NRDC Urges EPA to Set Firm ‘Deep Sleep’ Limit for Set-Top Boxes

The EPA should set a strong 2 watt or less “deep sleep” Energy Star requirement that set-top boxes have to meet for at least four hours per day, the Natural Resources Defense Council said. The agency should verify box compliance with the deep sleep limit in the field through “appropriate and sufficient testing and verification procedures,” the group said in comments on revisions proposed by the agency to the Energy Star set-top box specification.

NRDC said it supports the agency’s proposal to promote advanced efficiency capabilities in the boxes by granting service providers additional credit for deploying such boxes. But the decision to grant approval on a “case-by-case basis” wouldn’t give box makers and service providers the “certainty they need to make the investments required to implement effective energy efficiency in their products,” it said.

Even a 2 watt for 4 hours per day deep sleep requirement, though a “first step in the right direction,” falls “far short from the potential for deep sleep operation,” it said. “NRDC proposes that future revisions of this requirement drive [boxes] to maximize time spent in low-power mode, and limit active mode to a maximum of 1 hour per day beyond viewing and recording time.” This would include program guide updates and software downloads, but exclude speculative recording and update installations, it said.

While backing the proposal to let the manufacturer or service provider test and label leased set-top boxes whose energy performance is independent of configurations or usage, NRDC wanted the agency to spell out how it will hold accountable stakeholders whose boxes are found not in compliance. The group also wanted the EPA to group cable and telco boxes in a single category with a single “base functionality” typical energy consumption level. “This would encourage cable operators to accelerate adoption of best-in-class energy performance such as IPTV.” Satellite providers can be managed separately because they provide service in areas unserved by cable, it said.

Box maker Pace raised concerns over new Energy Star product testing and verification rules. “Significant issues” exist with the EPA’s proposal for independent testing in accredited labs, particularly where the manufacturer is not based in North America, “which could be deemed to be technical barriers to free trade,” Pace said.