Natural Resources Defense Council letter in support of TV Standards

NRDC SB6489 Support Letter.doc

Senator Phil Rockefeller, Chair
Senate Environment, Water and Energy Committee
218 John A. Cherberg Building
PO Box 40423
Olympia, WA  98504-0423

Dear Chairman Rockefeller,

RE:      SB 6489 – SUPPORT

On behalf of the Natural Resources Defense Council and its 1.3 million members and e-activists, I am writing to express our strong support for Senate Bill 6489 that establishes minimum energy efficiency requirements for new televisions sold in Washington State.   As a result of these standards new TVs sold in 2013 will use up to 50% less power than 2008 models and Washington citizens will save millions of dollars in the form of lower electric bills.  These standards are identical to the recently passed California standards and will help prevent inefficient models from being dumped and sold in the Washington market.

Background –Consumer electronics are one of the fastest growing sources of electricity use in the home, in many cases responsible for 15% of a home’s annual total. TV energy use has grown significantly due to the growth of flat panel TVs which are typically larger than the TV they replace.  In addition, TVs are frequently on more hours per day than in the past due to DVD movie viewing, video game play and the availability of more than a hundred channels via pay TV.

TVs are one of the largest unregulated energy uses in the home.  In fact some of the largest, least efficient models on the market consume more energy each year than a new refrigerator.  After an extensive two year long rulemaking, on December 2009 the California Energy Efficiency Commission (CEC) passed energy efficiency standards for new TVs sold in California.  The standard has two tiers, the first tier goes into effect in 2011 and more than 85% of the market already meets these levels, and the second, more stringent tier goes into effect in 2013.

Some key aspects of the standard:

The standards have two main components – standby power limit of 1W and active mode power limits that scale with screen size (e.g., TVs with larger screen areas are allowed to use more power).

The standards are technology neutral and performance based – Manufacturers have complete flexibility in how they want to design their TV.  Consumers will continue to be able to choose from all TV types – LCD, plasma, rear projection and TV technologies not yet even on the market.

The standards are readily achievable using currently available technology – Today more than 300 models are already available that meet the 2013 efficiency requirements.  This represents roughly 25% of the market.  These are made by all the leading manufacturers ranging from Samsung, Sony, Vizio and Panasonic and are available in a wide range of sizes.

The standard does NOT ban big screen TVs – As stated above the on mode power requirements allow bigger TVs to use more power than smaller ones.  Contrary to false stories that have appeared in the media, consumers will continue to be able to buy any sized TV they want.  In fact the California TV standards do NOT regulate the super large TVs, those >58 inches.  (California will likely address these in a follow-on rulemaking.)

In the attachment, I present more detailed information about the standards, the California process and responses to claims made by the Consumer Electronic Association (CEA).

Should you have any questions about our comments or seek additional information, please do not hesitate to contact me directly at 415-875-6100.


Noah D. Horowitz

Senior Scientist

Natural Resources Defense Council


cc:        Senator Eric Oemig
Sam Thompson, Counsel


During the California Energy Commission rulemaking process, the Consumer Electronics Association (CEA) and some of their members led a massive misinformation campaign in an attempt to block the CEC standards. As an active participant in the CEC process we observed these efforts directly and expect similar false claims to be made during the legislative process in Washington.   The CEA is staunchly opposed to mandatory energy efficiency requirements of any kind.  To help provide a more balanced perspective on these issues, below we provide an overview and additional information on many of the issues.

CEA’s Track Record – On three different occasions the CEA and its members have come to California to oppose proposed standards for external power supplies, standby power and most recently TVs.  In each case CEA and its members projected dire consequences of empty shelves, job loss, and stifling of innovation. Not a single one of their claims has ever come to pass. In fact, California’s pioneering efficiency standards for external power supplies, the little black box chargers, resulted in dramatic energy savings and have since been copied by leading countries around the world.

To promote their opposition to the proposed California TV efficiency standards, the CEA and others created an industry front group called “Californians for Smart Energy” (visit which included fear mongering headlines about, job losses and negative impacts to the California economy.  The facts are that none of the TVs are made in America, and that the CEA analysis failed to account for the near billion dollars in annual electricity savings that Californians would achieve once the standards are in full effect.

Recent Progress – In large part due to the pending California standard and incentives being offered by utilities in California and the Pacific Northwest, TV manufacturers are now designing dramatically more efficient TVs.   At the January 2010 Consumer Electronics Show, manufacturers introduced a wide range of new energy efficient models.  These included new LCD TVs that have LED backlights.  All of these models meet the California and the proposed Washington standards.  In addition, Samsung and Panasonic, the two leading producers of plasma TVs introduced new models that also meet the 2013 standards.  This is significant as historically plasma TVs used considerably more energy than other sized TVs.  In fact Panasonic’s new 2010 42 inch plasma TV uses 99W, which is 40% less than their 2009 model.

The introduction of all these new efficient models in addition to the 300 models complying models that are already available at retail, further demonstrates the inaccuracy of CEA’s claims about empty shelves and the unavailability of TVs in 2013 that can comply with the California and proposed Washington standards.  Much progress is indeed being made and establishing mandatory efficiency standards in states like Washington will provide a firm efficiency floor and lock in these savings for all models being sold.

Support for the Standard – The CEA does not speak on behalf of the entire TV industry.  In fact, 3M, a member of the CEA, strongly supported the energy efficiency standards in California. (3M produces an optical film that greatly increases the energy efficiency of LCD TVs.)  Also the leading TV maker Vizio, which represents every 1 in 5 TVs sold in N America, testified in favor of the California standards.  Vizio also recently introduced 30 new models for 2010, all of which meet the proposed Washington standard efficiency requirements.  Go to

During the CA proceeding, the LCD TV Association which represents many of the leading component suppliers also voiced their support for the CEC standard.  In their letter of support ( they stated:

Innovation – Equipment efficiency standards have a long and successful track record of stimulating innovation.  The existence of efficiency standards has not in any way hampered the introduction of new features for any regulated product.  For example, today’s refrigerators use ¼ the energy compared to older models and now include features such as frost free operation, ice makers, through the door cold water, etc.

The CEA has incorrectly claimed that mandatory efficiency standards will stifle innovation and that their industry changes too quickly to be regulated.  One can expect claims like “the standards will ban 3D TVs or internet enabled TVs”.  The fact is the new 3D TVs being introduced by the industry will not be impacted by the proposed standard.  That’s because the TV test method which the standard is based on only uses 2D images.  In other words, the power used by a TV when displaying 3D content is not being measured or regulated.   In addition, manufacturers including Sharp, Vizio and Samsung have recently introduced several new models that include internet connectivity (e.g., the ability to download videos from Netflix, view “widgets” from Yahoo, etc.) AND comply with the California and proposed WA efficiency standards.

For additional information, contact Noah Horowitz at 415-875-6100.