Wal-Mart Urges Energy Limits on Boxes Eligible for $40 Coupons

Wal-Mart’s comments were among the first submitted in NTIA’s rulemaking on how the $1.5 billion coupon program should be run. They came in a letter from Laura Phillips, vp & divisional mdse. mgr. for entertainment & wireless products, and Seong Ohm, her Sam’s Club counterpart for electronics & technology. An additional 27 comments were filed at NTIA through Sept. 15 and posted at ww.ntia.doc.gov. Most were from people protesting the use of taxpayer money for converter-box subsidies. Final comments in the rulemaking are due Sept. 25.

In their letter, Phillips and Ohm called Wal-Mart “an agent of the customer.” Wal-Mart’s “Every-Day Low Prices Policy” isn’t just about “initial purchase costs,” they said. It’s also about “the costs of ownership associated with energy consumption of the products we sell,” they said. Requiring an auto-power-down and 2-w “standby” for boxes to qualify for the $40 coupon could halve their energy use, they said. Auto-power-down would shift a converter box into standby power mode after 4 hours of inactivity, and 2-w standby is consistent with CEA standards, they said.

Wal-Mart believes the box “must be shipped” with auto- power-down enabled, Phillips and Ohm said: “The manufacturer may choose to offer an override feature to accommodate the needs of the small percent of users who program their VCRs to record a show.” Wal-Mart strongly backs efforts to reduce “on"-mode power use, to save energy, they said. But it defers “such discussions” to other policy forums, such as Energy Star and standards-settings efforts in individual states, they said. Heeding the recommendations would promote lower energy costs for consumers who can least afford them, they said. They would also help “limit the production of global-warming gases” and reduce the nation’s demand for power, “thereby contributing to the goal of U.S. energy independence,” they said.

The key to getting the CE industry to accept an auto- power-down function “is to spell out the specific requirements,” but allow manufacturers “flexibility” on realizing them in product designs, the Natural Resources Defense Council told NTIA in a similar plea. A user’s annual energy use and electric bill could drop more than 1/3 “simply by adopting an auto-power-down feature,” the Council said. “Adding auto-power-down is a critical complementary, alternative strategy for achieving real energy savings” in DTV converter boxes, it said. For the “large proportion” of consumers who will always leave their box powered up, “it allows one the potential to reduce power draw by as much as or more than may be reduced” by adopted only lower power draw requirements in the “on” mode, it said.

NTIA can’t stop the flow of public money to the coupon subsidy program. Its only charter from Congress is to run the program with as little waste and abuse as possible. Even so, several consumers wrote to express their outrage that taxpayer money was being used. “Enough is enough,” said one, Rich Cardone. “Let the programmers or national broadcasters pay for the transitioning effort, not the taxpayer.” Another, Michael Britton, suggested the costs should be absorbed “by those who manufacture, distribute and retail” the boxes -- “not me, the taxpayer.”

A 3rd consumer, Charles Soper, asked: “Since when did TV become a government-subsidized right instead of a privilege in this country?” Soper said that the last time he checked, “you could run down to your local Worst Buy and get a digital TV for less than $300. That’s roughly 3 times more than what these coupons would allow for.” His advice: “If you can’t afford even a modest digital TV, maybe you shouldn’t be spending so much time in front of an analog TV.” Amid so many federal budget challenges, “do we really need to be spending $1.5 billion on a non-essential communication protocol?” he asked. “Where else can we realistically use that money? Education? Health-care reform? Social Security reform? The list is rather long.”

Scott Donaldson wrote to say he refuses to spend “hard- earned money” to buy a new DTV set when his analog TV works “just fine!” If the govt. insists on turning off his analog signal, the least it should do is “give me a converter box FREE,” Donaldson raged. “How do I get this done? Who do I write to? Is anyone sticking up for us consumers?”

The DTV transition will render obsolete all analog TVs and wasn’t supported by most of the American public, said Richard Dabney, of Tanner, Ala. So all Americans should be eligible for a coupon for each analog TV they own, “regardless of whether they subscribe to satellite or cable,” or how much they make or where they live, Dabney said: “It was ludicrous in the first place for the government to allow DTV to become the nation’s first government-enabled instance of planned obsolescence for an entire class of consumer products. Therefore, the cost of providing the boxes should be fully covered by the government and those electronics manufacturers who supported the incompatible over-the-air DTV transmission system that was adopted by the FCC.” He noted with some irony that the introduction of digital HD Radio “has not required broadcasters to drop their analog signals and render obsolete all of the nation’s radios. Therefore, it appears that similar alternatives for digital television may have been available but were not considered by the FCC, perhaps due to the FCC’s plan to auction the original analog spectrum.”

An educator, Jon Kaps, AV media specialist at Flathead High School in Kalispell, Mont., wrote NTIA to say it took 17 years for his school to raise enough money to equip each of its 90 classrooms with a TV set. With budgetary demands rising, “it would help a great deal if schools were also eligible for assistance in this process” of converting to digital, Kaps said. “As it stands, schools are ineligible” for the $40 coupons, “and even if they were eligible under these proposed rules, 2 converter boxes would be insufficient,” he said. “The decision to base the distribution of converter box subsidy coupons only to off-air reception households appears questionable -- particularly so when one considers that schools will need these converter boxes to meet educational objectives.” That position received little or no attention in the congressional debate over the analog cutoff legislation.

An anonymous writer seemed to have the markings of a retailer. “There will be no real procedure in place to prevent fraud,” the writer said. “The question will be who is ultimately going to pay the price. If the government refuses to pay retailers for fraudulent coupons, can retailers refuse to sell the receivers?” Rebates might well be a better remedy for subsidizing the boxes than $40 coupons, the writer suggested: It would be the consumer’s responsibility to provide proof of purchase to obtain the rebate,” the writer said. “In this case, the consumer would provide proof of purchase to NTIA in order to receive a $40 rebate. The proof of purchase could be the UPC code from the receiver’s package. This would eliminate the retailer from the equation and cut down on the number of attempts of fraudulent activity due to the fact to receive the rebate you must provide proof of purchase.”