California Energy Efficiency Regulations
The California Energy Commission has issued a rule that would single out digital to analog DTV adapters (DTAs) for artificially low energy consumption restrictions. These regulations will make it difficult or impossible to sell DTAs in California.
The ruling unfairly places a disproportionate burden on DTA devices. The circuitry required in a DTA is much more complex than that in either a DVD or Compact Audio device -- two devices that the CEC has allowed to consume more power than a DTA. Even when reduced to highly-miniaturized integrated circuits, the density of the chips in a DTA is much higher than that in the other devices. This higher density means that the devices must consume more power than the other devices.
The ruling unfairly discriminates against over-the-air broadcast television. The satellite and cable television industries have deployed settop boxes that are of a similar functionality to the DTA. Direct-broadcast satellite in the U.S. has employed a digital transmission system that requires a level of circuitry comparable to the DTA. In addition, cable television operators have begun deploying digital video services, again using comparable technology. Yet, none of these other devices appear in the CEC Appliance Efficiency Regulations.
The ruling will impede the digital transition and will make it difficult for low-income households to continue to receive free, over-the-air TV. DTA devices, and specifically the Federal DTA subsidy program, are targeted to make the digital transition convenient and of low cost, especially to low-income households. The ruling may make it difficult, if not impossible, to manufacture low-cost DTA devices during the immediate digital transition period. The addition of selective power functions to any electronic device means added complexity, and hence added cost.
The ruling will impair the ability of broadcasters and manufacturers to implement an effective emergency public-safety alert system. The DTA provides a novel platform for the reception of emergency broadcast messaging. This is due to the inherent data-delivery capability of the ATSC digital television system. One such use, currently under elaboration, is the potential for the reciver to scan incoming data, and automatically react and alert the consumer, even when the device is not active. In order to provide such a service, the unit must have certain functions active while in the standby mode. Such functions will in all probability require the unit to draw more power than is allowed in the CEC Ruling.
For all of these reasons, we urge the California agency to withdraw the rule.
The ruling unfairly places a disproportionate burden on DTA devices. The circuitry required in a DTA is much more complex than that in either a DVD or Compact Audio device -- two devices that the CEC has allowed to consume more power than a DTA. Even when reduced to highly-miniaturized integrated circuits, the density of the chips in a DTA is much higher than that in the other devices. This higher density means that the devices must consume more power than the other devices.
The ruling unfairly discriminates against over-the-air broadcast television. The satellite and cable television industries have deployed settop boxes that are of a similar functionality to the DTA. Direct-broadcast satellite in the U.S. has employed a digital transmission system that requires a level of circuitry comparable to the DTA. In addition, cable television operators have begun deploying digital video services, again using comparable technology. Yet, none of these other devices appear in the CEC Appliance Efficiency Regulations.
The ruling will impede the digital transition and will make it difficult for low-income households to continue to receive free, over-the-air TV. DTA devices, and specifically the Federal DTA subsidy program, are targeted to make the digital transition convenient and of low cost, especially to low-income households. The ruling may make it difficult, if not impossible, to manufacture low-cost DTA devices during the immediate digital transition period. The addition of selective power functions to any electronic device means added complexity, and hence added cost.
The ruling will impair the ability of broadcasters and manufacturers to implement an effective emergency public-safety alert system. The DTA provides a novel platform for the reception of emergency broadcast messaging. This is due to the inherent data-delivery capability of the ATSC digital television system. One such use, currently under elaboration, is the potential for the reciver to scan incoming data, and automatically react and alert the consumer, even when the device is not active. In order to provide such a service, the unit must have certain functions active while in the standby mode. Such functions will in all probability require the unit to draw more power than is allowed in the CEC Ruling.
For all of these reasons, we urge the California agency to withdraw the rule.
posted by Aldo at 9:19 AM
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