California Energy Commission’s Proposed Regulations on Personal Computers Poses Threat to Prebuilt Gaming Desktops and Gaming Monitors

By | September 12, 2016

In a move to reduce power consumption and protect the environment, the California Energy Commission has proposed a series of regulations intended to reduce the idle power consumption of personal computers, as well as the overall power consumption of monitors.

The CEC met with stakeholders in the computing industry to discuss how to develop regulations that reduce power consumption in ways that don’t prevent certain types of devices from being sold. While this does help prevent the CEC from passing regulations that cannot realistically be met, it does raise the concern of special interests proposing regulations that provide them an advantage over new competition as a result of proprietary technology or trade secrets they posess the rights to.

The series of rules and regulations are planned to take effect between 2017 and 2021.

Potential Threat to Prebuilt Gaming Computers

To determine appropriate levels of idle power consumption, systems will be classified based on an ‘expandability’ score.

Most desktops will have limitations imposed on power consumption that gaming computers cannot realistically meet- however, “high expandability” systems won’t be subject to these power limitations. Instead, they’ll be subject to a different set of limitations designed for workstations, such as requiring a power supply that meets the 80 PLUS GOLD standard.

To be classified as “high-expandability” without meeting the minimum score of 690, a system must attain a minimum level of frame-buffer bandwidth(memory bandwidth on the graphics adapter). The proposed level is 400 GB/s by 2018, and 600 GB/s by 2020. In addition, the system must use a power supply of 600 watts or greater.

The level of frame-buffer bandwidth required is significantly higher than what is offered in high end graphics adapters today. For example the NVIDIA GTX 1080, which has a MSRP of $600, has a memory bandwidth of just 320 GB/S. This falls 20% short of the requirement slated to go into effect by 2018.

This is an extremely ineffective metric, because memory bandwidth is generally not the main factor that contributes to GPU idle power consumption. In many cases, the necessary memory bandwidth in modern GPUs has gone down due to improvements in memory compression technology.

The size of the die has generally been the contributing factor to the most realistically achievable short-idle power consumption in most modern graphics adapters- the number of transistors is likely not used in the classification of graphics adapters due to the difficulty in testing or verifying such an element(as well as improvements to transistor density as lithography tech improves), but die size is not difficult. Using TFLOPs as a measure of performance is also a poor idea, because performance will continue to improve, and eventually result in low-end devices being categorized as high performance if the specification is not updated.

HBM(High Bandwidth Memory) is an upcoming standard that will provide substantially increased memory bandwidth while consuming significantly less power, with the drawback of currently being very expensive. Obviously, the way in which the system’s drivers interact with the hardware to determine clock speed, power saving states, as well as the architecture of the GPU itself are the most important aspects of idle power consumption, but these are the types of factors that the CEC is seeking to improve through regulation.

If these regulations pass, there will likely be an increase in the cost of prebuilt gaming computers in markets/areas effected by these regulations. High-end graphics cards with HBM will likely meet the memory bandwidth requirements; however, mid range GPUs that will likely still use GDDR5 or GDDR5X are at risk. These GPUs may cause a system to draw too much power to meet the desktop power consumption requirements, but not posess enough memory bandwidth to meet the “high-expandability” metric.

A likely effect would be for system manufacturers to include unnecessary pieces of hardware in order to boost the expandability score of their system into higher ranges. This will increase costs while providing little benefit and less choices to the consumer. If the systems do meet the high-expandability metric, there’s still the costs associated with requiring a 80 PLUS GOLD power supply as well as the cost of testing and meeting regulations.


Regulations on Computer Monitors


In addition to regulations on personal computers/workstations, the CEC also proposed establishing limitations on the power consumption of computer monitors. These limitations will be dynamic based on the resolution and physical size of the screen, as well as a 1 watt increase for touch screens.

The CEC is also considering providing additional allowance for curved monitors, OLED monitors, and gaming monitors with high refresh rates. The formulas/methods used to determine increased power allowances for high refresh rate monitors, curved displays, and OLED displays have not yet been decided.

The CEC states that their proposed power requirements can be met by:

  • using more efficient LEDs
  • establishing and maintaining a standard for the default brightness(since most consumers never change their brightness)
  • including an ambient light sensor for automatic brightness control based on brightness of the room
  • setting standards for the efficiency of the monitor’s power supply.

There is a proposal to create an exemption for monitors with a resolution of 8.2 megapixels or higher. In comparison, the 4K UHD standard(3840×2160) meets this standard at just under 8.3 megapixels. The proposed exemptions also includes KVMs, KMMs, and medical devices.

Small Business Exemption


Small businesses are proposed to be exempt from most of the regulations that involve expensive testing fees. The exemption is planned to apply to organizations that meet all of these criteria:

  • Have a gross annual revenue of less than $2 Million
  • Produce 40 or less units of a similar system
  • Assembles and sells the computers at the same location

This exemption only applies to computers manufactured through said business, it does not apply to systems that are purchased directly from another manufacturer or wholesaler for resale.

The “Produce 40 or less units of a similar system” rule does not yet specify a methodology for what is considered a “similar system”. For example, it’s unclear if a manufacturer could simply use a variety of parts in order to avoid selling more than 40 of the same type of computer. In this case, it sounds like an unnecessary regulation that will only drive prices up by punishing small businesses that order parts in large volumes(by making them pay testing fees), and therefore forcing them to source a larger variety of parts in order to circumvent the 40 or less units clause.

This exemption will protect small businesses that sell custom built computers as well as people that build computers as a hobby.


Cost Savings or Increased Costs?

The CEC claims that these regulations will save consumers money through reduced energy bills, but these savings do not account for the inevitable increase in prices on computers and monitors that results from the costs associated with meeting this extensive set of regulations. It also doesn’t account for when users inevitably change their settings in the operating system, such as increasing the time before the computer goes to sleep, increasing brightness levels, or increasing the time before the display dims or turns off.

In addition to the costs of using more expensive materials or parts to meet regulations, there’s also the possibility of business finding cheaper alternatives to circumvent efficiency requirements. In this case, a business might spend more on certain types of hardware in order to qualify for particular exemptions or categories that reduce their efficiency requirements, while providing little benefit to the consumer as a result of them exploiting a loophole.

It’s unclear if these regulations will save or cost consumers money, however it is important to consider that the benefits do go beyond cost- reduced power consumption can benefit the environment, especially depending on the type of energy used.