which 

4 mode you’re going from. 

5 MR. DOMMU: Okay. 

6 MR. TURNER: So that would depend on what 

7 decoder is still running. 

8 MR. BROOKMAN: Noah. Did you have something? 

9 MR. A. GOLDBERG: Oh, I thought you said 

10 Noah. 

11 MR. BROOKMAN: I did. 

12 MR. A. GOLDBERG: At least there’s one person 

13 who gets us confused, huh. I sort of alluded to this 

14 or maybe went into some detail earlier, we have a 

15 question here on manual sleep and we’ll have a question 

16 in a few minutes about APD sleep, and I just wanted to 

17 reiterate the third mode, sort of scheduled sleep, and 

18 I expect that we’ll have some specific recommendation 

19 on what duty cycles should be and how to deal with 

20 that. But so you know, it’s coming, and I’m happy to 

21 talk about it if it’s appropriate. 

22 MR. BROOKMAN: We’ll see as we go on. 

23 MS. THAKKAR: Okay. So the second test in 

24 sleep mode is the APD test. Again, for this test, it 

25 should only be performed if the set-top box has APD 

26 capability. To perform the test, the set-top box 

27 should be operated in the multi-stream configuration 

28 for at least five minutes if it is capable of multi-
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1 streaming, or it should be operated in the on-Watch TV 

2 configuration. The power button on the remote should 

3 be pressed for less than one second, only for any 

4 locally connected clients to place the clients in sleep 

5 mode. 

6 Content should be streamed to only one 

7 connected display device. If more than one display 

8 device is connected, the power button on the remote for 

9 the additional displays should be pressed to turn them 

10 off. Once content has been streamed to only one 

11 display device, the set-top box remote control should 

12 not be used or moved. Operate the set-top box until it 

13 enters sleep mode or until four hours elapse, whichever 

14 occurs first. If the set-top box does not enter sleep 

15 mode at the end of four hours, then it is not 

16 considered to support APD and p-sleep APD, which is the 

17 power consumption in APD should be set equal to P18 watch. 

19 If the set-top box does, in fact, enter sleep 

20 mode within four hours, then record the average power 

21 consumption over the test duration of four to eight 

22 hours. 

23 Again, DOE’s proposed test procedure for 

24 power consumption in APD has been adopted from CEA’s 

25 power mode transition on to APD transition test. There 

26 are some differences. Similar to the manual sleep 

27 test, DOE is proposing a five minute duration to 

28 operate the set-top box in on mode. DOE’s proposed 
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1 test explicitly states that the power button should be 

2 pressed to place all connected clients in sleep mode, 

3 which is not specified in the CEA standard. DOE is 

4 setting a maximum four hour time limit within which the 

5 set-top box must transition from on to sleep mode via 

6 APD. The draft CEA standard does not specify a maximum 

7 time limit, but instead measures the time it takes to 

8 transition to sleep mode via APD. And finally, again, 

9 DOE is proposing to set p-sleep APD equal to p-watch, 

10 which is not specified in the CEA standard. 

11 So at this time, DOE requests comment on the 

12 proposed APD test, in particular, DOE request comment 

13 on the time required to transition to sleep mode from 

14 on mode, and whether the proposed time of four hours 

15 should be set as default, or be adjusted during 

16 testing. 

17 MR. BROOKMAN: Noah. 

18 MR. HOROWITZ: This builds off the comment 

19 Gregg made earlier. The way APD is currently written 

20 is if the user is done watching TV and forgets to turn 

21 off the remote control for the set-top box, does it 

22 automatically power down after some time period, here 

23 proposed to be four hours? We agree with that. 

24 There’s another important scenario, though. The user 

25 says at ten o’clock, I want you to record the news and 

26 at 11 o’clock it’s over. We want to make sure that at 

27 11:05 or whatever, that box also automatically powers 

28 down and we don’t have any way of determining that, so 
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1 we think there should be an additional test for the 

2 time to go back to sleep, and that should be either 

3 just simply recorded or you have some minimum value 

4 like you have the time you get to transition to on. 

5 And similarly, if there’s some major service 

6 provider wake event, again we want it to go back to 

7 sleep. I don’t know if we need a test method for that, 

8 but we want to make sure that that’s in there and 

9 depending on whether it happens quickly or not at all, 

10 that should impact the total annual energy consumption. 

11 MR. BROOKMAN: Adam. 

12 MR. A. GOLDBERG: So the NOPR says something 

13 like allow the STB to operate until STB enters sleep 

14 mode, or until four hours are elapsed. So -- which 

15 maybe begs the question of how do you know it’s in 

16 sleep mode? 

17 MS. THAKKAR: This would be again similar to 

18 the manual sleep test where no channel viewing is 

19 supported by the set-top box. 

20 MR. A. GOLDBERG: Well, wait a minute. We’ve 

21 powered down the boxes and then we hang around watching 

22 the meter for four hours, right? At some point, if it 

23 supports sleep, at some point something’s going to 

24 happen, but we don’t know what that is. It’s up to the 

25 manufacturer -- apparently it’s up to whoever’s running 

26 the test to determine when it’s entered sleep mode. 

27 And then maybe an initial complication is, what if it’s 

28 got two steps? It’s one way of saying, okay, it’s 
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1 gotten into sleep mode as you’re watching the power, at 

2 some point the power drops, right? Or if the power -- 

3 what if after two hours the power drops, and after an 

4 hour the power drops more. Which is sleep mode? 

5 MR. BROOKMAN: Gary. 

6 MR. LANGILLE: Yeah, I was just going to 

7 comment, I think the test actually calls that you 

8 actually -- you don’t power anything off, you basically 

9 leave everything running. So you’re going to see video 

10 on the connected TV, okay. So -- and I believe the 

11 indication of where it enters sleep mode, now that 

12 doesn’t mean what level of sleep mode, but the fact 

13 that it enters sleep mode is that all of a sudden that 

14 video goes away or the screensaver comes up or, you 

15 know, it transitions. And that’s the only measurement. 

16 The issue about the multiple levels, theoretically, 

17 that would be captured when you actually make the sleep 

18 mode measurement as opposed to -- this is just trying 

19 to test the time, so to speak. I think. 

20 MR. A. GOLDBERG: Well, whichever. I mean 

21 we were talking about auto or manual -- you start 

22 looking -- you have a condition based on it has entered 

23 sleep mode, and I’m not sure how you -- I’m not sure -- 

24 I mean, if the meaning of that is after you push the 

25 power button and then it stops showing you video, is 

26 that what’s meant by that? 

27 MS. THAKKAR: So in the manual sleep test we 

28 do specify that it enters sleep mode when it does not 
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1 show any channels. But if it’s not here in the APD 

2 test, maybe that’s something that we need to clarify. 

3 MR. A. GOLDBERG: Okay. 

4 MR. BROOKMAN: Noah. 

5 MR. HOROWITZ: Quickly, isn’t what we’re 

6 really trying to do after four hours and five minutes, 

7 say, you’re measuring the power, and that should then 

8 be informed the total annual energy consumption test. 

9 MS. THAKKAR: Right, so -- 

10 MR. HOROWITZ: That way we don’t have to 

11 define all these different modes and submodes and what 

12 does it mean to be asleep. It’s after four hours, is 

13 your power whatever it is, and hopefully it’s lower 

14 than what it was when on, and if it isn’t, then you get 

15 dinged in the energy equation. 

16 MR. BROOKMAN: Robert. 

17 MR. TURNER: In the sort of European18 Australian approach we’ve gone a step further than this 

19 and said, APD at four hours you get a credit. If you 

20 set, as a manufacturer, a shorter APD time then you get 

21 an extra credit because it’s obviously in a sleep mode 

22 for a longer time. 

23 MS. THAKKAR: So we do discuss that in the 

24 NOPR and Allen will cover that as the presentation 

25 moves on. 

26 Okay. At this time, if there are any more 

27 remarks on the sleep mode test procedure before we 

28 proceed to the off mode test? Okay. 
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1 So the next section is the off mode test. 

2 DOE recognizes that most set-top boxes cannot be turned 

3 off, but is proposing this test because it is required 

4 under EPCA. Again, the test must be performed only if 

5 the set-top box is capable of being placed in off mode, 

6 otherwise the test should be skipped. 

7 If the set-top box is capable of being placed 

8 in off mode, then place it in off mode and wait until 

9 it enters the mode. Once in off mode, record the 

10 average power consumption for two minutes. 

11 At this time, DOE requests comment on the 

12 proposed off mode test. 

13 MR. BROOKMAN: Gary. 

14 MR. LANGILLE: It seems fine. It seems 

15 reasonable. 

16 MR. N. GOLDBERG: I just have one question. 

17 This is Neal Goldberg from NCTA. You say if it’s 

18 required by -- it is required by the statute. That, of 

19 course would be required by the statute if the set-top 

20 box is a covered product. Right? 

21 MR. BROOKMAN: Jeremy. 

22 MR. DOMMU: Yeah, I mean, for a test 

23 procedure we’re required to propose tests in on, 

24 standby, and off. 

25 MS. THAKKAR: Okay, so the last topic in the 

26 section is the test to measure the transition time from 

27 sleep to on mode. So this test is optional, and should 

28 be performed to determine if the set-top box is capable 
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1 of supporting sleep mode as defined by DOE’s proposed 

2 definition, which requires that the set-top box should 

3 be capable of transitioning from sleep to on mode 

4 within 30 seconds. 

5 So this test is performed twice, once for the 

6 manual sleep test and once for the APD test. To 

7 perform this test, place the set-top box in sleep mode 

8 according to the steps specified for the manual sleep 

9 test when testing for the manual sleep transition time, 

10 and according to the APD test when testing for the 

11 transition time for the APD test. For both the tests, 

12 wait until the set-top box power consumption reaches P13 sleep, which is between P-sleep and P-sleep plus 0.5 

14 watts. 

15 After the power consumption reaches the 

16 desired value, remain in sleep mode for at least five 

17 minutes, then press the power button on the remote or 

18 front panel of the set-top box. Once powered, begin 

19 the elapsed time measurement and stop the measurement 

20 when the set-top box enters on mode. Record this time 

21 duration as T-sleep to on. The set-top box is 

22 considered to enter on mode when it supports channel 

23 viewing on the connected display device. 

24 This test is adopted from CEA’s power mode 

25 transition, sleep to on transition test. Again there 

26 are some differences. First, DOE is proposing two 

27 methods to enter sleep mode for the two sleep mode 

28 tests proposed today. Second, DOE is proposing a 
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1 standard period of five minutes during which the set2 top box remains in sleep mode. The CEA standard does 

3 not specify this requirement and states that the entity 

4 specifying the use of this method should provide the 

5 time duration. 

6 At this time, DOE requests comment on the 

7 proposed sleep to on mode transition time tests. 

8 MR. BROOKMAN: Gregg. 

9 MR. HARDY: This is Gregg. So my 

10 understanding of the test procedure is that in order to 

11 run the sleep test, you’ve got to -- assuming you’re a 

12 manufacturer running the test -- you’ve got to sort of 

13 commit that your box at any point in time during that 

14 sleep mode would have less than or equal to a 30 second 

15 wake time. And then there’s this test which is 

16 optional, which is - sort of lays out a guideline for 

17 if you want to test, if you want to run a test to 

18 check, this would check at least within the first five 

19 minutes if your box has a 30 second wake time. 

20 MS. THAKKAR: It wouldn’t check within the 

21 first five minutes, it would check it only after the 

22 power consumption reaches the power consumption you got 

23 for the sleep mode test. 

24 MR. HARDY: That’s fair enough, but it’s a 

25 limited window, right? So if you pass this test, that 

26 doesn’t necessarily mean that your box remains within 

27 30 seconds of waking throughout the whole sleep period. 

28 So if a manufacturer wanted -- 
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1 MR. A. GOLDBERG: I see where you’re going. 

2 MR. HARDY: No, I’m just saying if a 

3 manufacturer wanted to be sure that their box 

4 maintained that, because maybe they have three 

5 different levels of sleep, right -- I mean broadcoms, 

6 new silicon, with all these different sleep levels -- 

7 MR. A. GOLDBERG: ... to wake up after five 

8 minutes, right. 

9 MR. HARDY: So if a manufacturer wanted to 

10 make sure, they might have to run this test several 

11 times throughout the four or eight hour sleep period to 

12 make sure that it stays in that state. That’s my only 

13 comment. 

14 MR. A. GOLDBERG: So, Gregg, you’re concerned 

15 about a game where someone might have ten minutes after 

16 you push the power button, ten minutes after it goes 

17 into sleep it would come right back up, and after ten 

18 minutes, it’s going to consume much less power and take 

19 much longer to come out, right? 

20 MR. HARDY: Right. 

21 MR. A. GOLDBERG: But you’re waiting -- step 

22 two, wait until power consumption reaches P-sleep or P23 sleep plus half a watt, there’s no advantage to after 

24 ten minutes decreasing the power consumption because 

25 your TEC calculation is going to use P-sleep. 

26 MR. BROOKMAN: Gary, go ahead. 

27 MR. LANGILLE: Yeah, Adam, I think you’re 

28 right. I think that’ll cover it, I mean so you can’t 
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1 game it. 

2 MR. BROOKMAN: Restate it Gary. I didn’t 

3 follow it. 

4 MR. LANGILLE: I got it. 

5 MR. BROOKMAN: Restate it, Gary. 

6 MR. LANGILLE: The point is that since you 

7 have to -- the time is, for the recovery is, you have 

8 to reach P-sleep, which means whatever you measured 

9 that goes into the duty cycle equation has to match 

10 what you can recover from in 30 seconds. 

11 MR. HARDY: So in other words -- 

12 MR. LANGILLE: There’s no way to get around 

13 that because you’re not measuring -- you’re not like 

14 waiting five minutes and then measuring it, you have to 

15 recover in 30 seconds. You actually have to wait until 

16 the power goes down to exactly what it matched when you 

17 actually made the four hour test. Or the eight hour 

18 test, whatever it was. 

19 MR. HARDY: So if you envision a scenario 

20 where you’ve spent the first ten minutes at light sleep 

21 and then thought, well, I’ll just go way in to deep 

22 sleep with a five minute wake time. Then when you run 

23 this check, you would never get to P-sleep. 

24 MR. LANGILLE: Right. 

25 MR. HARDY: Right. That’s a good point. I 

26 appreciate that. And in actuality, you know, when you 

27 design something like that you usually, you actually do 

28 want, for instance, a button on the remote -- there’s 
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1 so many accidental, you know, everyone here -- you roll 

2 over and you hit the remote button, you shut the TV 

3 off, right, so even TVs normally don’t drop until their 

4 normal sleep mode for a while, so they have really fast 

5 recovery if people accidentally hit a button or 

6 something, so it actually is pretty normal just to sort 

7 of drop just a little bit and then wait. 

8 MR. BROOKMAN: Okay. 

9 MS. THAKKAR: We’re scheduled to take a break 

10 at this time, but -- 

11 MR. BROOKMAN: Yes, let’s take a break. And 

12 looking at the content that we have, I think we’ll be 

13 out of here by four. So good progress, I really 

14 appreciate you all for the clarity that you’re bringing 

15 to these answers. We’ll take a break and we’ll resume 

16 at three. 

17 (Whereupon, the meeting was recessed for a 

18 brief period.) 

19 (First parts of Mr. Tsao’s presentation was 

20 not recorded.) 

 21 

 22 

23 Calculation of Annual Energy Consumption Metric 

24 (continued) 

25 MR. TURNER: The thing that sort of stops you 

26 taking a very short time is service providers won’t do 

27 it because they don’t want the service calls of 
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1 somebody ringing up saying, I messed up my box doing 

2 this. So there will be a sort of market force to keep 

3 you sensible. 

4 MR. BROOKMAN: Okay. Other comments here? 

5 Yes, Gary. 

6 MR. LANGILLE: I would just comment that we 

7 love credits. Just if, as I said, we don’t include 

8 annual energy consumption, I’m not sure where a credit 

9 may or may not apply. I can report that in our set-top 

10 boxes we recently did a software update where we now 

11 actually set the -- it’s sort of an intelligent time 

12 out where it’s actually set for two hours, but actually 

13 looks at the kind of channels being watched, and it 

14 looks up the program guide to see, you know, so if 

15 you’re watching football it doesn’t shut it off in the 

16 middle of the big play, which has happened to me. You 

17 know, as if you had a fixed four hours, so it will 

18 either shut off in two -- it always attempts to shut 

19 off in two, but it checks to see if there’s an active 

20 program going and will add an hour up to four, and then 

21 after four, you know, -- and that’s actually settable. 

22 But it shows the type thing, I think, Robert’s thing 

23 that there are things you can do that can reduce 

24 energy. 

25 MR. BROOKMAN: Additional comments on scaling 

26 APD? 

27 MR. DOMMU: I have one more question -- 

28 MR. BROOKMAN: Yes, Jeremy. 
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1 MR. DOMMU: I have one more question that I 

2 want to bring up to the floor before we move on, and 

3 actually this is something that I got e-mailed from the 

4 Federal Trade Commission, that they were hoping that 

5 they could get some feedback on this question during 

6 our meeting, and that is, if DOE were to finalize this 

7 test procedure, the FTC would be required 18 months 

8 after the issuance of the test procedure to direct -- 

9 to prescribe labeling for set-top boxes. However, they 

10 do not have to require labeling if it’s determined that 

11 labeling is not technically or economically feasible or 

12 not likely to assist consumers in making purchasing 

13 decisions. 

14 MS. SANFORD: Can you read that again? 

15 MR. DOMMU: The FTC is required to prescribe 

16 labeling for set-top boxes 18 months after the issuance 

17 of a DOE test procedure. However, FTC does not have to 

18 require labeling if it determines labeling is (1) not 

19 technically or economically feasible, or (2) not likely 

20 to assist consumers in making purchasing decisions. 

21 So the question that I was asked to bring up 

22 here was is there any feedback on whether or not the 

23 FTC should move forward with looking at labeling for 

24 set-top boxes? 

25 MR. BROOKMAN: Gary first. 

26 MR. LANGILLE: I just ask that are you 

27 referring to the energy guide label, the yellow? 

28 MR. DOMMU: Yes. 
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1 MR. LANGILLE: Okay. My only comment would 

2 be that -- I recall some discussion on this issue, I 

3 don’t know if they already tried to label set-top boxes 

4 or not, did they? But I think the biggest issue that 

5 came up previously was the fact that a very, very large 

6 percentage of set-top boxes are installed by service 

7 technicians who unpack them and all that, and it’s not 

8 -- very few are in a retail location where a customer 

9 actually would see the yellow label and compare one 

10 against the other. So it wasn’t deemed as effective. 

11 In fact, we think what will be more effective, and it’s 

12 part of the voluntary agreement, is that everyone 

13 participating in the voluntary agreement is planning to 

14 put up energy usage information for all set-top boxes 

15 sold, I believe, by the end of 2014, once we get 

16 through this first -- so beginning of 2014 -- that all 

17 service providers will be able to go to the website and 

18 look at any set-top box and see the energy usage for 

19 that device. We think that’s actually more visible, 

20 and that would allow customers to look at it ahead of 

21 time by the way. So if they say, hey, I think a lower 

22 DISH system, you know, how much is one of these suckers 

23 going to cost me in energy. They’ll be able to 

24 actually look before they buy it. 

25 MR. BROOKMAN: Robert. 

26 MR. TURNER: I think this is a very strange 

27 market. People do not buy set-top boxes. You buy a 

28 service. I want to watch these programs. I need that 
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1 platform to watch them, so the consumer is not 

2 particularly going on and saying I’ll have cable box 

3 based on energy. It’s on the basket of programs being 

4 offered. So giving people labels on products is not 

5 going to have any value, because it’s not going to 

6 change purchasing decisions. 

7 MR. BROOKMAN: Okay. Paul, do you want in? 

8 No? Jennifer. 

9 MS. AMANN: I just wanted to add one point to 

10 Gary’s point. So, the FTC has recently, in December, 

11 promulgated new rules on labeling requirements for on 

12 line that applies to manufacturers and retailers to 

13 display the energy guide label. So that’s been the 

14 case for TV since the TV label went into effect, but 

15 it’s now for all products covered by the energy -- the 

16 appliance labeling program. So in fact, consumers 

17 would have an opportunity to go on in advance as 

18 they’re researching the different technologies and 

19 deciding whether they’re going to go with cable, or 

20 Dish, or DirecTV, or whatever, and compare the energy 

21 guide labels for the different products. So, just to 

22 clarify that that is now an option or a requirement, 

23 actually. 

24 MR. BROOKMAN: Okay. Thank you. Final 

25 comments on this, on this request from Jeremy? Let’s 

26 move on. 

27 Estimated Burden to Small Businesses 

28 MR. TSAO: So the last section is the 
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1 estimated burden to small businesses. So DOE estimated 

2 the impact of this rulemaking that it would have on 

3 small business manufacturers of set-top boxes, and DOE 

4 has identified at least five small businesses as 

5 follows using the North American Industry 

6 Classification System, or NAICS codes. The table here 

7 shows the different codes, what the criteria are for 

8 what is considered a small business, and these are the 

9 breakdown of the five that DOE identified. 

10 In order to estimate burden, DOE estimated 

11 that each of the small business manufacturers typically 

12 manufactured four basic models, and that the cost for 

13 testing four basic models was about $10,000 for initial 

14 setup of capital equipment and $7400 for labor 

15 associated with testing those four models. And based 

16 on the revenue of those small businesses, the total 

17 testing cost for a year amount to a pretty small 

18 percentage, less than 0.1 percent of the average 

19 revenue for those small businesses. So at this time 

20 DOE has tentatively concluded that the proposed rule 

21 doesn’t pose a significant burden to small businesses. 

22 MR. BROOKMAN: Adam. 

23 MR. A. GOLDBERG: Sorry, maybe I should keep 

24 quiet in some of these matters, but can you go back one 

25 slide? What you see is that there is a manufacturer -- 

26 sorry, so the -- so there’s four companies that make 

27 equipment -- they’re small businesses with less than 

28 750 employees, is that right? 
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1 MR. TSAO: Yeah. 

2 MR. A. GOLDBERG: And each of -- the next 

3 slide -- each of them you estimate makes four models? 

4 MR. TSAO: Yes, that was our estimate. 

5 MR. A. GOLDBERG: It’s hard to imagine that 

6 many, but okay. 

7 MR. TSAO: On some of these, they might be 

8 conservative estimates if it wasn’t clear exactly. 

9 MS. SANFORD: Can I ask a quick question 

10 about -- 

11 MR. BROOKMAN: Jennifer. 

12 MS. SANFORD: -- the definition, 

13 “manufacturer” here? Earlier in the NOPR you had set 

14 manufacturer -- 

15 MR. BROOKMAN: Is your microphone on? 

16 MS. SANFORD: Sorry? 

17 MR. BROOKMAN: Is your microphone on? 

18 MS. SANFORD: Yes, it is. 

19 MR. BROOKMAN: Thank you. 

20 MS. SANFORD: Also included importers, I 

21 notice. So are importers small businesses -- would 

22 they be considered manufacturers of set-top boxes as 

23 well? 

24 MR. TSAO: Yeah, I believe so. 

25 MS. SANFORD: So you’re saying there are five 

26 small businesses, including importers.\ 

27 MR. TSAO: Yes. I mean that’s -- that’s what 

28 DOE has identified in this analysis. 
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1 MS. SANFORD: Okay. That’s surprising to me, 

2 but okay. Thank you. 

3 MR. BROOKMAN: So if you have additional 

4 data, the Department would really welcome that. Yes, 

5 Gregg. 

6 MR. N. GOLDBERG: I have a question. I’m 

7 sorry. 

8 MR. BROOKMAN: Neal, follow on then, please. 

9 MR. N. GOLDBERG: Just a quick question. 

10 When we say manufacturers, we mean manufacturers as 

11 defined in the earlier part of this presentation. 

12 MR. TSAO: That’s right. 

13 MR. N. GOLDBERG: So even though we might 

14 have an effect on say a small cable operator, at least 

15 an indirect effect, we wouldn’t be covered -- they 

16 would not be included in this impact, is that correct? 

17 MR. TSAO: That's correct. 

18 MR. N. GOLDBERG: Thank you. 

19 MR. TURNER: What happens if the cable 

20 operator has different software to a big cable 

21 operator, so his product costs him a different amount 

22 of energy. Does he become a manufacturer then? 

23 MR. TSAO: I would say the definition of the 

24 manufacturer as we discussed earlier is irrelevant to 

25 the size of whether it’s a large manufacturer or a 

26 small manufacturer. If somebody -- there’s an entity 

27 that meets the definition of manufacturer as we’ve 

28 previously provided, then it would be covered by this 
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1 test procedure, and if they were considered a small 

2 business manufacturer, then this information would 

3 apply. 

4 MR. BROOKMAN: Gregg. 

5 MR. HARDY: To continue that thought. I 

6 think there’s some ambiguity about the current 

7 definition of manufacturer. It may not matter for a 

8 test procedure, but it may matter for other reasons. 

9 The big question is can service providers be considered 

10 manufacturers? And I don’t know if we need to address 

11 that here, but it may become important at some point in 

12 time, and it may be important how we define it in the 

13 test procedure for other reasons besides the test 

14 procedure. 

15 MR. BROOKMAN: Okay. Adam. 

16 MR. A. GOLDBERG: So maybe this brings up the 

17 sort of base model discussion we had earlier. I mean 

18 if me and my two kids in our back room, three 

19 employees, less than $15 million dollars, so I design a 

20 single set-top box and we manage to sell it to Comcast, 

21 Time Warner, Echostar, and DirecTV. Each of them has a 

22 version of software in the field and a version of 

23 software being tested, and I have one piece of 

24 hardware, but I think it’s eight base models, right, 

25 and this calculation is based on four. But I mean I 

26 think you might need to multiply that by the number of 

27 software versions, because I think the base model 

28 description, discussion as I thought it turned out, 
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1 yielded every software version difference yielded a 

2 different model. 

3 MR. BROOKMAN: Gregg. 

4 MR. HARDY: In your -- in this definition of 

5 manufacturing that I think we’re talking about, I don’t 

6 think that you as a single person in your garage shop 

7 would be considered a manufacturer. I think those 

8 people who did the final integration would be 

9 considered the manufacturer. 

10 MS. SANFORD: Can I jump in here, sorry. 

11 This is Jen with Cisco. In the manufacturer of set-top 

12 box, if we go back to slide 26, so it’s EPCA defines 

13 the term manufacturer as to manufacture, produce, 

14 assemble, or import. So any person that manufactures a 

15 device that meets the proposed definition of set-top 

16 box would be considered a manufacturer under DOE’s 

17 regulations. 

18 MR. A. GOLDBERG: And DOE amended that to add 

19 the software component. So if you view that as the 

20 final software, then the garage shop isn’t putting on 

21 the final software. 

22 MR. HARDY: Wait. What? The NOPR -- 

23 MR. A. GOLDBERG: Excuse me, so -- something 

24 doesn’t make sense here. So me and my kids, we design 

25 a box and we have TPV assemble it in Taiwan, and we 

26 import it, right. So we’re the -- we didn’t put the 

27 chips on the board, but we designed it and we imported 

28 it. And we sell it to a handful of different 
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1 operators, each of which has a handful of different 

2 software versions. That’s M times N different models. 

3 MR. HARDY: My point is there’s ambiguity 

4 here. Either the person that makes the box that’s 

5 capable of being the final product is the manufacturer, 

6 because that’s what we all tend to call them today, or 

7 the person who puts the final software on that box is 

8 the manufacturer. 

9 MR. BROOKMAN: Jennifer, you want to come in 

10 here? 

11 MS. SANFORD: Well, I was going to say based 

12 on our conversation earlier, my take away was that you 

13 would be responsible for that box as it was sent to 

14 your customers, whether it was the same version 

15 supplied to all your customers or you tweaked it for 

16 each one, and then they would be responsible for it 

17 after they had put their software on it. So, it could 

18 be that you have one base model of four base models, 

19 and then each of your clients would have a model. 

20 PARTICIPANT: So that would be interpreting 

21 manufacturer as putting different software version on 

22 the box. 

23 MR. N. GOLDBERG: Could I ask for a 

24 clarification. This is Neal Goldberg, no relation to 

25 Adam. Keeping on the question I had before, if all of 

26 this is correct, then there could be a small cable 

27 operator who downloads software to a device made in 

28 Adam’s garage, who wouldn’t be picked up by this small 
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1 business impact. I assume this is impact on small 

2 businesses, it doesn’t say small business 

3 manufacturers, right? 

4 MS. SANFORD: But we’re saying the definition 

... 5 

6 MR. N. GOLDBERG: No, I understand that and I 

7 -- 

8 (overspeak) 

9 PARTICIPANT: I think we agree with each 

10 other, that it’s underestimated by entity and software 

11 versions and everything else. 

12 MR. BROOKMAN: Jeremy. 

13 MR. DOMMU: No, I mean, I would just say that 

14 this was our initial small business impact analysis, 

15 where we’re trying to figure out -- this is a proposed 

16 regulation to establish a test procedure for set-top 

17 boxes. And we’re analyzing here what the impact of 

18 that regulation would be on an entity that meets the 

19 definition of a small business by the North America 

20 Industry Classification System. So to the extent that 

21 there are additional small businesses that you have 

22 identified, we would encourage you to submit that 

23 information to us so that we could update our analysis. 

24 MR. BROOKMAN: All right. 

25 MR. TSAO: Follow on with a quick comment. 

26 So for -- when you’re talking about cable operators, I 

27 think I agree, I think there may be some ambiguity as 

28 to what constitutes a manufacturer. If the cable 
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1 operator receives a box, doesn’t change it with any 

2 software or anything, and redeploys it, then I don’t 

3 think that there’s disagreement that that could be 

4 considered a manufacturer in any way. I don’t think 

5 there’s any ambiguity there. The question is are there 

6 small cable operators that do add software layers on 

7 top of that that would be considered as a manufacturer, 

8 then this seems ambiguous, right, and if you could 

9 provide those companies or the numbers or information 

10 related to them, then that would be useful. 

11 MS. PINTO: This is Francine. I think given 

12 all the -- this is Francine. Given all the comments 

13 that have just been discussed, we’re just going to have 

14 to come back with answers in our final rule later on. 

15 Please feel free to give us comments on your position 

16 on the issues that have just been discussed about 

17 manufacturer. 

18 MR. BROOKMAN: Okay. Yes, Robert. 

19 MR. TURNER: Again, it may not be that small 

20 manufacturers or small service providers put new 

21 software on the box, because they’re not big enough to 

22 -- they don’t know how to package software, but two 

23 service providers may take an identical box with 

24 identical software and preconfigure it in different 

25 ways so that one party’s box is APD enabled and one 

26 doesn’t. It becomes a different product at that point, 

27 and that’s in the control of the service provider. 

28 MR. BROOKMAN: Okay. Anything else, Allen? 
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1 MS. KAPLAN: I have one comment. This is 

2 Katherine from EnergyStar. And, you know, we’ve 

3 encountered this very issue in our program and had to 

4 put out a clarification because we were holding 

5 manufacturers responsible for certifying that a product 

6 met requirements and we heard from some test labs or 

7 certification bodies that they didn’t have the final 

8 software yet. The box went from the manufacturer to 

9 the test lab without the final software provisioned 

10 yet, but that got loaded when the box was deployed in 

11 someone’s home. 

12 So, in any case, I think this is kind of a 

13 real question and what we ultimately did, which may 

14 very well not work for a federal standard, or even for 

15 the purposes of a test procedure, is we said our 

16 service provider partners had to ensure that the box 

17 continued to meet the EnergyStar requirements once 

18 deployed. And, you know, the box is verified and then 

19 they’re held responsible. 

20 MR. BROOKMAN: Okay. Thank you. Final 

21 slide. As we promised this morning first thing, now is 

22 an opportunity for anybody that wants to, to make a 

23 closing statement to feature any other issues that 

24 haven’t been covered sufficiently. No additional 

25 comments at this time. Okay. 

26 Then, back to Jeremy for closing remarks. 

 27 

28 Closing Remarks 
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1 MR. DOMMU: Yeah. There’s a couple more 

2 slides. I’ll just go through them quickly. It’s just 

3 the closing information. 

4 Okay. So this slide right here just -- 

5 MR. BROOKMAN: Excuse me, Jeremy, I dropped 

6 somebody out of the queue. James reminds me that Roger 

7 Goodner -- Roger, I apologize, I’ve had your name 

8 sitting here in front of me for five minutes now. 

9 Please speak. 

10 MR. GOODNER: Thank you. I just want to 

11 comment on the last bit of the analysis. The analysis 

12 that I see is done at $41.08 per hour, which might be a 

13 reasonable rate for an engineer running testing. 

14 However, that does not include the overhead of a 

15 company, nor does it reflect what would be a standard 

16 charge rate for an external lab making any 

17 measurements, which is probably more likely for a small 

18 company to have to do, or a small business. And those 

19 rates we’re finding to be more in the order of $150 to 

20 $200 an hour, depending on what they have to do. If 

21 you take the $150 and you do your analysis, it’s no 

22 longer $7400, but it’s $27,000, which represents a 

23 significant percentage of the profit line for a small 

24 business. 

25 MR. BROOKMAN: Okay. Roger, thank you. And 

26 I hope, Roger, you’ll put all those comments in writing 

27 and send them in. 

28 MR. GOODNER: I will. Thank you. 
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1 MR. BROOKMAN: Thank you. Okay. Jeremy, 

2 back to you. 

3 MR. DOMMU: Okay. So again, all this 

4 information here is about how to submit written 

5 comments. It is in the Federal Register notice, it is 

6 on the Department of Energy set-top box rulemaking 

7 website, and it’s here on this slide of how to go about 

8 the process to either e-mail, hand deliver, or send in 

9 the post comments to the docket, and identifying some 

10 of the following information listed here. 

11 Again, the written comment deadline, April 8, 

12 2013. 

13 Here are some URL relevant links. This is 

14 the Appliance Standard website link. There’s a 

15 specific product webpage on DOE’s website, specifically 

16 for set-top boxes and there’s a separate rulemaking 

17 page specifically the rulemaking activities related to 

18 establishing a test procedure for set-top boxes. And 

19 then there’s also the rulemaking docket and that’s on 

20 regulations.gov and that docket will contain all 

21 supporting documents, all notices, and that’s where all 

22 written comments will be posted, so you are able, as 

23 comments come in, to go to the docket and you’ll see 

24 everyone else’s written comments that are submitted, 

25 and there’s the URL for that. 

26 Finally here is my contact information. The 

27 contact information for Celia Sher, the General Counsel 

28 representative for set-top boxes. Francine was here 
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1 today, if you have any further questions. 

2 So with that, I thank you all so much for 

3 incredibly valuable insight that you provided during 

4 today’s meeting. We look forward to your written 

5 comments and continuing to work with all of you as we 

6 move forward in these rulemaking procedures. So thank 

7 you so much, we really appreciate it. 

8 MR. BROOKMAN: Please fill out the evaluation 

9 form which is a part of your packet and safe travels 

10 everyone. 

11 (Whereupon, at approximately 4:00 p.m., the 

12 meeting in the above captioned matter was adjourned.) 

 13 

 14 

 15 

 16 

 17 

 18 

REPORTER'S CERTIFICATE

This is to certify that the attached proceedings 

before:

 UNITED STATES OF AMERICA 

DEPARTMENT OF ENERGY 

 

 

In the Matter of:

 

NOTICE OF PROPOSED RULEMAKING PUBLIC MEETING ON 
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TEST PROCEDURE FOR SET-TOP BOXES 

Were held as herein appears and that this is the

original transcript thereof for the file of the 

Department, Commission, Board, Administrative Law Judge 

or the Agency.

Further, I am neither counsel for or related to any 

party to the above proceedings.

 

Wendy Greene 

 Official Reporter 

Dated: March 6, 2013