Comments Regarding Draft 45-Day Language on Appliance Efficiency Standards for Televisions and Related Documents

The Consumer Electronics Association opposes the California Energy Commission’s mandatory performance-based restrictions on energy consumption [for televisions] as detrimental to innovation, consumers, and industry. The Commission bases its proposed regulations on a stacked deck consisting of demonstrably false assumptions, admittedly stale and outmoded data, basic mathematical errors, and conceptual mistakes, that both exaggerate the “problem” to be solved and overestimate the potential energy savings.The regulations violate California law. They will cost consumers far more than they may save and will interfere with consumer enjoyment of one of today’s most dynamic and desired products.
 
The regulations are unnecessary. Energy consumption by today’s digital television models approximates the energy required for two light bulbs. That’s it: two average light bulbs. And through continuous improvements, manufacturers are bringing those levels even lower. Contrary to the disinformation spread by certain proponents of regulation, digital TVs are hardly the electronic equivalent of gas-guzzling Hummers.