DirecTV, EPB Raise Concerns Over New Energy Star Testing Rules

The EPA’s new product qualification and verification testing rules would result in “uncertain cost and schedule impacts” that will likely deter service provider participation in the Energy Star program for set-top boxes, DirecTV said. The satellite provider was commenting on draft changes proposed by EPA to the Energy Star specification for cable, satellite and IPTV boxes. The new rules, including testing by third-party or in-house accredited labs, come after a GAO investigation found that the Energy Star program was prone to fraud and abuse.

The new testing rules would insert third-party labs, accreditation and certification bodies between Energy Star partners and the EPA, DirecTV said. “The costs of supporting this new infrastructure of businesses will be borne by program partners, even as they receive no benefits as a result.” Issues include how much a third-party lab test would cost, given the “high cost to the lab” to build a simulated DirecTV distribution network, and the fact that only a few tests will be ordered in a year. It’s also uncertain how EPA would shield partners like DirecTV from certification bodies “maximizing profits,” by “performing verification tests on 100% of previously certified products every year."

DirecTV also took issue with EPA’s proposal to collect more data on box deployments and usage. Service providers are providing “extremely sensitive” data on total numbers of Energy Star and other set-top box purchases at “risk of being exposed to competitors,” it said. “Reporting requirements that force a service provider to expose in even more detail its operations and deployments present an increased deterrent to program participation.” With many issues “yet to be discussed, let alone resolved,” the EPA should consider moving the effective date for version 3.0 to 2012 from next year and shift the effective date for version 4.0 to 2014, the company said.

"This certainly will allow service providers to join Energy Star today, with the expectation that in 2012 they'll not only have plans in place that will allow them to stay in the program as version 3.0 becomes effective, but will be prepared to launch utility-sponsored programs as well,” DirecTV said. The company urged the EPA to permit both thin client set-top boxes and multiroom boxes to use “home network interface” allowance and harmonize allowances for DOCSIS and home network interface.

Tennessee utility EPB, which provides cable and DSL services, sought more transparency to customers from Energy Star qualified service providers about the efficiency of the boxes they deploy. EPB is one of only four service providers that have joined the Energy Star program for set-top boxes since its launch in 2008. Energy Star requires service providers to make 50 percent of their yearly box purchases Energy Star qualified, the company said. That may lead to the belief among customers that the boxes they are getting are energy efficient, which may not always be the case, it said. “EPB believes that customers should either be assured of receiving an energy-efficient box or understand that one must be requested,” it said.

The agency should also allow service providers to use “witness testing” as an alternative to qualification testing in an EPA-recognized accredited lab, EPB said. Small service providers don’t own labs that meet EPA standards and contracting out the tests could be “cost prohibitive,” it said. On the EPA’s proposal to collect more data from service providers, the utility said the move could mean “customer usage data will play a role in compliance standards.” EPB’s customer privacy policies could affect its “ability to comply with the proposed standard,” it said. “If EPA is considering integrating customer usage into the requirements, EPB asks that EPA provide existing standardized data taken from a national average that can be applied to all service providers’ required calculations.”