April 13, 2012 Katharine Kaplan EPA Team Lead ENERGY STAR Product Development US Environmental Protection Agency 1200 Pennsylvania Avenue, N.W. Washington, DC 20460
[email protected] Re: ENERGY STAR® Specification for Set-top Boxes Version 4.0 Dear Ms. Kaplan: On behalf of the National Cable & Telecommunications Association (“NCTA”), I am responding to the Environmental Protection Agency’s (“EPA”) March 20, 2012 request for comment on ENERGY STAR® Specification for Set-top Boxes Version 4.0 (“ESv4”). Since the adoption of EPA’s Energy Star Version 3.0 and 4.0 specifications for set-top boxes, the cable industry has launched new initiatives dedicated to improving the energy efficiency of cable-provided consumer set-top boxes on an aggressive timeline. These new initiatives include (1) the creation of CableLabs - Energy Lab (a specific facility within CableLabs1 dedicated to improving energy efficiency); (2) focused projects to increase the efficiency of set-top boxes through development of “light sleep” and “deep sleep” set-top box modes that function with U.S. cable system architectures; and (3) cable operator volume procurement commitments for set-top boxes that meet ENERGY STAR standards to move the 1 Cable Television Laboratories or CableLabs, founded in 1988, is the cable industry’s R&D consortium playing a role similar to that played by BellLabs for the telephone industry. CableLabs has over 40 cable operator members representing over 80 million customers, predominantly in North American (US and Canada), but also internationally in Europe, Asia, and Central America. Among other things, CableLabs developed common specifications for the cable modem enabling the size and price of such modems to plummet in a short time as they were made available at retail outlets across the country which, in turn, spurred the revolution in broadband access the Nation has experienced in recent years.