Arlington, Va. - The Consumer
Electronics Association (CEA) submitted Tuesday final comments to the
California Energy Commission (CEC) regarding its proposed restrictions on
television sets that are sold in California.
The CEA urged 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,"
stated 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 said it also pointed out to the commission numerous
mathematical errors and incorrect assumptions that the CEC is using to justify
the new regulations.
In a report by financial and economic expert Paul Wazzan, he
affirmed 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.
These 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 concluded 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," added 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."