Consumer Electronics Association (CEA) has submitted final comments to the California Energy Commission (CEC) regarding its proposed restrictions on television sets that are sold in California. In its comments, CEA urges the CEC to take a “bold step” and work cooperatively with the consumer electronics industry to realize the desired energy savings without impeding technological progress and consumer freedom to enjoy home entertainment.
“Consumer electronics manufacturers have already dramatically reduced the amount of energy used by digital televisions-”without regulation,” notes Gary Shapiro, CEA’s president and CEO. “In less than two years, the energy efficiency of Energy Star TVs has improved by 41 percent. These successful efforts resulted from competition among manufacturers to reduce costs to consumers in the global marketplace-”not government mandates. By combining voluntary industry efforts, new initiatives to educate and encourage consumers to conserve TV energy and new requirements related to energy-saving features, the CEC can minimize costs to consumers and avoid economic harm to California and the damage these regulations will cause to technological progress, design freedom, retailer interests, and consumer rights.”
CEA also submitted a detailed analysis of the numerous mathematical errors and incorrect assumptions that the CEC is using to justify the new regulations. In a report by LECG, financial and economic expert Dr. Paul Wazzan affirms that “the CEC analysis suffers from grave computational and conceptual errors” and concludes that not only are consumers unlikely to save dollars from reduced energy costs, they are rather more likely to incur significant costs and suffer from reduced access to technology and innovation.
CEA’s comments also included a study of readily adoptable alternatives that will achieve the same or better energy savings for California. The alternatives include Energy Star 3.0 and 4.0; new requirements for auto power-down and forced menu brightness settings, a statewide educational campaign to encourage consumers to change the preset viewing modes on TVs they already own; and a DTV acceleration program that would reduce TV energy consumption by incentivizing the retirement of old, inefficient analog TVs.
In its comments, CEA concludes that the costs of these regulations outweigh any foreseeable benefit: “A fair assessment of the facts shows that voluntary efforts, in concert with reasonable regulations requiring forced mode menus and automatic shut-off, will result in savings at least as great as those anticipated by the CEC. Consequently, the regulations cannot be justified and should not be promulgated by the Commission.”
“Green is good, but simply calling any onerous new regulatory proposal ‘green’ does not make it good for the environment or good for consumers,” adds Shapiro. “This ban on new and evolving TV technologies is inconsistent with consumer behavior, with economics and with fact-based decision making. It is bad for California, bad for energy savings, bad for innovation and bad for the phenomenally successful Energy Star program.”
