CEC COMPUTER POWER MANAGEMENT REQUIREMENTS MARK HOLLENBECK, HP INC. APRIL 26,

Computer Power Management Concerns Industry had worked with CEC and other advocates to draft language addressing multiple situations where computers are shipped with non- traditional power management schemes – CHAPTER 8 - Proposed Regulatory Language for computer power management addressed one of several situations involving computers shipped without a “traditional power management scheme” – Shipping computers without an Operating System (OS) installed (when requested by customers) However, there are a number of other situations where the regulatory language will prohibit shipping computers with Operating Systems (OS) providing “non-traditional power management schemes”, or where there is ambiguity about how to comply with other requirements involving power management. – Non-user adjustable power management schemes and TEC formula weightings The table on the following slides identify specific issues or questions involving power management We recommend reviewing each case to determine if CEC wants to permit or prohibit selling computers configured with OS software that does not conform to the requirements CEC specified 2

Specific Power Management Issues Regulation Reference Power Management Issue Scope of Products Impacted Typical Use, Etc. Page 44 (actual 56) (v) (4) (B) (3) and Page 45 (57 actual) Section (v) (5) (C) and (D) Computers sold or shipped to customers with a FreeDOS Operating System (that does not provide power management of the computer or "connected displays" Desktops, Notebooks, Thin Clients, Workstations, Small Scale Servers Typically used by customers one time to boot up computer for installation of customer's custom software image (that typically includes an Operating System with power management capability (Windows, Chrome, etc.) Page 44 (actual 56) (v) (4) (B) (3) and Page 45 (57 actual) Section (v) (5) (C) and (D) Computers sold or shipped with the Open Source LINUX Operating System (multiple variations) that do not typically provide power management of the computer Desktops, Notebooks, Thin Clients, Workstations, Small Scale Servers Typically used by commercial customers who do not need or wish to pay for a full-featured Operating System. Computer Manufacturers do not want to be forced to layer on power management of the computer (system unit) when customers request computers configured with a LINUX Operating System. Page 44 (actual 56) (v) (4) (B) (3) and Page 45 (57 actual) Section (v) (5) (C) and (D) Notebook Computers sold or shipped to customers with a Google Chrome Operating System that does not include a 30 minute default Sleep Mode for the computer. Notebook Computers Typically smaller Notebook Computers that do not require a full-featured Operating System and “actively” manage power consumption through use of the Long Idle or similar modes. 3

Specific Power Management Issues Regulation Reference Power Management Issue Scope of Products Impacted Typical Use, Etc. Page 44 (actual 56) (v) (4) (B) (3) and Page 45 (57 actual) Section (v) (5) (C) and (D) Notebook Computers sold or shipped to customers with an Android based Operating System that does not include a default Sleep Mode for the computer, but actively regulates power use through use of the Long Idle or similar modes. Notebook Computers Typically smaller Notebook Computers that do not require a full-featured Operating System and “actively” manage power consumption of the computer through use of the Long Idle or similar modes. Pg. 42 (54 actual) Section 1604 (v) (4) B) ii Computers shipped an Operating System that does not provide power management or users with ability to disable power management, to different TEC Mode Weightings. (See questions in “Typical Use” field and next slide) Computers (all types) Questions (for CEC) – next slide 4

Specific Power Management Issues For Notebooks, Desktops, and Integrated Desktops that use an alternative low power mode in place of system sleep mode (systems that do not support a traditional ACPI S3 sleep mode), alternative low power states or modes may be used instead of power in Sleep mode in the TEC equation for qualification if the alternative low power mode is less than or equal to 10 W. In such instances (P SLEEP X T SLEEP ) is replaced by (P LONG_IDLE X T SLEEP ). Specific questions about CEC’s objectives of modified weights for computers where the user can’t disable power management: – Does CEC intend to allow use of the modified TEC weightings for Computers configured without an Operating System (OS) or configured with an OS like FreeDOS that will not likely be used over the life of the product? Where a power managed OS will most often be installed by the customer or manufacturer as part of customer software image loading services? – What should happen when the user re-images the machine? – Does CEC intend to allow use of the modified TEC weightings for Computers configured with an Operating System like Google Chrome or Android that do not provide traditional power management functionality? – What should happen when the user wants to make power management more aggressive? – What should happen when the user needs to use their compute power un-attended for extended period of time? 5

Industry Recommendations - Power Management Manufacturers need for Flexibility When TEC based power consumption limits are met: – Power management requirements should permit shipment of all computers when the TEC based power consumption limits are met. We appreciate CEC’s willingness to continue working with industry to get power management requirements right Once CEC has determined if they will permit continued sales of computers configured with software providing non- traditional power management schemes, we can work collectively to determine how to specify the regulatory requirements to eliminate ambiguity and accomplish CEC’s goals 6